News & Analysis as of

Chief Compliance Officers The Foreign Corrupt Practices Act

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

Data Analysis In a Compliance Best Practices Program

by Thomas Fox on

An in-depth look at the use of data analysis in a best practices compliance program under the Foreign Corrupt Practices Act (FCPA), UK Bribery Act or other anti-corruption compliance regime....more

The Risk Management Process in Compliance

by Thomas Fox on

An exploration of risk forecasting, risk assessment and risk-based monitoring for the compliance profession. ...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

Lawyers and Culture in the Financial Services Industry

by Michael Volkov on

The rise of the compliance profession has had a number of positive impacts on the corporate governance landscape. One of the most important results has been increased focus on corporate culture....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

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

The Fall of the Alamo and Empowerment of the Compliance Professional

by Thomas Fox on

Today is the anniversary of the most historic day of many in the history of the great state of Texas, the date of the fall of the Alamo. While March 2, Texas Independence Day, is when Texas declared its independence from...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

Horse-trading Your Way to a Better Compliance Program

by Thomas Fox on

On this day in 1836, Colonel William Barrett Travis issued his now famous call for help on behalf of the Texan troops defending the Alamo. It has gone down as one of the great cries for freedom-loving peoples everywhere. The...more

The Embraer FCPA Enforcement Action

by Thomas Fox on

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning 2016 run of Foreign Corrupt Practices Act (FCPA) decisions with the announcement of the resolution of the Embraer SA...more

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part II

by Thomas Fox on

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of...more

The FCPA Pilot Program Disciplinary Standards (Part II of II)

by Michael Volkov on

Returning to the FCPA Pilot Project requirements for timely and appropriate remediation, the Justice Department added three new elements, one of which reinforces the CCO “independence” requirement. The two other elements for...more

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part I

by Thomas Fox on

I guess Matt Kelly cannot leave his journalist roots for it was he who broke the story within the greater compliance community that the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of...more

Unpacking the Justice Department’s Compliance Remediation Standards (Part I of II)

by Michael Volkov on

The Justice Department has a lot to be proud about when it comes to its FCPA enforcement program. In one area in particular – promoting effective ethics and compliance strategies – DOJ’s FCPA prosecutors have played a...more

A ‘Most Daring Act’ and the SQM FCPA Enforcement Action – Part I

by Thomas Fox on

A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more

Effective Ethics and Compliance Training

by Thomas Fox on

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

Leadership Lessons from Mutiny on the Bounty

by Thomas Fox on

In honor of February and its traditional run up to the Oscars, in my podcast on business leadership, 12 O’Clock High, a podcast on business leadership, I am exploring leadership lessons from Oscar-winning Best Pictures. In...more

Compliance Lessons from Super Bowl LI

by Thomas Fox on

Tom Brady is now Number 2 on the all-time list for hoisting the NFL Championship Trophy. Number One on the list is still Cleveland Browns quarterback Otto Graham with six, including four from the All-American Football...more

FCPA: 2016 in Review Webinar

by Bryan Cave on

Enforcement of the Foreign Corrupt Practices Act (FCPA) remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2016, resulting in more than 50 combined enforcement actions, record...more

Global Anti-Bribery Year-in-Review: 2016 Developments and Predictions for 2017

by WilmerHale on

The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC’s first DPA with an individual for FCPA violations. In April 2016, the DOJ’s...more

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