News & Analysis as of

Self-Disclosure Requirements Fraud

Phelps Dunbar

DOJ Expands Whistleblower Rewards to Include Immigration Violations

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Since May 12, when the U.S. Department of Justice (DOJ) announced policy changes to the Corporate Whistleblower Awards Pilot Program (CWAP), employers now face increased scrutiny and potential risks due to the DOJ’s recent...more

Rivkin Radler LLP

The Latest Refinements to DOJ’s White Collar Enforcement Policy

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Last month, the head of the Criminal Division of the U.S. Department of Justice (DOJ), Matthew R. Galeotti, issued a Memorandum outlining DOJ’s enforcement priorities and policies for prosecuting white-collar crime,...more

Society of Corporate Compliance and Ethics...

Understanding the DOJ's Recent Corporate Enforcement Policy Changes

On May 12, 2025 the head of the Criminal Division at the US Department of Justice issued a memo to all Criminal Division personnel with the subject: Focus, Fairness and Efficiency in the Fight Against White Collar Crime. To...more

Morrison & Foerster LLP

DOJ Criminal Division Revises Its Corporate Enforcement Policy, Monitor Selection Policy, and Whistleblower Award Program

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more

Cohen Seglias Pallas Greenhall & Furman PC

DOJ Increases Incentives to Self-Disclose with Revised Corporate Enforcement Policy

Earlier this month, the Department of Justice (DOJ) announced revisions to the Corporate Enforcement and Self Disclosure Policy (CEP). Under the new policy, announced by DOJ Criminal Division Head Matthew Galeotti, companies...more

A&O Shearman

U.S. DOJ announces substantial strategic shifts in white-collar crime enforcement

A&O Shearman on

A new U.S. DOJ memo published on May 12 announces significant changes to the DOJ’s white-collar crime enforcement priorities, aligning the DOJ’s approach with the Trump Administration’s “America First” agenda. ...more

Carlton Fields

Shifting Priorities in White Collar Enforcement: May 2025 DOJ Memo and What It Means for Companies

Carlton Fields on

On May 12, 2025, the Department of Justice (DOJ) Criminal Division announced significant changes in its policies on investigating and prosecuting white collar crime, including a shift in focus toward several areas deemed to...more

Bracewell LLP

DOJ Alert: New White-Collar Priorities and Stronger Incentives to Self-Report

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DOJ sets out new enforcement priorities for corporate and white-collar crime and emphasizes “focus, fairness and efficiency.”...more

Akin Gump Strauss Hauer & Feld LLP

DOJ’s Criminal Division Turns Page on White Collar Crime—But Keeps One Foot in the Past

On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more

Health Care Compliance Association (HCCA)

Private-pay “crime stoppers”: Digesting the Corporate Whistleblower Awards Pilot Program

The U.S. Department of Justice’s (DOJ) Criminal Division launched its Corporate Whistleblower Awards Pilot Program (“Criminal Whistleblower Program”) in August of 2024 to encourage tips for various types of fraud, including...more

Mintz

Alleged Carbon Markets Fraud Leads to Criminal Charges

Mintz on

1 The U.S. Attorney's Office for the Southern District of New York recently launched a criminal prosecution in connection with “a scheme to commit fraud in the carbon markets,” specifically that a company and its executives...more

Baker Botts L.L.P.

CFTC, SEC, and SDNY Break New Ground and File Charges Against Carbon Credit Project Developer and Former Executives for Fraudulent...

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On October 2, 2024, the Commodities Futures Trading Commission (“CFTC”), the Securities and Exchange Commission (“SEC”), and the United States Attorney’s Office for the Southern District of New York announced parallel...more

Bracewell LLP

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

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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

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

Proskauer Rose LLP

DOJ Triples Down on Incentivizing Disclosures with Launch of Three-Year Corporate Whistleblower Awards Pilot Program

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Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...more

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

The Volkov Law Group on

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

Morrison & Foerster LLP

True Facts About False Claims: MoFo's FCA Newsletter - July 2024

Designed for busy in-house counsel and compliance professionals, this newsletter seeks to bring you up to speed on key federal and state False Claims Act (FCA) developments, with links to primary resources. Each quarter, we...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

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

ArentFox Schiff

Investigations Newsletter: Biomedical Company Avoids DOJ Prosecution After First Ever Voluntary Corporate Self-Disclosure of Fraud...

ArentFox Schiff on

Biomedical Company Avoids DOJ Prosecution After First Ever Voluntary Corporate Self-Disclosure of Fraud Under NSD Enforcement Policy - On May 22, the US Department of Justice (DOJ) announced that it will not prosecute a...more

Jenner & Block

Client Alert: DOJ Continues Its Trend of Strengthening Incentives to Report Corporate Misconduct

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Just over a month after Deputy Attorney General Lisa Monaco announced the upcoming launch of the Department of Justice’s whistleblower rewards program, the DOJ Criminal Division unveiled its newest program to incentivize...more

Mintz

Another Declination from DOJ’s Criminal Division Emphasizes the Continued Focus on Voluntary Self-Disclosure in 2024

Mintz on

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

Foley Hoag LLP - White Collar Law &...

Anticorruption Enforcement and the Foreign Corrupt Practices Act: Trends to Track in 2024

This is the seventh in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Snell & Wilmer

United States Attorney’s Offices Announce Innovative Voluntary Self-Disclosure Programs for Individuals

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Last year, on February 22, 2023, the Department of Justice (DOJ) announced a corporate Voluntary Self-Disclosure (VSD) policy, which is applicable to all U.S. Attorney’s Offices, setting nationwide incentives for voluntary...more

Morgan Lewis

DOJ Update : Financial Awards for Corporate Whistleblowers, Enhanced Penalties for Fraud Involving AI Misuse

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The US Department of Justice (DOJ) continues to enhance its tougher-on-corporate-crime policy stance as first announced by Deputy Attorney General Lisa Monaco in 2021. In remarks on March 7 and March 8, DAG Monaco and Acting...more

Holland & Knight LLP

"Call Us Before We Call You": SDNY Announces Pilot Whistleblower Program

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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

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