Law/Legal
Here's a look at documents from law firms and legal groups
Featured Stories
Greenberg Traurig Wins Wrongful Seizure of Imported Goods Cases for Castro Business Enterprises Valued at $3.148M
MIAMI, Florida, March 20 [Category: BizLaw/Legal] -- Greenberg Traurig, a law firm, issued the following news release:
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Greenberg Traurig Wins Wrongful Seizure of Imported Goods Cases for Castro Business Enterprises Valued at $3.148M
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MIAMI - March 20, 2026 - A Greenberg Traurig, LLP team led by Litigation Practice Shareholder Francisco O. Sanchez and Associate Carlos J. Andreu-Collazo triumphed March 13 in the U.S. District Court for the District of Puerto Rico for importer Castro Business Enterprises (CBE) in two related, multiyear wrongful seizure of imported goods cases (19-cv-1550
... Show Full Article
MIAMI, Florida, March 20 [Category: BizLaw/Legal] -- Greenberg Traurig, a law firm, issued the following news release:
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Greenberg Traurig Wins Wrongful Seizure of Imported Goods Cases for Castro Business Enterprises Valued at $3.148M
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MIAMI - March 20, 2026 - A Greenberg Traurig, LLP team led by Litigation Practice Shareholder Francisco O. Sanchez and Associate Carlos J. Andreu-Collazo triumphed March 13 in the U.S. District Court for the District of Puerto Rico for importer Castro Business Enterprises (CBE) in two related, multiyear wrongful seizure of imported goods cases (19-cv-1550and 19-cv-1551). The decision brings clarity to several issues involving the federal government's statutory authority to seize property in international trade matters.
The virtually identical cases, which relate to CBE's importing two shipments of cigarettes from Canada that were seized by U.S. Customs and Border Protection (CBP) in 2018 in San Juan, were brought when the government alleged CBE failed to comply with import requirements set forth in statute 19 U.S.C. SS 1681a.
The government contended that CBE, as the importer of the cigarettes into Puerto Rico, was required to submit and obtain approval of its own surgeon general health warning rotational plan from the Federal Trade Commission (FTC). However, the language of Section 1681a, together with the governing regulatory framework, requires only that an importer certify compliance with an FTC-approved rotational plan -not that the importer independently develop and secure approval of its own plan - which CBE had done.
Although a magistrate judge in the U.S. District Court for the District of Puerto Rico initially issued a report and recommendation in favor of the government, District Judge Silvia Carreno-Coll rejected that recommendation. The court instead granted summary judgment in CBE's favor, holding that CBE did not violate Section 1681a and fully complied with its requirements. The court further ordered the government to return the value of the wrongfully seized property -which perished in government custody during the lengthy case -based on the appraisal conducted by CBP at the time of seizure.
The total amount of the award between both cases is $3.148 million, which represents the total CBP appraised value of the property at seizure. A yet-to-be-determined amount of attorneys' fees and costs were granted by the court pursuant to the mandatory fee-shifting language contained in 28 USC SS 2465(b)(1).
"Prevailing for CBE is truly rewarding, not only for its importance to the company, but also for the many importers that may find more clarity in requirements for the shipment of their property as a result of this decision," Sanchez and Andreu-Collazo said in a joint statement.
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Original text here: https://www.gtlaw.com/en/news/2026/03/press-releases/greenberg-traurig-wins-wrongful-seizure-of-imported-goods-cases-for-castro-business-enterprises-valued-at-3148m
Gibson Dunn Secures Seventh Circuit Victory in Major Insurance Dispute
LOS ANGELES, California, March 20 [Category: BizLaw/Legal] -- Gibson, Dunn and Crutcher, a law firm, issued the following news:
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Gibson Dunn Secures Seventh Circuit Victory in Major Insurance Dispute
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Gibson Dunn secured a significant victory for National Union in the U.S. Court of Appeals for the Seventh Circuit in a high-profile insurance coverage dispute arising from ethylene oxide emissions in Willowbrook, Illinois. The firm's team successfully argued that coverage for nearly 1,000 underlying lawsuits was barred by the policies' pollution exclusion. Following a certified question
... Show Full Article
LOS ANGELES, California, March 20 [Category: BizLaw/Legal] -- Gibson, Dunn and Crutcher, a law firm, issued the following news:
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Gibson Dunn Secures Seventh Circuit Victory in Major Insurance Dispute
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Gibson Dunn secured a significant victory for National Union in the U.S. Court of Appeals for the Seventh Circuit in a high-profile insurance coverage dispute arising from ethylene oxide emissions in Willowbrook, Illinois. The firm's team successfully argued that coverage for nearly 1,000 underlying lawsuits was barred by the policies' pollution exclusion. Following a certified questionto the Illinois Supreme Court -which ruled unanimously in National Union's favor and overruled prior precedent -the Seventh Circuit held that no coverage was owed and remanded with instructions to enter judgment accordingly.
The decision is a landmark for insurance law, with broad implications for coverage disputes involving environmental pollution nationwide.
