News & Analysis as of

Chief Compliance Officers Dept. of Justice

This Week in FCPA-Episode 54, the Rubber Match Edition [Video]

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Tom reports on Compliance Week 2017? 2. If the DOJ releases new information in the form of the...more

Day 20 - Compliance Leadership from the Bottom [Video]

by Thomas Fox on

The key concept from the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Program (Evaluation) is operationalization. For instance, under the query Shared Commitment is the following question - “How is...more

Compliance Lessons for Executive Leadership from The Wells Fargo Investigation Report

by Thomas Fox on

Compliance lessons from truly one of the most damning reports of complete corporate failures around ethics and culture that has recently been seen....more

Operationalizing Compliance: Part I – It All Starts with Pizza

by Thomas Fox on

With the release of their Evaluation of Corporate Compliance Programs (Evaluation) in February, the Department of Justice (DOJ) emphasized yet again the importance of actually doing compliance and not simply having a paper...more

The ‘Way of Compliance' Adds Value Regardless of Who's in the White House

I am astonished there are still so many articles out there advising readers on how to establish the imperative for compliance. Nearly 15 years after the rise of compliance to an officer-level position, with significant...more

U.S. Department of Justice Issues New Guidance on Evaluation of Corporate Compliance Programs

by Poyner Spruill LLP on

On February 8, 2017, the Fraud Section of the U.S. Department of Justice (DOJ) published new guidance titled “Evaluation of Corporate Compliance Programs” (Compliance Guidance), which can be found at...more

Attorney General Sessions reemphasizes DOJ commitment to FCPA enforcement, individual accountability: 4 takeaways for business

by DLA Piper on

As the Trump Administration wraps up its first 100 days, practitioners have a bit more clarity regarding how the new Administration will assess corporate compliance programs, cooperation and white collar cases. Over the past...more

CCOs Say Policies Are Getting Stronger; Adoption of Technology – Not So Much

by NAVEX Global on

KPMG recently published its latest survey of chief compliance officers. The report highlights the increasing value of effective Compliance. It also reveals growing pains of our industry, specifically in maximizing...more

How to garner a NPA and Declination

by Thomas Fox on

It certainly did not take long for companies to see the benefit of the Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Pilot Program as there where two public declinations granted by the DOJ for companies...more

Defining the Duty of the Board of Directors over Compliance Functions

by Ruder Ware on

I recently posted a blog article about a document released by the Department of Justice entitled “Evaluation of Compliance Programs.” As the title of the document might suggest, the DOJ release covers a variety of issues it...more

LRN Compliance Program Effectiveness Report: Part III

by Thomas Fox on

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

LRN Compliance Program Effectiveness Report: Part II

by Thomas Fox on

Yesterday I began a series on the LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report) by outlining some of its general findings. Today, I want to focus on its detailed findings as it...more

Doing Business in Cuba Under the FCPA

by Thomas Fox on

I want to consider the impending opening of Cuba to US business, what you can do now and what you must wait for until the embargo is lifted; all from the perspective of compliance with the Foreign Corrupt Practices Act...more

Operationalizing Compliance – Natural Partners and Breaking Down Walls (Part I of IV)

by Michael Volkov on

An effective compliance program is built on internal coordination and relationships. Applying the Justice Department’s terminology, an effective compliance program is one that is operationalized. At first glance, you may...more

DOJ Extends FCPA Pilot Program

On Friday, March 10, Kenneth Blanco, the acting assistant attorney general for the Department of Justice’s Criminal Division, announced that the FCPA Pilot Program would not expire on April 5, 2017, as originally scheduled....more

Use of Social Media In a Best Practices Compliance Program

by Thomas Fox on

Why should you integrate social media into your compliance program? In a compliance program, a large portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the...more

Creation of Roundabout and Operationalization of Compliance

by Thomas Fox on

Readers of this blog know of my love for progressive rock music and that my favorite prog rock group is Yes. You might understand how thrilled I was when the Wall Street Journal (WSJ), of all places, ran an interview with...more

DOJ Publishes New Guidance for Compliance Programs

by Ropes & Gray LLP on

On February 8, 2017, the Fraud Section of the U.S. Department of Justice (the “DOJ”) published a guide for companies called “Evaluation of Corporate Compliance Programs” (the “Guidance”). The Guidance is composed of common...more

The General Cable FCPA Enforcement Action

by Thomas Fox on

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning run of 2016 Foreign Corrupt Practices Act (FCPA) enforcement actions right up to the end of the year with the announcement...more

DOJ issues additional guidance on how it evaluates corporate compliance programs

by DLA Piper on

In a notable but quiet development, the Department of Justice's Fraud Section recently issued additional information about how DOJ prosecutors evaluate a business's compliance program "in conducting an investigation …,...more

DOJ Sheds Light on How it Evaluates Corporate Compliance Programs

by Bryan Cave on

Earlier this month, the Criminal Division of the U.S. Department of Justice (“DOJ”) issued guidance on how it evaluates corporate compliance programs when investigating a corporate entity, deciding whether to bring charges,...more

Recent DOJ Guidance Highlights Substantial Benefits of Being Proactive About Compliance

by Epstein Becker & Green on

The Criminal Fraud Section of the U.S. Department of Justice (DOJ) recently released guidance entitled “Evaluation of Corporate Compliance Programs,” setting forth over 100 questions in 11 categories that the Fraud Section...more

How Effective is Your Corporate Compliance Program?

On February 8, the Fraud Section of the United States Department of Justice (DOJ) posted on its website a document entitled “Evaluation of Compliance Programs” (the “Guidance”). This is the first formal guidance issued by the...more

DOJ’s Compliance Program Evaluation: the Role of the CCO (Part II of IV)

by Michael Volkov on

DOJ’s Compliance Evaluation highlights important trends in the role and independence of the Chief Compliance Officer. DOJ has stopped short of requiring direct reporting of a CCO to a CEO or other senior officer but it is...more

Under the Dark of Night, DOJ Moves the Compliance Ball (Part I of IV)

by Michael Volkov on

In an unusual move, the Justice Department issued an important document in the dead of night – Evaluation of Corporate Compliance Programs. We have no explanation from the Justice Department for the issuance of this...more

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