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
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
Host Gregg N. Sofer welcomes Husch Blackwell partner Catherine Hanaway to the podcast to discuss the recent sentencing of Nishad Singh, a former key lieutenant of Sam Bankman-Fried, the cryptocurrency mogul responsible for...more
On September 16, the US Attorney's Office for the Northern District of Illinois (NDIL) announced the launch of its Individual Self-Disclosure (ISD) Pilot Program. The program offers non-prosecution agreements to qualifying...more
In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more
The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more
On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more
Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more
On April 15, 2024, the Department of Justice (DOJ) criminal division announced a new pilot program designed to reward individuals with non-prosecution agreements (NPAs) who voluntarily self-disclose "actionable, original...more
2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more
The U.S. Attorney's Office for the Southern District of New York (SDNY) on Jan. 10, 2024, announced a Whistleblower Pilot Program (Program) that it is presenting as another "tool in [the SDNY's] toolkit" that could unearth...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 October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more
Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more
On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more
A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more
In March 2023, the Department of Justice announced two policy changes that attempt to incentivize self-disclosure to the federal government and self-imposed remedial measures by corporations charged with criminal wrongdoing....more
Introduction - Over the first quarter of this year, the Department of Justice announced notable policy changes for corporate compliance programs. These policy changes are particularly relevant to in-house counsel who may...more
Assistant Attorney General (AAG) Kenneth A. Polite Jr. of the US Department of Justice’s (DOJ’s) Criminal Division recently joined several high-profile, diverse US Attorneys at the inaugural Charlotte E. Ray Lecture and White...more
On March 3, 2023, the Consumer Protection Branch (CPB) of the Civil Division of the U.S. Department of Justice (DOJ) publicly released a new voluntary self-disclosure policy (“CPB VSD Policy”). The CPB VSD Policy seeks to...more
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
In late February, the United States Attorneys for the Southern and Eastern Districts of New York announced a new “Voluntary Self-Disclosure Policy” (VSD Policy), effective immediately, that applies to all United States...more
American Conference Institute’s expert faculty of DOJ and SEC alumni will update you with the most recent developments and risk factors confronting industry in Brazil and will lay out practical takeaways for satisfying the...more
On February 22, 2023, the Department of Justice (“DOJ”) announced that all 93 United States Attorneys’ Offices throughout the country are implementing, effective immediately, a Voluntary Self-Disclosure Policy (“Policy”) for...more
Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more
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