Updated DOJ Guidance calls on corporations to devote additional resources and attention to detect and prevent misconduct.
A well-structured and effective compliance program must evolve with lessons learned, be understood...more
Companies must now address three questions proactively.
On April 30, 2019, the DOJ’s Criminal Division issued updated guidance on how it will evaluate corporate compliance programs in its charging decisions going forward....more
5/14/2019
/ Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Department of Justice (DOJ) ,
Employee Training ,
Guidance Update ,
Internal Controls ,
Risk Assessment ,
Risk Management ,
Third-Party Risk ,
Training ,
Whistleblower Protection Policies ,
Whistleblowers
On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more
4/15/2016
/ Bribery ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Internal Investigations ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes ,
Yates Memorandum
A leak of 11.5 million documents from a law firm in Panama may implicate politicians, criminals, and celebrities in sheltering of fortunes in offshore tax havens through the use of shell companies. Called the “Panama Papers,”...more
On January 13, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury (Treasury), as part of its continued efforts to combat money laundering, issued its first Geographic...more
On September 9, 2015, Deputy Attorney General Sally Quillian Yates introduced a new policy aimed at aggressively prosecuting individuals for white-collar crimes. A product of a DOJ working group that started under former...more