Compliance Stuff

  On June 10, the head of the US Department of Justice’s (DOJ) Criminal Division, Matthew R. Galeotti, gave a speech before the American Conference Institute (ACI) outlining the DOJ’s white-collar enforcement priorities. Galeotti’s remarks follow the DOJ’s recent revisions to the Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP).   Read our previous alert about the CEP  here .   Galeotti emphasized that if defense counsel representing companies under investigation “do the right thing, report potential crimes, root out misconduct, cooperate with the [DOJ], and help the company remediate ,” then the company will receive “significant benefits.” He highlighted three key points: Companies that “voluntarily self-report, cooperate, and remediate” fraud and other white-collar offenses will receive a declination — not just a “presumption” of declination — unless there are aggravating factors . Galeotti said that he would personally scrutinize ...

 On May 12, Matthew R. Galeotti, the head of the US Department of Justice’s (DOJ) Criminal Division, announced a new white collar enforcement plan, outlined changes to the Corporate Enforcement and Voluntary Disclosure Policy, and added new priority areas to the Corporate Whistleblower Awards Pilot Program Policy . The DOJ also introduced a new corporate monitor selection policy. Below, we highlight what to know about the new White Collar Enforcement Plan and the revised Corporate Whistleblower Awards Pilot Program Policy and what actions you can take today.  Below, we highlight what to know about the new White Collar Enforcement Plan and the revised Corporate Whistleblower Awards Pilot Program Policy and what actions you can take today. What to Know The plan underscores the US government’s “America First” priorities. Foreign organizations may be at increased enforcement risk. The DOJ is committed to investigating and prosecuting bribery, despite the temporary Foreign Corrupt ...