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The V&E Report
Insights in Government Enforcement and Investigations

Where in the World Is Dirty Money Going? FinCEN’s Newest Investigation Unit Targets Global Money Laundering

The Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) recently announced the launch of a Global Investigations Division (“GID”). GID will focus its efforts on implementing targeted investigation strategies to combat money laundering and terrorism financing in domestic and international contexts.

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Walmart Doesn’t “Save Money,” But It May “Live Better” After DOJ Agrees to Significant Concessions to Narrow Scope of its Corporate Monitorship

In a significant departure from previous practice, the Department of Justice (“DOJ”) imposed a corporate monitor on a company even after it engaged in extensive remedial measures and enhanced its compliance functions, but DOJ also agreed to narrow the scope, obligations and term of the corporate monitorship in what is the most meaningful example yet of how DOJ intends to implement its new policy on corporate monitors.

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New Guidelines Reward Voluntary Self-Disclosure of FCA Violations and Cooperation with DOJ

The U.S. Department of Justice (“DOJ”) announced this month its latest initiative to incentivize companies to voluntarily self-disclose potential False Claims Act (“FCA”) violations and to cooperate with DOJ during FCA investigations.1 These new guidelines, which have been incorporated into the U.S. Attorney Manual (recently renamed the Justice Manual), formalize DOJ’s established practice of decreasing FCA penalties sought when a company voluntarily discloses and actively cooperates with DOJ’s investigation into its conduct.

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Updated DOJ Guidance Provides Useful Roadmap for Implementing and Enhancing Corporate Compliance Programs

On Tuesday, the U.S. Department of Justice released perhaps the most comprehensive guidance to date on how prosecutors evaluate the design, implementation, and effectiveness of corporate compliance programs in making charging decisions, framing sentencing recommendations, and determining whether on-going corporate compliance obligations, such as the imposition of a monitor, may be necessary as part of any enforcement resolution. In announcing the release of the Criminal Division’s Evaluation of Corporate Compliance Programs guidance document (“Guidance”), DOJ Criminal Division, Assistant Attorney General Brian A. Benczkowski explained that the updated guidance is intended to align the Fraud Section’s 2017 guidance with other Department instructions and legal standards, and to provide greater transparency into prosecutors’ assessments.

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DOJ Updates FCPA Cooperation Credit Policy for M&A

Last week, the Department of Justice (“DOJ” or “Department”) made a series of changes to the 2017 FCPA Corporate Enforcement Policy (“Policy”) contained in the Justice Manual (until last year, known as the United States Attorneys’ Manual). These changes, which were first announced by Assistant Attorney General Brian Benczkowski on March 8, 2019 during the ABA White Collar Crime Conference, include rescinding the requirement that companies prohibit the use of disappearing messages applications, clarifying the Department’s “de-confliction” policy, and updating language to soften companies’ requirement to disclose facts about involved individuals consistent with a policy change announced in November 2018.

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