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Articles by Sarah Bartle
Updated DOJ Guidance Keeps Compliance in the Spotlight
On Friday, the Department of Justice released an updated version of its Evaluation of Corporate Compliance Programs (“ECCP”) guidance—the latest in a series of updates to the administration’s approach to corporate criminal resolutions, and the first substantive update to the ECCP guidance since June 2020.
Did the DOJ just narrow the path to declinations?
The January 2023 revisions to DOJ’s Corporate Enforcement Policy for the first time spelled out the factors that allow a company to qualify for a declination even in the presence of aggravating circumstances. This change has been touted alongside other significant revisions to the Policy—including increased penalty reductions in certain scenarios—as providing further encouragement for companies to self-disclose misconduct.
Cybersecurity compliance requirements may surprise higher ed
Institutions that work with the federal government are required to maintain certain security controls to protect covered information systems. Now, the DOJ is going after universities and research institutions. AdobeStock As has been widely reported, the Department of Justice (DOJ) launched its new Civil Cyber-Fraud Initiative on October 6, targeting entities that fail to follow cybersecurity-related contract requirements.
Treasury Agencies Issue Virtual Currency Sanctions Compliance Guidance and Ransomware Trends Statistics
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued its first-ever sanctions compliance guidance (the “OFAC Guidance” or “Guidance”) for the virtual currency industry. The Guidance represents a focused effort by OFAC to highlight sanctions risks present in the virtual currency industry, which has experienced tremendous growth in the past few years, and to suggest methods for ensuring compliance.
DOJ’s “Déjà vu All Over Again” for Corporate Crime
On October 28, Deputy Attorney General (“DAG”) Lisa O. Monaco delivered remarks at the ABA’s 36th National Institute on White Collar Crime. Department of Justice (“DOJ” or “Department”) officials have recently referenced the coming enforcement “surge,” and the DAG’s remarks last week provide a roadmap to corporate criminal enforcement under the current administration.
DOJ's 'déjà vu all over again' for corporate crime
(November 10, 2021) - Tom Hanusik, Rebecca Ricigliano, Sarah Bartle and Tiffany Wynn of Crowell & Moring LLP discuss U.S. Deputy Attorney General Lisa O. Monaco's recent announcement regarding changes in corporate criminal enforcement. On October 28, Deputy Attorney General Lisa O. Monaco delivered remarks at the ABA's 36th National Institute on White Collar Crime.
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