The Gibson Dunn team included partners Tom Dupree and Nick Harper and associates Aaron Hauptman and Aly Cox.
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Original text here: https://www.gibsondunn.com/gibson-dunn-secures-seventh-circuit-victory-in-major-insurance-dispute/
Gibson Dunn Pro Bono Team Secures Unanimous U.S. Supreme Court Victory in Olivier v. City of Brandon et al.
LOS ANGELES, California, March 20 [Category: BizLaw/Legal] -- Gibson, Dunn and Crutcher, a law firm, issued the following news:
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Gibson Dunn Pro Bono Team Secures Unanimous U.S. Supreme Court Victory in Olivier v. City of Brandon et al.
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A Gibson Dunn pro bono team secured a unanimous victory at the U.S. Supreme Court on March 20, 2026, in Olivier v. City of Brandon et al., a civil rights case in which our team was supported by a diverse coalition of 11 amicus briefs.
Gabriel Olivier, an evangelical Christian, shared his faith on a public sidewalk near the City of Brandon, Mississippi's
... Show Full Article
LOS ANGELES, California, March 20 [Category: BizLaw/Legal] -- Gibson, Dunn and Crutcher, a law firm, issued the following news:
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Gibson Dunn Pro Bono Team Secures Unanimous U.S. Supreme Court Victory in Olivier v. City of Brandon et al.
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A Gibson Dunn pro bono team secured a unanimous victory at the U.S. Supreme Court on March 20, 2026, in Olivier v. City of Brandon et al., a civil rights case in which our team was supported by a diverse coalition of 11 amicus briefs.
Gabriel Olivier, an evangelical Christian, shared his faith on a public sidewalk near the City of Brandon, Mississippi'samphitheater during well-attended events. He was silenced when the City adopted an ordinance prohibiting him from communicating his religious beliefs on the public sidewalk, and then arrested him for violating the ordinance by continuing to share his faith. After paying a fine, he sued the city in federal court, challenging the constitutionality of the ordinance.
The district court dismissed his lawsuit without considering the merits, relying on a Supreme Court decision that the U.S. Court of Appeals for the Fifth Circuit has applied to prevent persons convicted under a law from challenging the constitutionality of that law. The Fifth Circuit affirmed and then declined to revisit its past precedent by a narrow one-vote margin over vigorous dissents.
The Supreme Court justices unanimously agreed that the previous Supreme Court decision does not bar legal challenges such as Olivier's. Writing for the full court, Justice Elena Kagan said that the previous decision "has no bearing on Olivier's suit seeking a purely prospective remedy."
"We're delighted that the Supreme Court unanimously affirmed Gabe's right to his day in court," said Gibson Dunn partner Allyson Ho, who presented oral arguments for Olivier before the Supreme Court in December 2025. "It's just common sense that a citizen who is arrested under an unconstitutional law should be able to challenge that law. As people of faith, we look to the judiciary to protect our constitutional right to spread the gospel."
Along with Allyson, our team included partner David Casazza and associates Aaron Smith, Patrick Fuster, Giuliana Carozza Cipollone, Jack Reed, Aly Cox, Andrew Ebrahem, and Savannah Silver.
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Original text here: https://www.gibsondunn.com/gibson-dunn-pro-bono-team-secures-unanimous-u-s-supreme-court-victory-in-olivier-v-city-of-brandon-et-al/
Frantz Ward Issues Commentary: EEOC Lawsuit and Fortune 500 Letter Signal New Phase of Enforcement on Workplace Diversity Programs
CLEVELAND, Ohio, March 20 -- Frantz Ward, a law firm, issued the following commentary on March 19, 2026, by member Ryan T. Smith:
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EEOC Lawsuit and Fortune 500 Letter Signal New Phase of Enforcement on Workplace Diversity Programs
Recent EEOC actions show the agency has begun executing the enforcement priorities announced by Chair Andrea Lucas.
Two Developments Illustrate This Point:
On February 17, 2026, the EEOC filed a lawsuit challenging a women-only leadership retreat hosted by a Coca-Cola bottler. Nine days later, on February 26, 2026, Chair Lucas sent a letter to Fortune 500 companies
... Show Full Article
CLEVELAND, Ohio, March 20 -- Frantz Ward, a law firm, issued the following commentary on March 19, 2026, by member Ryan T. Smith:
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EEOC Lawsuit and Fortune 500 Letter Signal New Phase of Enforcement on Workplace Diversity Programs
Recent EEOC actions show the agency has begun executing the enforcement priorities announced by Chair Andrea Lucas.
Two Developments Illustrate This Point:
On February 17, 2026, the EEOC filed a lawsuit challenging a women-only leadership retreat hosted by a Coca-Cola bottler. Nine days later, on February 26, 2026, Chair Lucas sent a letter to Fortune 500 companieswarning that diversity initiatives must comply with Title VII's prohibition on employment decisions based on protected characteristics. Taken together, these actions indicate that the EEOC is focusing attention on workplace programs that it views as limiting opportunities based on race or sex, even when those programs are described as diversity or professional-development initiatives.
