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FCPA Blog Daily News

Entries in Yates Memo (20)

Monday
Dec192016

Rebecca Gantt: Looking for clues about the future of the Pilot Program

Last April, the DOJ's Criminal Division launched the one-year Pilot Program. The remaining four months of the Pilot Program promise to provide valuable information on several fronts.

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Monday
Oct312016

Brackett and Neale: Enforcement Innovations for the Post-Yates Environment

During a recent webinar sponsored by the Washington Legal Foundation, we explored the impacts intensive individual-focused criminal enforcement can have on an industry, using the recent history of criminal enforcement of food safety laws as a case study. 

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Monday
Sep192016

Mike Scher: Three questions for Wells Fargo

Employees at Wells Fargo opened about two million deposit and credit card accounts that customers didn't authorize. Why? To earn incentive compensation for new accounts.

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Monday
Aug222016

When It Absolutely, Positively Has to Be Indicted Overnight: How to Prevent Future Debacles Like the FedEx Prosecution

Against the backdrop of years of unprecedented monetary penalties imposed through DOJ civil settlements and deferred prosecution agreements with financial institutions embroiled in the 2008 financial meltdown, the DOJ came under withering criticism for perceptibly treating scrutinized corporations simply as cash cows rather than addressing the actual criminal conduct of the corporations and their executives.

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Thursday
Jun232016

The Analogic Settlement: What's behind the issue of cooperation credit?

As reported by the FCPA Blog Tuesday, the SEC and DOJ entered into parallel resolutions with Analogic Corporation and Analogic's wholly-owned Danish subsidiary BK Medical ApS in connection with violations of the books and records and accounting controls provisions of the FCPA.

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Wednesday
Jun012016

U.S. Chamber: ‘Yates Memo could lead to more enforcement abuses’

The Institute for Legal Reform -- part of the U.S. Chamber of Commerce -- issued a paper last week with a harsh review of the Yates Memo, also known as the DOJ's Individual Accountability Policy

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Wednesday
May182016

Joseph Spinelli: Yes, the Yates Memo is a watershed event

Career prosecutor and current Deputy AG Sally Yates authored one the most important DOJ policy papers in decades -- the Yates Memo, also known as the DOJ's Individual Accountability Policy.

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Wednesday
May112016

Yates Speaks: Prosecuting individuals is really hard, so companies need to come clean

Deputy Attorney General Sally Q. Yates spoke Tuesday to the New York City Bar Association White Collar Crime Conference. Her topic? That's right. The Yates Memo, more formally known as the DOJ's Individual Accountability Policy.

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Thursday
Apr072016

The DOJ Pilot Program: Financial considerations for both companies and their executives

The DOJ Fraud Section’s recently released FCPA Enforcement Plan and Guidance outlines a novel one-year pilot program for corporate self-reporting and cooperation, with specific fine reduction incentives.

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Tuesday
Apr052016

DOJ launches FCPA self-reporting pilot program with new guidance

Assistant Attorney General Leslie R. CaldwellAssistant Attorney General Leslie Caldwell announced a one-year pilot program Tuesday intended to encourage companies to self report FCPA offenses and cooperate with the Justice Department.

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Tuesday
Apr052016

Save the Date: Panel discussion about the Yates Memo (Chicago - April 14)

The American Bar Association's 2016 Section of Litigation Annual Conference happens on April 13 - 16 in Chicago. One event during the conference will be a panel discussion called A Price on their Heads: The DOJ’s Yates Memo and the Future of Corporate Investigations.

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Friday
Mar182016

Worth MacMurray: You’re the new compliance chief. Now what?

Heads up: The six-month anniversary in your new position will arrive in a flash. 

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