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Policies and Procedures Cooperation

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Program - March 13th - 14th, Mexico City, Mexico

ACI’s Mexico Summit on Anti-Corruption & Compliance Programs returns on March 13-14, 2024 in Mexico City! Given the uncertainty with the looming Presidential election, as well as increased U.S. enforcement focus on Mexico...more

White & Case LLP

A View from Abroad: Unpacking DOJ’s M&A Safe Harbor Policy, Part II

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On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...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

Dorsey & Whitney LLP

Department of Justice Seeks to Reward Due Diligence and Timely Self-Disclosures in Mergers & Acquisitions Through New Safe Harbor...

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The United States Department of Justice (DOJ) recently announced a new department-wide Mergers & Acquisitions Safe Harbor Policy that protects acquiring companies that self-disclose criminal misconduct discovered at an...more

Latham & Watkins LLP

DOJ Announces Safe Harbor Policy for Voluntary SelfDisclosure of Criminal Misconduct Uncovered in M&A

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The policy expands upon DOJ’s efforts to encourage self-reporting of criminal violations discovered during M&A and other transactions. On October 4, 2023, US Deputy Attorney General Lisa Monaco announced a new Department...more

BakerHostetler

DOJ Announces Department-Wide Safe Harbor Policy for Voluntary Self-Disclosures Made in the Context of Mergers and Acquisitions

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In an important policy announcement aimed at rewarding robust due diligence and compliance programs, DOJ announced that acquiring companies that promptly and voluntarily disclose criminal misconduct discovered at the acquired...more

Eversheds Sutherland (US) LLP

DOJ incentivizes self-reporting with new M&A Safe Harbor Policy

On October 4, 2023, US Deputy Attorney General (DAG) Lisa Monaco announced that the US Department of Justice (DOJ) is adopting a new Mergers & Acquisitions Safe Harbor Policy, incentivizing companies to voluntarily disclose...more

Seward & Kissel LLP

DOJ Releases New Voluntary Self-Disclosure Policy

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On February 22, 2023, the Department of Justice (“DOJ”) released a new voluntary self-disclosure (“VSD”) policy (available here) that applies to all United States Attorney’s Offices (“USAO”). The policy details the...more

Goodwin

When Perquisites Stop Being Fun And Create Serious Liability Risks To An Issuer

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Last week, the U.S. Securities and Exchange Commission (“SEC”) brought enforcement actions against a company and its former CEO for failure to adequately disclose certain compensation and related party transactions. The move...more

Latham & Watkins LLP

New DOJ Guidance Increases Benefits for Robust Antitrust Compliance Programs - What Companies Need to Know

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The Antitrust Division’s new policy gives credit for pre-existing compliance programs, but only those that meet certain high standards. On July 11, 2019, Assistant Attorney General Makan Delrahim announced that the US...more

Maynard Nexsen

Cooperation Credit in False Claims Act Defense and the Potential Impact of Reimbursement Analysis and Compliance

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While white collar and healthcare counsel have long known that one of the best strategies to reducing risk in defending a False Claims Act (FCA) case is cooperation and execution of compliance actions, the Department of...more

Thomas Fox - Compliance Evangelist

Farewell to V.S. Naipaul and Creating Priorities in Your Compliance Program

V.S. Naipaul died last week. He was a Trinidadian born grandson of Indian indentured servants sent to the island to work in the sugar plantations. From those humble beginnings, Naipaul rose to the heights of the literary...more

Holland & Knight LLP

DOJ Implements Policies On Environmental Enforcement

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• A recent memorandum from the U.S. Department of Justice's (DOJ) Environment and Natural Resources Division (ENRD) provides guidance on civil and criminal enforcement of environmental laws. DOJ will continue to pursue...more

Dechert LLP

Corporate Compliance Programs: US and UK Perspectives

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In today’s regulatory environment, companies face mounting pressure from law enforcement agencies to maintain robust compliance programs to deter and detect misconduct by employees, third-party vendors and business partners....more

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