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Non-Prosecution Agreements White Collar Crimes

Kohn, Kohn & Colapinto LLP

U.S. Attorney Office “Whistleblower” Programs Sow Confusion and Pose Risks to Corporate Whistleblowers

In recent weeks, a number of U.S. Attorneys’ Offices (USAOs) across the country have rolled out “Whistleblower Pilot Programs” offering the potential of non-prosecution agreements in exchange for voluntary self-disclosure of...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2024

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

BakerHostetler

7 More US Attorneys’ Offices Issue Whistleblower Non-Prosecution Pilot Programs

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There was a flurry of DOJ whistleblower program activity over the last two weeks as the U.S. Attorneys’ Offices for the Eastern District of New York (EDNY Program), District of New Jersey (DNJ Program), Southern District of...more

Mintz

DOJ Issues its Highly Anticipated Whistleblower Awards Pilot Program

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In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...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

McCarter & English, LLP

DOJ Launches Pilot Program to Encourage Reporting of Criminal Activity

The Department of Justice (DOJ) has announced a pilot program to encourage potential whistleblowers to report criminal activity and cooperate with government investigations in exchange for substantial monetary payouts in the...more

Lowenstein Sandler LLP

DOJ Says You Can Put the Fire Out From Inside the House: New Voluntary Self-Disclosure Program Seeks to Root Out Corporate Crime...

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Introduction: On April 15, 2024, the Department of Justice’s (DOJ) Criminal Division announced a new Pilot Program on Voluntary Self-Disclosure for Individuals. Under this program, individuals who voluntarily disclose certain...more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

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The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

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On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more

Jones Day

DOJ Criminal Division Offers Non-Prosecution Agreements to Individuals Who Voluntarily Report Corporate Wrongdoing

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The Development: On April 15, 2024, the Department of Justice ("DOJ") Criminal Division announced a pilot program that will offer mandatory non-prosecution agreements ("NPAs") to individuals who provide original and...more

Paul Hastings LLP

DOJ Criminal Division Announces New Voluntary Self-Disclosure Pilot Program for Individuals

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On April 22, 2024, the Acting Assistant Attorney General for the Department of Justice (“DOJ”) Criminal Division (“Acting AAG”) Nicole M. Argentieri offered commentary in a blog post regarding the Criminal Division’s newest...more

The Volkov Law Group

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

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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

Robinson & Cole LLP

Department of Justice Criminal Division Announces Voluntary Self-Disclosure Pilot Program for Culpable Individuals

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Last week, the Department of Justice (DOJ) announced the Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Program). Pursuant to the Program, “an individual who voluntarily self-discloses...more

Society of Corporate Compliance and Ethics...

Understanding the Whistleblower Pilot Program in the Southern District of New York

In January 2024 the US Attorney’s Office for the Southern District of New York (SDNY) set a shockwave through the business world by announcing a new whistleblower pilot program. To understand what the policy says and what it...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

Womble Bond Dickinson

Criminal Division of U.S. Department of Justice Announces Pilot Program on Voluntary Self-Disclosure for Individuals

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In the U.S. Department of Justice’s (DOJ) latest policy in furtherance of its “carrots and sticks” approach to corporate criminal enforcement, senior leadership of its Criminal Division announced a new Pilot Program on...more

Venable LLP

DOJ Announces Pilot Program for Individual Voluntary Self-Disclosures

Venable LLP on

On April 15, 2024, the Department of Justice (DOJ) criminal division announced a new pilot program designed to reward individuals with non-prosecution agreements (NPAs) who voluntarily self-disclose "actionable, original...more

Nelson Mullins Riley & Scarborough LLP

Bringing Moths to the Flame: DOJ Promises Non-Prosecution to Execs for Tips to Combat Corporate Crime

Recently, the Department of Justice (DOJ) Criminal Division launched a pilot program promising “mandatory NPAs to incentivize individuals (and their counsel) to provide original and actionable information.” This most recent...more

Alston & Bird

The Race is On: DOJ's Criminal Division the Latest to Offer Non-Prosecution Deals to Whistleblowers

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Our White Collar, Government & Internal Investigations Group investigates the latest federal whistleblower program, which offers individuals yet another avenue to report corporate misconduct....more

WilmerHale

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

WilmerHale on

On April 15, 2024, the Criminal Division of the Department of Justice (DOJ) announced the Pilot Program on Voluntary Self-Disclosure for Individuals, providing transparency regarding the circumstances in which Criminal...more

Bradley Arant Boult Cummings LLP

DOJ Takes the Next Step in Its Effort to Increase Voluntary Self-Disclosures By Incentivizing Those Complicit in Wrongdoing

On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the “Pilot”) designed to encourage individuals to report certain types of criminal...more

Bradley Arant Boult Cummings LLP

“Take Me to the Pilot” – DOJ Announces Plan to Entice Self-Disclosures of Government Contract Fraud

On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Pilot) designed to encourage individuals to report certain types of criminal...more

BakerHostetler

DOJ’s Criminal Division Announces New Pilot Program onVoluntary Self-Disclosure for Individuals

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Under the newly announced pilot program, individuals who fully cooperate and voluntarily provide the Criminal Division with information on certain types of corporate and white-collar offenses may receive an NPA in exchange...more

Thomas Fox - Compliance Evangelist

Changing Sales Models

Over the past 12 months or so there have been a series of Foreign Corrupt Practices Act (FCPA) enforcement actions where the respondents have changed and/or modified their sales models to get away from external third parties...more

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