VARIABLE |
APPLICABLE TO |
TYPE |
DESCRIPTION |
ACCEPTS_RESPONSIBILITY |
DP/NP |
Boolean |
Indicates whether organization accepted responsibility. See "ACCEPTS_RESPONSIBILITY_DESC" for details. |
ACCEPTS_RESPONSIBILITY_DESC |
DP/NP |
String |
Describes how the firm was credited with having accepted responsibility for the relevant crimes. |
ADDITIONAL_REGULATORY_FINE_OR_PAYMENT |
DP/NP/plea/trial conviction |
Integer |
|
AGREEMENT_LENGTH |
DP/NP |
Integer |
Length of agreement in months. |
AGREEMENT_REQUIRED_NEW_POSITIONS |
DP/NP |
Boolean |
Indicates whether or not the agreement stated new positions be created at a firm, typically related to compliance. See "AGREEMENT_REQUIRED_NEW_POSITIONS_DESC" for details. |
AGREEMENT_REQUIRED_NEW_POSITIONS_DESC |
DP/NP |
String |
Description of new positions to be created at a firm, typically related to compliance. |
AGREEMENT_REQUIRED_OUTSIDE_AUDITORS_OR_EXPERTS |
DP/NP |
Boolean |
Indicates if the agreement required outisde auditors or experts. See "AGREEMENT_REQUIRED_OUTSIDE_AUDITORS_OR_EXPERTS_DESC" for details. |
AGREEMENT_REQUIRED_OUTSIDE_AUDITORS_OR_EXPERTS_DESC |
DP/NP |
String |
Describes how firm must retain outsiders to examine books and records or to provide other assistance, typically in implementing compliance provisions. |
CASE_ID |
All except NP |
String |
Case id as given in PACER. Takes the form of: 1:09-cr-12345 |
CASE_NAME |
acquittal/dismissal/DP/plea/trial conviction |
String |
Name of case (e.g. "U.S.A. v. Walmart"). |
CITATION_AND_DESCRIPTION |
DP/NP |
String |
Additional citation to the agreement and description of its contents |
CIVIL_JUDGMENT_OR_SETTLEMENT |
DP/NP |
Boolean |
Indicates whether there was a civil judgment or settlement. See "CIVIL_JUDGMENT_OR_SETTLEMENT_AMT" and "CIVIL_JUDGMENT_OR_SETTLEMENT_DESC" for details. |
CIVIL_JUDGMENT_OR_SETTLEMENT_AMT |
DP/NP |
Integer |
Amount of civil judgment or settlement. |
CIVIL_JUDGMENT_OR_SETTLEMENT_DESC |
DP/NP |
String |
Description of civil judgment or settlement. |
COMPANY |
All |
String |
Name of company. |
COMMUNITY_SERVICE_OR_OTHER |
DP/NP/plea/trial conviction |
Integer |
Amount of community service or other punishment, in dollars. |
COMPLIANCE_PROGRAM_DESC |
DP/NP |
String |
Description of compliance program. |
COMPLIANCE_PROGRAM_REQUIRED_BY_AGREEMENT |
DP/NP |
Boolean |
Indicates if agreement required a compliance program. |
COMPLIANCE_REQUIRED_BY_REGULATORS |
DP/NP |
Boolean |
Indicates if a regulatory agency required a compliance program. |
COMPLIANCE_REQUIRED_BY_REGULATORS_DESC |
DP/NP |
String |
Description of compliance program required by regulators. |
COUNTRY |
All |
String |
Country where company is headquartered. If a subsidiary, this indicates where the subsidiary is headquartered. |
DATE |
All |
Date (YYYY-MM-DD) |
For deferred and non-prosecution agreements, this field reflects the date of the agreement. For acquittals, dismissals, plea agreements, and trial convictions this field reflects the date of the judgement or dismissal. For declinations, this field reflects the date of the declination. |
DESCRIPTION_OF_PAYMENTS |
DP/NP |
String |
Additional description of the different types of payments required by the agreement. |
DISPOSITION_TYPE |
All |
String |
Describes how the dispute with an organization was resolved. Can take on the following values: Acquittal, declination, dismissal, DP, NP, plea, trial convication. |
DOJ_CAN_UNILATERALLY_TERMINATE |
DP/NP |
Boolean |
Indicates if the DOJ can unilaterally terminate the agreement. See "DOJ_CAN_UNILATERALLY_TERMINATE_DESC" for details. |
DOJ_CAN_UNILATERALLY_TERMINATE_DESC |
DP/NP |
|
