Episode 340: DOJ Updates Evaluation of Corporate Compliance Programs
The Presumption of Innocence Podcast: Episode 35 - A Double-Edged Sword? The DOJ Confronts AI
Understanding the Whistleblower Pilot Program in the Southern District of New York
Corporate Criminal Liability in South America
What DAG Lisa Monaco's Speech Means for Compliance Programs
New DOJ Guidance Tightens Corporate Enforcement Strategy
The Justice Insiders: Former U.S. Attorney General Barr Appears on The Justice Insiders
Digging Deeper Episode 10: Misguided or Misconduct? Understanding Bad Behavior in the Corporate World
WorldSmart: Policing International Corporate Crime as the World Recovers from COVID-19
Doing Business in the European Union | Anonymity & Keeping the Whistleblower's Identity Confidential
Doing Business in the European Union | Key Elements of the EU Directive on Whistleblower Protection
Doing Business in the European Union | Global Laws & Compliance Program
Do I Need a Lawyer? Federal Employees Under Investigation [More with McGlinchey Ep. 1]
FCPA Compliance Report-Episode 333, Professor Samuel Buell
On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...more
The UK Economic Crime & Corporate Transparency Act 2023 sets out two major reforms making it much easier for UK authorities to prosecute corporate wrongdoing: - it substantially increases the circumstances in which a company...more
On this Ropes & Gray podcast, join Amanda Raad, co-head of the firm’s global anti-corruption and international risk and crisis management & investigations practices, Nitish Upadhyaya, director of behavioral insights at the...more
In our client alert, “The Case for Compliance: Why UK and EU Businesses Should Continue to Invest in Their Compliance Programs”, we highlighted seven reasons why, despite the US’ pause on bribery enforcement under the Foreign...more
The Crime and Policing Bill 2025, published by the UK Government on February 25, 2025, proposes extending the new ‘senior manager’ test of corporate criminal attribution to all criminal offences, not just economic crime...more
The State Department’s February 20, 2025, designation of specific Mexican drug cartels and Transnational Criminal Organizations (TCOs) as foreign terrorist organizations (FTOs) creates serious new risks for businesses...more
In the wake of the Grenfell Tower tragedy in 2017, which claimed 72 lives, the UK government has undertaken significant measures to address the systemic failures that contributed to the disaster. This year, several key...more
Fraud is the most common offence in the UK, amounting to 41% of all crime. On 26 October 2023, the UK’s long-awaited Economic Crime and Corporate Transparency Act 20232 (the Act) received Royal Assent, setting out...more
The final UK Government guidance on failure to prevent fraud has now been published Economic Crime and Corporate Transparency Act 2023: Guidance to organisations on the offence of failure to prevent fraud (accessible version)...more
Background - The Economic Crime and Corporate Transparency Act 2023 (the Act) seeks to prevent economic crime and to enhance the transparency of companies and other legal entities....more
As Donald J. Trump prepares to begin his second presidential administration on January 20, 2025, many Department of Justice (“DOJ”) priorities and policies are likely to change. One new Biden administration initiative that is...more
In 2024, Argentina experienced a pivotal moment in corporate law enforcement with the first significant application of its Corporate Criminal Liability Law No. 27,401, enacted in 2018. This law holds private entities...more
As we approach Inauguration Day on January 20, 2025, one question among anticorruption practitioners is how the Trump administration will handle enforcement of the Foreign Corrupt Practices Act (“FCPA”). In the meantime, we...more
"The FCA's approach to enforcement is changing." So stated Therese Chambers, joint executive director of enforcement and market oversight at the Financial Conduct Authority, speaking in September to the Association for...more
On December 6, 2024, Principal Associate Deputy Attorney General Marshall Miller provided an update on the Justice Department’s (DOJ) corporate criminal enforcement efforts during his keynote address at the Practicing Law...more
In February 2024, the FCA sent a survey to 1,028 wholesale firms (insurers, market intermediaries, banks and brokers) asking about recorded incidents of non-financial misconduct between 2021 and 2023. With a 96% response...more
We distil key practical takeaways from the UK Government’s official guidance on the corporate criminal offence of failure to prevent fraud (the Guidance). Businesses and compliance teams will be working to review and...more
The UK Government has finally published its official guidance on the corporate criminal offence of failure to prevent fraud (the Guidance). The offence will come into force on 1 September 2025. By then, businesses that fall...more
On November 12, 2024, the DOJ Antitrust Division updated its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (ECCP), which was initially issued in 2019. The ECCP provides guidance to...more
A phone call comes in from a panicked client, the owner of a small, successful business. Your client was reviewing some financial records – a task usually handled by a long–time and trusted employee – and the client noticed a...more
On 6 November 2024, the UK Government published the much-anticipated guidance on the new corporate offence of failure to prevent fraud (the “Guidance”). The failure to prevent fraud offence forms part of a huge shift in the...more
Our White Collar, Government & Internal Investigations Team discusses the UK’s new guidance on the “failure to prevent fraud” offense. The guidance addresses the “failure to prevent fraud” offense created by the Economic...more
On 6 November 2024, the UK government published its guidance on the new ‘failure to prevent fraud’ offence, which was introduced in the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023).1 We covered the details...more
The U.K.'s Home Office has published guidance on the new corporate criminal offense of failure to prevent fraud under the Economic Crime and Corporate Transparency Act 2023. Under the offense, large organizations may be held...more
The Economic Crime and Corporate Transparency Act 2023 (Commencement No. 3) Regulations 2024 have been published. The Regulations bring into force certain provisions of the Economic Crime and Corporate Transparency Act 2023....more