News & Analysis as of

White Collar Crimes Voluntary Disclosure Cooperation

BakerHostetler

7 More US Attorneys’ Offices Issue Whistleblower Non-Prosecution Pilot Programs

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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

Katten Muchin Rosenman LLP

Chicago United States Attorney's Office Launches Pilot Program to Encourage Self-Disclosure

On September 16, the US Attorney's Office for the Northern District of Illinois (NDIL) announced the launch of its Individual Self-Disclosure (ISD) Pilot Program. The program offers non-prosecution agreements to qualifying...more

WilmerHale

DOJ Rolls Out Corporate Whistleblower Pilot Program

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On August 1, 2024, the Department of Justice officially launched a three-year pilot program to reward whistleblowers who report corporate misconduct....more

Snell & Wilmer

The Department of Justice Offers Individual Corporate Wrongdoers a “Get Out of Jail Free Card” in New Voluntary Self-Disclosure...

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The Department of Justice’s Criminal Division (DOJ) recently announced a Pilot Program on Voluntary Self-Disclosures for Individuals (the Individual VSD Pilot Program or Pilot Program), which allows certain individuals...more

The Volkov Law Group

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

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On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more

Robinson & Cole LLP

Department of Justice Criminal Division Announces Voluntary Self-Disclosure Pilot Program for Culpable Individuals

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Last week, the Department of Justice (DOJ) announced the Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Program). Pursuant to the Program, “an individual who voluntarily self-discloses...more

Mintz

DOJ’s Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

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Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more

Venable LLP

DOJ Announces Pilot Program for Individual Voluntary Self-Disclosures

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On April 15, 2024, the Department of Justice (DOJ) criminal division announced a new pilot program designed to reward individuals with non-prosecution agreements (NPAs) who voluntarily self-disclose "actionable, original...more

BakerHostetler

DOJ’s Criminal Division Announces New Pilot Program onVoluntary Self-Disclosure for Individuals

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Under the newly announced pilot program, individuals who fully cooperate and voluntarily provide the Criminal Division with information on certain types of corporate and white-collar offenses may receive an NPA in exchange...more

Goodwin

In Continuing Efforts to Incentivize Self-Disclosures and Cooperation, DOJ Announces Pilot Program to Pay Criminal Whistleblowers

Goodwin on

Over the last few years, the U.S. Department of Justice (“DOJ”) has continuously announced significant policies and programs directed at encouraging and rewarding the timely reporting of corporate wrongdoing, incentivizing...more

Tucker Arensberg, P.C.

U.S. Department of Justice (DOJ) Provides Corporate Fraud Enforcement Update

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During the American Bar Association’s 39th National Institute on White Collar Crime, the most senior executives of the DOJ (Attorney General Merrick B. Garland and Deputy Attorney General Lisa Monaco) delivered remarks...more

Thomas Fox - Compliance Evangelist

Self-Disclosure is Now the Key

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

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

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2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

The Volkov Law Group

BIS Announces Further Enhancements to Voluntary Self-Disclosure Process

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On January 16, 2024, the U.S Department of Commerce’s Bureau of Industry and Security (“BIS”) released a series of enhancements to its existing voluntary self disclosure (“VSD”) program, pursuant to which organizations...more

Eversheds Sutherland (US) LLP

SDNY announces new whistleblower program, continuing Justice’s push for self-disclosure

“Call us before we call you.” With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in...more

Holland & Knight LLP

"Call Us Before We Call You": SDNY Announces Pilot Whistleblower Program

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The U.S. Attorney's Office for the Southern District of New York (SDNY) on Jan. 10, 2024, announced a Whistleblower Pilot Program (Program) that it is presenting as another "tool in [the SDNY's] toolkit" that could unearth...more

Troutman Pepper

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

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On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Wilson Sonsini Goodrich & Rosati

DOJ Releases New M&A Safe Harbor Policy: Key Takeaways for Deal Makers, Corporate Executives, and In-House Counsel

On October 4, 2023, Deputy Attorney General (AG) Lisa Monaco announced the U.S. Department of Justice’s (DOJ’s) new Mergers & Acquisitions Safe Harbor Policy for acquirers that uncover wrongdoing at a target company. Deputy...more

Robinson & Cole LLP

DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence

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On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more

Morgan Lewis

US Attorneys Emphasize Benefits of New Voluntary Self-Disclosure Policy

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Assistant Attorney General (AAG) Kenneth A. Polite Jr. of the US Department of Justice’s (DOJ’s) Criminal Division recently joined several high-profile, diverse US Attorneys at the inaugural Charlotte E. Ray Lecture and White...more

Barnea Jaffa Lande & Co.

Cooperating May Credit Corporations with Leniency in Enforcement

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

Williams Mullen

DOJ Implements Corporate Self-Disclosure Policy for Criminal Misconduct

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A new voluntary self-disclosure policy issued by the United States Department of Justice (DOJ) provides incentives for companies that voluntarily report criminal misconduct by their employees or agents....more

Cranfill Sumner LLP

DOJ Announces Sweeping Voluntary Corporate Self-Disclosure Policy

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In late February, the United States Attorneys for the Southern and Eastern Districts of New York announced a new “Voluntary Self-Disclosure Policy” (VSD Policy), effective immediately, that applies to all United States...more

Dorsey & Whitney LLP

Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

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On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more

Seward & Kissel LLP

DOJ Releases New Voluntary Self-Disclosure Policy

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On February 22, 2023, the Department of Justice (“DOJ”) released a new voluntary self-disclosure (“VSD”) policy (available here) that applies to all United States Attorney’s Offices (“USAO”). The policy details the...more

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