Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors.
In a speech at Georgetown University Law Center on...more
2/7/2023
/ Bribery ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Declination ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
UK companies should be aware of the increasing focus on corporate culture by regulators on both sides of the Atlantic.
In a recent speech that has garnered significant attention, US Deputy Attorney General Lisa Monaco...more
11/8/2021
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Crimes ,
Corporate Culture ,
Department of Justice (DOJ) ,
Environmental Social & Governance (ESG) ,
Financial Conduct Authority (FCA) ,
Foreign Corrupt Practices Act (FCPA)
The priorities will impact non-US companies who may face a US DOJ with a renewed emphasis on combating corporate crime.
In a recent speech that has garnered significant attention, the Deputy Attorney General of the...more
11/5/2021
/ Biden Administration ,
Compliance ,
Compliance Monitoring ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Criminal Prosecution ,
Cross Border Privacy Rules (CBPR) ,
Cross-Border ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corporations ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Personal Liability ,
UK ,
White Collar Crimes
Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations.
On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more
8/10/2019
/ Cooperation ,
Corporate Cooperation Credits ,
Corporate Investigations ,
Criminal Investigations ,
Cross-Border ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Privilege Waivers ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
The DOJ’s recently updated guidance poses helpful questions for UK corporates evaluating the effectiveness of their internal compliance programmes.
It is well known that a corporate’s failure to prevent offences can be...more