News & Analysis as of

Compliance Department of Justice (DOJ) Employee Misconduct

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
American Conference Institute (ACI)

Addressing the Jurisdictional Challenges of Compensation Clawbacks

The Department of Justice’s newly launched compensation and clawback pilot program is certain to bring with it numerous implementation hurdles and jurisdictional challenges, but it also incentivizes companies to have in place...more

King & Spalding

What DOJ Really Cares About: What Do The Updates To DOJ'S Compliance Guidance Mean In Practice?

King & Spalding on

On June 1, 2020, the U.S. Department of Justice (“DOJ”) released updated guidance entitled “Evaluation of Corporate Compliance Programs” (“Updated Guidance”), which provides the DOJ Criminal Division’s views on what comprises...more

Pillsbury Winthrop Shaw Pittman LLP

Compliance Programs Must Track and Adapt to Changes and Risks

Updated DOJ Guidance calls on corporations to devote additional resources and attention to detect and prevent misconduct. A well-structured and effective compliance program must evolve with lessons learned, be understood...more

Latham & Watkins LLP

Prioritizing Corporate Culture: Lessons for Companies from the Major League Baseball Sign-Stealing Investigation

Latham & Watkins LLP on

The MLB Commissioner held senior leadership accountable for illegal sign stealing - even though the conduct generally involved players and low-level operations employees. On January 13, 2020, Major League Baseball (MLB)...more

Thomas Fox - Compliance Evangelist

Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...more

Thomas Fox - Compliance Evangelist

Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance

I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more

Thomas Fox - Compliance Evangelist

Day 11 of One Month to Better Compliance Through HR-the Fair Process Doctrine

Procedural fairness is one of the things that will bring credibility to your Compliance Program. Today it is called the Fair Process Doctrine and this Doctrine generally recognizes that there are fair procedures, not...more

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