In a series of key policy announcements between November 2017 and May 2018, the Department of Justice has demonstrated an increasingly coherent perspective on how it will handle key aspects of white collar criminal enforcement. The policies largely reiterate a message federal prosecutors have delivered for years regarding what they want to see from companies… Continue Reading
In April 2016, the Department of Justice (DOJ) announced its Foreign Corrupt Practices Act Enforcement Plan and Guidance, which includes a one-year pilot program to incentivize individuals and companies to voluntarily self-disclose Foreign Corrupt Practices Act-related (FCPA) misconduct, cooperate with DOJ investigations and remediate controls and compliance programs. Under the guidance, the DOJ may extend… Continue Reading
For at least the second time in recent weeks, the Justice Department’s criminal division chief delivered lengthy public remarks on what the department expects from companies choosing to cooperate with federal investigators. In a speech at the New York Bar Association’s Fourth Annual White Collar Crime Institute last week, Assistant Attorney General Leslie Caldwell returned… Continue Reading
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