extraordinary cooperation Archives - Corruption, Crime & Compliance

30 Jan, 2023

Justice Department Tweaks Corporate Enforcement Policy to Entice More Corporate Voluntary Disclosures

The Department of Justice announced revisions to its Corporate Enforcement Policy (“CEP”) yet again in order to promote voluntary disclosures by Companies that discover potential wrongdoing. DOJ’s latest action demonstrated its commitment to several ideas: (1) Increasing prosecution of individual wrongdoers; (2) Offering benefits to companies to encourage self-reporting, cooperation and remediation; (3) Reducing the burdens on corporate shareholders from large fines and penalties that...

General

7 Dec, 2022

Lessons Learned and the Big Picture: ABB – the Three-Time Loser – Settles Yet Another FCPA Case (Part III of III)

The ABB case, like most significant FCPA enforcement actions, sets important precedent and policy reminders. With time, and looking back, ABB gives companies with a prior criminal history a way forward to seek a fair resolution notwithstanding huge obstacles based on past performance. If you are ABB, you dodged a significant bullet – the appointment of an independent compliance monitor, which DOJ has been regularly...