Chief Compliance Officers Dept. of Justice

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Compliance Trends and Predictions for 2017

The past year was another great success for the compliance profession and related technologies. Compliance continues to grow as the “professionalization” of compliance continues to skyrocket. As my good friend Donna Boehme...more

General Cable FCPA Enforcement Action – Part II: The Comeback

Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more

2016 Antitrust Year in Review

Wilson Sonsini Goodrich & Rosati is pleased to present its 2016 Antitrust Year in Review. In this report, we summarize the most significant antitrust matters and developments of the past year. We begin with a look at the...more

5 Trends in Whistleblower Hotlines and Protections to Be Aware of in 2017

Every year it’s safe to assume that our list of Top 10 trends will include the latest developments pertaining to helplines, whistleblower reporting and retaliation, and this year is no exception. We begin by examining some...more

The Compliance Oversight Review Committee

This week has evolved into an exploration of different types of compliance committees a company might employ to make their compliance function more effective. On Monday, together with Baker Hughes Incorporated (BHI) Chief...more

E-Mail Communications: The Devil is on the Server

It is hard to imagine how prosecutors were able to bring cases before there was email communications. When I was a prosecutor, we looked for evidence in a lot of other sources, internal memos, calendars and other places where...more

Do You Know and Understand Your Compliance Policies?

My question appears to be fairly obvious, right? This is not a question or a quiz of every chief compliance officer. Rather, this is a question for everyone but the CCO and compliance and legal staff. Think about it....more

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

The Unsinkable Molly Brown – Compliance, Stakeholder Engagement and CSR

Tammy Grimes died earlier this week. For those of you not familiar with that name, you may well know the name of the Broadway musical which catapulted her to fame, The Unsinkable Molly Brown. Grimes garnered a Toni in 1960...more

Embraer FCPA Enforcement Action – Part II

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

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

Monster Movie Month: Episode 2 – The Bride of Frankenstein and Upcoming Events

Welcome to my second installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series and today I want to explore and, indeed, honor the second in the series but what many viewers...more

Corporate Law and Governance Update - October 2016

New Officer and Director FCA/Stark Exposure - Recent developments may merit a measured briefing to corporate leadership on the potential exposure of health industry officers and directors to financial penalties and other...more

Declinations and Profits Disgorgement – It Was There All Along

Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more

Good-Bye to Arnold Palmer and Revolutionizing Compliance

The golfing world and the world of beverages lost one of their giants earlier this week. I, of course, refer to golfing and beverage legend Arnold Palmer. The legend around the beverage is that at dinner one evening Palmer...more

How Compliance Can Be Built to Succeed! An In-Depth Discussion with Donna Boehme PART 1 [PODCAST]

Donna Boehme is back on the Masters of Disaster® podcast to discuss what it takes for compliance to succeed. Donna often refers to the new approach for the architecture of Compliance 2.0. Fundamentally, Compliance 2.0 starts...more

Hallmark 9 – Continuous Improvement: Periodic Testing and Review

You should keep track of external and internal events which may cause change to business process, policies and procedures. Some examples are new laws applicable to your business organization and internal events which drive...more

Hallmark 7-Third-Party Due Diligence and Payments

There are five steps in the life cycle of third party management. - Business Justification and Business Sponsor; - Questionnaire to Third Party; - Due Diligence on Third Party; - Compliance...more

Hallmark 6-Incentives and Disciplinary Measures

The FCPA Guidance states, “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance program...more

Hallmark 3 – Oversight, Autonomy and Resources

I. Autonomy - The DOJ has made clear over the years the importance of this hallmark. In the FCPA Guidance it states, “In appraising a compliance program, DOJ and SEC also consider whether a company has assigned...more

Compliance is a Business

Compliance is a business. That statement should not come as a shock or even a surprise to anyone who has worked in the corporate world. Every part of a business should work towards doing business. Yet many compliance...more

The Real Value of Lawyers to Compliance

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 UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

Want to Work in Compliance – Learn How to Read a Balance Sheet

One of the most interesting tag lines I heard at Compliance Week 2016 was the following, if you want to work in my compliance department; you need to learn how to read a balance sheet. I thought that single line encapsulated...more

Do Former Prosecutors Make Good CCOs?

A number of companies have adopted the requirement that a new Chief Compliance Office come from the ranks of former federal prosecutors. I am not sure exactly why companies have adopted this requirement. Perhaps company...more

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