News & Analysis as of

Self-Disclosure Requirements Penalties

ArentFox Schiff

BIS Issues Final Rule for Voluntary Self-Disclosure Procedures

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On Thursday, September 12, 2024, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule updating the agency’s policies on voluntary self-disclosures and the Guidance on Charging and Penalty...more

Alston & Bird

Enter the Matrix: CFTC’s New Framework for Self-Reporting, Cooperation, and Remediation

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Our White Collar, Government & Internal Investigations Group analyzes new enforcement guidance from the Commodity Futures Trading Commission (CFTC) that aims to incentivize self-reporting of potential violations....more

Gardner Law

Honesty is the Best Policy: Navigating the DOJ’s M&A Safe Harbor

Gardner Law on

The recent announcement of the Department of Justice’s (DOJ) M&A Safe Harbor policy has significant implications for companies involved in mergers and acquisitions (M&A) within the healthcare industry. This new policy...more

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

Guidepost Solutions LLC on

Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more

Bradley Arant Boult Cummings LLP

TD Bank’s Historic $3.1B Money Laundering Settlement a Warning to All Financial Institutions

On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more

Foley & Lardner LLP

DOJ Stresses AI Risk and Whistleblower Protection in Revised Corporate Compliance Guidance

Foley & Lardner LLP on

On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...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

Snell & Wilmer

Department of Justice Announces Groundbreaking Whistleblower Program in its Ongoing Effort to Incentivize Voluntary Self...

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Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more

Akin Gump Strauss Hauer & Feld LLP

BIS Announces Key Updates to Voluntary Self-Disclosure Process

Key Points - On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

K2 Integrity on

The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...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

Ankura

Key Compliance Takeaways from DOJ Memorandum

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“Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group” - Compliance programs play a critical role for healthcare organizations, ensuring both individuals...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

Snell & Wilmer

CFIUS Releases Guidance Concerning Enforcement and Penalty Actions

Snell & Wilmer on

On October 20, 2022, the Committee on Foreign Investment in the United States (“CFIUS”) issued the “CFIUS Enforcement and Penalty Guidelines” (the “Guidelines”). These are the first-ever Guidelines issued by CFIUS which is a...more

King & Spalding

Treasury Publishes First-Ever CFIUS Enforcement and Penalty Guidance

King & Spalding on

Publication indicates a more robust enforcement posture - On October 20, 2022, the U.S. Department of the Treasury (“Treasury”) released the first-ever Enforcement and Penalty Guidelines (the “Guidelines”) for the...more

Holland & Knight LLP

CFIUS Enforcement and Penalty Guidelines Enhance Transparency for Cross-Border Dealmakers

Holland & Knight LLP on

The Committee on Foreign Investment in the United States (CFIUS) released the first-ever CFIUS Enforcement and Penalty Guidelines (Guidelines) on Oct. 20, 2022, providing the public a roadmap describing three categories of...more

Ankura

BIS Issues Important Policy Changes on Trade Controls Violations Prevention and Enforcement

Ankura on

Matthew Axelrod, the Assistant Secretary of Commerce for Export Enforcement with the Department of Commerce, recently made two important statements on how the Department will enforce trade controls and address violations....more

Davies Ward Phillips & Vineberg LLP

First Remediation Agreement under the Canadian Criminal Code: Key Takeaways

The Superior Court of Québec recently published its reasons1 approving Canada’s first remediation agreement under the Criminal Code, which is Canada’s version of a deferred prosecution agreement (DPA). In his reasons, the...more

Husch Blackwell LLP

BIS Modifies and Expands List of Russian-Controlled Aircraft Subject to the EAR Known or Suspected to Have Violated the EAR

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On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations...more

Holland & Hart LLP

EPA Under Biden Signals Continuing Importance of Self-Disclosure

Holland & Hart LLP on

On February 5, 2021, the U.S. Environmental Protection Agency (EPA) issued updated Frequently Asked Questions (FAQs) regarding its Audit Policy Program, signaling that the Biden Administration will continue to support...more

Holland & Knight LLP

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

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

Ballard Spahr LLP

MDE Self-Disclosure Can Limit, Even Eliminate Risk of Environmental Penalties

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Maryland entities that voluntarily discover and disclose environmental violations can still receive penalty reductions, or even complete forgiveness, under the rarely invoked Maryland Department of the Environment (MDE)...more

Baker Donelson

2013 Healthcare Fraud and Abuse Bootcamp Webinar Series, Part V: Compliance

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Bill Mathias of Ober|Kaler's Health Law Group presented on compliance as a part of the 2013 Healthcare Fraud and Abuse Bootcamp Webinar Series sponsored by the American Health Lawyers Association. This webinar...more

Thomas Fox - Compliance Evangelist

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

Thomas Fox - Compliance Evangelist

Actions Taken During A FCPA Enforcement Action - Lessons From Parker Drilling And Ralph Lauren

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

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