All Nicole Argentieri articles
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PremiumDOJ eyeing more FCPA cases with whistleblower program
The Department of Justice anticipates its upcoming whistleblower reward program will help the agency increase its pipeline of cases involving apparent violations of the Foreign Corrupt Practices Act, said Acting Assistant Attorney General Nicole Argentieri.
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PremiumThe path to DOJ cooperation credit: Analyzing recent FCPA cases
Recent enforcement actions offer guidance on what the Department of Justice considers to be an “imminent threat” of disclosure or government action, what it means by “prompt” disclosure, and how a company can earn credit for revealing all relevant facts.
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OpinionTen things I’d like to see happen in 2024
Election years in the United States, United Kingdom, and at European Parliament, along with ongoing geopolitical tensions, make 2024 difficult to predict—aside from the expectation compliance officers will be busy.
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PremiumFive compliance triumphs from 2023
A financial services giant’s compliance mea culpa that could serve to benefit the rest of the profession, a chemical company’s praised FCPA settlement, and an example of the value of whistleblowers highlight CW’s annual list of laudable ethics and compliance moments.
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PremiumDOJ official: Agency to ‘double down’ on data analytics efforts
The Department of Justice is upping its game regarding its use of data analytics to identify potential misconduct, and it expects companies to be doing the same.
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PremiumDOJ cooperation credit breakdowns: Albemarle, Tysers, H.W. Wood
Nicole Argentieri, acting head of the Department of Justice’s Criminal Division, breaks down where Albemarle, Tysers Insurance Brokers, and H.W. Wood went right—and wrong—on the cooperation credit and remediation fronts as part of their FCPA settlements with the agency.
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News BriefDOJ announces international anti-bribery initiative
The Department of Justice will increase its efforts to build relationships and foster collaboration with its global counterparts to thwart bribery and corruption under a new strategy.
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PremiumOne company’s voluntary self-disclosure, two companies’ FCPA settlements
Nicole Argentieri, acting head of the Department of Justice’s Criminal Division, explained how the actions of Jardine Lloyd Thompson Group Holdings coming forward helped bring about the agency’s recent FCPA enforcements against Tysers Insurance Brokers and H.W. Wood.
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OpinionIncentive policies suggest calm before storm at DOJ
All the carrots being offered by the Department of Justice in the past year—greater penalty reduction thresholds, relief related to compensation clawbacks, voluntary self-disclosure incentives—are part of a strategy to strengthen the enforcement stick when companies don’t cooperate.
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ArticleDOJ official hints at policy changes for off-channel communications, clawbacks
The Department of Justice is considering issuing new guidance regarding companies’ record-keeping obligations for employees’ use of personal cell phones to conduct corporate business, as well as executive compensation clawback policies.