News & Analysis as of

White Collar Crimes Cooperative Compliance Regime

Robinson & Cole LLP

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary...

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On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

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On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more

Woods Rogers

Wax On, Wane Not: Corporate Investigations and Enforcement Actions are on the Rise at DOJ

Woods Rogers on

Every national election cycle, we are reminded that presidential administrations drive the trajectory of white-collar civil and criminal enforcement priorities. Halfway through President Biden’s first term, in 2022, Attorney...more

J.S. Held

INDEPTH FEATURE: Corporate Fraud & Corruption 2024

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To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more

Ballard Spahr LLP

DOJ Launches Whistleblower Pilot Program and Cracks Down on AI Misuse

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The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more

Troutman Pepper

DOJ's New Voluntary Self-Disclosure Policy Raises More Questions Than It Answers

Troutman Pepper on

On February 22, 2023, the Department of Justice (DOJ) issued a press release highlighting the new Voluntary Self-Disclosure (VSD) Policy for U.S. Attorney’s Offices (USAOs). The DOJ developed this policy, which is applicable...more

The Volkov Law Group

DOJ Issues Revised Corporate Compliance Guidance: Consequence Management, Clawbacks and Human Resource Cooperation (Part I of III)

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The Justice Department is rapidly pushing corporations to a new level of compliance.  We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs.  It would be a...more

Robinson & Cole LLP

DOJ Announces Significant Corporate Compliance Initiatives

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The U.S. Department of Justice (DOJ) recently announced several new policies and programs aimed at incentivizing corporate compliance. These programs underscore the need for companies to investigate, mitigate and resolve...more

Akerman LLP

Carrots and Sticks: DOJ Announces Policy Shift on Corporate Crime

Akerman LLP on

On September 15, Deputy Assistant General of the United States ("DAG") Lisa Monaco announced new U.S. Department of Justice ("DOJ") policy changes during a speech on corporate criminal enforcement at New York University Law...more

Dechert LLP

Measure Twice, Cut Once: New DOJ Compliance Certifications Put CEOs and CCOs at Risk of Individual Criminal Liability

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Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more

The Volkov Law Group

DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)

The Volkov Law Group on

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement...more

Jenner & Block

DOJ Initiatives Aim to Empower Chief Compliance Officers and Strengthen Corporate Compliance Programs

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On March 25, 2022, Kenneth Polite, Assistant Attorney General for the Department of Justice (DOJ)’s Criminal Division, delivered a speech at NYU Law School’s Program on Corporate Compliance and Enforcement announcing...more

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

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Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

The Volkov Law Group

DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over...

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The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021.  While many commentators sought to read the...more

Hogan Lovells

World Bank Investigations Arm Sets Anti-Corruption Priorities for 2021

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In October, the World Bank Group (WBG) published its third Sanctions System Annual Report for Fiscal Year 2020 (FY20), which covers the period from 1 July 2019 to 30 June 2020. The report provides a detailed look at the...more

Mitratech Holdings, Inc

COVID Risk Events and DOJ Compliance Expectations

To say it’s a challenge might be an understatement: Many managers are wondering to what extent their regulators will allow them to modify compliance standards during COVID-19....more

Foodman CPAs & Advisors

¿Qué hay de nuevo en la Guía del “DOJ” de Evaluación del Programa de Cumplimiento Corporativo actualizada?

El 1 de junio de 2020, la División Criminal del Departamento de Justicia (“DOJ”) publicó una actualización de la Evaluación de Programas de Cumplimiento Corporativo de la División Criminal del Departamento de Justicia de los...more

Hogan Lovells

The U.S. Department of Justice updates roadmap to an effective compliance program

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On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more

Hogan Lovells

Beware: Anti-bribery audits are now key in M&A transactions

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As compliance requirements continue to evolve in France, the guide offers focused, much-needed advice on three areas: audits as part of M&A, how and when to audit, and the outcomes. ...more

The Volkov Law Group

Keeping Your Eye on the Risk Ball

The Volkov Law Group on

Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces.  I am exaggerating a little bit to make...more

Hogan Lovells

OFAC, EU, and UK financial sanctions - are you compliant? Top tips for financial institutions, private equity, debt funds and...

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On 6 November we held a breakfast seminar focusing on the most important sanctions issues affecting the City and how to manage compliance with different financial sanctions regimes effectively. ...more

Ballard Spahr LLP

FinCEN Issues Advisory on Foreign Jurisdictions with AML Deficiencies

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On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more

Thomas Fox - Compliance Evangelist

Films of Val Lewton: Part 3 – I Walked with a Zombie and 20 Questions for the Board

Let’s consider a list of 20 questions to reflect the oversight role of directors. These are questions the Board should ask of both senior management and the Board itself. The questions are not intended to be an exact...more

Troutman Pepper

New DOJ Guidance Instructs Corporations on Hallmarks of an Effective Compliance Program

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On April 30, the Criminal Division of the Department of Justice released an update to the Fraud Section’s February 2017 guidance document titled “Evaluation of Corporate Compliance Programs.” ...more

Bricker Graydon LLP

DOJ updates guidance on evaluating the effectiveness of corporate compliance programs

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On April 30, 2019, the U.S. Department of Justice (DOJ) released updated guidance detailing how prosecutors will evaluate corporate compliance programs in charging and resolving criminal cases....more

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