News & Analysis as of

Self-Reporting Compliance Corporate Misconduct

Morrison & Foerster LLP

New CFTC Advisory Incentivizes Self-Reporting, Cooperation, and Remediation

The Advisory sets out factors that the Enforcement Division will use to rate self-reporting and cooperation. This rating places a company or individual within a “tier” used to determine the Mitigation Credit amount available....more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments – Q3 2024

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On August 1, 2024, the Department of Justice (DOJ) launched its Corporate Whistleblower Awards Pilot Program, first announced earlier this year. Through the pilot program, the DOJ may issue awards to whistleblowers who...more

Fenwick & West LLP

DOJ ‘Upping the Ante’ for Corporate Self-Disclosure with New Corporate Whistleblower Awards Pilot Program

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Earlier in 2024, DOJ’s Criminal Division announced a new Corporate Whistleblower Awards Pilot Program granting whistleblower awards to individuals who provide information in four priority areas. ...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 3-The Role of Internal Controls

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

White & Case LLP

DOJ Launches New Whistleblower Pilot Program

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In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more

Farella Braun + Martel LLP

New DOJ Corporate Whistleblower Awards Program Pits Company Compliance Programs Against the Clock

The Department of Justice announced a Corporate Whistleblower Awards Pilot Program on August 1, 2024. If a whistleblower voluntarily reports original, truthful, and complete information to DOJ in a relevant subject...more

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

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In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more

BakerHostetler

DOJ Corporate Whistleblower Awards Pilot Program

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DOJ has introduced the new three-year Pilot Program, managed by the Criminal Division’s Money Laundering and Asset Recovery Section, effective August 1. Under this Pilot Program, whistleblowers meeting certain criteria may be...more

K&L Gates LLP

Department of Justice Launches First-Of-Its-Kind Corporate Whistleblower Awards Program

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After months of anticipation, the Department of Justice (DOJ) unveiled the details of its new Corporate Whistleblower Awards Pilot Program (the Corporate WB Program or the Program)....more

Womble Bond Dickinson

DOJ Debuts Pilot Corporate Whistleblower Awards Program

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The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...more

Dorsey & Whitney LLP

DOJ’s New Whistleblower Program Incentivizes Individuals and Corporations to Disclose Wrongdoing

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The U.S. Department of Justice (DOJ) just launched the new corporate whistleblower awards pilot program that it previewed this past March. ...more

BCLP

DOJ Piles On the Incentives for Individuals to Blow the Whistle on Companies

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Historically, successful white-collar prosecutions often turn on the government’s ability to identify “insiders” with firsthand knowledge of the alleged criminal scheme, who opt to cooperate with prosecutors in exchange for...more

Latham & Watkins LLP

DOJ Launches New Whistleblower Incentive Program

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DOJ’s pilot program aims to fill gaps in existing federal whistleblower programs and incentivize prompt corporate self-disclosure alongside individual whistleblower tips. Following the March 2024 announcement of its...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Official Cites Old West ‘WANTED’ Posters in Announcement of New Whistleblower Monetary Awards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more

Society of Corporate Compliance and Ethics...

Encouraging and Managing Employee Self-Reporting

We spend a lot of time in compliance discussing how to encourage employees to come forward and report any wrongdoing they see around them. Considerably less time, though, is spent on how to handle employees who report their...more

A&O Shearman

DOJ Announces Safe Harbor For Companies That Self-Disclose Misconduct Discovered During M&A

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On October 4, 2023, Deputy Attorney General Lisa O. Monaco announced a Department of Justice-wide safe harbor policy for voluntary self-disclosures made in connection with mergers and acquisitions.  During her remarks at the...more

Alston & Bird

The Clock Is Ticking: DOJ Announces New, Department-Wide Mergers & Acquisitions Safe Harbor Policy

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Our White Collar, Government & Internal Investigations and Mergers & Acquisitions Teams explain how acquiring companies can find a limited safe harbor from enforcement when they find pre-merger misconduct....more

Sheppard Mullin Richter & Hampton LLP

DOJ Touts Emerging Results from New Corporate Crime Self-Reporting Initiatives

The Department of Justice’s recent criminal self-reporting policy changes are beginning to show results, according to Assistant Attorney General Kenneth Polite Jr. Speaking at the New York City Bar Association’s White Collar...more

Holland & Knight LLP

DOJ Announces Significant Policy Changes Affecting Corporate Criminal Enforcement

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In back-to-back speeches to the American Bar Association's National Institute on White Collar Crime on March 2-3, 2023, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco and Assistant Attorney General...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

Porter Hedges LLP

U.S. Attorneys’ Offices Implement New Voluntary Self-Disclosure Policy

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On February 22, 2023, the U.S. Department of Justice’s (DOJ) United States Attorneys’ Offices (USAO) announced a new Voluntary Self-Disclosure Policy that went into immediate effect. The purpose of the new policy is to create...more

BakerHostetler

DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

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On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

Blank Rome LLP

“We Have Ways of Making You Talk,” New DOJ Incentives for Self-Reporting Corporate Misconduct

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Last week, Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. (“AAG Polite”) announced revisions to the Department of Justice Criminal Division’s Corporate Enforcement Policy (the “CEP”). These...more

Snell & Wilmer

DOJ Updated Corporate Criminal Enforcement Policies

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In a highly anticipated speech, Deputy Attorney General Lisa O. Monaco delivered remarks outlining updates to the U.S. Department of Justice (“DOJ”) perspective on the Corporate Crime Enforcement policy. These updates are the...more

Husch Blackwell LLP

DOJ's New Policies Encourage Voluntary Self-Disclosure, Compensation Tied to Compliance

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In a speech given at NYU on September 15, 2022, Deputy Attorney General Lisa Monaco reviewed new and enhanced Department of Justice (DOJ) policies regarding criminal enforcement related to corporate entities. Assistant...more

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