Corporate Enforcement Policy
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First-ever DOJ-wide corporate enforcement policy announced
The new policy supersedes the existing patchwork of voluntary self-disclosure policies, replacing them with a framework applicable across the DOJ.
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SDNY’s new corporate enforcement policy charts path to declination
SDNY said after a company self-reports, it will issue a conditional letter stating intent to decline prosecution, if certain criteria are met.
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Millicom settles FCPA charges, receives reduced penalty
Millicom received a 50% discount on the possible criminal penalty it was facing, thanks to its extensive cooperation and remediation efforts.
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Podcast: Sandra Moser and John Pease walk us through DOJ’s Corporate Enforcement Policy
Moser and Pease talk about a corporate enforcement and voluntary self-disclosure policy that has seen a variety of iterations through several administrations.
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Podcast: Andrew McBride on the FCPA, compliance, and cooperating with government
Julie DiMauro spoke to the founder and CEO of Integrity Bridge, and former Chief Risk & Compliance Officer of Albemarle Corporation.
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DOJ relaxed its approach to corporate criminal enforcement (again)
Citing a need for transparency in the DOJ’s corporate criminal enforcement efforts, Deputy AG Argentieri outlined some tweaks to the agency’s Corporate Enforcement Policy.
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RTX sets aside $1.24 billion to resolve probes involving bribery, export controls
US weapons maker required to retain independent compliance monitors over the three-year term of the agreements.
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Merck KGaA subsidiary nabs first-of-its-kind declination letter from DOJ
The DOJ said the business proactively disclosed information about a scheme by an insider and others to export sensitive biochemicals to China.