Describes the provision specifying that prosecutors can determine, without being subject to additional review, that a firm is in breach of an agreement, in which case the agreement is no longer effective and prosecutors have the option to proceed with a criminal prosecution. |
FINANCIAL_INSTITUTION |
All |
Boolean |
Indicates whether or not a company is a financial insitution. |
FINE |
DP/NP/plea/trial conviction |
Integer |
Amount of fine in U.S. dollars. |
FINE_CALCULATION_INCLUDED |
DP/NP |
Boolean |
Indicates if the agreement included a fine calculation. See "FINE_CALCULATION_INCLUDED_DESC" for more details. |
FINE_CALCULATION_INCLUDED_DESC |
DP/NP |
String |
Describes calculations under the U.S. Sentencing Guidelines for the fine amount. |
FINE_DESCRIPTION |
DP/NP |
String |
Describes how fine was apportioned. |
FORFEITURE_DISGORGEMENT |
DP/NP/plea/trial conviction |
Integer |
Amount of forfeiture and/or disgorgement in U.S. dollars. |
INDEP_MONITOR_REQ |
DP/NP |
Boolean |
Indicates whether or not an independent monitor was required. See "INDEP_MONITOR_REQ_DESC" for more details. |
INDEP_MONITOR_REQ_DESC |
DP/NP |
String |
Describes requirements that an independent actor be retained to supervise implementation of a compliance program. |
JUDGMENT_DATE |
acquittal/dismissal/plea/trial conviction |
Date (YYYY-MM-DD) |
Date of judgment. |
JURISDICTION |
All |
String |
The U.S. Attorney's Office(s) involved. |
MONITOR_FORMER_PROSECUTOR |
DP/NP |
Boolean |
Indicates whether or not the monitor was a former prosecutor. |
MONITOR_LENGTH |
DP/NP |
Integer |
Number of months agreement requires monitorship. |
MONITOR_NAME |
DP/NP |
String |
Name of the monitor. |
MONITOR_SELECTOR |
DP/NP |
String |
Describes who selected the monitor. |
MUST_COMPORT_WITH_USSG_OR_AUDIT_COMPLIANCE |
DP/NP |
Boolean |
Indicates whether or not compliance programs by audited/assessed/review. See "MUST_COMPORT_WITH_USSG_OR_AUDIT_COMPLIANCE_DESC" for more details. |
MUST_COMPORT_WITH_USSG_OR_AUDIT_COMPLIANCE_DESC |
DP/NP |
String |
Describes provisions in agreement requiring compliance programs be audited for their effectiveness or periodically assessed or reviewed. |
NAICS |
All |
Integer |
Six digit integer describing the industry to which the company belongs. There is some degree of interpretation here so these may not always fit. More on NAICS codes can be found here |
OTHER_AGREEMENT_REQUIRED_GOVERNANCE_CHANGES |
DP/NP |
Boolean |
Indicates presence of other required governance changes. See "OTHER_AGREEMENT_REQUIRED_GOVERNANCE_CHANGES_DESC" for more details. |
OTHER_AGREEMENT_REQUIRED_GOVERNANCE_CHANGES_DESC |
DP/NP |
String |
Provides details on any parallel agreements involving the same conduct but with another enforcer who also imposes changes on a firm's governance, such as compliance program changes. |
OTHER_COMPLIANCE_OFFICER_OR_CONSULTANT_REQUIRED |
DP/NP |
Boolean |
Indicates whether another compliance officer or consultant was required. See "OTHER_COMPLIANCE_OFFICER_OR_CONSULTANT_REQUIRED_DESC" for more details. |
OTHER_COMPLIANCE_OFFICER_OR_CONSULTANT_REQUIRED_DESC |
DP/NP |
String |
Describes any requirement that the firm retain a compliance consult or create a position for a compliance officer that is not a third party or wholly independent monitor, but a person working as an agent of the firm tasked with compliance work. |
PARALLEL_CIVIL_SUIT |
DP/NP |
Boolean |
Indicates presence of a private action filed against the firm arising from the same conduct. |
PARALLEL_REGULATORY_ACTION_OR_LOCAL_PROSECUTOR |
DP/NP |
Boolean |
Indicates presence of parallel regulatory action or local prosecutor. See "PARALLEL_REGULATORY_ACTION_OR_LOCAL_PROSECUTOR_DESC" for details. |
