News & Analysis as of

Remediation Yates Memorandum

Skadden, Arps, Slate, Meagher & Flom LLP

Transatlantic Approach on Corporate Cooperation: How Newly Issued French and UK Guidance Compare to US Practices

As widely anticipated, French and U.K. regulators recently published guidance detailing their expectations for corporate cooperation in enforcement investigations. Both sets of guidance demonstrate further alignment of those...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

Ruder Ware on

By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC’s Enforcement Division Issues New Advisories on Cooperation"

On January 19, 2017, the U.S. Commodity Futures Trading Commission’s Division of Enforcement issued two new enforcement advisories outlining the factors the division will consider in evaluating cooperation in the agency’s...more

McGuireWoods LLP

Last Four Months of DOJ’s FCPA Pilot Program Could Provide Important Signals

McGuireWoods LLP on

Last April, the Criminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit. The pilot program, self-described as “building” on the...more

Snell & Wilmer

The Foreign Corrupt Practices Act’s One-Year “Pilot Program” Nears The Halfway Mark

Snell & Wilmer on

The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more

WilmerHale

A transatlantic consideration of recent developments in corporate self-reporting

WilmerHale on

More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more

Pillsbury Winthrop Shaw Pittman LLP

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

BakerHostetler

DOJ Attempts to Encourage Corporate Self-Disclosures With the Announcement of a One-Year FCPA Pilot Program

BakerHostetler on

Pursuing a classic “carrot and stick” approach to incentivizing corporate self-disclosure of FCPA violations and individual wrongdoing connected to FCPA violations, the Department of Justice (DOJ) Fraud Section announced a...more

Foley & Lardner LLP

DOJ Fraud Section Offers Super Credit in FCPA Pilot Program

Foley & Lardner LLP on

This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more

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