Posts Tagged ‘Justice Department’
No, the FCPA Is Not ‘Back’
Folks, we need to have a conversation about all these legal bulletins, marketing emails, and conference agendas declaring that enforcement of the Foreign Corrupt Practices is now somehow “back,” simply because the Justice Department released guidelines the other week explaining how it will consider FCPA enforcement from here forward. Snap out of it. FCPA enforcement…
Read MoreThe New FCPA Era Arrives
Well, the Justice Department has published its much-anticipated guidelines for future enforcement of the Foreign Corrupt Practices Act — and honestly, they’re a bit anticlimactic. Nothing in the new policies should surprise anyone who’s been paying attention, and nothing in them should change your compliance program all that much. The policy changes came in two…
Read MoreJustice Dept. Promises More Declinations
The Justice Department has announced new, more relaxed policies for when it will prosecute corporate crime, promising “a clear path to declination” that bypasses the criminal resolution process entirely for companies that self-disclose and remediate their misconduct. Matthew Galeotti, acting head of the Criminal Division at the Justice Department, announced the new policy in a…
Read MoreDOJ Monitorship Policy Disappears
The Justice Department has pulled down its policy statement on when compliance monitors will be assigned as part of corporate misconduct resolutions, which seems as good a reason as any to catch up on all the news swirling around compliance monitorships these days. The Justice Department had previously posted its policy on monitorships on the…
Read MoreJustice Department Policy Changes, Part II
We now have more clarity on attorney general Pam Bondi’s plan to overhaul Justice Department enforcement priorities — and yes, it’s going to be a big retreat from holding corporations accountable for certain types of misconduct, while the department spends more time prosecuting drug cartels, illegal aliens, and organizations with DEI programs. Bondi first announced…
Read MoreNew AG Signals FCPA Retreat
Well that didn’t take long: on the same day that Pam Bondi was sworn in as the next U.S. attorney general, Bondi issued a flurry of policy memos that will have the practical effect of taking several big steps back from enforcement of corporate misconduct laws. Bondi arrived at the Justice Department on Wednesday afternoon…
Read MoreAAR Settles Intriguing FCPA Case
Here’s a Christmas present for compliance professionals! AAR Corp., an aviation services company, has agreed to pay $55.6 million to settle civil and criminal charges that the company bribed government officials in Nepal and South Africa in the 2010s — and is giving the rest of us some points to ponder on Justice Department credit…
Read MoreCompliance Program Priorities That Endure
’Tis the season for speeches from Justice Department officials, as they reflect on the year’s enforcement activity — and these days, try to establish some sense of continuity even as the incoming Trump Administration portends a very different approach to corporate compliance and regulatory enforcement. Which brings us to a Justice Department speech delivered late…
Read MoreFour Reasons to Watch the Adani Case
Sometimes a tale of corporate corruption comes along that perfectly captures all the issues that ethics and compliance professionals face in our line of work. Such is the case with the Adani Group, and compliance officers everywhere should watch it closely; it could be a hugely telling case for corruption enforcement in 2025. By now…
Read MoreCorporate Enforcement Policy Tweaked Again
The Justice Department is relaxing its approach to corporate criminal enforcement yet again, this time giving companies a bit more breathing room for what counts as “self-disclosure” and “significant profit” — all to further entice companies to step forward and admit legal violations, so that those violations can be resolved more quickly. Nicole Argentieri, deputy…
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