News & Analysis as of

Voluntary Disclosure Fraud

Morrison & Foerster LLP

DOJ Criminal Division Revises Its Corporate Enforcement Policy, Monitor Selection Policy, and Whistleblower Award Program

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more

Cohen Seglias Pallas Greenhall & Furman PC

DOJ Increases Incentives to Self-Disclose with Revised Corporate Enforcement Policy

Earlier this month, the Department of Justice (DOJ) announced revisions to the Corporate Enforcement and Self Disclosure Policy (CEP). Under the new policy, announced by DOJ Criminal Division Head Matthew Galeotti, companies...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

DOJ Outlines White Collar Enforcement Blueprint

On May 12, 2025, Matthew Galeotti, Head of the Criminal Division at the Department of Justice – Criminal Division, released a memo (the “Memo”), outlining the DOJ’s priorities with respect to the investigation and prosecution...more

Seward & Kissel LLP

DOJ’s White Collar Enforcement Priorities: What’s In, What’s Out

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On May 12, the Criminal Division of the U.S. Department of Justice (DOJ) issued a series of changes in its white collar enforcement priorities. These changes were announced in the Criminal Division Enforcement Plan, the...more

Baker Donelson

Shifting Priorities: DOJ's New Approach to White Collar Enforcement

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The U.S. Department of Justice (DOJ) announced on May 12, 2025, a strategy shift in its approach to white collar enforcement, identifying specific high-impact areas of focus; an expansion of whistleblower and self-disclosure...more

Parker Poe Adams & Bernstein LLP

DOJ's New White-Collar Enforcement Plan Signals Strategic Shift in Corporate Investigations

This week the Department of Justice (DOJ) announced its new approach to corporate criminal enforcement, "Focus, Fairness, and Efficiency in the Fight Against White Collar Crime."...more

Mayer Brown

DOJ Announces White-Collar Enforcement Priorities and Revised Policies

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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

Troutman Pepper Locke

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

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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

Ropes & Gray LLP

An Easier Route To Avoiding Corporate Prosecution? The UK’s SFO Announces A Shift In Strategy And New Corporate Cooperation...

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In what was a busy week for the Serious Fraud Office (SFO), much of the attention has focused on the launch of its new streamlined ‘External Guidance on Corporate Co-Operation and Enforcement in relation to Corporate Criminal...more

ArentFox Schiff

Predicting the Unpredictable: DOJ’s Enforcement Priorities From the ABA’s 40th White Collar Crime Institute

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ArentFox Schiff attorneys William Ziegelmueller and Kaitlin Klamann attended the American Bar Association’s (ABA) 40th White Collar Crime Institute (WCCI) March 5-7, 2025, in Miami, Florida. In the absence of representatives...more

Health Care Compliance Association (HCCA)

Private-pay “crime stoppers”: Digesting the Corporate Whistleblower Awards Pilot Program

The U.S. Department of Justice’s (DOJ) Criminal Division launched its Corporate Whistleblower Awards Pilot Program (“Criminal Whistleblower Program”) in August of 2024 to encourage tips for various types of fraud, including...more

Mintz

Alleged Carbon Markets Fraud Leads to Criminal Charges

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1 The U.S. Attorney's Office for the Southern District of New York recently launched a criminal prosecution in connection with “a scheme to commit fraud in the carbon markets,” specifically that a company and its executives...more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

Rumberger | Kirk

How to Steer Clear of Employee Retention Credit Fraud

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Orlando firms need to make sure they aren’t among the thousands of U.S. businesses that potentially were tricked by scams to inadvertently file fraudulent employee retention credit claims — something punishable by fines and...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

Foodman CPAs & Advisors

ERC Voluntary Disclosure Program Re-Opens

On 7/15/24, the IRS announced via Notice IR-2024-212 the re-opening of the ERC (Employee Retention Credit) Voluntary Disclosure Program which will end on 11/22/24. The first ERC Voluntary Disclosure Program ended in March...more

Proskauer Rose LLP

DOJ Triples Down on Incentivizing Disclosures with Launch of Three-Year Corporate Whistleblower Awards Pilot Program

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Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...more

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

The Volkov Law Group on

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

Fox Rothschild LLP

IRS Reopens Employee Retention Tax Credit Voluntary Disclosure Program

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The ERC is a legitimate, refundable tax credit designed to help businesses that continued to pay employees while they were shut down because of the COVID-19 pandemic or that experienced a significant decline in gross receipts...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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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

Mintz

DOJ Issues its Highly Anticipated Whistleblower Awards Pilot Program

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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

Fox Rothschild LLP

IRS Begins Processing Some Employee Retention Tax Credit Claims Filed During the Moratorium

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The Internal Revenue Service has adjusted its moratorium on processing Employee Retention Tax Credit (ERC) claims, announcing last week it will begin processing claims filed between September 14, 2023 and January 31, 2024. In...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

ArentFox Schiff

Investigations Newsletter: Biomedical Company Avoids DOJ Prosecution After First Ever Voluntary Corporate Self-Disclosure of Fraud...

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Biomedical Company Avoids DOJ Prosecution After First Ever Voluntary Corporate Self-Disclosure of Fraud Under NSD Enforcement Policy - On May 22, the US Department of Justice (DOJ) announced that it will not prosecute a...more

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