News & Analysis as of

Self-Disclosure Requirements

Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy

by Ropes & Gray LLP on

In November 2017, the U.S. Department of Justice announced a revised Foreign Corrupt Practices Act (FCPA) Enforcement Policy that provides significant incentives for corporations to voluntarily self-disclose potential FCPA...more

Self-Disclosure and the FCA Statute of Limitations

by Holland & Knight LLP on

Most practitioners are aware that the statute of limitations under the False Claims Act (FCA) is six years after the date on which the violation is committed. 31 U.S.C. § 3731(b)(1). That is, unless the FCA’s tolling...more

Column: Achieving a culture of compliance

by Harris Beach PLLC on

Simply having a compliance program is no longer enough in today’s legal and regulatory climate. In the eyes of regulators, “check the box” or “paper” compliance programs are as good as not having one at all. Organizations...more

Day 29 of 31 Days to a More Effective Compliance Program

by Thomas Fox on

One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was the performance of a root...more

Digging Into the Details of New FCPA Guidance From the U.S. Justice Department

Over the last 10 years, 143 companies have paid a combined $10.9 billion to resolve Foreign Corrupt Practices Act cases. That staggering price tag shows the U.S. Department of Justice’s willingness to go after alleged...more

Revisions To FCPA Enforcement Policies Still Pose Tough Questions For Honest Companies

by Fox Rothschild LLP on

In recent remarks, Deputy Attorney General Rod Rosenstein announced significant revisions to the Department of Justice’s (DOJ) policies for enforcing the Foreign Corrupt Practices Act. The policy revisions make permanent...more

New FCPA Corporate Enforcement Policy Incentivizes Corporate Voluntary Self-Disclosure and Cooperation

Under the new FCPA Corporate Enforcement Policy recently released by the Department of Justice (“DOJ”), when a company has voluntarily self-disclosed misconduct, fully cooperated in the government’s ensuing investigation, and...more

DOJ Announces New FCPA Policy to Further Incentivize Corporate Voluntary Self-Disclosure and Cooperation

by Foley Hoag LLP on

The U.S. Foreign Corrupt Practices Act turned forty this year. The Department of Justice is marking that anniversary by announcing a new Corporate Enforcement Policy specific to FCPA matters. The new Policy makes explicit...more

DOJ Announces Revised FCPA Corporate Enforcement Policy

by BakerHostetler on

On November 29, 2017, Deputy Attorney General Rod Rosenstein expanded upon the Department of Justice’s (“DOJ”) long-running efforts to encourage companies to self-disclose Foreign Corrupt Practices Act (“FCPA”) violations by...more

DOJ Issues New FCPA Policy Offering Incentives to Encourage Disclosure of Foreign Bribery and Corruption Misconduct

by Foley & Lardner LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more

DOJ Makes Permanent Its Program to Incentivize Self-Disclosure in FCPA Investigations

by Holland & Knight LLP on

• The U.S. Department of Justice's (DOJ) pilot program established in 2016 to incentivize companies to self-report violations of the Foreign Corrupt Practices Act (FCPA) will, with slight revisions, be made permanent. •...more

FCPA Compliance Report-Episode 346, Mike Skopets on Miller’s Summer 2017 FCPA Report

by Thomas Fox on

In this episode, I visit with Mike Skopets, from Miller & Chevalier on the firm’s Summer 2017 FCPA Report. We discuss the background to the Report and begin with what macro trends the firm identified. We discuss the numbers...more

Why Healthcare and Life Sciences Companies Need to Step Up Their Compliance Efforts in Advance of a U.S. Government Investigation

by Hogan Lovells on

In this hoganlovells.com interview, Hogan Lovells partner Gejaa Gobena discusses how the perception of compliance, remediation, and self-disclosure has evolved in the eyes of government prosecutors from how they factor at...more

Evaluating FCPA Pilot Program: The Data, The Trends

by Ropes & Gray LLP on

April 5 marked the one-year anniversary of the "Foreign Corrupt Practices Act Enforcement Plan and Guidance." Announced by the U.S. Department of Justice, Criminal Division's Fraud Section, the guidance outlined three...more

Compliance 2.0 and the Significance of HHS OIG’s 2017 Resource Guide: “Measuring Compliance Program Effectiveness”

by King & Spalding on

On March 27, 2017, in conjunction with the Health Care Compliance Association (“HCCA”) annual Compliance Institute (“CI”), the Department of Health and Human Services (“HHS”), Office of the Inspector General (“OIG”) released...more

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

by 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

Updated Status of the DOJ FCPA Pilot Program

by Womble Bond Dickinson on

The FCPA Pilot Program was introduced on April 5, 2016 as a one year experiment that sought to ‘motivate companies to voluntarily self-disclose FCPA-related misconduct, fully cooperate with the Fraud Section and …remediate...more

DOJ Announces Extension of FCPA Pilot Program

by Morgan Lewis on

The US Department of Justice plans to extend its FCPA Pilot Program, an initiative developed to encourage companies to self-report bribery violations and provide extensive cooperation in exchange for reduced penalties,...more

OIG Finalizes CMP Regulations, Largely as Proposed

by Baker Ober Health Law on

On December 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) finalized [PDF] its proposal to update the civil monetary penalty (CMP) regulations – namely, incorporate new CMP authorities...more

Historic Risk Management Rules and Practices Go Live on March 1, 2017 in Leading Markets

by Seyfarth Shaw LLP on

For the first time in the history of derivatives, regulators in leading markets will require assets to collateralize many derivatives which are not settled in a regulated clearinghouse. It is not possible to overstate...more

The Bribery Act: To Disclose or Not To Disclose?

In this video interview, Barry Vitou (www.thebriberyact.com), Partner, Pinsent Masons, and head of their Global Corporate Crime Team, addresses: • His initial interest in global anti-corruption issues. • The role and...more

Provider Self-Disclosure Decisions – Voluntary Disclosure Process

by Ruder Ware on

The decision whether or not to voluntarily disclose non-compliance to the government can be very difficult. Not every case is clear. Clearly not every situation where there has been a billing error amounts to fraud or...more

When Leslie Caldwell Talks FCPA, You Should Listen

by Thomas Fox on

November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more

AAG Caldwell Touts Success of FCPA Enforcement and Pilot Program

by Michael Volkov on

In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more

The City of Portland Issues Rules for “Ban the Box”

We previously blogged about Portland, Oregon’s restrictive “ban the box” ordinance. The City of Portland recently issued administrative rules for its ordinance. The administrative rules are available here. The key...more

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