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In recently released updated guidance, the Antitrust Division (“Antitrust Division”) of the U.S. Department of Justice (“DOJ”) outlined how its prosecutors will assess corporate compliance programs when conducting criminal...more
In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more
On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more
Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more
What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or...more
The Justice Department “listens and learns” from companies and compliance practitioners. As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more