EEOC Lawsuit Targets Women-Only Leadership Retreat
On February 17, 2026, the EEOC sued Coca-Cola Beverages Northeast in federal court in New Hampshire, alleging sex discrimination. According to the complaint, the company hosted a two-day leadership and networking retreat for women. About 250 female employees were invited, excused from their regular duties, and paid their normal wages while attending. Male employees were not invited. The EEOC alleges that excluding men from the event denied them access to a workplace opportunity in violation of Title VII.
The case is also notable because it does not involve hiring, firing, or pay cuts. The alleged harm is exclusion from a professional development opportunity. That theory may draw support from the Supreme Court's 2024 decision in Muldrow v. City of St. Louis, which held that Title VII plaintiffs need only show "some harm," not a significant employment injury. Under that standard, courts may consider whether the loss of workplace opportunities--such as training, networking events, or leadership programs--can satisfy the harm requirement. The Coca-Cola case may become a notable application of how broadly courts apply that standard.
EEOC Letter Warns Companies About DEI Programs
Shortly after filing the lawsuit, Chair Lucas sent a letter to the CEOs, general counsel, and board chairs of Fortune 500 companies on February 26, 2026, addressing workplace diversity initiatives. The letter reiterates the EEOC's view that Title VII applies fully to workplace policies and programs labeled "DEI." According to the letter, employment decisions must be based on neutral, job-related criteria rather than race or sex, including:
* Hiring
* Promotion
* Training opportunities
* Access to workplace benefits
The letter also emphasizes that the agency intends to actively enforce that position. Chair Lucas stated that the EEOC is prepared to use its full range of enforcement tools, including investigations, systemic cases, and litigation, to address practices the agency views as discriminatory.
The audience of the letter is also notable. Rather than directing the message to HR professionals alone, the EEOC sent it to CEOs, general counsel, and board chairs of the Fortune 500, emphasizing that these issues are now being framed as high-level corporate governance and compliance risks.
Takeaways
As has been well-documented, the agency's focus on diversity programs represents a shift in enforcement and legal emphasis. Prior EEOC administrations generally challenged discriminatory conduct that excluded historically underrepresented groups from workplace opportunities. The agency now appears prepared to scrutinize programs that limit participation based on protected characteristics, regardless of which employees are excluded.
To remain legally compliant, employers should reevaluate how development programs are structured. Leadership retreats, mentorship programs, networking events, and similar initiatives remain common tools for developing talent, but when access to those opportunities is limited based on protected characteristics, the programs may attract closer attention from the EEOC. Moreover, in light of Muldrow's lower threshold for showing harm, employers may want to review eligibility rules and selection criteria to determine whether professional opportunities should be characterized by job-related factors, rather than protected characteristics.
If you have questions about this or other labor and employment law issues, contact Ryan T. Smith or another member of the Frantz Ward Labor & Employment Practice Group.
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Original text here: https://www.frantzward.com/eeoc-lawsuit-and-fortune-500-letter-signal-new-phase-of-enforcement-on-workplace-diversity-programs/
[Category: BizLaw/Legal]
Fisher Phillips Issues Commentary: DOJ Provides Employers With Playbook for Avoiding Criminal Prosecution Through Self-Disclosure - 4 Biggest Takeaways
ATLANTA, Georgia, March 20 -- Fisher Phillips, a law firm, issued the following commentary on March 19, 2026, by partner Brandon B. Brown and associate Christopher J. Merken:
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DOJ Provides Employers With Playbook for Avoiding Criminal Prosecution Through Self-Disclosure: 4 Biggest Takeaways
If your company discovers that it may have committed criminal misconduct, you may be able to avoid prosecution entirely - but only if you act quickly and follow a newly streamlined federal roadmap. The US Department of Justice announced its first-ever agency-wide Corporate Enforcement and Voluntary Self-Disclosure
... Show Full Article
ATLANTA, Georgia, March 20 -- Fisher Phillips, a law firm, issued the following commentary on March 19, 2026, by partner Brandon B. Brown and associate Christopher J. Merken:
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DOJ Provides Employers With Playbook for Avoiding Criminal Prosecution Through Self-Disclosure: 4 Biggest Takeaways
If your company discovers that it may have committed criminal misconduct, you may be able to avoid prosecution entirely - but only if you act quickly and follow a newly streamlined federal roadmap. The US Department of Justice announced its first-ever agency-wide Corporate Enforcement and Voluntary Self-DisclosurePolicy last week, allowing employers to reduce or even completely eliminate criminal penalties by self-disclosing the wrongdoing and taking other administrative steps. What are the four key takeaways you need to know about this March 10 announcement?
What are the DOJ's Goals in Rolling Out the New CEP?
The CEP, which you can read here, is in line with the May 2025 update to the DOJ's Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy. DOJ described the CEP rollout as intended to promote "uniformity, predictability, and fairness in how it pursues white-collar cases." This new policy is intended to supersede previously in-place DOJ component or district-specific corporate enforcement programs.
What Does This Mean for Employers?
