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Criminal Prosecution Compliance Ethics

Nossaman LLP

Compliance Notes - Vol. 4, Issue 16

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Welcome to Compliance Notes from Nossaman’s Government Relations & Regulation Group – a periodic digest of the headlines, statutory and regulatory changes and court cases involving campaign finance, lobbying compliance,...more

Nossaman LLP

Compliance Notes - Vol. 4, Issue 14

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Campaign Finance & Lobbying Compliance - Former president Trump's campaign raised more than $5 million in the first 48 hours after reports broke that he had been indicted by a grand jury in Manhattan–receiving more than $4...more

Society of Corporate Compliance and Ethics...

The Sentencing Guidelines at Thirty

The Organizational Sentencing Guidelines have turned thirty, and what began as an experiment is now an established framework for compliance programs in the US and around the globe. To commemorate the milestone, the United...more

NAVEX

The Justice Department’s New Emphasis on a Culture of Compliance

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The week of September 12 was an important one for corporate compliance professionals. We saw two high-ranking officials at the U.S. Justice Department give back-to-back speeches outlining ambitious plans to transform the...more

The Volkov Law Group

U.S. Sentencing Commission Report: Corporate Prosecutions Decline and Ethics and Compliance Programs Increase

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The proper balance in corporate prosecutions remains a tricky issue.  On the one hand, many argue that large fines and penalties against corporations are needed to deter criminal conduct, while others contend that...more

The Volkov Law Group

The Glencore Settlement: Lessons Learned (Part V of V)

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The Justice Department has resumed FCPA enforcement with a bang.  The new enforcement approach has been unveiled and the message for CCOs and corporate business leaders is clear — anti-corruption compliance should be a...more

The Volkov Law Group

The Urgency of Ethics and Compliance – The Biden Administration and Enforcement

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The Biden Administration has a lot on its plate – that is obvious.  Tackling the COVID-19 pandemic and restoring economic growth is one of the most difficult challenges ever facing our country....more

Jones Day

New Guidance for Dutch Prosecutor on the Investigation and Prosecution of Foreign Corruption

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On October 1, 2020, the new Instruction on the Investigation and Prosecution of Foreign Corruption for the Dutch Public Prosecution Service ("DPPS") entered into force, indicating certain factors that play a role in...more

Nossaman LLP

Compliance Notes – Vol. 1, Issue 12

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Campaign Finance & Lobbying Compliance - Arizona: The Secretary of State’s Office found reasonable cause that the Goldwater Institute violated a law requiring lobbyists to register with the state after Goldwater testified...more

Thomas Fox - Compliance Evangelist

May the Fourth Be With You – Farewell to Blue Bell

May 4th is universally recognized (at least in the universe I inhabit) as Star Wars Day. According to Wikipedia, “May 4 is called Star Wars Day because of the popularity of a common pun spoken on this day. Since the phrase...more

The Volkov Law Group

2019 FCPA Enforcement Highlights (Part II of III)

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In a record year, there are bound to be numerous interesting enforcement actions and principles.  I picked out a few to highlight....more

Thomas Fox - Compliance Evangelist

Corruption in China: Part 1 – I am Shocked, Just Shocked

Sometimes you have to wonder if companies ever have figured out that they need to comply with the Foreign Corrupt Practices Act (FCPA) by putting in place a compliance program that actually works. ...more

A&O Shearman

DOJ Criminal Division Announces Updated Corporate Compliance Program Guidance

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On April 30, 2019, the United States Department of Justice, Criminal Division (“DOJ”), released an updated version of its guidance on “Evaluation of Corporate Compliance Programs” (“Compliance Program Guidance”). This...more

Thomas Fox - Compliance Evangelist

Shakespeare’s Problem Plays: Part 2 – Troilus and Cressida and Farce in Compliance as Tragedy

This week we have seen how the tragedy of the victims of Larry Nassar go to a new level when Michigan State University (MSU) Interim President John Engler said (on the record) to the Editorial Board of the Detroit News,...more

The Volkov Law Group

CEOs Under the Criminal Spotlight – More C-Suite Misconduct

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We live in a bizarre time — an information age where lines are blurred between truth and lies — a strange era in which our daily doses of information are dominated by scandals, corruption, and repeated claims of “fake news.” ...more

The Volkov Law Group

Justice Department Charges Former Volkswagen CEO in Diesel Vehicle Emissions Cheating Scheme

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We all know the saying – A fish rots from the head. Sometimes a clear and simple statement says it all. The Volkswagen diesel emissions cheating scandal is yet another example of C-Suite, even CEO, misconduct....more

The Volkov Law Group

Volkswagen: When Car Companies Veer Off Course (Part I of III)

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Corporate misconduct occurs in a variety of forms. Starting with the basic truism – companies act through people, and when companies engage in misconduct it requires the coordination and collaboration of multiple actors. The...more

Thomas Fox - Compliance Evangelist

Compliance at the Tipping Point, Part V – Protection Afforded From a Compliance Program

Today, I wrap up my series on why I think compliance is at the Tipping Point. However as it is a Friday in October, I continue my tribute to the Man in the Shadows, producer Val Lewton, whose films for RKO had some of the...more

Holland & Knight LLP

DOJ Targets Executives and Individuals in Corporate Investigations

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Responding to criticism stemming from a lack of individual prosecutions as a result of the financial crisis, Deputy Attorney General Sally Yates has issued a new guidance memorandum establishing six new steps for federal...more

The Volkov Law Group

Misconduct in the C-Suite: The United Airlines Scandal

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It was like a bolt out of the blue – United Airlines’ CEO and two senior executives hastily announced their resignation as a result of their involvement in a bribery scandal with the New York Port Authority....more

The Volkov Law Group

DOJ’s Warning to High-Tech Companies: SAP Official Pleads Guilty To FCPA Violation

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When DOJ acts, they like to make a splash. While the FCPA Paparazzi have been lamenting the “slow down” in FCPA enforcement actions and the increase in case closings, DOJ still makes its mark when it acts, and I expect more...more

King & Spalding

DOJ Hires Compliance Counsel to Assist in Charging Decisions

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New Compliance Counsel Will Assess Effectiveness of Corporate Compliance Programs - Last week the U.S. Department of Justice (DOJ) revealed it is hiring a compliance counsel to assist DOJ prosecutors in assessing the...more

The Volkov Law Group

Good People Do Bad Things

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It is good to be an optimist. I am sure that optimistic people are happier, more loving and tend to live longer. All of this rings true. But not everyone is an angel, and not everyone at your company is a “good...more

NAVEX

Global Anti-Corruption Enforcement Trends Hit FIFA

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Insights on the anti-corruption trends that contributed to the Fédération Internationale de Football Association (FIFA) scandal, and six essential characteristics of organizations whose cultures help prevent bribery and...more

NAVEX

2015 Trends: #7 Crime and Punishment

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On the accountability and punishment front, three trends bear watching: 1) Deferred Prosecution Agreements (DPAs) DPAs and Non-Prosecution Agreements (NPAs) allow prosecutors to require corporate reforms and...more

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