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Whistleblowers Department of Justice (DOJ) Self-Disclosure Requirements

Mintz

DOJ Reinforces Emphasis on Voluntary Self-Disclosure With Latest Updates to the Evaluation of Corporate Compliance Programs...

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On September 23, 2024, the Criminal Division of the United States Department of Justice (“DOJ” or the “Department”) revised its Evaluation of Corporate Compliance Programs guidance (the “ECCP”)....more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...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

Foley & Lardner LLP

DOJ Stresses AI Risk and Whistleblower Protection in Revised Corporate Compliance Guidance

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On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more

Katten Muchin Rosenman LLP

Chicago United States Attorney's Office Launches Pilot Program to Encourage Self-Disclosure

On September 16, the US Attorney's Office for the Northern District of Illinois (NDIL) announced the launch of its Individual Self-Disclosure (ISD) Pilot Program. The program offers non-prosecution agreements to qualifying...more

Sheppard Mullin Richter & Hampton LLP

DOJ Announces Changes to Guidance on Corporate Compliance Programs, Updates on Whistleblower Program

In an address this week to the Society of Corporate Compliance and Ethics, Principal Deputy Assistant Attorney General Nicole M. Argentieri of the Department of Justice’s (“DOJ”) Criminal Division, highlighted several updates...more

Hogan Lovells

It’s the final countdown... for self-disclosure under DOJ’s amended Corporate Enforcement Policy

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The recent amendment to the Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) of the Department of Justice’s (DOJ’s) Criminal Division expects companies to self-disclose allegations of misconduct within 120...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for August 2024

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

Proskauer Rose LLP

DOJ Triples Down on Incentivizing Disclosures with Launch of Three-Year Corporate Whistleblower Awards Pilot Program

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Corporate Whistleblower Awards Pilot Program (“Pilot Program”), aimed at incentivizing whistleblowers to report potential criminal conduct. The announcement was anticipated, having been previewed in March 2024 by Deputy...more

Foley & Lardner LLP

Understanding the Risk vs. Reward of Department of Justice’s Corporate Criminal Whistleblower Awards Pilot

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The Securities & Exchange Commission, the Department of Health & Human Services, and other agencies have long had established bounty programs that reward successful tipsters. On August 1, 2024, the Department of Justice’s...more

Orrick, Herrington & Sutcliffe LLP

DOJ announces Corporate Whistleblower Awards Pilot Program

Recently, the DOJ announced the launch of the Corporate Whistleblower Awards Pilot Program, starting on August 1. This initiative aims to address corporate crime by encouraging whistleblowers to submit original information...more

Lowenstein Sandler LLP

DOJ’s New Whistleblower Policies Will Bring Increased Scrutiny to Businesses in the Financial and Health Care Industries and Those...

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Earlier this month, the U.S. Department of Justice (DOJ) announced its Corporate Whistleblower Awards Pilot Program (Program). The Program—which will last for three years—is designed to incentivize, through money awards,...more

NAVEX

Whistleblower Awards Keep Adding New Compliance Pressures

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Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more

Dinsmore & Shohl LLP

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

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?? 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

BCLP

DOJ Piles On the Incentives for Individuals to Blow the Whistle on Companies

BCLP on

Historically, successful white-collar prosecutions often turn on the government’s ability to identify “insiders” with firsthand knowledge of the alleged criminal scheme, who opt to cooperate with prosecutors in exchange for...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

Bracewell LLP

Creating an Army of In-House Investigators

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In its never-ending war on corporate fraud, the Department of Justice (“DOJ”) has just commissioned a private army to fight as never before. On August 1, the DOJ launched a three-year program to provide financial rewards to...more

Katten Muchin Rosenman LLP

DOJ Details Its Bounty Program as New Corporate Whistleblower Program Rolls Out

After teasing the release of a new corporate whistleblower program in March 2024, Deputy Attorney General Lisa Monaco and Principal Deputy Assistant Attorney General Nicole M. Argentieri each took turns announcing on August 1...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

Gardner Law

DOJ Enforcement Insights: Key Strategies to Mitigate Risks

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The DOJ had a record year, and we reviewed FCA enforcement action trends to identify trends to help you stay informed and proactive in your compliance efforts. This alert summarizes key takeaways from Amanda Johnston’s recent...more

Snell & Wilmer

Department of Justice Announces Groundbreaking Whistleblower Program in its Ongoing Effort to Incentivize Voluntary Self...

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Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Launches New Pilot Program to Allow Whistleblowers Who Report Financial Crimes, Corruption to Avoid Prosecution

On April 15, 2024, the U.S. Department of Justice (DOJ) Criminal Division launched a new pilot program to enable whistleblowers to avoid prosecution when they voluntarily report new information to federal law enforcement...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

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

Morrison & Foerster LLP

DOJ Criminal Division Initiates Self-Disclosure Pilot Program for Individuals

On April 15, 2024, the Criminal Division of the Department of Justice (DOJ) announced a new pilot program setting forth the circumstances in which it will offer non-prosecution agreements (NPAs) to individuals who voluntarily...more

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