Chief Compliance Officers Dept. of Justice

News & Analysis as of

The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal...more

CCO Independence, Authority and Resources as Indicia of an Effective Compliance Program

At the Opening Session of Compliance Week 2016, Stephen L. Cohen, Associate Director of Enforcement, Securities and Exchange Commission (SEC) and Andrew Weissmann, Chief of the Department of Justice (DOJ) Criminal Division’s...more

The SEC, CCOs and Compliance Programs

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Joe Howell on the PCAOB, Audits and Compliance – Part IV

This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly...more

[Webinar] FCPA Spotlight: Best Practices for Controls and Records - May 20th, 1:00pm EDT

In this era of increased attention to corruption, the U.S. Justice Department and Securities and Exchange Commission are increasingly using the FCPA's books and records and internal controls provisions to prosecute improper...more

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

Shakespeare Week – Part III: Much Ado About Nothing and Incorporation of Social Media into Your Compliance Program

How does Shakespeare portend social media in the 21st century? I would submit that one only need look at Much Ado About Nothing to see how it should all play out. As with all Shakespeare’s plays there is quite a bit going on...more

Assess and enhance your compliance program in this time of elevated risks

Continuous changes in the healthcare industry are delivering exciting innovations and new opportunities, but they are also creating new threats. Healthcare organizations face changing operational and enforcement environments...more

New DOJ Guidance and FCPA Pilot Program – Part IV: Impact

This week I have been exploring the implications of the Department of Justice (DOJ) announcement last week of a new program Pilot Program around Foreign Corrupt Practices Act (FPCA) enforcement, together with the document,...more

New DOJ Guidance and FCPA Pilot Program – Part II: Cooperation

Today, I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement (herein “Pilot Program”)....more

New DOJ Guidance and FCPA Pilot Program, Part I-Introduction

Last week the Department of Justice (DOJ) held a Press Conference, open to all, led by Andrew Weissmann and Leslie Caldwell. At this Press Conference, they announced the culmination of several ongoing initiatives into a new...more

A Lesson in Compliance: Part II

The following is an interview with Richard Bistrong and Alessia Lamonaca, Program Marketing Specialist at Resolver Inc. In “A Lesson in Compliance with Richard Bistrong: Part I“, Richard discussed the thought process...more

DOJ Fraud Section Chief and Compliance Counsel shed light on compliance program evaluations: the four areas of inquiry

There has been quite a buzz since the Department of Justice announced last year that it had appointed a compliance counselor to aid prosecutors’ evaluation of compliance programs and would focus on individual culpability for...more

The Olympus Debacle: Why Internal Whistleblowing is a Good Thing for Compliance

The U.S. Department of Justice announced last week that Olympus Corporation of the Americas (OCA) agreed to pay $646 million to resolve three cases relating to its longstanding practice to bribe doctors and hospitals in the...more

Interview: Erica Salmon Byrne EVP Governance & Compliance

Word of the Year: Culture - Erica Salmon Byrne shares insights into benchmarking best practices, the recent push for compliance from government to start-ups, and how it all impacts culture....more

Raising the Stakes for AML Compliance Officers: Court Refuses to Rule Out Potential Liability for Role in Employer's BSA...

Why it matters - A federal court judge in Minnesota has rejected the motion of a former chief compliance officer to dismiss the U.S. government's claim that he is liable under the federal Bank Secrecy Act for his...more

Ethics and Compliance Predictions for 2016

The New Year brings new promise for compliance professionals. I always sympathize with compliance officers because of their inevitable conflict – their idealism often is confronted by corporate realities – a CEO who...more

How Does an Antitrust Compliance Program Meet DOJ Standards? For the First Time, the DOJ Explains

For the first time, the Department of Justice has described what makes a company-imposed antitrust compliance pro­gram effective enough to earn a recommended lowering of the antitrust fine under the Unit­ed States Sentencing...more

Compliance Counsel Metrics – Part III: Program Evolution and Incentivizing Compliance

Today, we continue our exploration of the new Department of Justice (DOJ) Compliance Counsel and the metrics laid out by Assistant Attorney General Leslie R. Caldwell who called for her review of compliance programs. These...more

DOJ Announces New Compliance Counsel and Outlines Metrics for Evaluating Corporate Compliance Programs Under Scrutiny

In July 2015, the U.S. Department of Justice’s Criminal Division revealed that it was hiring a Compliance Counsel to assist in assessing the quality and effectiveness of companies’ corporate compliance programs under scrutiny...more

DOJ’s Pursuit of Individual Liability for Corporate Misconduct: The Yates Memo

Cooperation credit is a critical issue for corporations that become embroiled in investigations or enforcement activity. In both the criminal and civil contexts, it is the only way to mitigate the financial impact of...more

Whom Should You Suspend During an Internal Investigation?

Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more

Evolving Best Practices in FCPA Compliance Training

As Houston, TX, is the epicenter of Foreign Corrupt Practices Act (FCPA) enforcement, most energy companies in my hometown have mature compliance programs or at least more mature than in other industries, which have not gone...more

2015-16 Compliance Developments & Calendar for Private Fund Advisers

Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more

Compliance Connected – Line of Sight, Part I

Sometimes the simplest visual can provide the greatest insight about transformation. I had that particular insight when I recently had the chance to catch up with Scott Lane, Chief Executive of the Red Flag Group, at the SCCE...more

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