PARALLEL_REGULATORY_ACTION_OR_LOCAL_PROSECUTOR_DESC |
DP/NP |
String |
Describes any action filed by civil enforcement authorities or a state or local prosecutor arising from the same conduct. |
PLEA_DATE |
plea |
Date (YYYY-MM-DD) |
Date of plea agreement. |
PRE_AGREEMENT_COMPLIANCE |
DP/NP |
Boolean |
Indicates presence of pre-agreement compliance. See "PRE_AGREEMENT_COMPLIANCE_DESC" for details. |
PRE_AGREEMENT_COMPLIANCE_DESC |
DP/NP |
String |
Description of pre-agreement compliance measures that the firm undertook. |
PRIMARY_CRIME_CODE |
All |
String |
Can take on the following values:
Accounting Fraud: |
Federal crimes relating to false statements or entries, such as under 18 U.S.C. § 1001 (a)(3). |
Antitrust: |
Prosecutions brought under the Sherman Antitrust Act's criminal provisions. |
Act to Prevent Pollution from Ships (APPS): |
Violations of the Act to Prevent Pollution from Ships (APPS), 33 U.S.C. §§ 1905-1915. |
Bank Secrecy Act |
Prosecutors brought under the Bank Secrecy Act, including 18 U.S.C. § 5331-5332 regarding failure to file reports of financial transactions or lack of adequate controls to prevent money laundering. |
Bribery |
Violations of federal bribery and gratuities statutes such as 18 U.S.C. § 201. |
Controlled Substances |
These include violations of the Controlled Substances Act (CSA). |
Environmental |
These include prosecutions brought under any of the range of federal environmental statutes, including the Clean Air Act, the Clear Water Act, the Resource Conversation and Recovery Act, and statutes regulating marine pollution, handling of hazardous waste, and others.
|
FCPA (Foreign Corrupt Practices Act) |
These include criminal prosecutions brought under the FCPA's bribery provisions and willful violations of the internal controls and books and records provisions, 15 U.S.C. §§ 78dd-1, et seq. A useful federal resource guide explaining these provisions is available at: https://www.justice.gov/sites/default/files/criminal-fraud/legacy/2015/01/16/guide.pdf |
False Statements |
These include prosecutions for making false statements to federal authorities under statutes including 18 U.S.C. § 1001. |
Firearms |
Violations of federal criminal firearms registration and sales statutes. |
Food |
Criminal violations of federal food safety laws including for adulterating or misbranding under the Federal Food, Drug, and Cosmetic Act (FDCA). |
Fraud |
These include mail fraud and wire fraud prosecutions brought under 18 U.S.C. § 1341 and 1343, as well as other fraud crimes, such as conspiracy to defraud the federal government, 18 U.S.C. §371. However, health care fraud, securities fraud, and tax fraud cases are listed separately. |
Gambling |
Illegal gambling business under 18 U.S. Code § 1955 or violations of other federal gambling laws. |
Health Care Fraud |
These include prosecutions brought under 18 U.S.C. § 1347. |
Immigration |
These include prosecutions brought for violating immigration rules concerning employment of noncitizens and unlawful employment practices under 8 U.S.C. §1324a and b, as well as crimes concerning bringing in and harboring illegal aliens under 8 U.S.C. §1324. |
Import / Export |
These include violations of U.S. customs regulations concerning imports and exports as well as violations of U.S. sanctions regarding international trade and financial transactions, including violations of the International Emergency Economic Powers Act (IEEPA). |
Kickbacks |
Violation of the federal anti-kickback statutes, including 42 U.S. Code § 1320a-7b. |
Money Laundering |
