News & Analysis as of

Self-Disclosure Requirements Clawbacks Corporate Misconduct

Society of Corporate Compliance and Ethics...

Understanding the Latest DOJ Changes to Corporate Prosecutions

On November 22, 2024, then Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand...more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

Bracewell LLP on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

ArentFox Schiff

Show Me the Money: Using Compensation Structures to Promote Compliance

ArentFox Schiff on

Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more

Williams Mullen

DOJ Implements Corporate Self-Disclosure Policy for Criminal Misconduct

Williams Mullen on

A new voluntary self-disclosure policy issued by the United States Department of Justice (DOJ) provides incentives for companies that voluntarily report criminal misconduct by their employees or agents....more

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series: Protecting Your Business Against Non-Compliance and DOJ Penalties - March 23rd, 12:00...

McDermott Will & Emery on

During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more

King & Spalding

DOJ Corporate Enforcement Policy Revisions Target Executive Compensation, Following Multi-Agency Trend

King & Spalding on

On March 2, 2023 and March 3, 2023, in a pair of speeches by Deputy Attorney General (DAG) Lisa Monaco and Criminal Division Assistant Attorney General (AAG) Kenneth Polite, the U.S. Department of Justice (DOJ) announced...more

Kramer Levin Naftalis & Frankel LLP

DOJ Reinforces Its Focus on Affirmative Corporate Accountability at the ABA’s 38th Annual White Collar Conference

Earlier this month, at the American Bar Association’s (ABA) 38th National Institute on White Collar Crime, Deputy Attorney General Lisa O. Monaco and Assistant Attorney General Kenneth A. Polite, Jr. highlighted the...more

Cozen O'Connor

Compensation Clawbacks and Preservation of Messaging App Communications Top DOJ Changes to its Evaluation of Corporate Compliance...

Cozen O'Connor on

As part of a sweeping revamp of its white-collar criminal enforcement policies that began last year, the Department of Justice (DOJ) announced two significant changes last week. The first is a new three-year pilot program...more

McDermott Will & Emery

DOJ Announces Major Changes to Corporate Compliance Program Evaluation Criteria

During speeches on March 2 and 3, 2023, at the American Bar Association (ABA) National Institute on White Collar Crime (the 2023 White Collar Conference), Deputy Attorney General (DAG) Lisa Monaco, Assistant Attorney General...more

Dorsey & Whitney LLP

Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

Dorsey & Whitney LLP on

On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more

Wiley Rein LLP

New Year, New Compliance Challenges: Good Reasons to Spruce up Your Compliance Program in 2023

Wiley Rein LLP on

At the start of 2023, we made a number of corporate criminal enforcement predictions. With 2023 launched, we are circling back to highlight initiatives that government contractors may wish to consider undertaking as...more

Proskauer - Employee Benefits & Executive...

“Clawback Comeback”: DOJ’s New Focus on Clawbacks to Prevent Corporate Crime

In September 2022, Deputy Attorney General Lisa Monaco delivered remarks unveiling the Department of Justice’s revised corporate crime guidance to “prioritize and prosecute corporate crime.” She reiterated that the number one...more

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