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DOJ Criminal Division Announces Pilot Program Targeting Corporate Compensation Arrangements

USA - March 9 2023 Last week, the Department of Justice (“DOJ”) announced a Compensation Incentives and Clawbacks Pilot Program (the “Pilot Program” or “Program”) that…

Andrew S. Boutros, Vincent H. Cohen, Jr, David N. Kelley, Andrew J. Levander, Jonathan R. Streeter

U.S. Department of Justice Issues Nationwide Corporate Self-Disclosure Policy for the 94 United States Attorney’s Offices

USA - February 23 2023 Earlier this week, the United States Attorneys for the Southern and Eastern Districts of New York announced the implementation of a new nationwide…

Andrew S. Boutros, Lindsey B. Cohan, David N. Kelley, Andrew J. Levander, Jonathan R. Streeter

“More Cooperation Please”: DOJ Revises Corporate Enforcement Policy to Encourage Even Greater Cooperation

USA - January 20 2023 This week the DOJ published revisions to its Corporate Enforcement Policy designed to further encourage companies to make voluntary self-disclosures…

Andrew S. Boutros, Vincent H. Cohen, Jr, David N. Kelley, Andrew J. Levander, Jonathan R. Streeter

Don’t Trade on Me: Second Circuit Excludes Confidential Agency Information From the Definition of “Property” in Insider Trading Case

USA - January 17 2023 A divided panel of the U.S. Court of Appeals for the Second Circuit held, on December 27, 2022, in United States v. Blaszczak (“Blaszczak II”) that…

Roger A Burlingame, Steven A. Engel, Andrew J. Levander, Michael H. McGinley, Jonathan R. Streeter

Third Circuit Rejects Use Of “Intended Loss” as Enhancement Under U.S. Sentencing Guidelines

USA - December 1 2022 In United States v. Banks, the defendant filed an appeal to the Third Circuit after he was convicted by a jury of wire fraud and sentenced to over…

Brian Kulp, Clare Putnam Pozos, Andrew S. Boutros, Roger A Burlingame, Michael H. McGinley