The CEP is applicable to potential criminal penalties an employer may face for violating various laws such as safety and health regulations, environmental compliance, immigration and anti-bribery provisions. Antitrust matters are excepted from the policy. If found guilty of these criminal laws, an employer could face hundreds of millions of dollars in penalties, restitution and ongoing external compliance monitoring.
But if employers discover misconduct, the new policy means that all hope is not lost. Employers can reduce or even completely eliminate these penalties by self-disclosing and entering into some type of CEP agreement. The agency-wide CEP approach enhances predictability and streamlines corporate decision-making regarding voluntary self-disclosures.
Overview of the New, Comprehensive CEP
Like the former Criminal Division Policy, the CEP includes three paths under which a company may benefit from self-disclosure:
* Declination Under the CEP;
* "Near Miss" Voluntary Self-Disclosures or Aggravating Factors Warranting Resolutions"; and
* Resolutions in Other Cases.
However, the hallmark tenants of the new CEP include revisions to the requirements and benefits under the policy.
Path #1: What Makes a Declination?
Mirroring the Criminal Division Policy, if a company voluntarily self-discloses misconduct, DOJ will decline to prosecute so long as the company:
* timely and voluntarily discloses the misconduct to an appropriate DOJ component or agency;
* fully cooperated with DOJ's investigation; and
* timely and appropriately remediated the misconduct where no aggravating circumstances exist.
Importantly, declinations approved under the CEP will be publicly announced. Employers must also meet a number of requirements to qualify for declination of prosecution under the CEP.
* Voluntariness of the self-disclosure. To be considered voluntary, the company must report to the appropriate Department with the DOJ prior to an imminent threat of disclosure or government investigation and within a reasonably prompt time after becoming aware of the misconduct.
* Factual disclosures of misconduct. Next, full cooperation requires disclosure of all facts and non-privileged information relevant to the misconduct including identification of all individuals (both internal and external to the company) involved in or responsible for the misconduct.
* Timeliness of the self-disclosure. Finally, timely and appropriate remediation requires effective root cause analysis of the wrongdoing and prompt remediation of the root causes which allowed the conduct to occur.
Previously, self-disclosure needed to be made within 120 days of the whistleblower's report. Now, corporations must self-report "as soon as reasonably practicable but no later than 120 days after receiving the whistleblower's internal report." This makes timely disclosure paramount.
Companies should also implement an effective compliance program if one did not previously exist.
Path #2: "Near Miss" Voluntary Self-Disclosures of Aggravating Factors Warranting Resolution
The "Near Miss" path applies to companies that do not qualify for routine declination under Part I solely because:
* it acted in good faith by self-reporting the misconduct but that self-report did not qualify as a voluntary disclosure; and/or
* it had aggravating factors that warrant a criminal resolution.
Under the "Near Miss" path, companies will receive a non-prosecution agreement with a term of fewer than three years, no independent compliance monitor, and a 50 to 75% reduction off the low end in the fine range due under the U.S. Sentencing Guidelines. The Criminal Division Policy provided for a 75% reduction. This change highlights prosecutorial discretion and the necessity of having a strong advocate when self-disclosing to DOJ.
Path #3: Resolutions in Other Cases
This section remains mostly the same under the new CEP. If a company is ineligible for the preceding paths, DOJ retains discretion to determine appropriate resolution. This can include reductions in fines and penalties, with only a maximum 50% reduction in the monetary penalty available for companies who are ineligible for Parts 1 or 2.
What the CEP Means for Corporate Self-Disclosure Moving Forward
The CEP's main benefit to corporations is the uniformity it imposes on the self-disclosure process. Under the CEP, there are no division-specific or jurisdiction-specific requirements to be eligible for declination of prosecution or other benefits associated with self-disclosure. Companies of all sizes will benefit from well-established compliance systems and related internal reporting programs which will support early detection and correction of potential wrongdoing.
Importantly, the CEP applies only to criminal investigations, not civil investigations. Companies should ensure they consider the impact of self-disclosure under the CEP on parallel or subsequent civil investigations or enforcement actions.
Superseded Policies
As previously noted, the new DOJ-wide CEP not only replaces the Criminal Division Policy, but also preempts corporate enforcement policies from other United States Attorneys' Offices. This results in uniformity for corporations and their representation regardless of the jurisdiction or misconduct at issue.
Specific DOJ components and USAOs have the discretion to develop practices that comport with and do not run afoul of the new CEP. However, the release of the new CEP led to component- or district-specific formal policies being preempted as of March 10.
That said, there are still some unanswered questions. One hot-button issue is how the new CEP affects the Southern District of New York's USAO's Corporate Enforcement and Voluntary Self-Disclosure Program for Financial Crimes, issued on February 24 of this year.
4 Key Takeaways for Employers
* Now is the time for the companies to review and evaluate their compliance policies to ensure they are educating all employees on the company's compliance expectations and internal reporting systems when noncompliance is suspected. Speed is key. Although the decision to self-disclose is fact-specific and difficult, the CEP incentivizes swift disclosures and punishes delays.
