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Billy Jacobson, a former federal prosecutor now at Jacobson Lopez in Washington, DC, said the continued usage of the phrase “aggravating circumstances” in the guidance gives the DOJ latitude to interpret cases as it sees fit. “It’s hard to say with definitiveness when there will be a declination and when there won’t be,” using that language, said Jacobson, who believes the new guidance still improves on past iterations.

On August 1, 2024, the U.S. Department of Justice (DOJ) launched the Corporate Whistleblower Awards Pilot Program (Program) to encourage reports of corporate misconduct not covered by other federal whistleblower programs.

Over the past year, there have been several noteworthy advancements in anti-corruption enforcement and compliance expectations. These include policy announcements and initiatives, updated DOJ guidance, and new tools added to the U.S. government’s arsenal for combating corruption.

The award-winning FCPA Compliance Report is the longest-running podcast in compliance. In the episode, Tom Fox welcomes Billy Jacobson to discuss why he co-founded the firm, the type of work it takes on, and where he hopes it might grow.

Jonathan Lopez joins John Byrne to discuss the state of corruption, how prosecutors see their cases, advice for BSA/AML officers to avoid personal liability, and other white collar issues.

In March 2023, the DOJ Criminal Division revised its valuable Evaluation of Corporate Compliance Programs (ECCP) to emphasize two priorities for corporate...

Many an in-house compliance professional has spent a weekend (or ten) consumed with handling the tricky questions presented when an employee finds...