Chief Compliance Officers Dept. of Justice

News & Analysis as of

Tea Leaves from AAG Caldwell on An Effective Compliance Program

The government is on a public relation campaign. Department of Justice and SEC officials have been making the rounds and giving important speeches on criminal prosecutions, cooperation and voluntary disclosure and ethics and...more

On the Oregon Trail: the BHP Enforcement Action and High-Risk Hospitality

The settlers who took off on this Great Emigration on the Oregon Trail did not have anything in the way of a road map. Fortunately for the modern day anti-corruption compliance practitioner, you do have road maps that can...more

Compliance Week 2015 Wrap Up

Compliance Week 2015 has ended. This year was the tenth anniversary of the annual conference and in many ways I found it to be the best one yet. Matt Kelly and his team put together a conference and experience, which was...more

They Grow Up So Fast: Alstom and the UK Bribery Act at Five Years

In April 2015, the UK Bribery Act (UKBA) celebrated its fifth birthday. In the same month, the Serious Fraud Office brought a third round of corruption charges under the UKBA in the Alstom case. Those allegations, brought...more

The Sixth Circuit Reins in the Government's Measure of False Claims Act Damages

Pharmaceutical and device companies, financial institutions, government contractors, oil and gas conglomerates, and other public and private entities continue to be in the crosshairs of aggressive federal government...more

DOJ Criminal Investigations: “Boiling the Ocean” and Other Fish Tales (Part II of IV)

The old maxim – “Justice delayed is justice denied” – is a powerful statement relating to our criminal justice system. A subject of a criminal investigation – corporate or individual — undergoes enormous stress from a...more

DOJ: Companies Need Not Expend Exorbitant Fees to Get Full Cooperation Credit

During an FCPA panel event, the Chief of the US Department of Justice’s Fraud Section advised companies to conduct “targeted” FCPA investigations, dismissing the suggestion that companies must spend hundreds of millions of...more

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA [Video]

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

Senn Interview, Part I – Investigations Under the FCPA

One of the things that I am questioned on is when to bring in outside counsel for a Foreign Corrupt Practices Act (FCPA) investigation or simply to take a look at an issue that may have raised a Red Flag but is not yet a FCPA...more

April Whistleblower News Digest | Consider Targeted Anti-Retaliation Training as part of Your Ethics and Compliance Training...

If April showers bring May flowers, then May is going to be a veritable hurricane of whistleblower-related fines (and also pollen). Our first three items come to us from the SEC, with awards and fines galore, most notably the...more

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose [Video]

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

Schlumberger OFAC Enforcement Action – A New Threat?

I have been writing lately about the rise of OFAC sanctions enforcement. OFAC and the Justice Department have started to build a close working relationship similar to that between the SEC and the Justice Department relating...more

Implementing an Effective Third Party “Audit” Program

Explore new approaches to third party audits for a more effective, risk-aligned third party risk management program.    Compliance officers have been insisting on (and should continue to insist on) including third party...more

DOJ Criminal Division Chief Provides Guidance on Corporate Charging Decisions

On April 17, 2015, Assistant Attorney General Leslie Caldwell provided helpful guidance regarding the Justice Department’s approach to corporate charging decisions in remarks that she delivered at New York University Law...more

Top Ten International Anti-Corruption Developments for March 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more

A Neglected Compliance Task: Program Assessments

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. – Groucho Marx - Sometimes compliance practitioners miss the forest from the trees. They can get lost in the details of their...more

International Anti-Corruption Enforcement Efforts

While the US Foreign Corrupt Practices Act (FCPA) is still the most widely recognized and enforcement anti-bribery and anti-corruption law across the globe, there have been a number of initiatives which will lead directly to...more

FCPA Compliance and Ethics Report-Episode 148-Mike Volkov on Criminal Enforcement of the Internal Controls Provisions of the FCPA [Video]

In this episode I visit with Mike Volkov on his recent series on internal controls under the FCPA and his belief that the DOJ may be moving towards criminal enforcement of the internal controls provisions....more

FCPA Books and Records and Internal Controls Enforcement – A Retrospective (Part III of IV)

Plan for the future because that’s where you are going to spend the rest of your life. – Mark Twain. The SEC enforces its books and records and internal controls provisions, most of which involve non-FCPA violations....more

Why It's Wise to Pay Attention to Your FCPA Compliance

Companies in the automotive industry would be wise to pay attention to Foreign Corrupt Practices Act (the “FCPA”) compliance. What has in the past been a risk management issue principally for massive multi-national...more

Miss Marple Short Stories and SEC Enforcement of the FCPA, Part V – Final Thoughts

I conclude my week of exploration of Agatha Christie’s Miss Marple short stories and the Securities and Exchange Commission’s (SEC) enforcement of the Foreign Corrupt Practices Act (FCPA) by reviewing some of the new things...more

Compliance Reponses to Economic Downturns: A Focus On The Energy Sector

I. The Problem - As I write, oil is hovering around $50 per barrel. The price will inevitably rebound, but all compliance officers need to be prepared for responding to economic downturns in their respective industries...more

Practical Advice on Risk and Compliance Program Assessments

Sometimes the compliance industry makes things harder than they really need to be. As a result, Chief Compliance Officers are left to modify and transform practices and tools to fit the real world. I understand why CCOs do...more

Who is Responsible for Complying with the FCPA?

The Department of Justice (DOJ) still faces criticism over its Foreign Corrupt Practices Act (FCPA) enforcement strategy. Some decry that it is too aggressive, that the DOJ has moved into waters Congress never intended the...more

Is Strict Liability Coming to FCPA Enforcement?

I think that a strict liability standard is coming to Foreign Corrupt Practices Act (FCPA) enforcement. A number of factors have caused me to come to this conclusion. While there may well be wide disagreement as to whether...more

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