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White Collar Crimes Foreign Corrupt Practices Act (FCPA) Federal Pilot Programs

McCarter & English Blog: Government Contracts...

A New Frontier in Corporate Accountability: The DOJ’s Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice (DOJ) Criminal Division introduced its Corporate Whistleblower Awards Pilot Program (Program), which, like a modern-day Western posse, aims to bring justice to the wild frontier...more

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

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In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more

Womble Bond Dickinson

DOJ Debuts Pilot Corporate Whistleblower Awards Program

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The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...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

McCarter & English, LLP

DOJ Launches Pilot Program to Encourage Reporting of Criminal Activity

The Department of Justice (DOJ) has announced a pilot program to encourage potential whistleblowers to report criminal activity and cooperate with government investigations in exchange for substantial monetary payouts in the...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

Nelson Mullins Riley & Scarborough LLP

Bringing Moths to the Flame: DOJ Promises Non-Prosecution to Execs for Tips to Combat Corporate Crime

Recently, the Department of Justice (DOJ) Criminal Division launched a pilot program promising “mandatory NPAs to incentivize individuals (and their counsel) to provide original and actionable information.” This most recent...more

Proskauer - Whistleblower Defense

DOJ Announces Development of a Pilot Whistleblower Rewards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco announced that the U.S. Department of Justice (“DOJ”) is creating a pilot whistleblower rewards program, which will be developed and implemented over the next 90 days,...more

BakerHostetler

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

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Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more

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

DOJ Official Cites Old West ‘WANTED’ Posters in Announcement of New Whistleblower Monetary Awards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

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At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

WilmerHale

DOJ Announces Pilot Whistleblower Rewards Program and Increased AI Enforcement

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On March 7, 2024, Deputy Attorney General Lisa Monaco announced Department of Justice (DOJ) initiatives to incentivize whistleblowers with payouts from civil or criminal forfeitures and to integrate artificial intelligence...more

Littler

Proper Planning and Swift Action Can Help Employers Avoid Foreign Corrupt Practices Act Prosecution

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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

Thomas Fox - Compliance Evangelist

Farewell to Robbie Robertson and a Welcomed District Court Decision in the FCPA World

Robbie Robertson died this week. He was the lead songwriter and one of the five members of a rock and roll group that was so impactful, it was simply known as The Band. Robertson came from Canada but wrote in a genre which is...more

Goodwin

DOJ Announces Nationwide Voluntary Corporate Self-Disclosure Policy in Effort to Standardize and Incentivize Timely Self-Reporting

Goodwin on

On February 22, 2023, the US Department of Justice (DOJ) announced a Voluntary Self-Disclosure Policy (VSD Policy) to formalize DOJ’s efforts to incentivize companies to voluntarily self-report criminal misconduct to the...more

Thomas Fox - Compliance Evangelist

HorrorFest 2019 Celebration – The Films of Val Lewton and Role of the Compliance Function

In the 2017 FCPA Corporate Enforcement Policy, the Department of Justice (DOJ) listed the following factors relating to a corporate compliance function, that it would consider as indicia of an effective compliance and ethics...more

The Volkov Law Group

DOJ Expands FCPA Corporate Enforcement Policy

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The Justice Department’s FCPA Corporate Enforcement Policy was announced in November 2017 with much fanfare – it was the culmination of a step-by-step process beginning with the FCPA Pilot Program....more

Thomas Fox - Compliance Evangelist

Evolution of Best Practices – Part I

Perhaps the most consistent process in the compliance field is its evolution. Compliance programs began in response to the US Sentencing Guidelines for Corporations back in 1992....more

A&O Shearman

DOJ Announces Intent To Apply Principles From FCPA Corporate Enforcement Policy To Other White Collar Contexts

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At the recent American Bar Association’s National Institute on White Collar Crime, the Department of Justice’s (“DOJ”) Acting Head of the Criminal Division, John Cronan, announced that the Criminal Division will use the FCPA...more

BakerHostetler

Foreign Corrupt Practices Act 2017 Year-End Update

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2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more

Parker Poe Adams & Bernstein LLP

Digging Into the Details of New FCPA Guidance From the U.S. Justice Department

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

Holland & Knight LLP

2017, We Hardly Knew You: A Look Ahead to 2018

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Taking over as editors of Holland & Knight’s Government Contracts Blog has been a labor, but it has been a labor of love. Like the rest of the Government Contracts Team, we are passionate about staying on top of the latest...more

Farella Braun + Martel LLP

FCPA in the Trump DOJ: Continuing Down the Same Path, with a Little More Heft

Next week marks the 40th anniversary of the Foreign Corrupt Practices Act – it became effective December 19, 1977. Deputy Attorney General Rod Rosenstein marked the occasion this month by providing an update on the FCPA Pilot...more

Williams Mullen

The DOJ’s Revised FCPA Corporate Enforcement Policy: A New Blueprint for Corporate Cooperation and Credit

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On November 29, 2017, Deputy Attorney General Rod Rosenstein announced the issuance of a revised FCPA Corporate Enforcement Policy (the “Policy”). Rosenstein announced that the “new policy enables the Department [of Justice]...more

Blank Rome LLP

DOJ Incorporates FCPA Pilot Program into U.S. Attorneys' Manual Providing Permanent Incentives for Strong FCPA Compliance

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Action Item: The U.S. Department of Justice (“DOJ”) recently included the principles of its Foreign Corrupt Practices Act (“FCPA”) Pilot Program into the U.S. Attorneys’ Manual (“USAM”), and reinforced its message to...more

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