* Take this opportunity to educate senior management on the self-disclosure requirements and the benefits for self-reporting potential criminal wrongdoing. These changes reflect the need for effective internal controls and robust compliance programs. This will support efficient decision making should the organization need to make a rapid decision regarding potential self-reporting.
* Internal investigations must be thorough and well documented. The relevant facts and individuals involved may need to be disclosed, if the company wishes to obtain credit for self-disclosing to the DOJ.
* There is now uniformity, given the new Department-wide CEP applies to all criminal matters (with the exception of antitrust). Companies considering self-disclosure will need to assess where to self-report based on a DOJ component, USAO's jurisdiction or professional relationships established.
Conclusion
For more information and assistance in reviewing your workplace compliance systems and related investigation processes or taking the actions described above, contact your Fisher Phillips attorney, the authors of this Insight, or any attorney on our Corporate Compliance and Governance Practice Group. Make sure you are subscribed to Fisher Phillips' Insight System to get the most up-to-date information.
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Original text here: https://www.fisherphillips.com/en/insights/insights/doj-provides-employers-with-playbook-for-avoiding-criminal-prosecution-through-self-disclosure
[Category: BizLaw/Legal]
Faegre Drinker Biddle and Reath Issues Commentary: Immigration Considerations for Individuals and Employers During Periods of Conflict or Civil Unrest
MINNEAPOLIS, Minnesota, March 20 -- Faegre Drinker Biddle and Reath, a law firm, issued the following commentary on March 18, 2026, by counsel Claire D Nilson, London paralegal Abilio Jaribu and trainee solicitor Isabel Philips:
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Immigration Considerations for Individuals and Employers During Periods of Conflict or Civil Unrest
Taking a Proactive and Well-Informed Approach Can Help
At a Glance
* Periods of conflict or civil unrest can disrupt international travel, airspace access, and immigration processes with little notice.
* Travellers may experience visa expiries, border restrictions,
... Show Full Article
MINNEAPOLIS, Minnesota, March 20 -- Faegre Drinker Biddle and Reath, a law firm, issued the following commentary on March 18, 2026, by counsel Claire D Nilson, London paralegal Abilio Jaribu and trainee solicitor Isabel Philips:
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Immigration Considerations for Individuals and Employers During Periods of Conflict or Civil Unrest
Taking a Proactive and Well-Informed Approach Can Help
At a Glance
* Periods of conflict or civil unrest can disrupt international travel, airspace access, and immigration processes with little notice.
* Travellers may experience visa expiries, border restrictions,or limited commercial transport options when attempting to leave affected regions.
* Employers with staff overseas should review crisis response procedures, immigration status, and potential remote working or relocation arrangements.
* Maintaining access to travel documentation and monitoring official government guidance is essential for both individuals and organisations.
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Recent developments in the Middle East highlight how quickly geopolitical events can disrupt international travel and global mobility. Escalating conflict, airspace closures, and security restrictions may leave travellers unable to leave affected regions or return to their home country as planned.
These disruptions may affect both individuals travelling for business or leisure and employees living and working in the region on longer-term assignments. In serious situations, governments may advise their nationals to leave affected countries or organise assisted departures where commercial travel is unavailable.
Beyond immediate safety considerations, travel disruption can also create immigration challenges. Individuals may face visa expiries, difficulties exiting a country, or delays in residence permit processing. Employers may need to manage immigration compliance issues, remote working arrangements, and potential relocation of staff.
This article outlines some practical steps for individuals and employers navigating immigration issues during periods of conflict, civil unrest, or other crises.
Preparing for Potential Disruption
While crises are often unpredictable, both employers and individuals can take steps in advance to reduce disruption to international travel.
Review Insurance and Duty-of-Care Arrangements
Before travelling, it is important to understand what protection may be available if travel plans are disrupted.
Individuals should review the terms of their travel insurance policies, while employers should assess their corporate travel insurance and duty-of-care coverage to understand the support available to employees travelling in higher-risk regions.
Standard travel insurance policies frequently exclude losses arising from war, military activity, or government-mandated airspace closures. As a result, some costs associated with travel disruption, evacuation, or extended stays abroad may fall outside the scope of cover.
Individuals and organisations should therefore confirm:
* what assistance their insurer may provide in the event of travel disruption
* whether emergency evacuation or crisis support services are included
* what exclusions may apply in situations involving conflict or political unrest
Monitor Official Travel Advice
Travellers should monitor travel advice issued by their home government prior to departure and throughout their time abroad. For example, for British nationals, guidance published by the UK government's Foreign, Commonwealth and Development Office (FCDO) provides country-specific security updates and travel restrictions.
Employers sending employees overseas should ensure that relevant governmental travel advice is reviewed before approving travel. From an insurance perspective, failure to comply with government guidance may also invalidate certain travel insurance policies.
Guidance for Individuals in Affected Regions
Individuals currently located in areas experiencing unrest should prioritise staying informed and ensuring their home government can contact them if necessary.
