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Clawbacks Enforcement Actions Compliance

American Conference Institute (ACI)

[Event] The Brazil Summit on Anti-Corruption, Integrity & ESG - May 22nd - 23rd, São Paulo, Brazil

Hosted by American Conference Institute, the 14th Annual Summit on Anti-Corruption, Integrity & ESG returns to Brazil for another groundbreaking year to discuss the current high-stakes dilemmas impacting your organization....more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 8, Enhancing Your Compliance Program

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 6, Clawbacks and Holdbacks

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

NAVEX

How to Meet the Letter, Spirit and Intent of the DOJ’s Evolving Compliance Program Expectations

NAVEX on

With any new administration, the U.S. Department of Justice (DOJ) often shifts focus from one set of enforcement priorities to another. However, one area has remained a focus from administration to administration: guidance...more

Mintz

EnforceMintz — DOJ and OIG Guidance Emphasizes the Importance of a Robust and Dynamic Compliance Program

Mintz on

2023 was a busy year across several federal agencies in terms of issuing compliance guidance for corporations, including health care companies. For example, the Department of Justice (DOJ) issued significant compliance...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Paul Hastings LLP

More Clarity on the Horizon for FCPA Resolutions? DOJ and SEC Officials Discuss Enforcement Trends

Paul Hastings LLP on

On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 5-Lessons Learned

Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action.  We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more

Lowenstein Sandler LLP

The SEC’s Private Fund Adviser Rules Explained — Part 1: The Restricted Activities Rule

Lowenstein Sandler LLP on

On August 23, 2023, the U.S. Securities and Exchange Commission (SEC) adopted new and amended rules under the Investment Advisers Act of 1940, as amended (the Advisers Act), to address what it perceives as certain conflicts...more

Jackson Walker

SEC Adopts Sweeping New Private Fund Adviser Rules

Jackson Walker on

On August 23, 2023, the U.S. Securities and Exchange Commission (“SEC”), by a party-line vote of 3-2, adopted new rules applicable to investment advisers to private funds (“Private Fund Advisers”) that address transparency,...more

Perkins Coie

DOJ Announces Pilot Program and Updated Expectations on Corporate Compensation Programs

Perkins Coie on

The U.S. Department of Justice (DOJ) on March 3, 2023, unveiled a new pilot program and announced several important updates to its Evaluation of Corporate Compliance Programs (ECCP) regarding corporate compensation incentives...more

Sheppard Mullin Richter & Hampton LLP

DOJ Revises Guidance on Evaluation of Corporate Compliance Programs Concerning Compensation and Employee Use of Personal Devices...

Following remarks made on March 2 and March 3, 2023 at the American Bar Association’s 38th Annual National Institute on White Collar Crime, the U.S. Department of Justice (“DOJ”) issued revisions to its Evaluation of...more

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series: Protecting Your Business Against Non-Compliance and DOJ Penalties - March 23rd, 12:00...

McDermott Will & Emery on

During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more

Orrick, Herrington & Sutcliffe LLP

In Like a Lion: DOJ Marks March with a Series of New Compliance Policies

DOJ is roaring into March with updates to its guidance on the evaluation of corporate compliance programs, a new pilot program on compensation incentives and clawbacks, and a revised policy on monitor selection, all released...more

McDermott Will & Emery

DOJ Announces Major Changes to Corporate Compliance Program Evaluation Criteria

During speeches on March 2 and 3, 2023, at the American Bar Association (ABA) National Institute on White Collar Crime (the 2023 White Collar Conference), Deputy Attorney General (DAG) Lisa Monaco, Assistant Attorney General...more

Orrick, Herrington & Sutcliffe LLP

U.S. Department of Justice Rolls Out New Policy to Incentivize Companies to Implement Executive Compensation Systems that...

During a March 2, 2023, speech in Miami at the annual American Bar Association National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy designed to incentivize companies to factor...more

Morgan Lewis

DOJ Announces Compensation Clawback Pilot Program, Changes to Corporate Compliance Program Evaluation Criteria

Morgan Lewis on

The US Department of Justice recently announced a compensation clawback pilot program as well as changes to the corporate compliance program evaluation criteria in the latest of a flurry of policy updates....more

Wiley Rein LLP

New Year, New Compliance Challenges: Good Reasons to Spruce up Your Compliance Program in 2023

Wiley Rein LLP on

At the start of 2023, we made a number of corporate criminal enforcement predictions. With 2023 launched, we are circling back to highlight initiatives that government contractors may wish to consider undertaking as...more

Vinson & Elkins LLP

DOJ Chooses Sticks Over Carrots: Three Reasons Why Changes to DOJ’s Corporate Enforcement Policy May Chill Cooperation by...

Vinson & Elkins LLP on

In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more

Husch Blackwell LLP

DOJ's New Policies Encourage Voluntary Self-Disclosure, Compensation Tied to Compliance

Husch Blackwell LLP on

In a speech given at NYU on September 15, 2022, Deputy Attorney General Lisa Monaco reviewed new and enhanced Department of Justice (DOJ) policies regarding criminal enforcement related to corporate entities. Assistant...more

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