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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...
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...
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,...
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...
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...