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SDNY Launches Whistleblower Pilot Program to Encourage Self-Disclosure of Criminal Conduct

The recently created SDNY Whistleblower Pilot Program encourages individuals to self-disclose certain criminal conduct and cooperate in resulting investigations and prosecutions. ...more

FCPA 2023 Year in Review

Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more

FCPA 2022 Year in Review

Foreign Corrupt Practices Act (“FCPA”) enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated...more

FCPA 2021 Year In Review

The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more

FCPA 2020 Year in Review

In 2020, the biggest Foreign Corrupt Practices Act (“FCPA”) headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions involving a coordinated FCPA...more

DOJ Launches China-Focused Criminal Enforcement Initiative

The new "China Initiative" is intended to respond to perceived U.S. national security threats from China. The U.S. Department of Justice ("DOJ") has announced a new criminal enforcement initiative that targets China, with...more

DOJ's New FCPA Enforcement Policy Continues its "Carrot-and-Stick" Approach

The Situation: Companies that learn of Foreign Corrupt Practices Act ("FCPA") violations by employees or agents are faced with significant uncertainty as to whether the benefits and risks of self-disclosing the conduct to the...more

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