News & Analysis as of

Voluntary Disclosure New Guidance

Wilson Sonsini Goodrich & Rosati

DOJ Streamlines Voluntary Self-Disclosure Policy for More Favorable Corporate Criminal Resolutions

When a company detects potential criminal misconduct, it must decide whether to self-disclose the misconduct to the U.S. Department of Justice (DOJ). This decision—while always complicated—is even more difficult during...more

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

BakerHostetler

DOJ Criminal Division Announces Leniency and Potential Declination for Companies That Self-Disclose

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Earlier this month, the DOJ’s Criminal Division Head, Matthew R. Galeotti, spoke at the Securities Industry and Financial Markets Association’s (SIFMA) Anti-Money Laundering and Financial Crimes Conference in Washington,...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

Epstein Becker & Green

With New White Collar Enforcement Priorities Memo, DOJ Seeks to Provide More Pathways to Declinations and Non-Prosecution...

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In Part One of this series, we discussed the May 12, 2025, U.S. Department of Justice Criminal Division’s new guidance memo on white-collar enforcement priorities in the Trump 2.0 Administration entitled “Focus, Fairness, and...more

Benesch

Compliance and Self-Disclosure of Misconduct Must be Top Priorities for Corporate Organizations, According to New Guidance from...

Benesch on

On May 12, 2025, Assistant Attorney General Matthew R. Galeotti, head of the U.S. Department of Justice’s Criminal Division, issued a new policy memorandum entitled “Focus, Fairness, and Efficiency in the Fight Against...more

Cooley LLP

The DOJ’s Policy Shift to Incentivize Self-Reporting

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Earlier this week, the Department of Justice’s Criminal Division released three new documents on corporate misconduct, whistleblowers, compliance monitors, and enforcement priorities that outline significant changes to the...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

Katten Muchin Rosenman LLP

Increased Clarity for White-Collar Clients: The Department of Justice Unveils its Revised Corporate Self-Disclosure Policy

What should U.S. businesses take from the Department of Justice’s (“DOJ”) revisions to its Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”)? While DOJ has long promoted self-disclosure of wrongdoing as a...more

Fenwick & West LLP

DOJ Announces Key Revisions to Corporate Enforcement and Voluntary Self-Disclosure Policy

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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

Holland & Knight LLP

DOJ Announces New Policies and Priorities in Prosecution of White Collar Crime

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The U.S. Department of Justice (DOJ or Department) announced on May 12, 2025, new investigative and policy priorities, as well as changes to current DOJ guidance, that could have a significant impact on the prosecution of...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Baker Donelson

IRS Issues New Guidance on ERC Program – Should You Hold or Fold?

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Over the past week, the IRS has announced two significant developments in its administration and enforcement of the Employee Retention Credit (ERC). Last week, the IRS' three-part announcement signaled: (i) an end to the...more

Robinson & Cole LLP

Legal Update: DOJ Issues Final Guidance on New Whistleblower Awards Pilot Program, Placing Premium on Prompt and Detailed...

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On August 1, 2024, the Department of Justice (DOJ) issued final guidance on its Corporate Whistleblower Awards Pilot Program (Program), offering financial incentives to qualifying individuals who report certain criminal...more

Thomas Fox - Compliance Evangelist

New DOJ M&A Safe Harbor Policy

We continue our review of DOJ initiatives from 2023 and what they may portend for the compliance professional in 2024 and beyond. In October 2023, Deputy Attorney General Lisa Monaco announced a new policy regarding M&A. It...more

Ankura

U.S. DOJ’s New Safe Harbor Policy: Conducting Enhanced M&A Due Diligence

Ankura on

Last month, U.S. Deputy Attorney General Lisa O. Monaco announced a new Safe Harbor Policy for voluntary self-disclosure (the “Policy”) made in connection with merger and acquisition activity. The Policy is intended to bring...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Announces Safe Harbor Policy for Voluntary Self-Disclosures Related to Mergers & Acquisitions

In the U.S. Department of Justice’s (DOJ’s) latest effort to promote voluntary self-disclosure of corporate misconduct by companies, Deputy Attorney General (DAG) Lisa Monaco has announced guidance regarding a new safe harbor...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

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On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Polsinelli

Annual ABA White Collar Conference Brings Additional Updates to DOJ Corporate Enforcement Policy

Polsinelli on

Last week at the American Bar Association’s annual National Institute on White Collar Crime in Miami, Deputy Attorney General Lisa Monaco and Assistant Attorney General Kenneth A. Polite highlighted several new facets of the...more

Latham & Watkins LLP

New CFIUS Enforcement Guidelines: Top 5 Takeaways

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While the Guidelines are not legally binding, they signal CFIUS’s clear intent to take an active approach to compliance and enforcement. On October 20, 2022, the US Department of the Treasury, as Chair of the Committee on...more

Venable LLP

Part 1: Cooperation in Government Investigations and Voluntary Self-Disclosure: What to Expect After DOJ’s Latest Guidance

Venable LLP on

​​​​​​​On September 15, Deputy Attorney General Lisa Monaco issued a department-wide memorandum containing revisions to the Justice Department’s (DOJ) corporate criminal enforcement policies (“the Memorandum”), including...more

Latham & Watkins LLP

US Deputy Attorney General Monaco Announces Revised Policies on Corporate Crime

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Updated DOJ policies will continue to focus on individual accountability and corporate recidivism, while aiming to provide additional incentives for voluntary self-reporting, foster greater transparency on use of monitors,...more

Eversheds Sutherland (US) LLP

The DOJ’s new guidance on corporate criminal enforcement - and what it means for your business

​​​​​​​On September 15, 2022, Department of Justice (DOJ) Deputy Attorney General (Deputy AG) Lisa Monaco announced new guidance for the DOJ’s corporate enforcement policies, which is memorialized in the Memorandum on Further...more

Jackson Walker

DOJ Officials Announce New Priorities to Combat Corporate Crime with Additional Details Provided at Government Enforcement...

Jackson Walker on

On Thursday, September 15, 2022, Deputy Attorney General Lisa A. Monaco outlined new steps the Department of Justice will be taking in its ongoing efforts to police corporate crime. The next day, Assistant Attorney General...more

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