News & Analysis as of

Corporate Misconduct Compliance FCPA Corporate Enforcement Policy (CEP)

Thomas Fox - Compliance Evangelist

Argentieri at ABA White Collar Conference: Corporate Enforcement, Part 1

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco. The second...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 4: The Fines: Self-Disclose, Self-Disclose, Self-Disclose

We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more

Sheppard Mullin Richter & Hampton LLP

DOJ Touts Emerging Results from New Corporate Crime Self-Reporting Initiatives

The Department of Justice’s recent criminal self-reporting policy changes are beginning to show results, according to Assistant Attorney General Kenneth Polite Jr. Speaking at the New York City Bar Association’s White Collar...more

J.S. Held

Building a Strong Compliance Program That Meets the Revised DOJ Corporate Enforcement Policy

J.S. Held on

A corporate compliance program can be thought of as a magnet that brings a company’s compliance efforts together. It is an operational program, not simply a code of expected ethical behavior. An effective compliance...more

Paul Hastings LLP

A Commitment to Transparency: Clarifying Key Enhancements to the U.S. Department of Justice’s Corporate Enforcement Guidance

Paul Hastings LLP on

Since September 2022, the U.S. Department of Justice (“DOJ” or “the Department”) has made a number of announcements signaling notable changes to its U.S. corporate enforcement policies. These changes include key revisions to...more

The Volkov Law Group

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

The Volkov Law Group on

The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing...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

The Volkov Law Group

DOJ Begins Implementation of Compliance Compensation Requirements

The Volkov Law Group on

The Justice Department has taken steps to implement its new compliance compensation requirement announced in its Corporate Enforcement Policy revisions.  With little fanfare, the Danske Bank $2 billion settlement with the...more

Bradley Arant Boult Cummings LLP

DOJ Expands Availability of Declinations with Disgorgement for Corporations that Self-Disclose Misconduct

Earlier this month, DOJ updated its Corporate Enforcement Policy (CEP). Aimed at encouraging companies to voluntarily disclose unlawful conduct, the updated CEP gives greater opportunities to companies to avoid charges...more

The Volkov Law Group

Justice Department Tweaks Corporate Enforcement Policy to Entice More Corporate Voluntary Disclosures

The Volkov Law Group on

The Department of Justice announced revisions to its Corporate Enforcement Policy (“CEP”) yet again in order to promote voluntary disclosures by Companies that discover potential wrongdoing.  DOJ’s latest action demonstrated...more

BakerHostetler

DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

BakerHostetler on

On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

Dechert LLP

“More Cooperation Please”: DOJ Revises Corporate Enforcement Policy to Encourage Even Greater Cooperation

Dechert LLP on

This week the DOJ published revisions to its Corporate Enforcement Policy designed to even further encourage companies to make voluntary self-disclosures of wrongdoing within their ranks, cooperate with investigations, and...more

Cozen O'Connor

DOJ Offering Increased Reductions in Fines up to 75% to Incentivize Companies to Voluntarily Report Misconduct

Cozen O'Connor on

On January 17, 2023, the Department of Justice (DOJ) rolled out a significant change to its existing Corporate Enforcement Policy (CEP) that will grant as much as a 75% reduction in fines for companies that voluntarily...more

The Volkov Law Group

Voluntary Self-Disclosure — DOJ’s Enforcement Engine

The Volkov Law Group on

The Department of Justice and many regulatory agencies have rolled out the red carpet for companies to cross the threshold and voluntarily disclose criminal conduct in the hopes of gaining leniency, immunity and reduced fines...more

The Volkov Law Group

DOJ Issues Declination to Global Advertising Company Under FCPA Enforcement Policy

The Volkov Law Group on

The Justice Department continues its enforcement “silence” with no major corporate prosecutions announced this year.  It is an interesting question but it appears that the wheels have ground to a halt, with one major...more

The Volkov Law Group

DOJ Tweaks FCPA Corporate Enforcement Policy

The Volkov Law Group on

The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more

The Volkov Law Group

DOJ “Tweaks” FCPA Corporate Enforcement Policy

The Volkov Law Group on

The Justice Department is wedded to its FCPA Corporate Enforcement Policy (excuse me for the use of “wedded,” we recently celebrated our son’s wedding). Nonetheless, DOJ has to adjust its Policy in response to experience and...more

The Volkov Law Group

Reflections on the Cognizant FCPA Resolution: Does DOJ Mean What it Says? (Part III of IV)

The Volkov Law Group on

We live in an era where credibility and truthfulness are character values that are often challenged, questioned and indeed overrun. Trust and integrity are values of utmost value and importance. ...more

Thomas Fox - Compliance Evangelist

Flame On-Tribute to the Fantastic Four: Part II – Four Issues from the FCPA Corporate Enforcement Policy

Yesterday, I considered four questions which the Department of Justice (DOJ) may ask Goldman Sachs. Today I want to consider what the company must show under the FCPA Corporate Enforcement Policy....more

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