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DOJ Updates Guidance on Corporate Compliance with Focus on Data Analysis and Continuous Monitoring for Effectiveness

USA - June 22 2020 The revisions highlight the DOJ’s consideration of the unique circumstances of each company and the design and implementation of its compliance…

Brittany Pagnotta, Christopher H. Casey, Eric R. Breslin, George D. Niespolo.

DOJ Makes Clarifying Changes to FCPA Corporate Enforcement Policy

USA - December 2 2019 Since announcing the policy in November 2017, the DOJ has consistently moved towards greater incentives for companies to self-report misconduct…

Christopher H. Casey.

DOJ Criminal Division Issues Comprehensive Guidance on Evaluating Claims of Inability to Pay Criminal Fines or Penalties

USA - October 14 2019 As can be seen through a cursory review of the factors DOJ wants addressed, in most cases the road to establishing inability to pay may be difficult…

Christopher H. Casey, Rebecca S. Ruffer.

In Major Shift, DOJ Antitrust Division Now Credits Compliance Programs at the Charging Stage

USA - July 31 2019 Assistant Attorney General Makan Delrahim stated that it is time for the Antitrust Division to “recognize the efforts of companies that invest…

Christopher H. Casey.