Register with Your Embassy or Consulate
Individuals should register their presence with their home country's embassy or consulate as soon as possible.
Consular registration allows governments to identify and contact their nationals during emergencies and provide updates on security conditions, evacuation arrangements, and available assistance. Registration typically involves submitting basic personal details and contact information through an online government portal.
In many cases, registration also enables individuals to receive alerts and safety guidance during rapidly changing situations.
Individuals should also stay informed by closely monitoring updates from:
* their home country's foreign ministry or consulate
* local authorities in the host country
* airlines or transport providers
Planning Departure from an Affected Country
When arranging travel out of an affected country, individuals should follow official guidance carefully.
In particular, travellers should:
* only travel to airports or border crossings once they have confirmed departure arrangements
* comply with any movement restrictions or shelter-in-place orders issued by local authorities
* prepare for delays, cancellations. and congestion at transport hubs
Immigration requirements in transit or destination countries should also be checked before travelling, as entry restrictions or visa policies may change quickly in response to evolving security conditions.
Governments may also introduce temporary operational measures to assist nationals seeking to leave affected regions. For example, the UK government recently confirmed that dual British nationals are generally required to enter the UK using a valid British passport rather than a non-British passport.
However, in response to recent developments in the Middle East and the resulting travel disruption, the UK government has issued temporary guidance to airlines to facilitate travel to the UK. Under this guidance, carriers may, at their discretion, accept an expired UK passport (issued in 1989 or later) when presented alongside a valid passport from a visa-free country, provided the biographical details match. This temporary measure is intended to assist dual British nationals who may not have access to a valid UK passport but need to return to the UK during the current disruption.
Safeguard Travel Documentation
In addition to their physical documentation, individuals should ensure they have secure digital copies of key documents, including:
* passports
* visas or residence permits
* work permits
* other official identification
Securely stored digital copies can assist with replacement processes if documents are lost or damaged.
Where travel documents are lost, individuals should report the loss to the local authorities where possible and contact their embassy or consulate to request assistance. This may include issuing emergency travel documentation.
However, travellers should note that emergency travel documents may not always be accepted for entry into third countries and may only permit direct travel to the issuing country.
Managing Immigration Status
Travel disruption may create immigration complications, including visa expiry or delays in residence permit processing. In some situations, immigration authorities may temporarily suspend in-person services, biometric appointments, or document collection processes. This may delay visa renewals, residence permit issuance, or exit permit approvals.
Overstaying a visa can carry penalties in some jurisdictions, including fines, administrative sanctions, or restrictions on future entry.
Where individuals are unable to depart a country before their visa expires due to circumstances beyond their control, it is advisable to retain evidence demonstrating why travel was not possible. This may include documentation such as flight cancellations, immigration and other related office closures, government announcements, or other travel restrictions.
Where possible, individuals should seek immigration advice to understand the options available to them and to mitigate potential compliance issues once normal operations resume.
Considerations for Employers
Employers with employees located in affected regions should take proactive steps to understand the situation and support their workforce.
Activate Crisis Response Protocols
Organisations should activate internal crisis response procedures and coordinate across relevant teams, including HR, global mobility, legal, and corporate security functions.
Employers should also conduct an immediate review of the location of all personnel in the region, including:
* employees on business travel
* expatriate employees
* contractors
* accompanying family members.
Maintaining accurate information about employee location and immigration status can assist employers in responding quickly if evacuation or relocation becomes necessary.
Monitor Immigration Status
Employers should review visa expiry dates for employees located in affected countries and assess whether extension applications may be required.
Where immigration authorities remain operational, employers should consider submitting extension applications or other filings where possible. Maintaining evidence of attempted filings or system outages may also be helpful if authorities later review immigration compliance.
In previous crises, governments have sometimes introduced grace periods or amnesty arrangements for individuals who were unable to depart before their visa expired. However, such measures are discretionary and cannot be assumed in advance.
Remote Working and Temporary Relocation
Where employees cannot return to their usual place of work, employers may consider temporary remote working arrangements or relocation to another country.
However, cross-border remote working can raise several legal and compliance issues, including:
* immigration permission to work in the country where the employee is located
* local employment law requirements
* individual tax residency risks
* potential corporate tax or permanent establishment exposure
Employers should seek cross-border legal and tax advice where employees may be working from another jurisdiction, especially if it may be for more than a short period.
Managing Immigration Documentation
Employers may wish to ensure that copies of key immigration documents are retained securely for employees travelling to or staying in higher-risk regions. Having access to copies of passports, visas, and residence permits can assist with replacement processes where documents are lost.
Conclusion
Periods of conflict or civil unrest can quickly create complex challenges for individuals travelling or working overseas, as well as for employers responsible for supporting an internationally mobile workforce.
Recent global events have highlighted how disruptions to travel, government services, and immigration systems can arise with little warning. Individuals may face cancelled travel plans, visa expiries, or limited access to consular services, while employers may need to address employee safety, immigration compliance. and potential relocation arrangements across multiple jurisdictions.
