News & Analysis as of

Enforcement Foreign Corrupt Practices Act (FCPA) Self-Disclosure Requirements

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Guidepost Solutions LLC

A “Quick Guide” to Government Whistleblower and Voluntary Self-Disclosure Programs: Heed the Warning from DOJ to Strengthen...

The Department of Justice (DOJ) has sounded the alarm: an aggressive crackdown on corporate misconduct is imminent. With an enforcement program on the horizon, corporations must heed the warning and take proactive measures to...more

Bracewell LLP

Lifting the Fog on the Foreign Corrupt Practices Act: Enforcement and Compliance Trends to Watch in San Francisco

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As lawyers, corporate executives and federal law enforcement officials prepare to gather this week in San Francisco for the ABA’s 39th National Institute on White Collar Crime, we offer our takeaways from January’s Houston...more

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

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2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

ArentFox Schiff

Show Me the Money: Using Compensation Structures to Promote Compliance

ArentFox Schiff on

Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more

Pillsbury Winthrop Shaw Pittman LLP

Voluntary Self-Disclosure: Is the Value Self-Evident?

How should companies think about DOJ, BIS and OFAC voluntary disclosure in the wake of the DOJ’s massive investment in sanctions and export control enforcement? The DOJ, BIS and OFAC released a joint compliance note...more

Jenner & Block

Client Alert: Assistant Attorney General Announces Changes to DOJ’s Corporate Enforcement Policy

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On January 17, 2023, Assistant Attorney General (AAG) Kenneth Polite, Jr., delivered a speech announcing several important revisions to the Department of Justice (DOJ) Criminal Division’s Corporate Enforcement Policy (CEP)...more

Bracewell LLP

DOJ to Companies: If You Step Up & Own Up, You Might Not Have to Pay Up

Bracewell LLP on

Late last year, the Department of Justice (DOJ) announced material changes to the way it intended to investigate, prosecute, and resolve corporate cases. The changes were aggressive, leading us to title our update “DOJ’s...more

WilmerHale

Latin America Anti-Bribery Year-in-Review: 2019 Developments and Predictions for 2020

WilmerHale on

Foreign Corrupt Practices Act (FCPA) enforcement activity reached new heights in 2019. Corporate penalties paid to US enforcement agencies topped last year’s record levels, and individuals were charged at a pace matching last...more

Eversheds Sutherland (US) LLP

DOJ revises FCPA corporate enforcement policy to clarify self-disclosure and cooperation credit requirements

On November 20, 2019, the US Department of Justice (DOJ) announced the latest revisions to the Foreign Corrupt Practices Act Corporate Enforcement Policy (the Corporate Enforcement Policy). The revised language provides...more

King & Spalding

H1 2019: Latin America Enforcement Observations

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The U.S. Justice Department, the U.S. Securities and Exchange Commission, and their enforcement partners throughout Latin America remain focused on actively investigating corruption activities and bringing enforcement actions...more

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