News & Analysis as of

Ethics Dept. of Justice

Unfair and Unbalanced-Episode 18 [Video]

by Thomas Fox on

In this episode, Roy Snell and myself discuss how incentives are integral to the compensation plans of a wide range of workers. Many experts point to their value in rewarding behavior that is in the interest of the...more

Compliance Lessons for Executive Leadership from The Wells Fargo Investigation Report

by Thomas Fox on

Compliance lessons from truly one of the most damning reports of complete corporate failures around ethics and culture that has recently been seen....more

Understanding Special Counsel Mueller’s Authorization

by Michael Volkov on

Deputy Attorney General Rosenstein’s appointment of Special Counsel Robert Mueller last week was a blockbuster development in the investigation of the administration....more

FCPA Compliance Report-Episode 327, Pat Harned on Highlights from the ECI 2017 Conference [Video]

by Thomas Fox on

In this episode, I visit with Pat Harned, Chief Executive Officer of the Ethics and Compliance Initiative on the recently concluded annual conference. She discusses the speech of Attorney General Jeff Sessions and the panel...more

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

by Thomas Fox on

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

Day 8 of One Month to Better Compliance Through HR-Using Compensation to Operationalize Compliance [Video]

by Thomas Fox on

One of the areas that many companies have not paid as much attention to in their Foreign Corrupt Practices Act (FCPA) anti-corruption compliance programs is compensation. However the Department of Justice (DOJ) and Securities...more

AG Jeff Sessions Left Compliance Officers with More Questions than Answers … and an Invitation

by NAVEX Global on

Attorney General Jeff Sessions was a keynote speaker at the 2017 Ethics & Compliance Initiative’s Annual Conference last week. Whatever your politics are, it was important that we hear from him on his priorities for...more

Day 1 of One Month to Better Compliance Through HR-the Role of HR in Operationalizing Compliance [Video]

by Thomas Fox on

This month, I will consider the role of Human Resources (HR) in operationalizing a best practices compliance program. I have long advocated for a greater role of Human Resources (HR) in a compliance program. Indeed, one sign...more

Code of Conduct Week: Part V – Operationalization

by Thomas Fox on

I have reviewed the creation and update of a Code of Conduct this week, with a big assist from Eric Morehead, the Principal of Morehead Compliance Consulting. We reviewed the legal requirements, the suggested structure and...more

Code of Conduct Week: Part IV – Training on Your Code of Conduct

by Thomas Fox on

Today focus in the Code of Conduct series is on the aspect of training on your finalized Code of Conduct. Eric Morehead, Principal of Morehead Compliance Consulting, joins me in this series. While there have been criticisms...more

Code of Conduct Week: Part I – Introduction

by Thomas Fox on

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

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

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

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

by Thomas Fox on

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

Corporate Law & Governance Update - March 2017

by McDermott Will & Emery on

Executive Compensation Developments - The general counsel should anticipate questions from the board and its executive compensation committee from recent media coverage of executive compensation (especially in 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

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

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

How Effective is Your Corporate Compliance Program?

On February 8, the Fraud Section of the United States Department of Justice (DOJ) posted on its website a document entitled “Evaluation of Compliance Programs” (the “Guidance”). This is the first formal guidance issued by the...more

Insight from the DOJ Fraud Section

by Robins Kaplan LLP on

Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more

Under the Dark of Night, DOJ Moves the Compliance Ball (Part I of IV)

by Michael Volkov on

In an unusual move, the Justice Department issued an important document in the dead of night – Evaluation of Corporate Compliance Programs. We have no explanation from the Justice Department for the issuance of this...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

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

Yikes: The Perils of Remediation and Corporate Monitors

by Michael Volkov on

The Justice Department has raised the stakes on anti-corruption compliance. In other words, DOJ prosecutors expect companies to have more sophisticated and mature compliance programs. If a company walks into the Justice...more

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