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Department of Justice (DOJ) Corporate Misconduct Compliance

King & Spalding

DOJ Releases Updated Version of Evaluation of Corporate Compliance Programs Guidelines

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On September 23, 2024, DOJ announced updates to its Evaluation of Corporate Compliance Programs guidelines (Guidance). The updates are the latest in a series of updates (including in 2019, 2020, and 2023) since DOJ first...more

Venable LLP

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

Venable LLP on

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

Thomas Fox - Compliance Evangelist

Deere’s FCPA Case: Lessons on Gifts, Travel and Entertainment

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

King & Spalding

Department of Justice Continues to Focus on AI This Week

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On September 23, 2024, the U.S. Department of Justice (Department) announced that it had updated its guidance to prosecutors on how to evaluate the effectiveness of a corporation’s compliance program. The guidance, known as...more

The Volkov Law Group

DOJ Updates Evaluation of Corporate Compliance Programs

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The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs.  As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

DLA Piper

DOJ's Revised ECCP Signals Expectations of a Data-driven Compliance Program

DLA Piper on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced much-anticipated revisions to the US Department of Justice (DOJ)’s Evaluation of Corporate Compliance Programs (Revised ECCP)...more

Epstein Becker & Green

DOJ Updates Its Evaluation of Corporate Compliance Programs to Address New Technologies, Reinforce Promoting a “Speak Up” Culture,...

Epstein Becker & Green on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced updates to the U.S. Department of Justice’s (“DOJ”) guidance relative to its Principles of Federal Prosecution of Business...more

Alston & Bird

Getting on the Bandwagon: Eight Additional U.S. Attorneys’ Offices Announce Corporate Whistleblower Pilot Programs

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Our White Collar, Government & Internal Investigations Team examines a plethora of new whistleblower pilot programs from federal prosecutors across the country....more

Thomas Fox - Compliance Evangelist

Argentieri on the DOJ’s Corporate Whistleblower Awards Pilot Program

The Department of Justice (DOJ) recently unveiled the Corporate Whistleblower Awards Pilot Program (CWA) to bolster corporate enforcement efforts. Although the program has only been operational for a few weeks, it has already...more

Morgan Lewis

US Department of Justice Updates Its Evaluation of Corporate Compliance Programs

Morgan Lewis on

The Criminal Division of the US Department of Justice released a revised version of its Evaluation of Corporate Compliance Programs on September 23, 2024. The guidance is intended to help prosecutors assess the effectiveness...more

Dorsey & Whitney LLP

DOJ Updates the Evaluation of Corporate Compliance Program Memorandum, Emphasizing Emerging Technologies, Data Analytics, and...

Dorsey & Whitney LLP on

On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs policy (the “Updated ECCP”), building upon the March 2023 updates. Since 2017, DOJ has offered...more

Womble Bond Dickinson

DOJ Updates Its Corporate Compliance Programs Guidance

Womble Bond Dickinson on

On September 23, 2024, the Criminal Division of the U.S Department of Justice (“DOJ”) released revised Evaluation of Corporate Compliance Programs guidance (“September 2024 Guidance), last updated in March 2023....more

Foley & Lardner LLP

DOJ Stresses AI Risk and Whistleblower Protection in Revised Corporate Compliance Guidance

Foley & Lardner LLP on

On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more

Fenwick & West LLP

DOJ ‘Upping the Ante’ for Corporate Self-Disclosure with New Corporate Whistleblower Awards Pilot Program

Fenwick & West LLP on

Earlier in 2024, DOJ’s Criminal Division announced a new Corporate Whistleblower Awards Pilot Program granting whistleblower awards to individuals who provide information in four priority areas. ...more

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 1 - The Mandate

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Thomas Fox - Compliance Evangelist

Addressing Pre-taliation

One of the most talked about subjects in corporate compliance is the issue of pre-taliation—an increasingly common enforcement target by the U.S. Securities and Exchange Commission (SEC). Matt Kelly and I did a recent podcast...more

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

The Volkov Law Group on

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

Mitratech Holdings, Inc

DOJ Unveils Whistleblower Rewards Program: What Every Business Needs to Know

The Department of Justice has launched the Corporate Whistleblower Awards Pilot Program to fight corporate crime. See how it impacts your organization. The U.S. The Department of Justice (DOJ) has just rolled out the...more

Health Care Compliance Association (HCCA)

Beyond surveys: Rethinking traditional approaches to ethical culture assessments

To build a robust ethical culture, ethics and compliance professionals need effective culture assessments to pinpoint vulnerabilities and proactively address them. The U.S. Department of Justice’s (DOJ) update to the...more

White & Case LLP

DOJ Launches New Whistleblower Pilot Program

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In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

The Volkov Law Group on

While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

The Volkov Law Group

DOJ’s New Whistleblower Program: Filling in the Gaps and Encouraging Tips (Part II of II)

The Volkov Law Group on

DOJ is joining the whistleblower reward sweepstakes in a big way.  While the SEC has been grabbing headlines for its whistleblower reward program since 2010, DOJ now wants a piece of the action.  DOJ cited gaps that exist...more

Farella Braun + Martel LLP

New DOJ Corporate Whistleblower Awards Program Pits Company Compliance Programs Against the Clock

The Department of Justice announced a Corporate Whistleblower Awards Pilot Program on August 1, 2024. If a whistleblower voluntarily reports original, truthful, and complete information to DOJ in a relevant subject...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

Holland & Hart LLP on

On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

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