Public-Private Partnerships to Stem Corruption
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
INTERPOL Red Notices - do they expire?
The Legal Tightrope: Surviving Parallel Investigations
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Should you try to remove an INTERPOL Red Notice yourself?
Episode 335 -- The New DOJ Whistleblower Program
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
INTERPOL Red Notices and Immigration. Can You Obtain Immigration Relief in the U.S. Even with a Red Notice?
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
The Presumption of Innocence Podcast: Episode 43 - New Horizons: Impact of Recent Appellate Circuit Rulings on White-Collar Criminal Defense Law
INTERPOL and Politically Motivated Red Notices - What We Can Learn from INTERPOL’s Annual Reports.
Episode 333 -- The Boeing Proposed Plea Agreement
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
What to do when finding that you are the subject of a RedNotice?
Episode 324 -- Third-Party Risks and Sanctions Compliance
The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more
On September 23, 2024, the Department of Justice updated its guidance on the Evaluation of Corporation Compliance Programs to include questions specifically focused on companies’ use and implementation of artificial...more
On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced updates to the U.S. Department of Justice’s (“DOJ”) guidance relative to its Principles of Federal Prosecution of Business...more
The Department of Justice has revised its Evaluation of Corporate Compliance Programs guidance, adding new content related to technology, whistleblowers, and data analytics. Our White Collar, Government & Internal...more
There was a flurry of DOJ whistleblower program activity over the last two weeks as the U.S. Attorneys’ Offices for the Eastern District of New York (EDNY Program), District of New Jersey (DNJ Program), Southern District of...more
Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the Department of Justice’s (DOJ) approach to evaluating corporate compliance programs. As outlined in the updated 2024...more
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks? Well,...more
The potential for artificial intelligence (AI) to transform business has commanded enormous attention over the past year. Little noted, however, is the U.S. government’s increasing — and increasingly sophisticated — use of AI...more
The Department of Justice (DOJ) recently announced two new measures to enhance its corporate criminal enforcement efforts: a whistleblower rewards program and updated guidance under which federal prosecutors will assess risks...more
To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more
Following a year of new DOJ policies and guidance designed to incentivize companies to self-report misconduct and to cooperate with government investigations, the DOJ has added a new pilot whistleblower rewards program. In...more
Continuing to prioritize corporate criminal enforcement, the Department of Justice (DOJ) announced two new steps it is taking to identify potential corporate misconduct and evaluate companies’ compliance programs. Deputy...more
The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable and to protect the organization from potential private and government claims or investigations that...more
2023 was a busy year across several federal agencies in terms of issuing compliance guidance for corporations, including health care companies. For example, the Department of Justice (DOJ) issued significant compliance...more
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a...more
While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more
Hosted by American Conference Institute, the 11th Annual Advanced Forum on False Claims and Qui Tam Enforcement returns for another exciting year for lively discussions on FCA enforcement including the ramifications of two...more
The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management. The theoretical...more
Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...more
Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more
The U.S. Department of Justice (DOJ) announced significant new guidance on March 3, 2023, regarding the use of personal devices and the retention of corporate communications. The DOJ’s concern regarding the use of personal...more
Can a new Department of Justice enforcement approach make clawback policies covering criminal activities a best practice? The DOJ is implementing a new policy under which prosecutors will make clawback policies for...more