News & Analysis as of

Self-Disclosure Requirements Enforcement Actions

Fenwick & West LLP

CLE Takeaways: Federal Sales: Partner Compliance Programs and Investigations

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Channel partners offer significant benefits when your original equipment manufacturer, software manufacturer, or cloud-service provider is contracting with the federal government....more

ArentFox Schiff

BIS Issues Final Rule for Voluntary Self-Disclosure Procedures

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On Thursday, September 12, 2024, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule updating the agency’s policies on voluntary self-disclosures and the Guidance on Charging and Penalty...more

Alston & Bird

Enter the Matrix: CFTC’s New Framework for Self-Reporting, Cooperation, and Remediation

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Our White Collar, Government & Internal Investigations Group analyzes new enforcement guidance from the Commodity Futures Trading Commission (CFTC) that aims to incentivize self-reporting of potential violations....more

Bond Schoeneck & King PLLC

Office of Medicaid Inspector General Releases Annual Workplan

On Jan. 29, 2025, the New York State of Office of Medicaid Inspector General released its Annual Workplan, to provide a guide for stakeholders for its 2025 activities. As in past years, the Workplan provides a roadmap for...more

Hendershot Cowart P.C.

Texas Healthcare Providers Paid $21.3 Million to Resolve Stark Law Violations in 2024

Hendershot Cowart P.C. on

Healthcare fraud enforcement continues to be a top priority for federal authorities, with Stark Law violations remaining under particular scrutiny. The complex nature of physician self-referral regulations, combined with...more

Mintz - Health Care Viewpoints

EnforceMintz – DOJ Policy Developments in 2024 Seek to Motivate More Voluntary Self-Disclosures

Over the past two years, the Department of Justice (DOJ or the Department) has actively incentivized companies to voluntarily self-disclose potential civil and criminal violations. For example, in 2023, in the criminal...more

Society of Corporate Compliance and Ethics...

Understanding the Latest DOJ Changes to Corporate Prosecutions

On November 22, 2024, then Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand...more

Bracewell LLP

Enforcement Trends 2025: Magic 8 Ball Says "Try Again Later"

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As the world prepares for the change of administration in January, current government officials and industry experts convened at the New York Forum on Economic Sanctions to reflect on enforcement trends in 2024, and to...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Hot Springs Sawmill...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and USNR, LLC d/b/a Timber Automation, LLC (“USNR”) entered into a September 25th Consent Administrative Order (“CAO”) addressing...more

Baker Botts L.L.P.

CFTC, SEC, and SDNY Break New Ground and File Charges Against Carbon Credit Project Developer and Former Executives for Fraudulent...

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On October 2, 2024, the Commodities Futures Trading Commission (“CFTC”), the Securities and Exchange Commission (“SEC”), and the United States Attorney’s Office for the Southern District of New York announced parallel...more

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - November 1st, Scottsdale, AZ

Looking for compliance education and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance education on a wide variety of current and emerging topics...more

Torres Trade Law, PLLC

Noteworthy FCPA Enforcement Developments

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The Department of Justice really wants violators of the Foreign Corrupt Practices Act (FCPA) to come forward: following a January 2023 revision of its Corporate Enforcement Policy that incentivized voluntary self-disclosure,...more

Torres Trade Law, PLLC

BIS Tightens Export Control Enforcement

Torres Trade Law, PLLC on

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) just issued a significant rule change that reshapes the landscape of export control enforcement. Published on September 16, 2024, the rule amends the...more

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

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DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

Hogan Lovells

U.S. announces export enforcement and compliance resources for academic research institutions

Hogan Lovells on

The U.S. Department of Commerce’s Bureau of Industry and Security has published a compliance note on voluntary self-disclosure trends and a compendium of export compliance resources targeted to the academic community. The...more

Dinsmore & Shohl LLP

DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program

Dinsmore & Shohl LLP on

?? In this Spotlight on White Collar Defense and Government Investigations, Cincinnati's Lindsay Gerdes explains how the U.S. Department of Justice’s (DOJ) self-disclosure policy encourages companies to voluntarily disclose...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

Robinson & Cole LLP

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary...

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On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more

Sheppard Mullin Richter & Hampton LLP

BIS Summer Update: Essential Reading for Your Next Beach Trip!

As we pass the midpoint of a year marked by assertive enforcement of dual use laws, the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated version of its Don’t Let This Happen to You! Guide....more

ArentFox Schiff

Investigations Newsletter: Biomedical Company Avoids DOJ Prosecution After First Ever Voluntary Corporate Self-Disclosure of Fraud...

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Biomedical Company Avoids DOJ Prosecution After First Ever Voluntary Corporate Self-Disclosure of Fraud Under NSD Enforcement Policy - On May 22, the US Department of Justice (DOJ) announced that it will not prosecute a...more

Jenner & Block

Client Alert: DOJ Continues Its Trend of Strengthening Incentives to Report Corporate Misconduct

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Just over a month after Deputy Attorney General Lisa Monaco announced the upcoming launch of the Department of Justice’s whistleblower rewards program, the DOJ Criminal Division unveiled its newest program to incentivize...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – April 2024

You are reading the April 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. April saw...more

Cooley LLP

NSD’s Revised Enforcement Policy for Business Organizations Incentivizes Voluntary Self-Disclosures in M&A Context

Cooley LLP on

Companies engaged in mergers & acquisitions activities should take note of the revised voluntary self-disclosure policy (VSD Policy) of the National Security Division (NSD) of the US Department of Justice, released on March...more

Foley Hoag LLP - White Collar Law &...

Anticorruption Enforcement and the Foreign Corrupt Practices Act: Trends to Track in 2024

This is the seventh in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

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