All Voluntary Self-Disclosure articles
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PremiumBIS’s Axelrod makes plea to financial services: ‘We want to work with you’
Matthew Axelrod, assistant secretary for export enforcement at the Bureau of Industry and Security, addressed efforts to reach financial services firms, working with the Financial Crimes Enforcement Network, and more during his fireside chat at CW’s Financial Crimes Summit.
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News BriefAirbus U.S. unit dinged by BIS for antiboycott violations
Satellite communications company Airbus DS Government Solutions received a reduced penalty from the Bureau of Industry and Security for admitting self-disclosed violations of antiboycott regulations.
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PremiumDebate: Experts discuss pros, cons of whistleblower process
Compliance Week Advisory Board members Eric Young and Ellen Hunt participate in a debate-style discussion regarding whistleblower-related topics including culture of compliance, monetary incentives, retaliation, and more.
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News BriefProterial Cable America earns DOJ declination in apparent fraud case
Proterial Cable America received a declination notice from the Department of Justice related to its voluntary self-disclosure and remediation of apparent fraud committed by its employees.
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News BriefDOJ on sprint toward pilot whistleblower reward program
Deputy Attorney General Lisa Monaco said the Department of Justice will look to fill gaps in its whistleblower procedures with the launch of a 90-day sprint toward a DOJ-led pilot whistleblower reward program.
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PremiumThe path to DOJ cooperation credit: Analyzing recent FCPA cases
Recent enforcement actions offer guidance on what the Department of Justice considers to be an “imminent threat” of disclosure or government action, what it means by “prompt” disclosure, and how a company can earn credit for revealing all relevant facts.
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News BriefPenn State Health to pay $11.7M over self-disclosed Medicare violations
Multihospital healthcare system Penn State Health agreed to pay more than $11.7 million to resolve self-disclosed violations of Medicare rules related to improper billing.
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News BriefSDNY launches whistleblower pilot program
The U.S. Attorney’s Office for the Southern District of New York took its efforts to encourage voluntary self-disclosure a step further with the launch of a whistleblower pilot program for individuals involved in nonviolent offenses.
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OpinionTen things I’d like to see happen in 2024
Election years in the United States, United Kingdom, and at European Parliament, along with ongoing geopolitical tensions, make 2024 difficult to predict—aside from the expectation compliance officers will be busy.
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PremiumFive compliance triumphs from 2023
A financial services giant’s compliance mea culpa that could serve to benefit the rest of the profession, a chemical company’s praised FCPA settlement, and an example of the value of whistleblowers highlight CW’s annual list of laudable ethics and compliance moments.
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PremiumOne company’s voluntary self-disclosure, two companies’ FCPA settlements
Nicole Argentieri, acting head of the Department of Justice’s Criminal Division, explained how the actions of Jardine Lloyd Thompson Group Holdings coming forward helped bring about the agency’s recent FCPA enforcements against Tysers Insurance Brokers and H.W. Wood.
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News Brief
HealthSun Health Plans earns DOJ declination in employee fraud case
The impact of the Department of Justice’s voluntary self-disclosure program was on display in the agency’s declination of an enforcement action against Florida-based health insurance company HealthSun Health Plans for apparent fraud committed by its employees and agents.
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PremiumDOJ floats declinations as incentive under M&A self-disclosure safe harbor
The Department of Justice’s push to incentivize companies to voluntarily self-disclose potential misconduct reached its next stage in the form of a safe harbor policy regarding mergers and acquisitions.
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PremiumDOJ official: Compliance must have ‘prominent seat’ at M&A decision table
The Department of Justice is gearing up to provide more guidance on voluntary self-disclosures in the mergers and acquisitions space and the role compliance should play.
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News BriefGuidance sets self-disclosure expectations for sanctions, export control lapses
Companies seeking credit for voluntarily self-disclosing potential violations of sanctions or export control laws must be mindful of the regimes at play from agencies including the DOJ, BIS, and OFAC and their differing expectations.
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PremiumPotential sanctions violations: To voluntarily self-disclose or not?
The Department of Justice scrutinizing sanctions on par with how it views bribery under the Foreign Corrupt Practices Act alters the calculus of whether a company should voluntarily self-disclose potential violations, experts discussed at CW’s TPRM Summit.
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News BriefBIS updates voluntary self-disclosure policy to punish not coming forward
The Commerce Department’s Bureau of Industry and Security updated its guidelines to further clarify the advantages of voluntary self-disclosure to the agency when export control violations are uncovered.
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News BriefPolite: Look to ABB case for ‘extraordinary cooperation’ example
Compliance officers seeking clarity on what the Department of Justice means by “extraordinary” cooperation or “immediate” self-disclosure should look to the agency’s case history, said Assistant Attorney General Kenneth Polite Jr. during a speech.
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News BriefDOJ declines to prosecute Corsa Coal in FCPA case
Corsa Coal Corp. was notified by the Department of Justice it won’t face prosecution for alleged bribes employees paid to Egypt’s Al Nasr Company for Coke and Chemicals to secure coal supply contracts.
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News Brief
DOJ to implement new clawback, compensation policies for corporate settlements
Corporate resolutions involving the Department of Justice’s Criminal Division will now include a requirement the resolving company develop compliance-promoting criteria within its compensation and bonus system, according to Deputy Attorney General Lisa Monaco.