Compliance Dept. of Justice The Foreign Corrupt Practices Act

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory... 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 -
News & Analysis as of

Corporate Compliance Programs: US and UK Perspectives

In today’s regulatory environment, companies face mounting pressure from law enforcement agencies to maintain robust compliance programs to deter and detect misconduct by employees, third-party vendors and business partners....more

LRN Compliance Program Effectiveness Report: Part III

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

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

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

Understanding the New DOJ Guidance: Part 1 – Tone at the Top

In February, the Department of Justice’s Fraud Section offered a new perspective on what the government expects in a compliance program in the form of a series of questions that companies should be prepared to answer about...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

New Guidance Document: How DOJ Evaluates Corporate Compliance Programs

The U.S. Department of Justice (DOJ) has issued compliance guidance for corporations that outlines how the Fraud Section will likely evaluate the corporate compliance program of a company under criminal investigation....more

DOJ Announces Temporary Extension of FCPA “Pilot Program”

The U.S. Department of Justice (DOJ) announced on March 10, 2017 that it will temporarily extend the “Pilot Program” applicable to offenses under the U.S. Foreign Corrupt Practices Act (FCPA). Previously set to expire on...more

DOJ’s Recent Guidance on Compliance Programs

In assessing potential sanctions against corporations, prosecutors must decide whether and how to exercise their discretion when evaluating penalties to impose upon a company whose employees engaged in wrongdoing despite the...more

DOJ’s Compliance Program Evaluation Guidance

The Justice Department’s recent guidance on compliance programs, consisting of 110 separate questions, organized around specific compliance topics, has raised a number of interesting procedural and substantive issues....more

The DOJ Expects “Third-Party Management” from Compliance Programs

2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more

DOJ Pilot Program Will Continue…For Now

On March 10, a U.S. Justice Department official announced that agency will continue its one-year Pilot Program, which was introduced by DOJ’s Fraud Section and set to expire on April 5 of this year. As we described in an...more

Healthcare sector takes note: DOJ heightens its expectations for effective corporate compliance programs

The US Department of Justice Criminal Division Fraud Section has issued a new guideline for the Evaluation of Corporate Compliance Programs. The guidance expands the former "Filip Factors" and incorporates subsequent...more

FCPA Pilot Program Motors On

No one was really surprised when Kenneth Blanco, Acting Assistant Attorney General for the Criminal Division, US Department of Justice, announced last week that DOJ was planning to continue the FCPA Pilot Program past April...more

Use of Social Media In a Best Practices Compliance Program

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

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

Great Expectations - DOJ holds anti-corruption compliance programs to a high standard in evaluating their credibility

On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more

New Attorney General Issues Guidance on Corporate Compliance Programs

The US Department of Justice (DOJ) Fraud Section has published new guidance for corporate entities on corporate compliance programs. The guidance, titled, “Evaluation of Corporate Compliance Programs” (Compliance Program...more

My China Compliance Diary

When my supervision (probation) ended in January 2017, the US District Court in DC released my passport, and I could once again travel internationally. And with that milestone, a note of thanks to all the international event...more

DOJ Issues New Guidance on the Evaluation of Corporate Compliance Programs in Federal Fraud Investigations

On February 8th, the U.S. Department of Justice (DOJ) quietly issued new guidance on how the agency evaluates corporate compliance programs during fraud investigations. The guidance, published on the agency’s website as the...more

Top Ten International Anti-Corruption Developments for January 2017

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

DOJ Issues New Compliance Program Evaluation Guidance

Earlier this month, the Fraud Section of the US Department of Justice (DOJ) published its Evaluation of Corporate Compliance Programs (Evaluation Guidance). Although issued without fanfare, the Evaluation Guidance represents...more

DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits (Part IV of IV)

DOJ’s Compliance Evaluation questions provide important indications of “new” trends and approaches to compliance functions and issues. Training - In the area of training, DOJ’s Compliance Evaluation reiterates DOJ’s...more

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

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