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OGE Amends Executive Branch Ethics Program

Client Alert | 1 min read | 11.07.16

On November 2, 2016, the Office of Government Ethics issued a final rule amending the regulations setting forth the elements and procedures of the executive branch ethics program by defining and describing the executive branch ethics program, delineating the responsibilities of various government stakeholders, and enumerating key executive branch ethics procedures. Among the various amendments, which are detailed in our blog post, the final rule centralizes the procedures of the executive branch ethics program and modifies the procedures for the correction of agency noncompliance by outlining several remedial actions that may be taken.

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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. ...