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Corporate Misconduct Compliance New Guidance

Venable LLP

DOJ Revises Its Evaluation of Corporate Compliance Policy to Consider How Companies Address Risks Posed by AI

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The Department of Justice's Criminal Division is "using more tools than ever before to identify corporate misconduct and to encourage companies to be good corporate citizens," according to Nicole Argentieri, Principal Deputy...more

Society of Corporate Compliance and Ethics...

How a code of conduct reflects culture and meets DOJ requirements

Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it...more

WilmerHale

UK Criminal Enforcement Update - Spring 2024

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Recent weeks have seen several notable developments in the UK criminal enforcement landscape...more

Thomas Fox - Compliance Evangelist

New DOJ M&A Safe Harbor Policy

We continue our review of DOJ initiatives from 2023 and what they may portend for the compliance professional in 2024 and beyond. In October 2023, Deputy Attorney General Lisa Monaco announced a new policy regarding M&A. It...more

Ankura

U.S. DOJ’s New Safe Harbor Policy: Conducting Enhanced M&A Due Diligence

Ankura on

Last month, U.S. Deputy Attorney General Lisa O. Monaco announced a new Safe Harbor Policy for voluntary self-disclosure (the “Policy”) made in connection with merger and acquisition activity. The Policy is intended to bring...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Announces Safe Harbor Policy for Voluntary Self-Disclosures Related to Mergers & Acquisitions

In the U.S. Department of Justice’s (DOJ’s) latest effort to promote voluntary self-disclosure of corporate misconduct by companies, Deputy Attorney General (DAG) Lisa Monaco has announced guidance regarding a new safe harbor...more

Orrick, Herrington & Sutcliffe LLP

Three Things to Consider After DOJ’s Announcement on New Corporate Messaging Policy

The Department of Justice recently announced new policy changes relating to its evaluation of corporate communication policies. The DOJ’s new guidance makes clear that, when evaluating the adequacy of corporate compliance...more

WilmerHale

DOJ Announces Significant Guidance on Compliance, Compensation, Communications and Cooperation

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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

Venable LLP

Part 1: Cooperation in Government Investigations and Voluntary Self-Disclosure: What to Expect After DOJ’s Latest Guidance

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​​​​​​​On September 15, Deputy Attorney General Lisa Monaco issued a department-wide memorandum containing revisions to the Justice Department’s (DOJ) corporate criminal enforcement policies (“the Memorandum”), including...more

The Volkov Law Group

Criminal Division AAG Polite Reinforces New DOJ Corporate Enforcement Policy (Part IV of IV)

The Volkov Law Group on

The Justice Department is putting every business on notice — aggressive white collar criminal enforcement is here to stay. In a one-two punch, Deputy Attorney General Lisa Monaco announced a revised Corporate Enforcement...more

The Volkov Law Group

DOJ’s Revised Corporate Enforcement Policy Expands on Previous Factors: History of Misconduct; Voluntary Self-Disclosure; and...

The Volkov Law Group on

The Lisa Monaco Memo is a new and important restatement of the Justice Department’s approach to corporate crime.  It is a worthy read and it sets out a number of new requirements and procedures for DOJ prosecutors...more

Latham & Watkins LLP

US Deputy Attorney General Monaco Announces Revised Policies on Corporate Crime

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Updated DOJ policies will continue to focus on individual accountability and corporate recidivism, while aiming to provide additional incentives for voluntary self-reporting, foster greater transparency on use of monitors,...more

Eversheds Sutherland (US) LLP

The DOJ’s new guidance on corporate criminal enforcement - and what it means for your business

​​​​​​​On September 15, 2022, Department of Justice (DOJ) Deputy Attorney General (Deputy AG) Lisa Monaco announced new guidance for the DOJ’s corporate enforcement policies, which is memorialized in the Memorandum on Further...more

Jackson Walker

DOJ Officials Announce New Priorities to Combat Corporate Crime with Additional Details Provided at Government Enforcement...

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On Thursday, September 15, 2022, Deputy Attorney General Lisa A. Monaco outlined new steps the Department of Justice will be taking in its ongoing efforts to police corporate crime. The next day, Assistant Attorney General...more

Dechert LLP

DOJ Announces Substantial Revisions to Corporate Enforcement Policy

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Late last week, the Department of Justice’s Deputy Attorney General, Lisa Monaco, announced several new guidelines for prosecutors to use when determining how to assess and treat corporate offenders....more

Holland & Knight LLP

DOJ Expands Framework for Cracking Down on Corporate Crime

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In a speech to prosecutors, policymakers and academics on Sept. 15, 2022, U.S. Deputy Attorney General Lisa O. Monaco announced that the U.S. Department of Justice (DOJ) would no longer "accept business as usual" when it...more

NAVEX

3 Ways to Apply New DOJ Guidance to Antitrust Compliance

NAVEX on

The Justice Department gave compliance officers a significant piece of guidance in June with its latest update to the evaluation of corporate compliance programs. The guidance begs the fundamental question: Is the compliance...more

Pillsbury Winthrop Shaw Pittman LLP

Compliance Programs Must Track and Adapt to Changes and Risks

Updated DOJ Guidance calls on corporations to devote additional resources and attention to detect and prevent misconduct. A well-structured and effective compliance program must evolve with lessons learned, be understood...more

Vinson & Elkins LLP

Little “New” in SFO’s New Guidance on Compliance Programs

Vinson & Elkins LLP on

On January 17, 2020, the United Kingdom’s Serious Fraud Office (“SFO”) published new guidance regarding how the office assesses the compliance programs of organizations that are under investigation. “Evaluating a Compliance...more

ArentFox Schiff

Justice Department Offers New Antitrust Guidance With Lessons for Nonprofits, Associations, and Other Member-Owned and Operated...

ArentFox Schiff on

When was the last time your organization reviewed its antitrust compliance program? The Antitrust Division of the US Department of Justice announced a new policy to incentivize corporate antitrust compliance programs, which...more

BCLP

FCA Defendants and Counsel Beware: New DOJ Guidance on FCA Cooperation Credit May Leave Too Much to Prosecutors’ Discretion

BCLP on

In recent weeks, the United States Department of Justice (“DOJ”) published guidance in the Justice Manual at Section 4-4.112 on how it will award cooperation credit to entities and individuals that are being investigated for...more

Maynard Nexsen

Cooperation Credit in False Claims Act Defense and the Potential Impact of Reimbursement Analysis and Compliance

Maynard Nexsen on

While white collar and healthcare counsel have long known that one of the best strategies to reducing risk in defending a False Claims Act (FCA) case is cooperation and execution of compliance actions, the Department of...more

The Volkov Law Group

Watching the River Flow: The Evolution and Future of Compliance (Part I of III)

The Volkov Law Group on

Bob Dylan, Watch the River FlowI have to admit it – I still love to listen to Bob Dylan.  With age, his lyrics resonate more and more.  HERE is a nice version of Watch the River Flow in case you want to listen while reading...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Ruder Ware

The Federal Government Really Wants You to Self Disclose

Ruder Ware on

The Department of Justice (DOJ) along with other health care fraud enforcement agencies, continue to send strong signals that they want businesses to police themselves for potential compliance issues and self-disclose where...more

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