FCPA Compliance Report - James Koukios on the Monaco Speech
Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities
Nota Bene Episode 29: The Essential Elements of Effective Corporate Compliance Programs with Jim McGinnis
Day 13 of One Month to Better Investigations and Reporting-The Yates Memo and Internal Investigations
Day 9 of One Month to Better Reporting and Investigations-The Investigation Team
Day 8 of One Month to Better Investigations and Reporting Day 8-Preparing for the Investigation
Everything Compliance-Episode 11, the first 100 Days of the Trump Administration, Part II
FCPA Compliance Report-Episode 319-Brandon Essig on Prosecutor's View of the Yates Memo
Internal Investigations: The Impact of the Yates Memo, the FCPA Unit Pilot Program and Recent Legal Decisions
This Week in FCPA-Episode 1
A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more
Editor’s Note: From time to time, ComplexDiscovery highlights publicly available or privately purchasable announcements, content updates, and research from cyber, data, and legal discovery providers, research organizations,...more
As a product of the Department of Justice’s newly minted Corporate Crime Advisory Group, the DOJ has issued follow-up guidance to its October 2021 memo on corporate criminal enforcement, which reinstated prior guidance...more
There is almost universal agreement regarding predictions for 2022 federal enforcement in the following areas: ..The use of fraudulently obtained COVID relief funds in both healthcare and in general, but specifically as...more
In a speech to the ABA’s 2021 annual National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco emphasized that prosecuting individuals accused of white collar crime is a top priority for the Biden...more
Just one year after President Biden’s election, senior administration officials have signaled in public remarks that the federal government will amplify enforcement pressure on corporations and their employees through...more
In 2015, our colleagues in the white-collar criminal defense bar braced for the impact of a memorandum penned by then Deputy Attorney General Sally Yates. The Yates Memo encouraged both federal prosecutors and civil...more
In 2015, then-Deputy AG Sally Yates (Attorney General Eric Holder’s second-in-command) published DOJ’s new policy statement on the investigation and prosecution of corporate offenses, heavily increasing focus on individuals...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
As widely anticipated, French and U.K. regulators recently published guidance detailing their expectations for corporate cooperation in enforcement investigations. Both sets of guidance demonstrate further alignment of those...more
The U.S. Justice Department (DOJ) is still in the early days of applying a significant change to how companies get credit for cooperating during government investigations. In a speech delivered on November 29, 2018, Deputy...more
On November 29, 2018, during a speech at the International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced changes to the Department of Justice’s (DOJ or the Department)...more
• Recent Justice Manual changes roll back Yates memo requirements for corporations seeking cooperation credit in enforcement actions, including civil enforcement actions. • Corporations can now receive maximum cooperation...more
On November 29, 2018, in a speech at the 35th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ or the Department) revised...more
The Department of Justice (“DOJ”) announced that it is stepping back from its hard-line approach to corporate cooperation credit in which a corporation was not eligible for credit unless it disclosed all relevant facts about...more
In September 2015, then-Deputy Attorney General (DAG) Sally Q. Yates announced, in a memorandum (the “Yates Memo”), that the Department of Justice (DOJ) would place greater emphasis on pursuing individuals for corporate...more
The Justice Department’s revisions to the so-called “Yates Memo” continues a series of significant white collar enforcement policy changes. We hope this summary is helpful to businesses and their leaders in adjusting to these...more
In a November 29, 2018 speech, Deputy Attorney General Rod Rosenstein announced a softening of the US Department of Justice’s (DOJ) policy on giving credit for cooperation in corporate prosecutions. As memorialized in the...more
On November 29, 2018, Deputy Attorney General Rod Rosenstein announced revisions to the Department of Justice (“DOJ”) policy on individual accountability for corporate wrongdoing, which was originally announced in the Yates...more
After three years of working with the Yates Memo, the Department of Justice has memorialized the more practical applications federal prosecutors have been using on the ground. Our White Collar, Government & Internal...more
Deputy Attorney General Rod Rosenstein announced a series of changes to Department of Justice (DOJ) policy that clarified DOJ’s expectations for cooperation in investigations of corporate wrongdoing. The changes are sensible...more
The Fed released minutes from its November meeting yesterday, and they reinforced the expected December rate hike while showing a more uncertain path for hikes in 2019....more
On Sept. 9, 2015, then-Deputy Attorney General Sally Yates issued a memo requiring federal prosecutors to investigate any individuals responsible for illegal corporate conduct before settling a case. This applied to both...more
In recent years the buzz in organizational criminal liability has come from so-called “individual liability” for acts of corporate wrongdoing—the idea that managers and employees are not immune from individual prosecution for...more
It always comes when you least expect it – a government inquiry to investigate your business. While it may instill a sense of panic, there are steps you can take to make sure you’re in the best position possible when the...more