On August 1, 2024, the Department of Justice officially launched a three-year pilot program to reward whistleblowers who report corporate misconduct....more
8/7/2024
/ CFTC ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
FinCEN ,
Forfeiture ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On April 15, 2024, the Criminal Division of the Department of Justice (DOJ) announced the Pilot Program on Voluntary Self-Disclosure for Individuals, providing transparency regarding the circumstances in which Criminal...more
On March 7, 2024, Deputy Attorney General Lisa Monaco announced Department of Justice (DOJ) initiatives to incentivize whistleblowers with payouts from civil or criminal forfeitures and to integrate artificial intelligence...more
3/12/2024
/ Artificial Intelligence ,
CFTC ,
Corporate Crimes ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On December 14, 2023, the U.S. Congress (Congress) passed the Foreign Extortion Prevention Act (FEPA), as a part of the Fiscal Year 2024 National Defense Authorization Act. The FEPA, which received bipartisan support, makes...more
On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more
3/6/2023
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
New Guidance ,
Risk Assessment ,
White Collar Crimes
On February 22, 2023, the Department of Justice (DOJ) issued a Voluntary Self-Disclosure Policy (VSDP) which, effective immediately, applies to all U.S. Attorneys’ Offices (USAOs) nationwide with respect to corporate criminal...more
While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more
2/10/2023
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
CFTC ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Criminal Fines ,
Corruption ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
Assistant Attorney General Kenneth A. Polite, Jr. Announces Changes to Department of Justice Criminal Division’s Corporate Enforcement Policy -
On January 17, 2023, Assistant Attorney General for the Criminal Division...more
1/19/2023
/ Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Cooperation ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Voluntary Disclosure ,
White Collar Crimes
On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more
9/20/2022
/ Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Personal Liability ,
Voluntary Disclosure ,
White Collar Crimes
In 2021, the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases was relatively low compared with previous years, but there were numerous interesting developments, and enforcement activity going forward...more
1/28/2022
/ Anti-Corruption ,
Biden Administration ,
Bribery ,
Compliance ,
Cooperation ,
Corruption ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
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
11/10/2021
/ Advisory Board ,
Biden Administration ,
CFTC ,
Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Misconduct ,
Cryptocurrency ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Authority ,
Enforcement Guidance ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Federal Contractors ,
Federal Trade Commission (FTC) ,
Popular ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes ,
Yates Memorandum
Two recent rulings in separate foreign bribery cases highlight the continued impact of individual prosecutions on the interpretation of various provisions of the Foreign Corrupt Practices Act (FCPA). In United States v....more
3/4/2020
/ Agency Relationship ,
Bribery ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Email ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Foreign Subsidiaries ,
Indictments ,
Mail Fraud ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Subsidiaries ,
White Collar Crimes ,
Wire Fraud
On May 9, 2018, Deputy Attorney General Rod J. Rosenstein introduced a new Department of Justice (DOJ) Policy on Coordination of Corporate Resolution Penalties (the Policy) while speaking at the New York City Bar White Collar...more
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more
4/11/2016
/ Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Disgorgement ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes