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Investigation and Disclosure Best Practices

Client Alert | 1 min read | 06.06.16

In Importance of Disclosures and Cooperation During and After Internal Investigations, Crowell & Moring attorneys review several recent regulatory changes and highlight the growing importance of targeted communication with the government before, during, and after internal investigations. Among other things, the article lists suspension and debarment statistics taken from the System for Award Management for the first half of fiscal year 2016 to demonstrate the importance of, and benefits that may be achieved from, targeted communication to the government by experienced government contracts investigations attorneys.

Insights

Client Alert | 3 min read | 04.23.24

DOJ Promises NPAs to Certain Individuals Through New Voluntary Self-Disclosure Pilot Program

On April 15, 2024, the Acting Assistant Attorney General for the Criminal Division of the Department of Justice (“DOJ”) Nicole Argentieri announced a new Pilot Program on Voluntary Self-Disclosure for Individuals (“Pilot Program” or “Program”). The Pilot Program offers a clear path for voluntary self-disclosure by certain corporate executives and other individuals who are themselves involved in misconduct by corporations, in exchange for a Non-Prosecution Agreement (“NPA”). The Pilot Program specifically targets individuals who disclose to the Criminal Division at DOJ in Washington, D.C. information about certain corporate criminal conduct. By carving out a clear path to non-prosecution for those who qualify, DOJ has created another tool to uncover complex crimes that might not otherwise be reported to the Department. ...