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Incentives Compliance Department of Justice (DOJ)

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...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

Holland & Hart LLP

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

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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

Gardner Law

DOJ Enforcement Insights: Key Strategies to Mitigate Risks

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The DOJ had a record year, and we reviewed FCA enforcement action trends to identify trends to help you stay informed and proactive in your compliance efforts. This alert summarizes key takeaways from Amanda Johnston’s recent...more

Mintz

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

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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

Alston & Bird

Yet More Carrots: DOJ Announces New Whistleblower Pilot Program

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Our White Collar, Government & Internal Investigations Team reviews a new program announced by the Department of Justice (DOJ) that aims to incentivize reporting of corporate and financial misconduct....more

Harris Beach PLLC

False Claims Act Enforcement Highlights Need for Robust Compliance Programs

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The U.S. Department of Justice (“DOJ”) announced its False Claims Act (“FCA”) enforcement statistics for FY 2023 and identified key priorities for FCA enforcement in 2024 and beyond. The DOJ continues to pursue FCA...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

ArentFox Schiff

Show Me the Money: Using Compensation Structures to Promote Compliance

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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

The Volkov Law Group

How to Build a Compliance Compensation System (Part I of II)

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The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management.  The theoretical...more

BakerHostetler

New DOJ Policies Tie Employee Compensation to Compliance

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On March 15, 2023, the U.S. Department of Justice (DOJ or the Department) launched a three-year Compensation Incentives and Clawbacks Pilot Program (Clawback Program) intended to incentivize companies to create more robust...more

Perkins Coie

DOJ Announces Pilot Program and Updated Expectations on Corporate Compensation Programs

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The U.S. Department of Justice (DOJ) on March 3, 2023, unveiled a new pilot program and announced several important updates to its Evaluation of Corporate Compliance Programs (ECCP) regarding corporate compensation incentives...more

Sheppard Mullin Richter & Hampton LLP

DOJ Revises Guidance on Evaluation of Corporate Compliance Programs Concerning Compensation and Employee Use of Personal Devices...

Following remarks made on March 2 and March 3, 2023 at the American Bar Association’s 38th Annual National Institute on White Collar Crime, the U.S. Department of Justice (“DOJ”) issued revisions to its Evaluation of...more

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series: Protecting Your Business Against Non-Compliance and DOJ Penalties - March 23rd, 12:00...

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During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more

McDermott Will & Emery

DOJ Announces Major Changes to Corporate Compliance Program Evaluation Criteria

During speeches on March 2 and 3, 2023, at the American Bar Association (ABA) National Institute on White Collar Crime (the 2023 White Collar Conference), Deputy Attorney General (DAG) Lisa Monaco, Assistant Attorney General...more

Dorsey & Whitney LLP

Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

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On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more

Snell & Wilmer

DOJ Revisits its Corporate Criminal Enforcement Policy Offering Companies Additional Incentives to Self-Disclose, Cooperate, and...

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On January 17, 2023, Assistant Attorney General (“AAG”) Kevin Polite announced revisions to the Department of Justice’s (“DOJ”) Corporate Enforcement Policy (“CEP”), which will apply to all corporate criminal matters. The...more

Cozen O'Connor

DOJ Offering Increased Reductions in Fines up to 75% to Incentivize Companies to Voluntarily Report Misconduct

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On January 17, 2023, the Department of Justice (DOJ) rolled out a significant change to its existing Corporate Enforcement Policy (CEP) that will grant as much as a 75% reduction in fines for companies that voluntarily...more

The Volkov Law Group

DOJ Issues Sweeping New Corporate Criminal Enforcement Policy — A New Era of Compliance Begins with Increased Focus on...

The Volkov Law Group on

The Biden Administration promised a new, aggressive approach to corporate crime.  Well, the Justice Department just delivered a new, comprehensive policy that raises a number of new issues, some of which are likely to be...more

Thomas Fox - Compliance Evangelist

Sales incentives and Compliance

Sales incentives continue to be an area where Chief Compliance Officers (CCOs) and compliance professionals work refine their compliance regimes. In the 2020 Update to the Evaluation of Corporate Compliance Programs (Update),...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Philadelphia Regional Compliance & Ethics Conference - December 3rd, 8:25 am - 4:30 pm EST

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

Health Care Compliance Association (HCCA)

DOJ Is Trying to 'Incentivize Higher-Quality Compliance,' Former Official Says

Report on Medicare Compliance 28, no. 44 (December 16, 2019) - One way to find out whether compliance and integrity have seeped into the bones of an organization is asking people who would know. There may be a compliance...more

International Lawyers Network

New DOJ Antitrust Division Policy Incentivizes Robust Corporate Antitrust Compliance Programs

Last month the Department of Justice’s Antitrust Division announced a landmark new policy to incentivize companies to develop robust antitrust compliance programs. For the first time, the Antitrust Division will now consider...more

Perkins Coie

Compliance Is King: DOJ Announces Policy to Incentivize Corporate Antitrust Compliance Programs

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The U.S. Department of Justice (DOJ) announced a new policy on July 11, 2019, designed to incentivize the development and implementation of corporate antitrust compliance programs. In remarks made at the New York...more

Dechert LLP

Revised DOJ Policy on Antitrust Compliance Offers New Opportunities for In-House Counsel to Protect Their Companies

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Question: Can a company have both an effective antitrust compliance program and an antitrust violation? DOJ before June 11, 2019: Nope. DOJ today: Yes, and your company may even get a deferred prosecution agreement if...more

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