These include prosecutions brought under 18 U.S.C.§1956-1957 and under 18 U.S.C. §5324 regarding structuring transactions to evade reporting requirements. |
Obstruction of Justice |
These include prosecutions brought under 18 U.S.C. § 1503 and companion statutes. |
OSHA |
Workplace safety crimes, involving the willful violation of a worker safety standard in the Occupational Safety and Health Act, as well as other workplace safety statutes such as and the Federal Mine Safety and Health Act. |
Other |
Additional federal crimes, of which there are many, that do not fall within the categories described here. |
Pharmaceutical |
These include prosecutions brought under the Federal Food, Drug, and Cosmetic Act (FDCA) as well as anti-kickback and other related claims involving pharmaceutical sales and branding. |
Securities Fraud |
These include prosecutions brought under 18 U.S.C. § 1348. |
Tax Fraud |
These include prosecutions brought under 26 U.S.C. § 7201 and 7201 regarding attempted federal tax evasion and fraud and false statements to tax authorities. |
Wildlife |
Prosecutions under wildlife conversation laws including under Endangered Species Act and the Lacey Act. |
|
PRIVACY_WAIVER |
DP/NP |
Boolean |
Indicates presence of privacy waiver in agreement. See "PRIVACY_WAIVER_DESC" for more details. |
PRIVACY_WAIVER_DESC |
DP/NP |
String |
Describes provisions regardings company's waiver of attorney client privilege or confidential communications. |
PROBATION_LENGTH |
plea/trial conviction |
Integer |
Lenght of probation, in months. |
REASONS_OR_RELEVANT_CONSIDERATIONS_FOR_LENIENCY |
DP/NP |
Boolean |
Indicates presence of reasons or relevant considerations in agreement. See "REASONS_OR_RELEVANT_CONSIDERATIONS_FOR_LENIENCY_DESC" for more details. |
REASONS_OR_RELEVANT_CONSIDERATIONS_FOR_LENIENCY_DESC |
DP/NP |
String |
Describes why a deferred or non-prosecution agreement was entered with the firm. |
REG_AGENCY |
DP/NP |
String |
Describes civil administrative agency involved in the resolution of the enforcement actions involving the same conduct. |
REGULATORY_DISGORGEMENT_RESTITUTION_FORFEITURE |
DP/NP |
Integer |
Describes payments imposed by civil enforcers as disgorgement, or return of net proceeds from a crime, or a civil forfeiture of amounts related to a crime. |
REGULATORY_FINE |
DP/NP |
Integer |
Amount of penalty imposed by civil enforcers. |
RESTITUTION |
DP/NP/plea/trial conviction |
Integer |
Amount of restitution in U.S. dollars. |
STATEMENT_OF_FACTS |
DP/NP |
Boolean |
Indicates presence of statement of facts in agreement. See "STATEMENT_OF_FACTS_DESC" for more details. |
STATEMENT_OF_FACTS_DESC |
DP/NP |
String |
Describes if the agreement includes a statement detailing the events and activities leading to the criminal prosecution. |
SWISS_BANK_PROGRAM |
DP/NP |
Boolean |
Indicates whether or not agreement was part of the DOJ's Swiss Bank Program. |
TICKER |
All |
String |
Ticker symbol for company, if public. |
TOTAL_PAYMENT |
DP/NP/plea/trial conviction |
Integer |
Sum of fine, forfeiture, restitution, etc. amounts. |
TOTAL_REGULATORY |
DP/NP |
Integer |
The total payment to civil enforcers by the firm. |
UNRELATED_TERMS |
DP/NP |
Boolean |
Indicates presence of unrelated terms. See "UNRELATED_TERMS_DESC" for description. |
UNRELATED_TERMS_DESC |
DP/NP |
String |
Describes whether any terms in the agreement not relate to the criminal activity itself or a penalty for engaging in that activity, but instead imposed an additional consequences on the firm not designed to remediate that criminal activity or compensation victims. |
US_PUBLIC_CO |
All |
Boolean |
Indicates whether or not entity was a U.S. public company. |