News & Analysis as of

Self-Reporting Corporate Misconduct Cooperation

K&L Gates LLP

The Serious Fraud Office's Guidance on How to Best Avoid Prosecution

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The United Kingdom’s Serious Fraud Office (SFO) recently published updated guidance on how corporates can best avoid or reduce the risk of prosecution in cases involving economic crimes such as bribery, fraud and corruption...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Serious Fraud Office Releases New Guidance on Self-Reporting, Cooperation and Deferred Prosecution Agreements

On 24 April 2025, the Serious Fraud Office (SFO) released new guidance on corporate self-reporting, cooperation and deferred prosecution agreements (DPAs)....more

BakerHostetler

SEC Enforcement Director Grewal Doubles Down on Encouraging Self-Reporting

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In a recent interview with Law360, Securities and Exchange Commission (SEC) Enforcement Director Gurbir Grewal reiterated the agency’s commitment to the encouragement of voluntary self-reporting, going as far as to say that...more

Skadden, Arps, Slate, Meagher & Flom LLP

Decoding AFA’s Guide: A Comparison of Sponsorship and Charitable Donations in France, the US and the UK

On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more

Fisher Phillips

Workplace Law Update: 10 Essential Items on Your April To-Do List

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It’s hard to keep up with all the recent changes to labor and employment law, especially since the law always seems to evolve at a rapid pace. In order to ensure you stay on top of the latest changes and have an action plan...more

Fisher Phillips

Feds Encourage Companies to Come Clean on Criminal Conduct and Reward Whistleblowers for Reporting Wrongdoing: Key Takeaways for...

Fisher Phillips on

Federal prosecutors are exploring new ways to encourage business leaders to invest in their corporate compliance programs. Indeed, a Department of Justice official recently announced several new programs incentivizing...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

WilmerHale

DOJ Announces New Mergers & Acquisitions Safe Harbor Policy

WilmerHale on

On October 4, 2023, Deputy Attorney General Lisa Monaco announced a new safe harbor policy that may shield companies from criminal prosecution for misconduct they uncover at companies they are acquiring or have recently...more

BakerHostetler

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

BakerHostetler on

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

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Emphasizes Transparency and Encourages Cooperation

In 2019, the Criminal Division of the U.S. Department of Justice (DOJ) continued its efforts, begun a few years prior, to enhance transparency with respect to the DOJ's prosecutorial decision-making. In public statements, DOJ...more

Vedder Price

FINRA Issues Supplemental Guidance on Giving Credit for Extraordinary Cooperation

Vedder Price on

On July 11, 2019, FINRA issued Regulatory Notice 19-23 to restate and supplement its prior guidance to member firms on the circumstances under which FINRA awards credit for providing "extraordinary cooperation" during an...more

Kramer Levin Naftalis & Frankel LLP

The First PNF/AFA Common Guidelines

When Law No. 2016-1691 (Sapin II Law) created the convention judicaire d’intérêt public (CJIP), modeled after the American deferred prosecution agreement (DPA), it was feared that the existence of potentially dueling French...more

Latham & Watkins LLP

New DOJ Policy Will Curb “Piling On” Multiple Penalties for Same Corporate Misconduct

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Corporate resolution policy will provide greater clarity and predictability for companies that self-report and cooperate with DOJ. Key Points: ..The new policy requires DOJ civil and criminal prosecutors to coordinate...more

Blank Rome LLP

DOJ Announces FCPA Pilot Program in an Effort to Incentivize Companies to Self-Report Misconduct

Blank Rome LLP on

Action Item: On April 5, 2016, the U.S. Department of Justice (“DOJ”) issued a memorandum laying out a one-year pilot program designed to offer mitigation credit to companies that voluntarily disclose Foreign Corrupt...more

Miller Canfield

DOJ’s Fraud Section Issues Foreign Corrupt Practices Act Enforcement Plan and Guidance

Miller Canfield on

On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...more

Dorsey & Whitney LLP

DOJ’s New FCPA Pilot Program: The Offer of Enhanced Credit

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DOJ’s continuing focus on individuals has spawned a new one year FCPA Pilot Program which offers companies enhanced cooperation credit The new Pilot Program is part of an overall effort to bolster FCPA compliance. Those...more

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