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
On February 25, 2025, the CFTC released an Enforcement Advisory on Self-Reporting, Cooperation, and Remediation, introducing metrics the Division will use to evaluate a company’s or individual’s conduct before and leading up...more
2024 saw no change in the government's campaign to encourage self-reporting and cooperation. In the second installment of Season's Readings, we take a quick look at how the SEC treats self-reporting and how that differs...more
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
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
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
Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more
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
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
Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...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
CEP Magazine (September 2022) - This month’s column is about something I hope you never have to address: cooperating with government officials in connection with an investigation into a compliance violation at your...more
The approach to compliance programs of the Antitrust Division at the US Department of Justice has evolved considerably over the last few years, starting with the release of their watershed Evaluation of Corporate Compliance...more
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
The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more
The CFTC Division of Enforcement filed its Third Annual Report at the end of November 2019, reviewing the fiscal year. The Report is the typical mixture of goals, statistics, analysis and initiatives. Overall it offers...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
Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations. On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more
In a major policy shift, the Antitrust Division of the Department of Justice recently announced that it will now credit companies for effective corporate antitrust compliance programs in making charging decisions and penalty...more
On July 11, 2019, FINRA provided additional guidance on obtaining extraordinary cooperation credit to supplement its prior enforcement guidance. FINRA Regulatory Notice 19-23, FINRA Investigations: FINRA Supplements Prior...more
Companies facing liability under the False Claims Act (FCA) often desire early resolution with the Department of Justice (DOJ) through settlement. Hand in hand with the decision to settle comes the decision of whether or not...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
Introduction - The Commodity Futures Trading Commission (CFTC or Commission) recently took several steps to further encourage cooperation with and self-reporting to the Commission’s Division of Enforcement (Division). In...more
On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more
On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more
• The voluntary disclosure of a Foreign Corrupt Practices Act (FCPA) violation, “full cooperation” in an ensuing investigation, and timely and appropriate remediation, will create a presumption that the disclosing company...more