News & Analysis as of

Incentives Compliance White Collar Crimes

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

American Conference Institute (ACI)

U.K. Parliament Giving Whistleblower Protections a Fresh Review

Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...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

Bracewell LLP

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

Bracewell LLP on

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

The Volkov Law Group

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

The Volkov Law Group on

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

Perkins Coie

DOJ Announces Pilot Program and Updated Expectations on Corporate Compensation Programs

Perkins Coie on

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

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

Cozen O'Connor

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

Cozen O'Connor on

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

Farewell to Rip Torn and Hello to Compliance Incentives

In the recently released Evaluation of Corporate Compliance Programs, 2019 Guidance by the Department of Justice, incentives are specifically identified in the section under “is your program effectively implemented?” The 2019...more

Thomas Fox - Compliance Evangelist

Agile Compliance = Operationalized Compliance: Part III – Incentives, Recruiting and Development

As most of you know, when I get interested in something I can get carried away writing about it and it has happened again as I have been exploring the intersection of agile concepts for business processes and...more

Thomas Fox - Compliance Evangelist

Thaler Wins the Nobel Prize and Informs Compliance Programs

Richard H. Thaler won the Nobel Prize in Economics yesterday. Binyamin Appelbaum, reporting in a New York Times (NYT) a piece entitled, “Nobel in Economics Is Awarded to Richard Thaler”, wrote that “Thaler, whose work has...more

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