DOJ voluntary disclosure Archives - Corruption, Crime & Compliance

3 Mar, 2024

Episode 311: Tom Fox on FCPA Enforcement — DOJ’s Approach to Recidivism and Self-Disclosure

In this special episode of Corruption, Crime, and Compliance, Michael Volkov joins colleague and long-time friend Tom Fox as they delve into the intricacies of recent FCPA enforcement actions, shedding light on the evolving landscape of corporate compliance. From the ABB case to the SAP settlement, Michael and Tom dissect the nuances of voluntary disclosure, extensive remediation, and the shifting priorities of the Department of...

General

28 Apr, 2023

BIS Clarifies Approach to Export Enforcement Concerning Voluntary Self Disclosures and Reporting of Third Party Misconduct under Guise of “Policy Clarifications”

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for an important posting on policy clarifications issued by the BIS Office of Export Enforcement. Alex can be reached at [email protected]. On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) released a set of “policy clarifications” in the context of a memorandum authored...

General

5 May, 2021

SAP’s Comprehensive Export Control and Sanctions Settlement – A New Compliance Frontier for Cloud-Based Services (Part III of IV)

The Justice Department’s National Security Division used the SAP comprehensive settlement of export control and sanctions violations to send a message – a loud and clear one. As the first real flexing of its Business Organizations Corporate Enforcement policy, the Justice Department underscored that companies that voluntarily disclose illegal conduct, fully cooperate, and implement timely and robust remediation will earn a non-prosecution agreement or deferred...

General

29 Jan, 2020

DOJ Announces Voluntary Disclosure Program for Criminal Export and Sanctions Violations

The Justice Department is often criticized for its lack of transparency. But when it comes to policy changes or initiatives, DOJ is more than transparent – DOJ always tells the public what it plans to do and then does it. When people act surprised about a policy initiative or a DOJ announcement or speech on a subject, they simply failed to read DOJ’s statements or...