While such situations are often unpredictable, practical steps can help mitigate disruption. Individuals should remain informed about official guidance and maintain access to key documentation, while employers should review contingency planning, travel policies, and crisis response procedures for staff travelling internationally.
Taking a proactive and well-informed approach can help both individuals and organisations respond more effectively to periods of uncertainty while minimising potential immigration and compliance risks.
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The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.
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Meet the Authors
Claire D Nilson
Counsel
London
+44 (0) 20 7450 4592
claire.nilson@faegredrinker.com
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Abilio Jaribu
London Paralegal
London
+44 (0) 20 7450 4530
abilio.jaribu@faegredrinker.com
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Isabel Philips
Trainee Solicitor
London
+44 (0) 20 7450 4559
isabel.philips@faegredrinker.com
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Original text here: https://www.faegredrinker.com/en/insights/publications/2026/3/immigration-considerations-for-individuals-and-employers-during-periods-of-conflict-or-civil-unrest
[Category: BizLaw/Legal]
Faegre Drinker Biddle and Reath Issues Commentary: Department of Justice Introduces Department-Wide Corporate Enforcement Policy
MINNEAPOLIS, Minnesota, March 20 -- Faegre Drinker Biddle and Reath, a law firm, issued the following commentary on March 19, 2026, by associate Maria S. Downham and partners Peter W. Baldwin, Craig R. Heeren and Richard L. Scheff:
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The Department of Justice Introduces Department-Wide Corporate Enforcement Policy
Strategies and Ramifications for Companies
At a Glance
* Legal and compliance teams should revisit how the company evaluates potential disclosure decisions and ensure decision-makers understand the DOJ's incentives.
* Prompt and credible responses to internal reports can help
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MINNEAPOLIS, Minnesota, March 20 -- Faegre Drinker Biddle and Reath, a law firm, issued the following commentary on March 19, 2026, by associate Maria S. Downham and partners Peter W. Baldwin, Craig R. Heeren and Richard L. Scheff:
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The Department of Justice Introduces Department-Wide Corporate Enforcement Policy
Strategies and Ramifications for Companies
At a Glance
* Legal and compliance teams should revisit how the company evaluates potential disclosure decisions and ensure decision-makers understand the DOJ's incentives.
* Prompt and credible responses to internal reports can helpensure that potential issues are identified internally before they reach regulators, and is a condition precedent to credit in certain instances.
* Directors should understand the evolving enforcement landscape and the strategic considerations that may arise when misconduct is discovered, including devoting appropriate resources to the teams that should be positioned to respond quickly to potential misconduct and the disclosure determination.
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The US Department of Justice (DOJ or Department) recently announced what it describes as the first Department-wide corporate enforcement policy governing criminal cases. The initiative is intended to standardize how prosecutors across DOJ components -- such as US Attorney's Offices, the Criminal Division, and the National Security Division -- evaluate corporate misconduct and determine whether companies receive credit for voluntary disclosure, cooperation, and remediation.
For corporate leaders, the new policy is less about a dramatic shift in enforcement philosophy and more an effort at greater clarity and consistency, as well as clearer incentives, related to how companies respond when misconduct surfaces. By consolidating prior guidance into a single framework, the Department is attempting to make the consequences of corporate decisions more predictable.
The New Policy: Reinforcing DOJ's Incentives for Corporate Self-Reporting
At the center of the new policy is a familiar message: companies that identify misconduct, report it promptly, cooperate with investigators, and remediate effectively will be treated more favorably. Specifically, the Department's policy advises that it will decline to prosecute a company for criminal conduct when the following four factors are met:
1. Voluntary self-disclosure to an appropriate DOJ component
2. Full cooperation with the investigation
3. Timely and appropriate remediation of the conduct
4. No aggravating circumstances related to the misconduct or reflective of recidivism exist.
Even when a declination is not appropriate, the policy mandates a nonprosecution agreement, no independent compliance monitor, and substantial fine reductions for companies that attempt to meet the four factors above, but either do not meet the definition of "voluntary self-disclosure" (typically because the conduct is already known to the DOJ) or aggravating factors warrant a criminal prosecution. Finally, prosecutors retain discretion to determine appropriate resolutions over form, term length, and other factors in other cases where a company attempts to cooperate but does not meet the above standards. A copy of a flowchart produced by the DOJ that reflects the new policy is attached at the end of this alert.
The practical effect is to reinforce the DOJ's goal of encouraging companies to bring misconduct to the government before prosecutors discover it independently.
A Move toward Consistency among DOJ Components
Historically, different components of the Department, including Main Justice divisions and individual US Attorneys' Offices, developed their own voluntary disclosure policies. Indeed, shortly before this announcement, the Southern District of New York announced a new voluntary disclosure policy unique to that office. While those policies generally emphasized similar principles, the lack of a uniform approach sometimes created uncertainty about how disclosure decisions would be evaluated.
The new policy seeks to address that issue by applying a uniform baseline for corporate criminal enforcement across the DOJ. Prosecutors throughout the Department are now expected to apply the same core framework when determining how companies are treated in criminal investigations. Although not explicitly stated, the existing office-specific policies are now presumably superseded, or at least subordinate to, this Department-wide policy wherever they conflict.
