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Department of Justice (DOJ) Compliance Individual Accountability

BCLP

New DOJ Pilot Program Incentivizes Individuals to Report Criminal Conduct

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Companies beware! The U.S. Department of Justice (DOJ) announced a pilot program “designed to encourage voluntary self-disclosure by individual participants in certain types of criminal conduct involving corporations.” In...more

Axinn, Veltrop & Harkrider LLP

Conspiracy Theories Newsletter, 2024 Edition: Eight Predictions for the Future of Cartel Enforcement

2023 was a dramatic year for criminal antitrust enforcement in the United States. The Antitrust Division of the U.S. Department of Justice (“DOJ”) garnered big wins: three convictions at trial,1 $267 million in criminal fines...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

American Conference Institute (ACI)

[Event] 13th West Coast Forum on FCPA Enforcement and Compliance - June 14th - 15th, San Francisco, CA

Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...more

Guidepost Solutions LLC

U.S. Attorneys’ Offices Voluntary Self-Disclosure Policy - Watch Out for The Next Logical Step – Enforcement

It is safe to assume that the United States Attorneys’ Offices Voluntary Self-Disclosure Policy announced on March 2, 2023 is intended to decrease wrongdoing and impose rehabilitation and recovery for victims. But...more

Miles & Stockbridge P.C.

Individual Accountability Expanded: DOJ Launches Corporate Compliance Pilot Program Focused on Compensation System and Clawbacks

The U.S. Department of Justice (DOJ) announced Friday a three-year pilot program related to its continued efforts to hold individuals directly accountable for corporate wrongdoing. The two-pronged program incentivizes...more

Brownstein Hyatt Farber Schreck

DOJ Rolls Out Corporate Self-Disclosure Policy to Be Enforced by U.S. Attorney’s Offices

On Feb. 22, 2023, the U.S. Department of Justice announced a new Voluntary Self-Disclosure Policy to encourage self-disclosure of potential criminal activity in exchange for varying levels of amnesty from criminal charges....more

Gardner Law

Transatlantic Legal-Regulatory Update: Live from the Heart of Silicon Valley

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US and EU Life Sciences Law firms Fieldfisher & Gardner Law recently held a CLE event in Silicon Valley covering Healthcare Compliance, Data Privacy and Regulatory hot topics for MedTech and Pharma companies. Discussion...more

Foodman CPAs & Advisors

Corporate Crime At The Forefront Of The DOJ

On September 15, 2022, Department of Justice (DOJ) Deputy Attorney General Lisa Monaco delivered remarks on Corporate Criminal Enforcement at the NYU Program on Corporate Compliance and Enforcement and announced new guidance...more

Ankura

DAG Monaco Defines DOJ Guidance for Corporate Criminal Enforcement

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New Requirements Place Onus on Corporations to Demonstrate more Compliance Capabilities to Receive Consideration from Prosecutors On September 15, 2022, Deputy Attorney General (“DAG”) Lisa Monaco spoke at New York...more

Seward & Kissel LLP

DOJ’s Revised Corporate Criminal Enforcement Policies Encourage Voluntary Disclosure and Focus on Compensation

Seward & Kissel LLP on

On September 15, 2022, Deputy Attorney General Lisa O. Monaco announced new Department of Justice (“DOJ”) policies on corporate criminal enforcement. DOJ designed the new policies based on recommendations by the Corporate...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

Dorsey & Whitney LLP

DOJ Paving a More Structured Path for Corporate Criminal Enforcement

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​​​​​​​On September 15, 2022, Deputy Attorney General Lisa Monaco laid out the DOJ’s first substantive changes to white-collar criminal investigations and enforcement under the Biden administration....more

Womble Bond Dickinson

DOJ Announcements on Corporate Criminal Enforcement: Defining the Carrots and Sticks

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The Department of Justice (DOJ) has been touting revisions to its corporate criminal enforcement policies and signaling increased action for nearly a year. Yesterday, Deputy Attorney General Lisa O. Monaco formally announced...more

StoneTurn

Beyond Whistleblowing: Five Steps to Establish an Effective Speak-Up Program

StoneTurn on

"Whistleblowing," a fundamental component of any compliance program, refers to specific allegations of misconduct raised typically through an anonymous hotline or similar mechanism. "Speak-Up" is broader and refers to a...more

BakerHostetler

Attorney General Merrick Garland Emphasizes Criminal Corporate Enforcement and Individual Accountability

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On March 3, 2022, Attorney General Merrick B. Garland delivered a speech at the ABA Institute on White Collar Crime that underscored the Department of Justice’s (DOJ) commitment to prosecuting corporate crime and holding...more

Holland & Knight LLP

AG Merrick Garland: DOJ Prioritizing Prosecution of Individuals in White Collar Crime

Holland & Knight LLP on

In remarks to the American Bar Association (ABA) Institute on White Collar Crime on March 3, 2022, Attorney General Merrick Garland underscored the U.S. Department of Justice's (DOJ) renewed emphasis on corporate...more

Eversheds Sutherland (US) LLP

US Department of Justice adopts “bold” approach to prosecuting corporate crime and will engage in “rigorous enforcement”

On October 28, 2021, Deputy Attorney General (Deputy AG) Lisa O. Monaco gave remarks explicitly warning companies that the US Department of Justice (DOJ) intends to increase its efforts and devote additional resources to...more

Latham & Watkins LLP

Prioritizing Corporate Culture: Lessons for Companies from the Major League Baseball Sign-Stealing Investigation

Latham & Watkins LLP on

The MLB Commissioner held senior leadership accountable for illegal sign stealing - even though the conduct generally involved players and low-level operations employees. On January 13, 2020, Major League Baseball (MLB)...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

Morgan Lewis

DOJ Guidance Clarifies Cooperation Credit in FCA Matters

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The US Department of Justice (DOJ) issued formal guidance on May 8 on how companies can earn cooperation credit and what conduct it considers in awarding credit in False Claims Act investigations....more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: DOJ Policies Aim to Reduce Enforcement Burden on Cooperating Entities

The Department of Justice (DOJ) appears to be continuing to revamp its approach to companies suspected of financial crimes, and emphasize the importance of prosecutions of individuals. In a number of speeches in 2018, senior...more

NAVEX

Action Not Perfection: DOJ Revisions to Yates Memo Still Prioritize Individual Accountability

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In November, the U.S. Department of Justice revised principle 9-28.700 – The Value of Cooperation in its Justice Manual – aka the Yates Memo....more

A&O Shearman

DOJ Scales Back Yates Memo Policy For Corporate Cooperation

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On November 29, 2018, Deputy Attorney General Rod Rosenstein announced revisions to the Department of Justice (“DOJ”) policy on individual accountability for corporate wrongdoing, which was originally announced in the Yates...more

BCLP

In announcing changes to individual accountability policy, DOJ reaffirms that cooperating companies must name responsible...

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On November 29, 2018, Deputy Attorney General Rod Rosenstein announced changes to the Department of Justice’s policy concerning individual accountability in corporate cases, stating that “pursuing individuals responsible for...more

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