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Yates Memorandum Federal Pilot Programs

Foley & Lardner LLP

The Foreign Corrupt Practices Act and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

Since mid-2000s investigation of Siemens, and the resulting $800 million penalty for violations of the Foreign Corrupt Practices Act (FCPA), the FCPA has been an enforcement priority of the U.S. Government. Although a dip in...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

Ruder Ware on

By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

Pillsbury Winthrop Shaw Pittman LLP

Great Expectations - DOJ holds anti-corruption compliance programs to a high standard in evaluating their credibility

On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more

McGuireWoods LLP

Last Four Months of DOJ’s FCPA Pilot Program Could Provide Important Signals

McGuireWoods LLP on

Last April, the Criminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit. The pilot program, self-described as “building” on the...more

Thomas Fox - Compliance Evangelist

FCPA Enforcement Going Forward in the Trump Administration

Donald Trump has gone on the record as saying the Foreign Corrupt Practices Act (FCPA) is a “horrible law and it should be changed” and that it puts US businesses at a “huge disadvantage.” This statement was made in the...more

Thomas Fox - Compliance Evangelist

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

Thomas Fox - Compliance Evangelist

Monster Movie Month: Episode III – Son of Frankenstein and Evolution From Yates Memo and FCPA Pilot Program

Welcome to my third installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series. Today I want to explore the final movie where Boris Karloff starred as Frankenstein’s Monster;...more

Troutman Pepper

Lessons Learned from the FCPA Pilot Program's First Six Months

Troutman Pepper on

The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways: Government Enforcement Investigations – Trends and Perspectives from the UK, US and China

On September 20, 2016, Skadden presented a seminar titled “Government Enforcement Investigations – Trends and Perspectives from the UK, US and China” in London. The UK Financial Conduct Authority (FCA) Director of Enforcement...more

Snell & Wilmer

The Foreign Corrupt Practices Act’s One-Year “Pilot Program” Nears The Halfway Mark

Snell & Wilmer on

The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more

Seyfarth Shaw LLP

FCPA Compliance---Recent Department of Justice Initiatives

Seyfarth Shaw LLP on

The Department of Justice (DOJ) recently initiated a one-year pilot program to encourage companies to self-report violations of the Foreign Corrupt Practices Act (FCPA). Any company contemplating self-reporting such a...more

The Volkov Law Group

Yates, Whistleblowers and FCPA Pilot Project: Re-Examining Your Internal investigation Protocols

The Volkov Law Group on

Companies face an ever-changing constellation of risks, enforcement priorities and demands for internal controls and compliance program elements. As more resources are poured into government enforcement programs, companies...more

The Volkov Law Group

Headlines from Mid-Year FCPA Enforcement Review

The Volkov Law Group on

Just to add my voice to the cottage industry surrounding FCPA enforcement and compliance, I wanted to take a deep breath and offer some observations on FCPA enforcement in 2016. There are a few significant headlines...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for June 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Carlton Fields

DOJ’s FCPA Pilot Program Keeps Heat on Individuals

Carlton Fields on

In April, the Department of Justice (DOJ) announced a one-year pilot program offering certain violators of the Foreign Corrupt Practices Act (FCPA) the possibility of reduced sanctions on top of any credit provided for by the...more

Thomas Fox - Compliance Evangelist

Enforcement Week I: Troubling Questions Raised in HSBC Prosecution

We had an interesting week of anti-corruption enforcement actions last week, both in the US and the UK. We have now had four Foreign Corrupt Practices Act (FCPA) enforcement actions since the announcement of the Depart Of...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations and White Collar Defense - June 2016

Eye on the Supreme Court—Corruption and Fraud Edition - Why it matters: This session, the Supreme Court has undertaken the review of numerous cases that raise thorny issues arising in the white collar context. In our...more

Williams Mullen

USDOJ Beefs Up FCPA Efforts

Williams Mullen on

In April, the Fraud Section of the United States Department of Justice announced several measures designed to enhance its effort to discover and prosecute violations of the Foreign Corrupt Practices Act (FCPA). See, 15 U.S.C....more

Foster Garvey PC

DOJ’s New FCPA “Pilot Program” Targets Corporate Officers and Other Individuals

Foster Garvey PC on

For years, FCPA observers have predicted that the Department of Justice (“DOJ”) will increase its prosecutions of corporate officers and employees for FCPA violations. These predictions have so far proven disputable, as the...more

NAVEX

Is the DOJ’s New FCPA Pilot Program an Offer You Can’t Refuse?

NAVEX on

Earlier this month, Assistant US Attorney Leslie Caldwell announced that the US Department of Justice’s Criminal Division Fraud Section will try to entice companies to self-report potential FCPA issues. The DOJ included...more

WilmerHale

A transatlantic consideration of recent developments in corporate self-reporting

WilmerHale on

More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more

Dechert LLP

New US Department of Justice Foreign Corrupt Practices Act Enforcement Plan Creates "Pilot Program" to Encourage Voluntary...

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The U.S. Department of Justice (“DOJ”) released a memorandum (the “FCPA Enforcement Memorandum”) on April 5, 2016 detailing a new enforcement plan for Foreign Corrupt Practices Act (“FCPA”) investigations. The DOJ announced...more

Wilson Sonsini Goodrich & Rosati

DOJ Announces FCPA Enforcement Pilot Program

The U.S. Department of Justice (DOJ) recently announced a one-year enforcement pilot program intended to encourage companies to voluntarily self-report misconduct under the Foreign Corrupt Practices Act (FCPA). Building on...more

Alston & Bird

Government & Internal Investigations Advisory: DOJ’s New FCPA Pilot Program Provides Roadmap for “Cooperation”

Alston & Bird on

The Department of Justice (DOJ) on April 5 announced a new, one-year pilot program for companies to self-report Foreign Corrupt Practices Act (FCPA) violations. The announcement comes amid other increased FCPA enforcement...more

Pillsbury Winthrop Shaw Pittman LLP

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

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