Understanding the DOJ's Recent Corporate Enforcement Policy Changes
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
On May 12, 2025, the Head of the Department of Justice’s (DOJ) Criminal Division, Matthew Galeotti, announced a new white collar enforcement plan in a memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...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
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
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
Over the last 10 years, 143 companies have paid a combined $10.9 billion to resolve Foreign Corrupt Practices Act cases. That staggering price tag shows the U.S. Department of Justice’s willingness to go after alleged...more
Deputy Attorney General Rod J. Rosenstein recently announced a revision to the U.S. Department of Justice (“DOJ”) policy on corporate enforcement of the Foreign Corrupt Practices Act (“FCPA”). The revision codifies a pilot...more
Next week marks the 40th anniversary of the Foreign Corrupt Practices Act – it became effective December 19, 1977. Deputy Attorney General Rod Rosenstein marked the occasion this month by providing an update on the FCPA Pilot...more
On November 29, 2017, Deputy Attorney General Rod Rosenstein announced the issuance of a revised FCPA Corporate Enforcement Policy (the “Policy”). Rosenstein announced that the “new policy enables the Department [of Justice]...more
U.S Deputy Attorney General Rod Rosenstein recently announced the Department of Justice’s revised FCPA Corporate Enforcement Policy. The revised Policy is based on the DOJ’s FCPA Pilot Program (in place since April 2016),...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
Last week the Department of Justice (DOJ) issued its second Declination under the Sessions regime. Short with brevity, the matter nonetheless has some significant points for the compliance practitioner to help move their...more
This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit...more
Enforcement of the Foreign Corrupt Practices Act (FCPA) remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2016, resulting in more than 50 combined enforcement actions, record...more
Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more
Last April, the Criminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit. The pilot program, self-described as “building” on the...more
The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more
Breaking new ground, the Department of Justice (DOJ) recently issued two “declinations with disgorgement” to two companies accused of Foreign Corrupt Practices Act (FCPA) violations. These declinations, released under the...more
DOJ’s FCPA Pilot Program was panned when it was announced in April 2016. Critics contended that the incentive for voluntary disclosure of FCPA violations to DOJ was inadequate....more
Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more
Tom Fox and I recorded a podcast recently on the Johnson Controls enforcement action. In our podcast we discuss a number of issues relating to the Justice Department’s decision to reward Johnson Controls with a declination....more
Today, I end my exploration of recent Foreign Corrupt Practices Act (FCPA) enforcement actions (and one UK Bribery Act enforcement issue), which have occurred since the enactment of the Department of Justice (DOJ) Pilot...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
On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more