Voluntary self-disclosure

General

Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations

The Commerce Department's Bureau of Industry and Security ("DOC-BIS") is adopting procedures to generate voluntary self-disclosures for violations of export controls laws. Companies have to weigh carefully the risks when deciding whether to make such a disclosure. The Justice Department and DOC-BIS are

Podcasts

Episode 316 -- DOJ Announces New Whistleblower Program and Encourages Self-Disclosures

In a recent speech, on March 7, 2024, Deputy Attorney General Monaco announced that DOJ would be implementing in the next 90 days a new whistleblower program to reward reporting of criminal misconduct at both public and private companies. In particular DOJ will encourage reporting of potential violations of the

General

Carrots and Sticks: DOJ's Push to Incentivize Voluntary Disclosure of Corporate Misconduct (Part II of II)

DOJ has been on a public relations campaign to push a simple message for corporations: if companies learn of misconduct, companies should disclose such misconduct to earn valuable benefits. The quintessential question remains -- should companies disclose misconduct to the Department of Justice or should the company remediate the misconduct and

General

DOJ's Revised Corporate Enforcement Policy Expands on Previous Factors: History of Misconduct; Voluntary Self-Disclosure; and Compliance Monitors (Part III of IV)

The Lisa Monaco Memo is a new and important restatement of the Justice Department's approach to corporate crime. It is a worthy read and it sets out a number of new requirements and procedures for DOJ prosecutors investigating corporate crime. In this posting, we return to review a