Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement
Understanding the Latest DOJ Changes to Corporate Prosecutions
The Justice Insiders Podcast: Self-Disclosure, Cooperation, and the Hazards of Knowing Too Little
5 Key Takeaways | 2024 Emerging Trends: Delaware Unclaimed Property VDA and Multistate Audits
The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
FCPA Survival Guide: Step 1 - Self-Disclosure
Episode 316 -- DOJ Announces New Whistleblower Policy
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC
Episode 289 -- Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure
What DAG Lisa Monaco's Speech Means for Compliance Programs
Torres Talks Trade Podcast- Episode 13- When Government Agencies Come Knocking
Torres Talks Trade Episode 11 on Sanctions and Export Enforcement Cases by DOJ
The Justice Insiders Podcast: The DOJ Wants You! - Part II: Voluntary Disclosures
Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Anti-corruption & international risk developments
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
FCPA Compliance Report-Episode 366 Jonathan Marks on performing and using a root cause analysis
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more
The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement — the company has...more
On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more
In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to...more
Government contractors are no stranger to disclosure obligations. Since it went into effect in December 2008, the Federal Acquisition Regulation (FAR) Mandatory Disclosure Rule has been the stick the Government has used to...more
DOJ has been on a public relations campaign to push a simple message for corporations: if companies learn of misconduct, companies should disclose such misconduct to earn valuable benefits. The quintessential question...more
We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more
On February 13, the U.S. Attorney’s Office (USAO) for the Southern District of New York (SDNY) announced a pilot program through which whistleblowers who voluntarily self-disclose criminal conduct relating to public or...more
The Department of Justice (DOJ) has been making significant strides in emphasizing the importance of voluntary self-disclosure in corporate enforcement cases, particularly in the realm of the Foreign Corrupt Practices Act...more
Last September, US Deputy Attorney General Lisa Monaco issued a memorandum instructing the various departments in the Department of Justice to adopt a lenient enforcement policy toward corporations. The aim of this policy is...more
The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation. The Golden Ring for every company facing...more
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more
On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more
In the fourth quarter of 2019, U.S. enforcement authorities sustained efforts to prosecute individuals violating U.S. anticorruption laws in matters related to Latin America, while authorities in Latin America, including in...more
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...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
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more
In a recently released letter, the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to...more
How should a compliance practitioner use the information from these three Foreign Corrupt Practices Act (FCPA) enforcement actions going forward? Do the differing results in these three enforcement actions (Dun & Bradstreet...more
Today being the fortieth anniversary of the December 19, 1977 enactment of the Foreign Corrupt Practices Act (“FCPA”), we offer this Client Alert in celebration of the occasion. Fittingly, the U.S. Department of Justice...more
The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations. How is that for a profound grasp of the obvious?...more
The Justice Department recently resolved two separate FCPA investigations under its Pilot Program. To be sure, DOJ’s resolution of these two matters reinforces the real and tangible benefits of its Pilot Program....more
This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian meatpacker JBS agrees to the largest fine ever for fine for bribery and corruption, $3.2bn...more