News & Analysis as of

Voluntary Disclosure Enforcement Actions Whistleblowers

Vinson & Elkins LLP

Focus, Fairness, & Efficiency: DOJ White Collar Policy Shifts Signal Recalibration, But Not Revolution in Enforcement

Vinson & Elkins LLP on

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (“DOJ” or the “Department”) issued a series of significant policy changes outlining the Trump administration’s new approach to white-collar enforcement....more

Saul Ewing LLP

DOJ's New Direction: Implications of the Trump Administration's Recently Announced Corporate Enforcement Framework

Saul Ewing LLP on

A Significant Shift in White Collar Criminal Enforcement - The Department of Justice (“DOJ”) has unveiled a comprehensive plan for its white-collar crime enforcement strategy, laying out the “high-impact” areas where...more

Mintz - Health Care Viewpoints

Voluntary Self-Disclosure and Whistleblower Awards Initiatives Are Alive and Well in 2025: DOJ Issues White-Collar Enforcement...

The first 120 days of the Trump administration have been characterized by dramatic changes in the realm of white-collar enforcement. However, in the midst of a period wrought with uncertainty over what the administration may...more

Davis Wright Tremaine LLP

DOJ Criminal Division Reveals New White-Collar Crime Enforcement Priorities and Corporate Enforcement Policies

The U.S. Department of Justice's ("DOJ") Criminal Division published a memorandum on May 12, 2025, detailing new white-collar enforcement priorities and policies. DOJ's Memorandum, titled "Focus, Fairness, and Efficiency in...more

Patterson Belknap Webb & Tyler LLP

DOJ Announces Guidance on White Collar Enforcement Priorities and Corporate Cooperation

On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division of the Department of Justice (“DOJ”), announced changes to DOJ’s white collar enforcement priorities and corporate cooperation policy. During a speech on...more

Bradley Arant Boult Cummings LLP

SEC Enforcement Leadership Discusses New Priorities and Expectations

On May 20, 2025, as part of the annual “SEC Speaks” program, the leadership of the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement publicly discussed the enforcement priorities under new Chairman Paul...more

The Volkov Law Group

DOJ Expands Whistleblower Program to Include Tariffs, Sanctions and Export Controls (Part III of III)

The Volkov Law Group on

DOJ’s new Corporate Enforcement Program is designed to bring certainty to the voluntary disclosure and cooperation process.  DOJ’s intent is clear — voluntary disclosure is likely to lead to a declination, reduced penalties...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Announces Shift in Approach to Prosecuting Corporate Crime

The Criminal Division’s revisions to white-collar enforcement policies seek a new balance between uncovering corporate crime and unencumbering American businesses....more

Eversheds Sutherland (US) LLP

DOJ releases new corporate crime enforcement guidance, telling companies what to expect—and how to avoid criminal penalties

On May 12, 2025, the US Department of Justice’s (DOJ) Criminal Division issued a memorandum titled Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime (the Memo) to all Criminal Division personnel. The...more

Mayer Brown

DOJ Announces White-Collar Enforcement Priorities and Revised Policies

Mayer Brown on

On May 12, 2025, the Criminal Division of the US Department of Justice (DOJ) issued new guidance on white-collar enforcement priorities and revised its policies on corporate voluntary self-disclosure (VSD), the selection of...more

Arnall Golden Gregory LLP

"Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime": DOJ Revises Policies on White-Collar Criminal...

On May 12, 2025, the U.S. Department of Justice’s Criminal Division unveiled an overhaul of its white-collar enforcement policies in a memo issued by Matthew Galeotti, head of the Criminal Division. The memo, titled “Focus,...more

Perkins Coie

DOJ Signals Renewed Prioritization of Corporate Enforcement with New Policies Regarding Voluntary Disclosure, Monitors, &...

Perkins Coie on

On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Unveils White Collar Enforcement Overhaul: New Incentives, Streamlined Policies and Expanded Whistleblower Rewards

Revisions to Department of Justice (DOJ) white collar enforcement policies provide enhanced incentives for voluntary self-disclosure and clarify the consequences of failing to disclose wrongdoing. At the same time, expanded...more

McDermott Will & Emery

DOJ Unveils New Plan for White-Collar Crime and Corporate Enforcement

McDermott Will & Emery on

The US Department of Justice’s (DOJ’s) current approach to corporate criminal enforcement has come into focus with the issuance of a new White-Collar Enforcement Plan and several revised policy documents. The changes, which...more

Troutman Pepper Locke

DOJ’s Criminal Division Announces Updates to White-Collar Enforcement and Corporate Policies

Troutman Pepper Locke on

On May 12, 2025, the Head of the Criminal Division (the Criminal Division or Division) at the Department of Justice (DOJ), Matthew R. Galeotti, issued key memoranda to Criminal Division personnel on the Division’s new...more

Wiley Rein LLP

DOJ Announces Changes to White Collar Enforcement Policies, Focusing on “Most Egregious” Crimes

Wiley Rein LLP on

This week, the U.S. Department of Justice (DOJ) announced the Criminal Division’s new white collar enforcement plan, changes to its Corporate Whistleblower Pilot Program, and revisions to the Corporate Enforcement and...more

DLA Piper

Long-Awaited DOJ Guidance on White Collar Enforcement Priorities and Policies: Key Takeaways

DLA Piper on

This guidance follows a number of Executive Orders (EOs) and other memoranda from the DOJ, including (1) the February 10, 2025 EO pausing enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days, pending the...more

Foley & Lardner LLP

What Every Multinational Company Needs to Know About … Criminal Enforcement of Trade, Import, and Tariff Rules: A Growing Risk for...

Foley & Lardner LLP on

In less than 100 days, the Trump administration has implemented a dizzying array of new tariffs, significantly increasing costs and complexity for U.S. importers. The administration is keenly aware that companies operating in...more

BakerHostetler

Should You Consider a Voluntary Self-Disclosure for a Tariff Violation?

BakerHostetler on

Tariff evasion techniques such as transshipping goods through third countries, underreporting the value of goods, and mislabeling goods as other items subject to lower tariff rates have resulted in hundreds of billions of...more

The Volkov Law Group

DOJ’s Balancing Act — Incentives to Cooperate and Deterrence (Part III of III)

The Volkov Law Group on

While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies.  These measures were believed to coincide with a number of significant...more

Mintz - Health Care Viewpoints

EnforceMintz – DOJ Policy Developments in 2024 Seek to Motivate More Voluntary Self-Disclosures

Over the past two years, the Department of Justice (DOJ or the Department) has actively incentivized companies to voluntarily self-disclose potential civil and criminal violations. For example, in 2023, in the criminal...more

The Volkov Law Group

The FCPA Year in Review — More of the Same with Some Twists (Part I of III)

The Volkov Law Group on

With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement.  On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

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

Torres Trade Law, PLLC

Noteworthy FCPA Enforcement Developments

Torres Trade Law, PLLC on

The Department of Justice really wants violators of the Foreign Corrupt Practices Act (FCPA) to come forward: following a January 2023 revision of its Corporate Enforcement Policy that incentivized voluntary self-disclosure,...more

Dinsmore & Shohl LLP

DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program

Dinsmore & Shohl LLP on

?? In this Spotlight on White Collar Defense and Government Investigations, Cincinnati's Lindsay Gerdes explains how the U.S. Department of Justice’s (DOJ) self-disclosure policy encourages companies to voluntarily disclose...more

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