News & Analysis as of

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

Thomas Fox - Compliance Evangelist

The Boston Consulting Group Declination: A Money Shot for Clawbacks

In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more

Mintz

DOJ’s Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

Mintz on

Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Holland & Knight LLP

"Call Us Before We Call You": SDNY Announces Pilot Whistleblower Program

Holland & Knight LLP on

The U.S. Attorney's Office for the Southern District of New York (SDNY) on Jan. 10, 2024, announced a Whistleblower Pilot Program (Program) that it is presenting as another "tool in [the SDNY's] toolkit" that could unearth...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

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

Compelled Interviews Admissible in Criminal Prosecution Against Former Company President and Its General Counsel

A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more

American Conference Institute (ACI)

[Webinar] Anti-Corruption Brazil – FCPA Compliance and Enforcement in Brazil: DOJ and SEC Alumni Provide Critical Updates and the...

American Conference Institute’s expert faculty of DOJ and SEC alumni will update you with the most recent developments and risk factors confronting industry in Brazil and will lay out practical takeaways for satisfying the...more

Goodwin

DOJ Announces Nationwide Voluntary Corporate Self-Disclosure Policy in Effort to Standardize and Incentivize Timely Self-Reporting

Goodwin on

On February 22, 2023, the US Department of Justice (DOJ) announced a Voluntary Self-Disclosure Policy (VSD Policy) to formalize DOJ’s efforts to incentivize companies to voluntarily self-report criminal misconduct to the...more

Venable LLP

DOJ Announces Corporate Criminal Self-Disclosure Policy for All U.S. Attorneys' Offices

Venable LLP on

On Wednesday February 22, 2023, the Department of Justice (DOJ) announced a voluntary corporate self-disclosure policy for all U.S. Attorneys' Offices, effective immediately. The policy adopts a uniform standard for companies...more

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

Latham & Watkins LLP on

Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more

McDermott Will & Emery

DOJ Revamps Corporate Criminal Enforcement Policies with Continued Emphasis on Compliance

McDermott Will & Emery on

At a September 15, 2022, speech at New York University School of Law, US Deputy Attorney General (Deputy AG) Lisa Monaco announced several new policies intended to further the aggressive stance the US Department of Justice...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

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - December 2019

IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Emphasizes Transparency and Encourages Cooperation

In 2019, the Criminal Division of the U.S. Department of Justice (DOJ) continued its efforts, begun a few years prior, to enhance transparency with respect to the DOJ's prosecutorial decision-making. In public statements, DOJ...more

Dechert LLP

DOJ Revised Policy on Voluntary Self-Disclosures of Sanctions and Export Violations

Dechert LLP on

On December 13, 2019, the U.S. Department of Justice (“DOJ”) issued a new policy for companies that voluntarily disclose potential criminal violations of U.S. sanctions and export control laws to the DOJ’s National Security...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

McDermott Will & Emery

Assistant AG Provides Clarity on FCPA Self-Disclosure Credit

McDermott Will & Emery on

Assistant Attorney General Brian Benczkowski’s remarks provide important guidance for management and boards, and underscore the US Department of Justice’s commitment to prosecuting individuals for corporate misconduct....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

Fox Rothschild LLP

Revisions To FCPA Enforcement Policies Still Pose Tough Questions For Honest Companies

Fox Rothschild LLP on

In recent remarks, Deputy Attorney General Rod Rosenstein announced significant revisions to the Department of Justice’s (DOJ) policies for enforcing the Foreign Corrupt Practices Act. The policy revisions make permanent...more

Foley Hoag LLP

DOJ Announces New FCPA Policy to Further Incentivize Corporate Voluntary Self-Disclosure and Cooperation

Foley Hoag LLP on

The U.S. Foreign Corrupt Practices Act turned forty this year. The Department of Justice is marking that anniversary by announcing a new Corporate Enforcement Policy specific to FCPA matters. The new Policy makes explicit...more

BakerHostetler

DOJ Announces Revised FCPA Corporate Enforcement Policy

BakerHostetler on

On November 29, 2017, Deputy Attorney General Rod Rosenstein expanded upon the Department of Justice’s (“DOJ”) long-running efforts to encourage companies to self-disclose Foreign Corrupt Practices Act (“FCPA”) violations by...more

Holland & Knight LLP

DOJ Makes Permanent Its Program to Incentivize Self-Disclosure in FCPA Investigations

Holland & Knight LLP on

• The U.S. Department of Justice's (DOJ) pilot program established in 2016 to incentivize companies to self-report violations of the Foreign Corrupt Practices Act (FCPA) will, with slight revisions, be made permanent. •...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

Ruder Ware on

By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

Womble Bond Dickinson

Updated Status of the DOJ FCPA Pilot Program

Womble Bond Dickinson on

The FCPA Pilot Program was introduced on April 5, 2016 as a one year experiment that sought to ‘motivate companies to voluntarily self-disclose FCPA-related misconduct, fully cooperate with the Fraud Section and …remediate...more

Thomas Fox - Compliance Evangelist

When Leslie Caldwell Talks FCPA, You Should Listen

November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more

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