All Voluntary Self-Disclosure articles
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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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News BriefHealthSun Health Plans earns DOJ declination in employee fraud case
The impact of the Department of Justice’s voluntary self-disclosure program was on display in the agency’s declination of an enforcement action against Florida-based health insurance company HealthSun Health Plans for apparent fraud committed by its employees and agents.
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PremiumDOJ floats declinations as incentive under M&A self-disclosure safe harbor
The Department of Justice’s push to incentivize companies to voluntarily self-disclose potential misconduct reached its next stage in the form of a safe harbor policy regarding mergers and acquisitions.
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PremiumDOJ official: Compliance must have ‘prominent seat’ at M&A decision table
The Department of Justice is gearing up to provide more guidance on voluntary self-disclosures in the mergers and acquisitions space and the role compliance should play.
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News BriefGuidance sets self-disclosure expectations for sanctions, export control lapses
Companies seeking credit for voluntarily self-disclosing potential violations of sanctions or export control laws must be mindful of the regimes at play from agencies including the DOJ, BIS, and OFAC and their differing expectations.
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PremiumPotential sanctions violations: To voluntarily self-disclose or not?
The Department of Justice scrutinizing sanctions on par with how it views bribery under the Foreign Corrupt Practices Act alters the calculus of whether a company should voluntarily self-disclose potential violations, experts discussed at CW’s TPRM Summit.
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News BriefBIS updates voluntary self-disclosure policy to punish not coming forward
The Commerce Department’s Bureau of Industry and Security updated its guidelines to further clarify the advantages of voluntary self-disclosure to the agency when export control violations are uncovered.
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News BriefPolite: Look to ABB case for ‘extraordinary cooperation’ example
Compliance officers seeking clarity on what the Department of Justice means by “extraordinary” cooperation or “immediate” self-disclosure should look to the agency’s case history, said Assistant Attorney General Kenneth Polite Jr. during a speech.
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News BriefDOJ declines to prosecute Corsa Coal in FCPA case
Corsa Coal Corp. was notified by the Department of Justice it won’t face prosecution for alleged bribes employees paid to Egypt’s Al Nasr Company for Coke and Chemicals to secure coal supply contracts.
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News BriefDOJ to implement new clawback, compensation policies for corporate settlements
Corporate resolutions involving the Department of Justice’s Criminal Division will now include a requirement the resolving company develop compliance-promoting criteria within its compensation and bonus system, according to Deputy Attorney General Lisa Monaco.
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News BriefStanley Black & Decker discloses potential FCPA violations
Stanley Black & Decker voluntarily disclosed to the Department of Justice and Securities and Exchange Commission its international division might have violated the Foreign Corrupt Practices Act.
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ArticleDOJ to emphasize individual accountability, prior misconduct in corporate crime probes
Deputy Attorney General Lisa Monaco announced sweeping changes to the Department of Justice’s efforts to fight corporate crime, including new guidance regarding individual accountability, voluntary self-disclosure, compliance monitors, and ways to strengthen compliance culture.