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DOJ Criminal Division Offers Non-Prosecution Agreements to Individuals Who Voluntarily Report Corporate Wrongdoing

The Development: On April 15, 2024, the Department of Justice ("DOJ") Criminal Division announced a pilot program that will offer mandatory non-prosecution agreements ("NPAs") to individuals who provide original and...more

DOJ Announces New Whistleblower Program and Enforcement Initiatives

The Development: On March 7, 2024, Deputy Attorney General ("DAG") Lisa Monaco discussed updates to the Department of Justice's ("DOJ" or "Department") corporate criminal enforcement policies and announced a pilot program...more

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

SEC Enforcement in Financial Reporting and Disclosure: 2023 Year-End Update

We are pleased to present our latest update on financial reporting and issuer disclosure enforcement activity. This White Paper primarily focuses on the U.S. Securities and Exchange Commission’s (“SEC”) enforcement activity...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

Considerations for Addressing DOJ’s Corporate Compliance Guidance on Mobile Devices and Messaging Platforms

In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more

DOJ Announces New Voluntary Self-Disclosure Policy for All U.S. Attorneys' Offices

On February 22, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced the Voluntary Self-Disclosure Policy ("VSD Policy" or "Policy"), detailing the circumstances under which a company can receive credit for...more

DOJ Criminal Division Announces Revisions to its Corporate Enforcement Policy

In Short - The Situation: On January 17, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced significant revisions to the Criminal Division's Corporate Enforcement Policy....more

DOJ Announces Major Changes to Corporate Criminal Enforcement Policies

In Short - The Situation: On September 15, 2022, Deputy Attorney General Lisa Monaco announced significant changes and updates to the Department of Justice's corporate criminal enforcement policies. ...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

Australia-U.S. Cooperation in Criminal Cases

U.S. criminal law has a long reach outside the borders of the United States. Australian companies and individuals whose activities touch on the United States—even without having offices or any physical presence in the United...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'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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