Daniel S. Kahn, Greg D. Andres, Martine M. Beamon, Paul J. Nathanson and Tatiana R. Martins

Davis Polk Discusses DOJ Self-Disclosure Policy for Criminal Cases

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On March 10, 2026, the Department of Justice announced its first ever Department-wide corporate enforcement policy for all criminal cases.  Under the new policy, companies that self-report misconduct could be eligible for a declination and avoid fines or monitors.

The …

Davis Polk Discusses Second Circuit Reversal of LIBOR-Based Fraud Convictions

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On January 27, 2022, the Second Circuit reversed the wire fraud convictions of two traders for their purported roles in the London Interbank Offered Rates (LIBOR) manipulation scandal, which previously resulted in a number of resolutions by banks.  In United …