In a May 12, 2025, memorandum (the May Memorandum) on focus, fairness and efficiency in the fight against white collar crime, the Department of Justice (DOJ) Criminal Division1 again identified the total elimination of...more
Revisions to Department of Justice (DOJ) white collar enforcement policies provide enhanced incentives for voluntary self-disclosure and clarify the consequences of failing to disclose wrongdoing. At the same time, expanded...more
5/16/2025
/ Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Institutions ,
Non-Prosecution Agreements ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA...more
2/13/2025
/ Anti-Corruption ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
On 6 November 2024, the UK government published its guidance on the new ‘failure to prevent fraud’ offence, which was introduced in the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023).1 We covered the details...more
On September 23, 2024, the U.S. Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP) guidance. First published in 2017, the ECCP sets out factors that DOJ Criminal Division prosecutors...more
When the UK Modern Slavery Act 2015 (Act) came into force, it was considered a landmark legal development globally. The UK was one of the first jurisdictions to introduce a legal requirement concerning transparency in supply...more
9/19/2024
/ Anti-Corruption ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Human Rights ,
Human Trafficking ,
International Trade ,
Modern Slavery Act ,
Reporting Requirements ,
Supply Chain ,
Transparency ,
UK ,
White Collar Crimes
The UK government introduced a major overhaul of its framework for addressing financial crime — and brought into force numerous significant changes — when the Economic Crime and Corporate Transparency Act 2023 (the Act)...more
9/12/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Enforcement Actions ,
EU ,
Failure to Prevent ,
Financial Crimes ,
Fraud ,
Strict Liability ,
UK ,
White Collar Crimes
In Nuctech Warsaw (T-284/24), the EU Court of Justice held that EU subsidiaries can lawfully be required to provide access to email accounts and data held by their overseas parent company. The ruling involved the following...more
8/26/2024
/ Appeals ,
Commercial Litigation ,
Corporate Counsel ,
Corporate Governance ,
Enforcement Actions ,
EU ,
European Commission ,
European Court of Justice (ECJ) ,
Extraterritoriality Rules ,
Foreign Corporations ,
Popular ,
Privacy Laws ,
UK ,
White Collar Crimes
On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more
8/6/2024
/ Anti-Corruption ,
CFTC ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FinCEN ,
Government Agencies ,
Pilot Programs ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Below is a summary of recent developments and enforcement trends in the UK white collar crime space in the first quarter of 2024.
I. New Legislation -
The Economic Crime and Corporate Transparency Act 2023 (ECCTA)...more
On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more
5/13/2024
/ AFA ,
Anti-Corruption ,
Charitable Donations ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
EU ,
France ,
Internal Investigations ,
New Guidance ,
Self-Reporting ,
Sponsorship Agreements ,
UK ,
White Collar Crimes
On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more
4/24/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Pilot Programs ,
Financial Institutions ,
Financial Services Industry ,
Non-Prosecution Agreements ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On March 7, 2024, Deputy Attorney General (DAG) Lisa Monaco announced that the Department of Justice (DOJ) will soon launch a new monetary reward program for people who provide information about corporate or financial...more
On 26 October 2023, the Economic Crime and Corporate Transparency Act 2023 (the Act) became law in the UK. The Act represents a major overhaul of the UK government’s framework for tackling financial crime and has brought into...more
2/26/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Governance ,
Corporate Transparency Act ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
EU ,
Financial Crimes ,
Investigations ,
Regulatory Agenda ,
UK ,
White Collar Crimes
On January 10, 2024, Damian Williams, U.S. Attorney for the Southern District of New York (SDNY), announced the creation of that office’s Whistleblower Pilot Program (Program). This initiative provides notice of the...more
1/18/2024
/ Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
New York ,
Pilot Programs ,
Self-Disclosure Requirements ,
State Funding ,
Voluntary Disclosure ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
On December 22, 2023, President Biden signed into law the Foreign Extortion Prevention Act (FEPA) as part of the fiscal year 2024 National Defense Authorization Act. FEPA criminalizes demand-side bribery by foreign officials...more
1/9/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Corruption ,
Extortion ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Hobbs Act ,
NDAA ,
White Collar Crimes
Representatives from the French and U.S. governments, judiciary and private sector discussed early lessons from the 2022 reform of the so-called French “blocking statute” at a Skadden roundtable in Paris on 27 November...more
In a speech on October 24, 2023, the director of the Securities and Exchange Commission’s (SEC’s) Enforcement Division, Gurbir Grewal, described the scenarios in which the commission would bring an enforcement action against...more
In recent remarks, Principal Associate Deputy Attorney General (PADAG) Marshall Miller of the Department of Justice (DOJ) revealed that Deputy Attorney General Lisa Monaco will soon announce new voluntary self-disclosure...more
In early March 2023, the Department of Justice (DOJ) released several important updates to its policies related to corporate crime enforcement and compliance programs. We discuss below the following key topics:
(i) The DOJ...more
3/13/2023
/ Corporate Crimes ,
Corporate Entities ,
Corporate Financing ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Employees ,
Executive Compensation ,
Financial Institutions ,
Instant Messaging Apps ,
Mobile Devices ,
Pilot Programs ,
White Collar Crimes
On January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more
2/7/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Crypto Exchanges ,
Cryptocurrency ,
Enforcement Actions ,
EU ,
Financial Crimes ,
FinCEN ,
Law Enforcement ,
Money Laundering ,
NDAA ,
Patriot Act ,
Popular ,
Russia ,
U.S. Treasury ,
Virtual Currency ,
White Collar Crimes
On January 16, 2023, France’s financial prosecutor, the “Parquet National Financier” (PNF), issued updated guidance (the Guidelines) regarding its approach to offering, negotiating and entering into French deferred...more
2/6/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Attorney-Client Privilege ,
CJIP ,
Compensation ,
Corporate Crimes ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
France ,
Guidance Update ,
Public Statements ,
Reporting Requirements ,
UK ,
White Collar Crimes
On January 17, 2023, the U.S. Department of Justice (DOJ) announced revisions to the Criminal Division’s Corporate Enforcement Policy. The revisions follow Deputy Attorney General (DAG) Lisa Monaco’s September 2022...more
1/24/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Commodities ,
Corporate Governance ,
Corporate Misconduct ,
Cross-Border ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
False Claims Act (FCA) ,
Investigations ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
White Collar Crimes
In a recently published memorandum, Deputy Attorney General (DAG) Lisa Monaco announced important updates to the U.S. Department of Justice’s (DOJ’s) approach to investigating and prosecuting corporate crimes. In the...more
Remarks made by U.S. Department of Justice (DOJ) officials at the March 2022 American Bar Association’s (ABA’s) National Institute on White Collar Crime (the White Collar Conference) reflect the DOJ’s prioritizing white...more