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White Collar Crimes Self-Disclosure Requirements Federal Sentencing Guidelines

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 4: The Fines: Self-Disclose, Self-Disclose, Self-Disclose

We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more

Jones Day

DOJ Announces New Voluntary Self-Disclosure Policy for All U.S. Attorneys' Offices

Jones Day on

On February 22, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced the Voluntary Self-Disclosure Policy ("VSD Policy" or "Policy"), detailing the circumstances under which a company can receive credit for...more

Beveridge & Diamond PC

DOJ Implements Nationwide “Voluntary Self-Disclosure” Program: All U.S. Attorneys’ Offices Instructed to Follow Updated Corporate...

The U.S. Department of Justice (DOJ) formally implemented a nationwide Voluntary Self-Disclosure policy (VSD policy) on February 22, 2023—effective immediately—that has been in the works for several years. The VSD policy...more

Jenner & Block

Client Alert: DOJ Expands the Reach of Its Policies on Self-Disclosure of Corporate Misconduct

Jenner & Block on

On February 22, 2023, the Department of Justice announced a new Voluntary Self-Disclosure Policy (the Disclosure Policy) that now governs corporate prosecutions by US Attorney’s Offices (USAOs) nationwide. Building on a 2022...more

Ballard Spahr LLP

DOJ's Revisions to the Corporate Enforcement Policy Incentivize Self-Reporting of Misconduct

Ballard Spahr LLP on

Summary - The Department of Justice (DOJ) last week issued revisions to the Criminal Division’s Corporate Enforcement Policy that incentivize companies to promptly self-disclose corporate misconduct, cooperate with the DOJ,...more

Holland & Knight LLP

DOJ Makes Significant Revisions to Corporate Enforcement Policy

Holland & Knight LLP on

The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

Ruder Ware on

By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

Alston & Bird

Government & Internal Investigations Advisory: DOJ’s New FCPA Pilot Program Provides Roadmap for “Cooperation”

Alston & Bird on

The Department of Justice (DOJ) on April 5 announced a new, one-year pilot program for companies to self-report Foreign Corrupt Practices Act (FCPA) violations. The announcement comes amid other increased FCPA enforcement...more

Pillsbury Winthrop Shaw Pittman LLP

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

Parker Poe Adams & Bernstein LLP

Is Confession Good for the Corporate Soul?: DOJ announces new mitigation credit for self-disclosure of FCPA violations

On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more

WilmerHale

DOJ Launches FCPA Pilot Program to Encourage Corporate Voluntary Disclosure and Cooperation

WilmerHale on

On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more

Foley & Lardner LLP

DOJ Fraud Section Offers Super Credit in FCPA Pilot Program

Foley & Lardner LLP on

This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more

BCLP

DOJ’s “Half Off” Deals for Self-Reporting FCPA Misconduct: Certain Exclusions Apply, See Below for Details

BCLP on

For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more

Proskauer - Corporate Defense and Disputes

Criminal Division Launches New FCPA Pilot Program

On April 5, 2016, the Department of Justice upped the ante in its efforts to encourage companies to self-report potential Foreign Corrupt Practices Act (“FCPA”) violations when it unveiled a one-year pilot program that...more

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