Understanding the Whistleblower Pilot Program in the Southern District of New York
Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements
Federal Monitorships and Making Them Work
Salvador Dahan on the Journey of Petrobras
Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities
FCPA Compliance and Ethics Report-Episode 134, Judge Rakoff, Judge Leon and their comments on DPAs, with the FCPA Professor
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more
On April 15, the Department of Justice (DOJ) publicly released a memorandum fleshing out its previously announced corporate whistleblower program, which is intended to induce individuals to report alleged criminal conduct,...more
On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced the launch of its Pilot Program on Voluntary Self-Disclosures for Individuals. U.S. Dep’t of Justice, The Criminal Division’s Pilot...more
On March 14, 2024, the United States Attorney's Office for the Northern District of California ("NDCA") revealed details of its new whistleblower pilot program ("NDCA Program")....more
Telling on yourself is not an intuitive defense. But federal regulators and prosecutors at last week’s ABA National Institute on White Collar Crime urged companies and executives to consider doing so or risk being beat to the...more
The recently created SDNY Whistleblower Pilot Program encourages individuals to self-disclose certain criminal conduct and cooperate in resulting investigations and prosecutions. ...more
The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more
On January 10, 2024, U.S. Attorney Damian Williams announced the Whistleblower Pilot Program (Program) for the U.S. Attorney’s Office (USAO) of the Southern District of New York (SDNY) to encourage self-reporting and...more
Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more
On September 15, 2022, the U.S. Department of Justice (DOJ)’s Deputy Attorney General Lisa Monaco announced new guidance and policies regulating corporate criminal enforcement. The new policies emphasize that DOJ will not...more
In its second year, the Biden administration has made clear its prioritisation of white-collar prosecutions. This includes changes in policy and guidance, such as a renewed focus on individual accountability, an increased...more
On Tuesday, March 22, 2022, Assistant Attorney General Kenneth Polite of the Department of Justice (DOJ) told an audience of compliance professionals that DOJ will direct prosecutors to "consider requiring" chief compliance...more
The Department of Justice under the Biden Administration signaled yesterday that it will be putting more resources towards investigating corporate crime – and expecting more from companies who come under investigation. On...more
On October 28, 2021, Deputy Attorney General (DAG) Lisa O. Monaco gave the keynote address at the ABA’s 36th National Institute on White Collar Crime and announced a series of changes in the Department of Justice’s (DOJ)...more
The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more
Last week closed out one of the most interesting half-years in the Foreign Corrupt Practices Act (FCPA) realm. We have had the Cognizant Technology Solutions Corporation declination, Fresenius Medical Care AG & Co. KGaA...more
On March 29, 2019, the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) announced that they had reached resolution with a German-based major worldwide provider of medical equipment and...more
Summary: Deferred prosecution agreements have been widely used by US prosecutors since the early 2000s. Prosecutors in the UK and France only obtained this power in 2014 and 2016 respectively – but they are making up for...more
In a development with potentially far-reaching consequences for white collar enforcement, the U.S. Department of Justice (DOJ) Criminal Division has expanded the opportunity for companies to earn credit for voluntary...more
When investigating potential wrongdoing, government investigators have powerful tools that they can use to obtain information. As the U.S. Attorneys’ Manual explains, one such tool is the ability to enter into non-prosecution...more
On July 30, 2015, the Justice Department’s Tax Division announced that three more Swiss banks — PKB Privatbank AG, Falcon Private Bank AG and Credito Privato Commerciale in liquidazione SA (CPC) – have cut deals with the U.S....more
The civil money penalty was surprising for two reasons: first, that FinCEN would investigate and fine a casino unfamiliar even to analysts who cover the gaming industry, on an island chain few knew existed; and second, for...more