Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
Understanding the Latest DOJ Changes to Corporate Prosecutions
The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
The Presumption of Innocence Podcast: Episode 37 - Vintage or Trendsetting? The SDNY's Whistleblower Pilot Program
Episode 289 -- Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure
New DOJ Guidance Tightens Corporate Enforcement Strategy
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
Day 29 of 31 Days to a More Effective Compliance Program
FCPA Compliance Report-Episode 346, Mike Skopets on Miller’s Summer 2017 FCPA Report
The Bribery Act: To Disclose or Not To Disclose?
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
DOJ sets out new enforcement priorities for corporate and white-collar crime and emphasizes “focus, fairness and efficiency.”...more
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting...more
In 2025, whistleblower regulations are poised for major evolution, reflecting a renewed commitment to transparency and accountability. The Ethics and Compliance Initiative (ECI) 2023 survey revealed a startling statistic:...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
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
On February 13, the U.S. Attorney’s Office (USAO) for the Southern District of New York (SDNY) announced a pilot program through which whistleblowers who voluntarily self-disclose criminal conduct relating to public or...more
We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more
On November 29, 2023, Department of Justice (DOJ or Department) policymakers announced explicitly that they are, for the first time, leveraging data analytics to help proactively identify and prosecute crimes in foreign...more
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more
Earlier this month, DOJ updated its Corporate Enforcement Policy (CEP). Aimed at encouraging companies to voluntarily disclose unlawful conduct, the updated CEP gives greater opportunities to companies to avoid charges...more
We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more
On the eve of the July 4th holiday, the Criminal Division of the Department of Justice (the “DOJ”) and the Enforcement Division of the Securities and Exchange Commission (the “SEC”) quietly published the second edition of the...more
INTRODUCTION - On 3 July 2020, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) released the second edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (Resource...more
Obviously, there have been multiple developments by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) since 2012 release of the First Edition of the FCPA Resources Guide (2012 Resources Guide). The...more
The anti-corruption and bribery enforcement landscape is constantly evolving. Companies operating in the Aerospace, Defense, and Government Services (ADG) industry sector must therefore vigilantly track developments in this...more
Last week the Justice Department (DOJ) announced a resolution of the long stand Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It also requires companies whose securities are listed in the US to make and keep...more
According to Harry Cassin, writing in the FCPA Blog, “In late 2013 and early 2014, United Technologies self-disclosed to the DOJ, SEC, and the SFO the status of an internal investigation regarding a non-employee sales rep for...more
• 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