From a corporate perspective, this development may make disclosure decisions somewhat more predictable, particularly for companies operating in multiple jurisdictions.
Actual Cooperation and Remediation Remain Key to a Favorable Outcome
The new policy also indicates that voluntary disclosure alone is not sufficient. Companies seeking favorable treatment must show a significant commitment to cooperation and reform. In evaluating corporate conduct, prosecutors will continue to assess:
* Whether the company provided relevant information about individual misconduct
* The speed and completeness of the company's cooperation
* The strength of remedial measures, including improvements to compliance programs
* Whether responsible individuals were disciplined or removed
These factors will affect both the level of penalty reductions and the need for an independent compliance monitor.
Continued Focus on Individual Accountability
Consistent with prior DOJ policy, the Department continues to state that corporate cooperation must include identifying individuals responsible for wrongdoing. Companies that wish to receive full cooperation credit are expected to provide all relevant facts relating to the individuals involved in the misconduct. As in prior DOJ guidance, individual accountability is still a core objective of corporate enforcement policy.
What the Policy Means for Corporate Risk Management
The new DOJ policy carries several practical implications for companies.
1. The window for voluntary disclosure may remain narrow and investigations must be structured for speed.
Because the greatest benefits of the policy are tied to voluntary disclosure before the government learns of the misconduct (with some new, but limited exceptions), timing is critical. Companies that take too long to investigate and make the understandably difficult decision of whether or not to disclose may lose the opportunity to obtain maximum cooperation credit.
In many organizations, internal investigations historically progressed cautiously to fully develop the facts before making disclosure decisions. Under the new policy environment, companies may need to adopt investigation protocols that allow for earlier engagement with enforcement authorities when appropriate. That does not mean companies should disclose prematurely, but it does mean that companies must be prepared to evaluate disclosure options quickly, strategically, and sometimes even before they know all the underlying facts at issue. Gaining a reasonable level of comfort that the company understands what went wrong, why it went wrong, and the scope of the misconduct at an early stage will be critical.
2. Compliance programs will continue to be a critical factor.
The policy also highlights the continued importance of effective compliance infrastructure. When determining whether a company deserves favorable treatment, prosecutors will look closely at whether the company:
* Maintained a credible compliance program at the time of the misconduct
* Took meaningful remedial steps after the misconduct was identified
* Implemented reforms designed to prevent recurrence
Companies that can demonstrate serious investment in compliance and remediation will remain better positioned to obtain favorable outcomes.
3. The handling of whistleblowers is important, and not a bar to credit.
The disclosure calculus is also shaped by broader enforcement developments, including DOJ initiatives designed to incentivize whistleblowers and individuals to report misconduct directly to the government. Those incentives increase the possibility that regulators will learn about potential misconduct from sources outside the company. As a result, organizations may have a limited window to identify and disclose issues before they reach enforcement authorities through other channels. Importantly, however, the new policy provides an "exception" that permits voluntary self-disclosure credit even where a whistleblower has reported the conduct first, provided certain timing (less than 120 days after receiving the whistleblower report) and other factors are met.
Steps Companies Should Consider Now
In light of the Department's new policy framework, companies may wish to revisit several aspects of their compliance and investigation processes.
1. Evaluate internal investigation procedures.
Organizations should ensure that potential misconduct can be assessed quickly and escalated to senior leadership and the board when necessary.
2. Review voluntary disclosure decision frameworks.
Legal and compliance teams should revisit how the company evaluates potential disclosure decisions and ensure decision-makers understand the DOJ's incentives.
3. Reassess compliance program effectiveness.
Companies should periodically stress-test their compliance programs to ensure they are appropriately designed, resourced, empowered, and changed based on gaps or prior issues.
4. Strengthen whistleblower response mechanisms.
Prompt and credible responses to internal reports can help ensure that potential issues are identified internally before they reach regulators, and is a condition precedent to credit in certain instances.
5. Engage the board in enforcement readiness.
Directors should understand the evolving enforcement landscape and the strategic considerations that may arise when misconduct is discovered, including devoting appropriate resources to the teams that should be positioned to respond quickly to potential misconduct and the disclosure determination.
Chart: A Flowchart Produced by the DOJ That Reflects the New Policy
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The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.
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Meet the Authors
Peter W. Baldwin
Partner
New York
+1 212 248 3147
peter.baldwin@faegredrinker.com
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Craig R. Heeren
Partner
New York
+1 212 248 3163
craig.heeren@faegredrinker.com
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Richard L. Scheff
Partner
Philadelphia
New York
+1 215 988 2840
richard.scheff@faegredrinker.com
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Maria S. Downham
Associate
Indianapolis
+1 317 237 1248
maria.downham@faegredrinker.com
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Original text here: https://www.faegredrinker.com/en/insights/publications/2026/3/the-department-of-justice-introduces-department-wide-corporate-enforcement-policy
[Category: BizLaw/Legal]
