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Non-Prosecution Agreements

Mintz

DOJ Issues its Highly Anticipated Whistleblower Awards Pilot Program

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In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

WilmerHale

2024 Trade Secret Update: Whistleblower Protections in the Northern District of California

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WilmerHale lawyers advise clients on every aspect of trade secret law from contracts to complex litigation. Below please find a short update on an important development in trade secret whistleblower protections in the...more

Hogan Lovells

Enforcement risks increase: DOJ and SDNY initiate self-disclosure pilot programs for individuals

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In the past several years, the U.S. Department of Justice (DOJ) has been pursuing a variety of strategies to increase the number of corporate criminal prosecutions. As Assistant Attorney General Nicole Argentieri, chief of...more

Morrison & Foerster LLP

DOJ National Security Division Issues First-Ever Declination Under Voluntary Self-Disclosure Policy

On May 22, 2024, the Department of Justice’s (DOJ) National Security Division (NSD) announced its first-ever prosecution declination under its corporate voluntary self-disclosure (VSD) policy for sanctions and export controls...more

McCarter & English, LLP

DOJ Launches Pilot Program to Encourage Reporting of Criminal Activity

The Department of Justice (DOJ) has announced a pilot program to encourage potential whistleblowers to report criminal activity and cooperate with government investigations in exchange for substantial monetary payouts in the...more

Lowenstein Sandler LLP

DOJ Says You Can Put the Fire Out From Inside the House: New Voluntary Self-Disclosure Program Seeks to Root Out Corporate Crime...

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Introduction: On April 15, 2024, the Department of Justice’s (DOJ) Criminal Division announced a new Pilot Program on Voluntary Self-Disclosure for Individuals. Under this program, individuals who voluntarily disclose certain...more

NAVEX

Navigating the DOJ’s New Pilot Program

NAVEX on

In a bold move, the U.S. Department of Justice (DOJ) launched a pilot program designed to encourage corporate executives to disclose information about financial misconduct within their organizations. Through this initiative,...more

Faegre Drinker Biddle & Reath LLP

DOJ Launches Voluntary Self-Disclosure Pilot Program for Individuals Involved in Criminal Corporate Conduct

On April 15, 2024, the Department of Justice rolled out its most recent installment in a series of policies and programs aimed at furthering the Biden administration’s self-disclosure initiative, officially launching a pilot...more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

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The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

Kilpatrick

The Carrot & The Stick: New Voluntary Self-Disclosure Program for Government Contractor Fraud May Increase Disclosures by...

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Government contractors are no stranger to disclosure obligations.  Since it went into effect in December 2008, the Federal Acquisition Regulation (FAR) Mandatory Disclosure Rule has been the stick the Government has used to...more

Kilpatrick

The Carrot and the Stick: New Voluntary Self-Disclosure Program for Government Contractor Fraud May Increase Disclosures by...

Kilpatrick on

Government contractors are no stranger to disclosure obligations. Since it went into effect in December 2008, the Federal Acquisition Regulation (FAR) Mandatory Disclosure Rule has been the stick the Government has used to...more

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

Polsinelli on

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

Jones Day

DOJ Criminal Division Offers Non-Prosecution Agreements to Individuals Who Voluntarily Report Corporate Wrongdoing

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The Development: On April 15, 2024, the Department of Justice ("DOJ") Criminal Division announced a pilot program that will offer mandatory non-prosecution agreements ("NPAs") to individuals who provide original and...more

Paul Hastings LLP

DOJ Criminal Division Announces New Voluntary Self-Disclosure Pilot Program for Individuals

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On April 22, 2024, the Acting Assistant Attorney General for the Department of Justice (“DOJ”) Criminal Division (“Acting AAG”) Nicole M. Argentieri offered commentary in a blog post regarding the Criminal Division’s newest...more

The Volkov Law Group

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

The Volkov Law Group on

On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more

Morrison & Foerster LLP

DOJ Criminal Division Initiates Self-Disclosure Pilot Program for Individuals

On April 15, 2024, the Criminal Division of the Department of Justice (DOJ) announced a new pilot program setting forth the circumstances in which it will offer non-prosecution agreements (NPAs) to individuals who voluntarily...more

Robinson & Cole LLP

Department of Justice Criminal Division Announces Voluntary Self-Disclosure Pilot Program for Culpable Individuals

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Last week, the Department of Justice (DOJ) announced the Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Program). Pursuant to the Program, “an individual who voluntarily self-discloses...more

Fisher Phillips

DOJ’s New Whistleblower Program Will Lead More Employees to Report Corporate Misconduct: How It Works and 6 Steps You Should Take...

Fisher Phillips on

Employees will be more incentivized than ever to report corporate misconduct to the Department of Justice thanks to a recently rolled-out initiative. After previously introducing whistleblower programs that reward companies...more

Foley Hoag LLP

QPAM Amendment – Action Required by Investment Managers

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The U.S. Department of Labor (“DOL”) has amended the qualified professional asset manager (“QPAM”) class prohibited transaction exemption 84-14 (“QPAM Exemption”), effective as of June 17, 2024 (“QPAM Amendment”)....more

Society of Corporate Compliance and Ethics...

Understanding the Whistleblower Pilot Program in the Southern District of New York

In January 2024 the US Attorney’s Office for the Southern District of New York (SDNY) set a shockwave through the business world by announcing a new whistleblower pilot program. To understand what the policy says and what it...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

Cooley LLP

The Prisoner’s Dilemma Comes for Corporate Crime

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On April 16, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule revising its procedures for establishing supervisory authority over nonbank financial institutions on the basis that the institution poses...more

Katten Muchin Rosenman LLP

Whistleblower Rewards Program Update: DOJ Explains and Expands Pilot Program for Voluntary Disclosures

On April 15, the Department of Justice (DOJ) publicly released a memorandum fleshing out its previously announced corporate whistleblower program, which is intended to induce individuals to report alleged criminal conduct,...more

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