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January 18, 2024
A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you.  I know I am scratching my head trying to make sense of the whole picture here.  There are a...
January 12, 2024
The Justice Department’s FCPA enforcement record for 2024 was slow.  This  trend was unexpected, contrary to my own predictions and of various other prognosticators.  It is hard to...
March 3, 2023
The Justice Department is on a marketing campaign – pushing a simple message.  If your company commits misconduct, come in and confess to the Justice Department.  To push this message,...
February 24, 2023
Key Takeaways- On February 22, 2023, the U.S. Department of Justice (DOJ) announced a new corporate voluntary self-disclosure (VSD) policy applicable to all 94 U.S. Attorney’s...
February 6, 2023
Whenever a company detects criminal misconduct, it is faced with the difficult decision of whether to self-disclose the misconduct to the federal government. In an attempt to help nudge...
November 1, 2022
The Department of Justice and many regulatory agencies have rolled out the red carpet for companies to cross the threshold and voluntarily disclose criminal conduct in the hopes of...
October 4, 2022
In a coordinated set of speeches this month, Deputy Attorney General Lisa Monaco and two of her top staff – Principal Associate DAG Marshall Miller and Criminal Division head Kenneth Polite...
September 30, 2022
The Justice Department is putting every business on notice — aggressive white collar criminal enforcement is here to stay. In a one-two punch, Deputy Attorney General Lisa Monaco...
September 26, 2022
Today, we conclude our exploration of the Monaco Memo by considering what all this may mean for compliance professional going forward. Department of Justice (DOJ) officials have...
March 31, 2022
Without fanfare, DOJ recently published a “declination and disgorgement letter,” the first FCPA declination published by the Department since August 2020. As disclosed...