News & Analysis as of

White Collar Crimes Corporate Misconduct Investigations

Bracewell LLP

Digging for Trouble: The Double-Edged Sword of Decisions to Report Misconduct

Bracewell LLP on

On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more

DarrowEverett LLP

How DOJ's Safe Harbor Policy Rewards Honesty Within M&A Deals

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Be you a merger and acquisition attorney, corporate compliance officer, or counsel to an acquiring entity or target entity, you should review the Department of Justice’s new Merger and Acquisition Safe Harbor Policy...more

A&O Shearman

Belgian investigations trends and developments in white collar crime

A&O Shearman on

We continue to see increased investigation and prosecution of corruption, fraud, modern slavery and workplace misconduct, especially in the construction, transportation and financial sectors. Investigations are boosted by...more

McDermott Will & Emery

DOJ Formalizes Guidelines, Incentives for Corporate Self-Disclosure Through New Policy Directive for US Attorneys’ Offices

McDermott Will & Emery on

On February 24, 2023, the US Department of Justice (DOJ) rolled out a corporate self-disclosure policy (the Policy) to be applied by all 93 US Attorneys’ Offices throughout the country. The details of the Policy—which...more

Fox Rothschild LLP

DOJ Formalizes Framework for Corporate Cooperation Credit

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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

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Doubles Down on Efforts To Incentivize Early Self-Reporting and Cooperation

On January 17, 2023, the U.S. Department of Justice (DOJ) announced revisions to the Criminal Division’s Corporate Enforcement Policy. The revisions follow Deputy Attorney General (DAG) Lisa Monaco’s September 2022...more

Oberheiden P.C.

Developing a Robust DOJ Compliance Program

Oberheiden P.C. on

The United States Department of Justice (DOJ) is the federal agency tasked with enforcing a wide range of federal laws and regulations. When the DOJ suspects that an individual or business has violated a federal law or...more

Lowenstein Sandler LLP

DOJ 'Invigorates' Efforts to Combat Corporate and White Collar Crimes

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The Department of Justice (DOJ or Department), under the leadership of Attorney General Merrick Garland, has expressed that one of its top priorities in corporate criminal matters is “to prosecute the individuals who commit...more

Thomas Fox - Compliance Evangelist

Frank Discussions About Investigations

You may find yourself in the position that you will have to have some very frank discussions about what to expect in terms of costs and time outlays. While much of these discussions will focus on the investigative process and...more

The Volkov Law Group

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

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OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more

Downs Rachlin Martin PLLC

DOJ Announces Policy Changes On Corporate Cooperation In Both Criminal And Civil Cases

On November 29, 2018, during a speech at the International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced changes to the Department of Justice’s (DOJ or the Department)...more

Akin Gump Strauss Hauer & Feld LLP

Yates Memo Revisions Encourage Cooperation, but Fail Fully to Achieve a Common-Sense Approach to Civil Enforcement

• Recent Justice Manual changes roll back Yates memo requirements for corporations seeking cooperation credit in enforcement actions, including civil enforcement actions. • Corporations can now receive maximum cooperation...more

Blank Rome LLP

DOJ Revises Yates Memo and Relaxes Approach to Corporate Cooperation Credit

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The Department of Justice (“DOJ”) announced that it is stepping back from its hard-line approach to corporate cooperation credit in which a corporation was not eligible for credit unless it disclosed all relevant facts about...more

McGuireWoods LLP

Yates Memo Revised – DOJ Steps Back From All-or-Nothing Approach to Corporate Cooperation Credit

McGuireWoods LLP on

The Justice Department’s revisions to the so-called “Yates Memo” continues a series of significant white collar enforcement policy changes. We hope this summary is helpful to businesses and their leaders in adjusting to these...more

Alston & Bird

No More “All or Nothing” – DOJ Softens the Yates Memo

Alston & Bird on

After three years of working with the Yates Memo, the Department of Justice has memorialized the more practical applications federal prosecutors have been using on the ground. Our White Collar, Government & Internal...more

Holland & Knight LLP

“Yates Memo” Edited to Grant Prosecutors More Flexibility in Civil Cases

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On Sept. 9, 2015, then-Deputy Attorney General Sally Yates issued a memo requiring federal prosecutors to investigate any individuals responsible for illegal corporate conduct before settling a case. This applied to both...more

Thomas Fox - Compliance Evangelist

Evolution of Best Practices – Part IV

In addition to enforcement actions, the Department of Justice’s (DOJs) 2016 FCPA Pilot Program, coupled with 2017’s Evaluation of Corporate Compliance Programs (Evaluation) and the FCPA Corporate Enforcement Policy, all...more

Troutman Pepper

Lessons Learned from the FCPA Pilot Program's First Six Months

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The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more

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