Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review
Extraterritoriality — RICO Report Podcast
Fintech Focus Podcast | Sanctions Compliance: Regulators Set Their Sights on Fintechs
Sanctions Compliance: Regulators Set Their Sights on Fintechs
The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger
Episode 340: DOJ Updates Evaluation of Corporate Compliance Programs
Public-Private Partnerships to Stem Corruption
Navigating Compliance in Government Contracts: Insights from SEC and DOJ Perspectives
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
The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement — the company has...more
In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to...more
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
DOJ has been on a public relations campaign to push a simple message for corporations: if companies learn of misconduct, companies should disclose such misconduct to earn valuable benefits. The quintessential question...more
We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more
On February 13, the U.S. Attorney’s Office (USAO) for the Southern District of New York (SDNY) announced a pilot program through which whistleblowers who voluntarily self-disclose criminal conduct relating to public or...more
The Department of Justice (DOJ) has been making significant strides in emphasizing the importance of voluntary self-disclosure in corporate enforcement cases, particularly in the realm of the Foreign Corrupt Practices Act...more
On January 10, 2024, US Attorney for the Southern District of New York (“SDNY”) Damian Williams introduced a whistleblower pilot program targeting corporate crime, bribery and theft of government funds (the “SDNY...more
Last September, US Deputy Attorney General Lisa Monaco issued a memorandum instructing the various departments in the Department of Justice to adopt a lenient enforcement policy toward corporations. The aim of this policy is...more
The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation. The Golden Ring for every company facing...more
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more
On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more
White collar practitioners Neil Smith, William Semins, Nicole Stockey, and David Peet discuss their key takeaways from this year’s 37th International Conference on the Foreign Corrupt Practices Act....more
In this episode, we examine how two criminal defendants are aiming to leverage parallel FCPA investigations by the SEC and the DOJ to build their defense. We’ll also offer our thoughts on the SEC’s new (and improved?)...more
A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more
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
Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more
In a recently released letter, the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to...more
How should a compliance practitioner use the information from these three Foreign Corrupt Practices Act (FCPA) enforcement actions going forward? Do the differing results in these three enforcement actions (Dun & Bradstreet...more
The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations. How is that for a profound grasp of the obvious?...more
The Justice Department recently resolved two separate FCPA investigations under its Pilot Program. To be sure, DOJ’s resolution of these two matters reinforces the real and tangible benefits of its Pilot Program....more
Last week the Department of Justice (DOJ) issued its second Declination under the Sessions regime. Short with brevity, the matter nonetheless has some significant points for the compliance practitioner to help move their...more
This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian meatpacker JBS agrees to the largest fine ever for fine for bribery and corruption, $3.2bn...more
When speaking to clients or potential clients, the question of risk of enforcement is the moose on the table. Sometimes, the question gets asked and other times, the subject is never discussed. To be fair, it is not an easy...more