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Significant Revisions to Non-U.S. Content Disclosure and Financing Policies Proposed

Client Alert | less than 1 min read | 10.07.15

The Defense Security Cooperation Agency has informally circulated draft revisions to the August 2009 Guidelines for Foreign Military Financing of Direct Commercial Contracts, which would elaborate on, and in a number of instances significantly change, its policies with respect to the disclosure and financing of U.S., non-U.S., and now "host country" content. Please contact us if you would like to obtain a copy of the draft and/or participate in commenting on the proposal by the due date of November 16, 2015.


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Client Alert | 3 min read | 03.12.26

DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy

On March 10, 2026, the Department of Justice released the first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP” or “Policy”), which applies to all non-antitrust corporate criminal cases across the Department. The new policy has been anticipated since December 2025, when Deputy Attorney General Todd Blanche announced the Department’s plans to release a new, single corporate enforcement policy for all criminal matters. According to the Department, the new policy is designed to “help ensure consistency across the Department” and “transparently describe the Department’s policies and decisionmaking.”...