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Deferred Prosecution Agreements Foreign Corrupt Practices Act (FCPA) Ethics

StoneTurn

Meeting DOJ and SEC Post-Settlement Obligations: A Practical Guide

StoneTurn on

No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more

WilmerHale

DOJ Issues Updated Guidance on Evaluation of Corporate Compliance Programs

WilmerHale on

On April 30, 2019, the Assistant Attorney General for the Criminal Division, Brian A. Benczkowski, announced an update to the Department of Justice’s (“DOJ”) 2017 guidance document entitled Evaluation of Corporate Compliance...more

Thomas Fox - Compliance Evangelist

Code of Conduct Week: Part I – Introduction

I am joined by Eric Morehead as we begin a five-part series on the Code of Conduct, which serves as the foundational document of a compliance program. Morehead is well-known within the compliance community, having worked at...more

Thomas Fox - Compliance Evangelist

The Compliance Oversight Review Committee

This week has evolved into an exploration of different types of compliance committees a company might employ to make their compliance function more effective. On Monday, together with Baker Hughes Incorporated (BHI) Chief...more

The Volkov Law Group

A Teaching Moment Inside VimpelCom’s Boardroom

The Volkov Law Group on

The VimpelCom FCPA settlement underscored the importance of Compliance 2.0 and the need to reform board deliberations and governance. No one can read the facts without shaking their heads and asking – what was the VimpelCom...more

Thomas Fox - Compliance Evangelist

The Defeat Device: Compliance and Ethics in the Auto Industry

Things are seriously bad when one of the world’s most respected business focused publications, the Financial Times (FT), asks if the auto “industry faces ‘Libor moment’”? Yet that was a headline yesterday in the lead article...more

The Volkov Law Group

Future of Corporate Monitors

The Volkov Law Group on

No company wants a corporate monitor. If you ask any General Counsel, Chief Compliance Officer or Chief Executive Officer, they can list an infinite number of alternative punishments they would rather suffer than have a...more

Thomas Fox - Compliance Evangelist

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

Thomas Fox - Compliance Evangelist

Code of Conduct, Compliance Policies and Procedures-Part I

For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more

Thomas Fox - Compliance Evangelist

Commitment To Compliance: The Compliance Committee

Sunday was the 69th anniversary the most iconic photo of World War II, at least from the American perspective. Of course it was the raising of the American flag at Mt. Suribachi on Iwo Jima. To say that one photo cannot...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 29-Interview with the FCPA Professor-Part 1

In this episode 29 of the FCPA Compliance and Ethics Report, I have Part 1 of a 2 part visit with the FCPA Professor about some things on his mind. In this episode, we discuss SEC Chair Mary Jo White's comments about the need...more

Thomas Fox - Compliance Evangelist

Are DPAs Morally Suspect?

You know it is going to be a bad day when you are excoriated in public by a sitting federal district judge. It is even worse when the comments of that federal judge make it into one of the most prominent international...more

Thomas Fox - Compliance Evangelist

It’s The Great Pumpkin: Lessons In Process Validation And Oversight

Today is Halloween and we celebrate the greatest Halloween cartoon in the history of the world, ever, “It’s the Great Pumpkin, Charlie Brown”, which premiered in 1966. As usual, the story revolves around the Peanuts gang, who...more

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