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Risk Assessment Department of Justice (DOJ) White Collar Crimes

McCarter & English Blog: Government Contracts...

A New Frontier in Corporate Accountability: The DOJ’s Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice (DOJ) Criminal Division introduced its Corporate Whistleblower Awards Pilot Program (Program), which, like a modern-day Western posse, aims to bring justice to the wild frontier...more

Thomas Fox - Compliance Evangelist

Risk Assessment Lessons from Star Trek: Balance of Terror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...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

American Conference Institute (ACI)

Practical Implications of the Department of Justice’s M&A Safe Harbor Policy

In early October 2023, Deputy Attorney General (DAG) Lisa Monaco announced a “new” (but not new) Department of Justice (DoJ) policy intended to incentivize acquiring companies to voluntarily self-disclose criminal misconduct...more

StoneTurn

Meeting DOJ and SEC Post-Settlement Obligations: A Practical Guide

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No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

The Volkov Law Group on

Let’s move beyond the headline – trade compliance is the new FCPA.  We get it.  The next step is to do something about it.  The Justice Department has repeated this refrain – it is one of its greatest hits.  In addition, DOJ,...more

The Volkov Law Group

A Five Step Program for Every Company to Address the New Enforcement Threats

The Volkov Law Group on

Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized...more

WilmerHale

DOJ Announces Significant Guidance on Compliance, Compensation, Communications and Cooperation

WilmerHale on

On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more

StoneTurn

5 Tips For Meeting DOJ’s New CCO Certification Requirements

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The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more

Guidepost Solutions LLC

The Looming Bear Market is Likely to Bring More Prosecutions

When the tide goes out, as it appears to be doing now with the market down 20% percent from its highs in January, bad actors will be left exposed for everyone to see. Simply put, as the market drops those companies hiding...more

The Volkov Law Group

CCOs and Criminal Cartel Compliance Programs (Part II of III)

The Volkov Law Group on

Chief compliance officers have plenty of things to do and risks to manage.  CCOs have a unique remit and a set of skills that should be applied whenever needed.  While I am not trying to increase CCO workload (and forgive me...more

Skadden, Arps, Slate, Meagher & Flom LLP

Practical Steps To Address DOJ Changes to Corporate Enforcement Policies

In one of the first substantive speeches on corporate criminal enforcement under the Biden administration, Deputy Attorney General Lisa Monaco announced on October 28, 2021, several immediate changes to Department of Justice...more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Guidance on Evaluating Corporate Compliance Programs

Earlier this month, the Criminal Division of the United States Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. In considering enforcement actions against companies, prosecutors...more

Jones Day

DOJ Updates Its "Evaluation of Corporate Compliance Programs" Guidance

Jones Day on

The Situation: The Department of Justice ("DOJ") has updated its "Evaluation of Corporate Compliance Programs" guidance for prosecutors. The Result: The updates provide additional insights into the factors the DOJ is...more

Seyfarth Shaw LLP

Department of Justice Issues Updated Guidance on Evaluation of Corporate Compliance Programs

Seyfarth Shaw LLP on

On June 1, 2020, the Criminal Division of the US Department of Justice (“DOJ”) released  an updated guidance document for white-collar prosecutors on the evaluation of corporate compliance programs....more

Dechert LLP

DOJ Releases Revised Guidance on Corporate Compliance Programs and in Doing so Takes a More Nuanced Approach to Compliance...

Dechert LLP on

On June 1, 2020, the Department of Justice Criminal Division published updated guidance on an important piece of DOJ literature, the “Evaluation of Corporate Compliance Programs” (“Guidance”), which for many is...more

Morgan Lewis

DOJ Updates Corporate Compliance Evaluation Guidance: New Refinements Stress that Programs Need to be 'Empowered to Function...

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The US Department of Justice’s (DOJ’s) Criminal Division published an update on June 1 to its Evaluation of Corporate Compliance Programs guidance, which is used by its prosecutors to assess the adequacy and effectiveness of...more

Morgan Lewis

UK Serious Fraud Office Emphasizes Importance of Compliance Programs

Morgan Lewis on

In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more

K2 Integrity

China Emerging as an Increasing Driver of Global Illicit Finance Risk

K2 Integrity on

Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more

White & Case LLP

President Trump's trade wars and the expansion of customs violations into the white-collar space

White & Case LLP on

The US' ongoing trade wars—with various trading partners and particularly with China—are everywhere in the news. Putting politics and policy aside, the "trade wars" reflect a basic disagreement over the rules that should...more

Akin Gump Strauss Hauer & Feld LLP

[Podcast] DOJ’s New Guidance on Evaluating Compliance Programs: What You Need to Know

In this episode, Akin Gump health care and life sciences counsel Taylor Jones and Matt Wetzel discuss the Justice Department’s recent guidance on evaluation of corporate compliance programs. Among the topics covered: •...more

Foley & Lardner LLP

DOJ Antitrust Division Announces New Policy to Incentivize Corporate Compliance

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The Department of Justice Antitrust Division will now consider a target company’s antitrust compliance program when determining how to resolve criminal matters. This represents a fundamental shift in the Antitrust Division’s...more

Thomas Fox - Compliance Evangelist

Antitrust Compliance Programs: Part 2 – Elements of an Effective Compliance Program (Elements 1-4)

As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division, in July the released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations...more

Wilson Sonsini Goodrich & Rosati

DOJ's Antitrust Division Announces New Policy Incentivizing Qualified Corporate Antitrust Compliance Programs

On July 11, 2019, Assistant Attorney General Makan Delrahim of the U.S. Department of Justice (DOJ) announced a new policy to incentivize corporate antitrust compliance. The DOJ will, for the first time, formally consider...more

Akin Gump Strauss Hauer & Feld LLP

DOJ’s New Corporate Compliance Evaluation Guidance

Key Considerations and Updates for Life Sciences Companies - On April 30, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) issued updated guidance for white-collar prosecutors on evaluating the...more

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