Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Encouraging and Managing Employee Self-Reporting
The Latest on Antitrust Compliance
Andy Dunbar and Nick Morgan on What the SEC Expects from Your Internal Investigation
Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement
FERC: A Discussion on its Mission, Market Manipulation Investigations, and Common Violations
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
FCPA Compliance and Ethics Report-Episode 380, Laura Perkins on issues around self-disclosure
Nonpayment of Subcontractors: Can Subcontractors Get Any Help From the Government?
Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
Corporate Criminal Liability – Interview with Bridget Rohde, Member, Mintz Levin
The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more
U.S. Attorney General (AG) Pam Bondi on her first day in office – Feb. 5, 2025 – sent several memos to all employees of the U.S. Department of Justice (DOJ) laying out top priorities. In one memo, the DOJ instructs its...more
Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more
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
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
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
On January 17, 2023, Assistant Attorney General Kenneth Polite announced revisions to the Department of Justice (DOJ) Criminal Division’s Corporate Enforcement Policy (CEP), expanding the availability of a potential full...more
The DOJ Antitrust Division recently announced new requirements for DOJ's Leniency Program, which allows the first individual or company to self-report its involvement in an antitrust conspiracy to avoid prosecution and lessen...more
The U.S. Department of Justice (DOJ) released revisions to its Antitrust Division Leniency Policy and Procedures as well as updated guidance in the form of Frequently Asked Questions (FAQs) on April 4, 2022. Since its...more
Antitrust is a long-time risk area for compliance teams to manage, but its longevity does not mean it is not evolving. New issues arise as times and Administrations in Washington change. Nathan Mendelsohn, Associate in the...more
A recurring question of general counsel and chief compliance officers is whether their proactive investments in compliance programs, voluntary self-disclosure of issues, and cooperation will be meaningfully rewarded. For too...more
While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement. OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions. That is quite an increase...more
Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more
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
One year into the Trump administration, it remains difficult to forecast what lies ahead with respect to regulatory and white collar enforcement activity. Perhaps most instructive are recent public statements of officials at...more
The Business Law Section’s Director and Officer Liability Committee conducted a program at the Section’s Spring Meeting in Montréal. The program focused on the recent Yates memorandum of the U.S. Department of Justice (DOJ),...more
For years, FCPA observers have predicted that the Department of Justice (“DOJ”) will increase its prosecutions of corporate officers and employees for FCPA violations. These predictions have so far proven disputable, as the...more
Let’s start with a big “If.” I know that sounds like a real turn off but bear with me. Assuming that the Justice Department is ready to turn over a new approach to criminal enforcement and aggressively prosecute culpable...more
More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more
Both the United States Department of Justice (DOJ) and the United States Securities and Exchange Commission (SEC) have continued their focus on anticorruption enforcement in 2015. Although there was a decline in enforcement...more
In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that...more
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
The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more