Understanding the DOJ's Recent Corporate Enforcement Policy Changes
FCPA Compliance Report: Recent DOJ Policy Announcements
An Ounce of Prevention Podcast | The International Anti-Corruption Prosecutorial Taskforce and the Future of Global Enforcement
Everything Compliance: Episode 154, The Law Firms in Trouble Edition
SBR-Author’s Podcast: The Unseen Life of an Undercover Agent: A Conversation with Charlie Spillers
Compliance into the Weeds: Leaving on a (Qatari) Jet Plane
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
The JustPod: A murder-for-hire allegation, public corruption trial, and notable acquittal
Work This Way: A Labor & Employment Law Podcast | Episode 43: How Employers Can Navigate White Collar Crime with Erica Barnes & Christian Dysart of Maynard Nexsen
Daily Compliance News: April 15, 2025, The Redefining Corruption Edition
Criminal Health Care Fraud Enforcement: Projections for 2025 and Beyond – Diagnosing Health Care Video Podcast
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
An Ounce of Prevention Podcast | Preparing for the UK Failure to Prevent Fraud Offence
Sunday Book Review: March 23, 2025, The Hard-Boiled Edition
Jones Day Talks®: Corporate Fraud Investigations in 2025: Lessons, Trends, and Need-to-Knows
Episode 359 -- Review of the EU Whistleblowing Directive with Alex Cotoia and Daniela Melendez
The Presumption of Innocence Podcast: Episode 56 - A Strategic Gamble: The Risks, Costs and Rewards of Going to Trial
What’s the difference between a Red Corner Notice and a Red Notice?
False Claims Act Insights - Some FCA Whistles Are Louder Than Others
RICO's Person/Enterprise Distinction - RICO Report Podcast
On June 9, 2025, the U.S. DOJ issued new FCPA enforcement guidelines to the global anti-corruption community, effectively ending the recent enforcement pause. This newly released enforcement framework signals a focused and...more
Issued on February 10, 2025, Executive Order 14209 (“Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security”) called on the Department of Justice (DOJ) to “review guidelines and...more
On August 1, 2024, the US Department of Justice (DOJ) Criminal Division introduced its Corporate Whistleblower Awards Pilot Program (Program), which, like a modern-day Western posse, aims to bring justice to the wild frontier...more
It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? If you can quickly and quietly fix the problem, then you may be able...more
Robbie Robertson died this week. He was the lead songwriter and one of the five members of a rock and roll group that was so impactful, it was simply known as The Band. Robertson came from Canada but wrote in a genre which is...more
This is not your typical FCPA enforcement action Lessons Learned column. Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more
As expected when a new administration takes office, 2021 saw a surge in white-collar enforcement activity. There was a 12% increase in white-collar prosecutions during US President Joe Biden’s first year in office, and that...more
With the holiday season upon us, companies waiting for a nice surprise this Christmas are more likely to find a lump of coal in their stocking. In a series of recent announcements, Department of Justice (“DOJ”) officials have...more
In one of the first substantive speeches on corporate criminal enforcement under the Biden administration, Deputy Attorney General Lisa Monaco announced on October 28, 2021, several immediate changes to Department of Justice...more
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin...more
In 2019, the Criminal Division of the U.S. Department of Justice (DOJ) continued its efforts, begun a few years prior, to enhance transparency with respect to the DOJ's prosecutorial decision-making. In public statements, DOJ...more
I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more
Quad/Graphics, a Wisconsin print and digital marketing company agreed to pay the SEC almost $10 million to settle FCPA charges for foreign bribery violations in Peru and China. ...more
The much heralded Corporate Co-operation Guidance published by the Serious Fraud Office recently offers little comfort to corporates struggling with the dilemma of whether to self-report wrongdoing. Instead it offers a...more
The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more
Recent Trends And Patterns In FCPA Enforcement - Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more
The Justice Department has been criticized on numerous occasions about its approach to criminal investigations and prosecutions. In a recent decision, the chief judge in the Eastern District of New York criticized DOJ for...more
On March 8, 2019, the Department of Justice (“DOJ”) released a revised version of its FCPA Corporate Enforcement Policy (the “Policy”), which provides enforcement and practice guidance to DOJ prosecutors and was formally...more
Yesterday, I considered four questions which the Department of Justice (DOJ) may ask Goldman Sachs. Today I want to consider what the company must show under the FCPA Corporate Enforcement Policy....more
This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more
• Deputy Attorney General Rod Rosenstein has announced a new U.S. Department of Justice (DOJ) policy to discourage government agencies from "piling on" duplicative corporate penalties. • Rosenstein signaled a desire for...more
The United States Department of Justice, the U.S. Securities and Exchange Commission, and non-U.S. governments and agencies have recently emphasized their continued commitments to pursuing both corporate and individual...more
In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more
Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly scoped, and were independent, objective, appropriately conducted, and properly documented? These...more
Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same rigor when it comes to an...more