DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
The Presumption of Innocence Podcast: Episode 37 - Vintage or Trendsetting? The SDNY's Whistleblower Pilot Program
Episode 289 -- Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure
New DOJ Guidance Tightens Corporate Enforcement Strategy
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
Day 29 of 31 Days to a More Effective Compliance Program
FCPA Compliance Report-Episode 346, Mike Skopets on Miller’s Summer 2017 FCPA Report
The Bribery Act: To Disclose or Not To Disclose?
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
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
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
In recent remarks, Principal Associate Deputy Attorney General (PADAG) Marshall Miller of the Department of Justice (DOJ) revealed that Deputy Attorney General Lisa Monaco will soon announce new voluntary self-disclosure...more
At the Global Investigations Review Annual Meeting in New York on September 21, 2023, Principal Associate Deputy Attorney General Marshall Miller (“Miller”) delivered remarks that provide an invaluable glimpse into the...more
DOJ is roaring into March with updates to its guidance on the evaluation of corporate compliance programs, a new pilot program on compensation incentives and clawbacks, and a revised policy on monitor selection, all released...more
The US Department of Justice recently announced a compensation clawback pilot program as well as changes to the corporate compliance program evaluation criteria in the latest of a flurry of policy updates....more
The Department of Justice (DOJ) announced a new voluntary self-disclosure policy February 22, 2023, that sets uniform criteria for how and when prosecutors should reward corporate cooperation in criminal investigations. The...more
On February 22, 2023, the U.S. Department of Justice (DOJ) announced a new nation-wide policy to incentivize companies to self-report criminal activity. Among the cited benefits of self-reporting are discounts on fines and...more
The U.S. Justice Department unveiled new policies about how it will prosecute cases of corporate misconduct, offering new incentives for companies whose misconduct includes “aggravating circumstances” to step forward and...more
On September 15, 2022, Deputy Attorney General Lisa Monaco announced new changes to the United States Department of Justice's (the "DOJ") corporate criminal enforcement policies, through the publication of a new memo titled...more
Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more
At a September 15, 2022, speech at New York University School of Law, US Deputy Attorney General (Deputy AG) Lisa Monaco announced several new policies intended to further the aggressive stance the US Department of Justice...more
Deputy Attorney General (DAG) Lisa Monaco announced several significant policy updates affecting the U.S. Department of Justice’s (DOJ) enforcement practices for both corporations and individuals on September 15, 2022...more
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more
China continues to be a high-risk location for US companies to do business. While the current administration has laid numerous tariffs on Chinese goods, the fact that it holds 6 billion potential consumers will continue to...more
Over the last 10 years, 143 companies have paid a combined $10.9 billion to resolve Foreign Corrupt Practices Act cases. That staggering price tag shows the U.S. Department of Justice’s willingness to go after alleged...more
On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more
November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more
In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more
“Official Acts”—What They Are… and Are Not - Why it matters: On June 27, 2016, the Supreme Court decided McDonnell v. U.S., holding that, for purposes of the federal public corruption statutes, an “official act”...more
For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more