News & Analysis as of

Chief Compliance Officers Cooperative Compliance Regime

Dechert LLP

Measure Twice, Cut Once: New DOJ Compliance Certifications Put CEOs and CCOs at Risk of Individual Criminal Liability

Dechert LLP on

Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more

The Volkov Law Group

DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)

The Volkov Law Group on

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement...more

The Volkov Law Group

DOJ Compliance Program Certification Requirements (Part I of III)

The Volkov Law Group on

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action.  DOJ has adopted this new requirement to...more

Jenner & Block

DOJ Initiatives Aim to Empower Chief Compliance Officers and Strengthen Corporate Compliance Programs

Jenner & Block on

On March 25, 2022, Kenneth Polite, Assistant Attorney General for the Department of Justice (DOJ)’s Criminal Division, delivered a speech at NYU Law School’s Program on Corporate Compliance and Enforcement announcing...more

Burr & Forman

FINRA Clarifies CCO Supervisory Liability

Burr & Forman on

In the securities industry, regulators like to say that the compliance professionals are their “partners.” But every so often, those regulators charge one of their compliance partners with rule violations. The compliance...more

Thomas Fox - Compliance Evangelist

2020 Update Review: Part 1 – Key Themes

Late Monday, the Department of Justice (DOJ) without fanfare, released an update to its 2019 Evaluation of Corporate Compliance Programs, the 2019 Guidance. ...more

The Volkov Law Group

Keeping Your Eye on the Risk Ball

The Volkov Law Group on

Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces.  I am exaggerating a little bit to make...more

Ballard Spahr LLP

CFPB issues policy statement on compliance resources

Ballard Spahr LLP on

The CFPB published a policy statement in today’s Federal Register to announce that, going forward, it is establishing a new “Compliance Aids” designation for certain Bureau guidance.  The policy statement becomes applicable...more

The Volkov Law Group

Ethics and Compliance Trends and Predictions for 2020

The Volkov Law Group on

2019 was a big year for ethics and compliance.  In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more

Thomas Fox - Compliance Evangelist

Films of Val Lewton: Part 3 – I Walked with a Zombie and 20 Questions for the Board

Let’s consider a list of 20 questions to reflect the oversight role of directors. These are questions the Board should ask of both senior management and the Board itself. The questions are not intended to be an exact...more

Alston & Bird

DOJ Updates Guidance on Evaluating Corporate Compliance Programs

Alston & Bird on

The Department of Justice Criminal Division revised and shuffled two-year-old guidance to help prosecutors evaluate corporate compliance policies when making charging decisions. Our White Collar, Government & Internal...more

Thomas Fox - Compliance Evangelist

The CCO as a Futurist

Every Chief Compliance Officer (CCO) and compliance practitioner who thinks about their compliance program one, three or five years down the road is a budding futurist. The Compliance Week 2017 Annual Conference opened this...more

Thomas Fox - Compliance Evangelist

From Dr. No to an Agile Compliance Program

How agile is your compliance program? How does this fit into the operationalization requirement laid out in the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation)? While many have argued...more

Thomas Fox - Compliance Evangelist

Moving into New Space – Communicating the Operationalization of Compliance

While many are no doubt celebrating Cinco de Mayo today, it is also the 66th anniversary of the first foray into space for the US, albeit in a sub-orbital way. It was on this date in 1961, that Navy Commander Alan Shepard was...more

Thomas Fox - Compliance Evangelist

Writing Tips Inform Your Compliance Program

Today I consider some tips from the world of fiction composition for your compliance program. These lessons are applicable for both the design, enhancement and implementation of your compliance regime. Moreover, by...more

The Volkov Law Group

Lessons Learned and Compliance Trends from the VW and Takata Scandals (Part III of III)

The Volkov Law Group on

When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more

Thomas Fox - Compliance Evangelist

When the Compliance Counsel Speaks, CCOs Should Listen

I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more

Thomas Fox - Compliance Evangelist

Tangled Up in Blue and Rethinking the Role of the Compliance Professional

Today, I conclude my tribute to Bob Dylan-Nobel Laureate, by discussing my personal favorite Bob Dylan song, Tangled up in Blue. The time shifts and jumps in the song have always resonated with me. Indeed, it is one of the...more

Thomas Fox - Compliance Evangelist

Passion for Compliance

Norbert Schemansky died last week. Are you as unfamiliar with that name as I was? I must sheepishly admit I had never heard of him before I read his obituary in the New York Times (NYT). Schemansky was one of the world’s...more

Thomas Fox - Compliance Evangelist

John Hancock and Cultural Transformation

On this day in 1776, members of Congress affixed their signatures to an enlarged copy of the Declaration of Independence. Congress adopted the more poetic Declaration of Independence, drafted by Thomas Jefferson, on July 4....more

The Volkov Law Group

The Real Value of Lawyers to Compliance

The Volkov Law Group on

The legal profession is transforming itself, especially in the area of compliance. Lawyers are an invaluable part of a compliance program. They provide important perspective and understanding of risk, they help a company to...more

The Volkov Law Group

New York Department of Financial Services Issues New AML and Sanctions Regulations

The Volkov Law Group on

The New York DFS finalized its new AML and Sanctions screening regulations. Interestingly, the NYDFS backed off its original proposal to require a Chief Compliance Officer to certify to a compliance “finding” that the...more

Thomas Fox - Compliance Evangelist

Innovation in Compliance – Part III: Design Thinking

I continue to explore innovation in the compliance function by considering how design thinking can help the Chief Compliance Officer (CCO) move forward in an innovative cutting edge manner to make a compliance program not...more

Thomas Fox - Compliance Evangelist

Innovation in Compliance Week, Part II-Superforecasting

I continue my Innovation in Compliance series today by discussing “superforecasting” and its use by a compliance function. Imagine that as a Chief Compliance Officer (CCO), you could create a team which might well...more

The Volkov Law Group

When Lawyers Get in the Way of Compliance

The Volkov Law Group on

I hate to pick on lawyers. I have been practicing law for nearly 35 years. I have worked with and met a lot of lawyers, some great, some good and some not so good. Lawyers can sometimes be their own worst enemies. When...more

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