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White Collar Crimes Foreign Corrupt Practices Act (FCPA) Self-Reporting

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

Mintz - Health Care Viewpoints

DOJ Announces it is Designing a Whistleblower Rewards Program

In early March 2024 at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco’s keynote remarks previewed the development of new and significant Department of...more

Morrison & Foerster LLP

DOJ to Pay Whistleblowers

On March 7, 2024, during her keynote remarks at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new Department of Justice (DOJ) Criminal Division...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

Vinson & Elkins LLP

“Call Us Before We Call You”: SDNY Creates New Individual Self-Disclosure Program

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On January 10, 2024, the United States Attorney’s Office for the Southern District of New York (“SDNY”) introduced the SDNY Whistleblower Pilot Program (“Pilot Program”), aimed at encouraging individuals to disclose...more

Vinson & Elkins LLP

To Self-Report or Not to Self-Report: With New M&A Safe Harbor Policy, DOJ Tries to Answer the Question

Vinson & Elkins LLP on

It is one of the hardest questions a company can face: after discovering criminal conduct inside your company, do you self-report to the government or not? If you can quickly and quietly fix the problem, then you may be able...more

Sheppard Mullin Richter & Hampton LLP

“Sanctions Are The New FCPA”: DOJ Increases Focus on Sanctions and Export Control Enforcement

On March 2, 2023, Deputy Attorney General Lisa Monaco delivered remarks to the ABA’s National Institute on White Collar Crime. Unsurprisingly, her remarks focused heavily on inspiring a culture of compliance – including...more

Vinson & Elkins LLP

DOJ and SEC Stick Stericycle with a Two-Year Monitorship, Despite Acknowledgment of Extensive Remedial Measures

Vinson & Elkins LLP on

In yet another indication that the Biden administration is continuing to ramp up white collar enforcement, the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on April 20, 2022 that...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Emphasizes Transparency and Encourages Cooperation

In 2019, the Criminal Division of the U.S. Department of Justice (DOJ) continued its efforts, begun a few years prior, to enhance transparency with respect to the DOJ's prosecutorial decision-making. In public statements, DOJ...more

Jones Day

DOJ Policy Increases Incentives for Self-Reporting of Potentially Willful Trade Violations

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The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more

Foley & Lardner LLP

FCPA Notebook: Trends in 2019

Foley & Lardner LLP on

Foley & Lardner LLP’s International Government Enforcement Defense & Investigations team has created its latest FCPA infographic, which presents an overview of some high-level enforcement trends in an easy-to-view,...more

Butler Snow LLP

2019 Developments and Trends in the Foreign Corrupt Practices Act (FCPA) & Global Anti-Corruption Efforts, Part 2 of 3

Butler Snow LLP on

Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more

Latham & Watkins LLP

UK SFO Releases Guidance on Corporate Cooperation Credit

Latham & Watkins LLP on

Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations. On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action-Lessons Learned

We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more

Jones Day

CFTC Issues Advisory on Self-Reporting of Foreign Corrupt Practices for Non-Registrants

Jones Day on

The Advisory is part of the agency's broader commitment to provide "incentives for companies and individuals to engage in ethical corporate behavior." On March 6, 2019, the U.S. Commodity Futures Trading Commission...more

Jones Day

DOJ Loosens Prohibition on "Ephemeral Communications"; SEC Does Not

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The Situation: Most companies have faced challenges in finding the right balance between their information governance programs and their employees' use of technologies that do not permit retention of communications....more

A&O Shearman

DOJ Revises FCPA Corporate Enforcement Policy

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On March 8, 2019, the Department of Justice (“DOJ”) released a revised version of its FCPA Corporate Enforcement Policy (the “Policy”), which provides enforcement and practice guidance to DOJ prosecutors and was formally...more

Katten Muchin Rosenman LLP

Bridging the Week - March 2019 #2

Unexpectedly, the Commodity Futures Trading Commission announced a new initiative to encourage non-registrants to self-report foreign corrupt practices, which it claimed might also constitute violations of laws and rules it...more

A&O Shearman

CFTC Announces Further Incentives For Self-Reporting, Cooperation For Unregistered Individuals And Entities, While Highlighting...

A&O Shearman on

On March 6, 2019, the head of the U.S. Commodity Futures Trading Commission’s (“CFTC’s”) Enforcement Division, James McDonald, announced a new policy related to the benefits of self-reporting foreign corrupt practices-related...more

Stinson - Corporate & Securities Law Blog

CFTC Issues Advisory on Violations of the Commodity Exchange Act Involving Foreign Corrupt Practices

The CFTC announced an Enforcement Advisory on self-reporting and cooperation for violations of the Commodity Exchange Act, or CEA, involving foreign corrupt practices. ...more

Dechert LLP

CFTC Issues Enforcement Guidance to Encourage Self Reporting of FCPA Violations

Dechert LLP on

On March 6, 2019, the Commodity Futures Trading Commission (“CFTC”) published an Enforcement Advisory describing the circumstances in which companies that self-report violations of the Foreign Corrupt Practices Act (“FCPA”)...more

Jones Day

FCPA 2018 Year In Review

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Under the second year of the Trump Administration, the biggest story was the increase of corporate declinations one year after the DOJ adopted a permanent FCPA policy incentivizing self-disclosure, cooperation, and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Agencies Indicate Efficient, Targeted Enforcement Priorities That Rely on Self-Disclosure

One year into the Trump administration, it remains difficult to forecast what lies ahead with respect to regulatory and white collar enforcement activity. Perhaps most instructive are recent public statements of officials at...more

Bracewell LLP

DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations

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On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more

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