Ethics Dept. of Justice

News & Analysis as of

5 Ways Training on Your Compliance Policies Can Protect Your Organization

We write a lot about the importance of creating, implementing and managing the right policies. But implementation is only half the battle. If you don’t give your employees thorough, effective and regular training on them, you...more

A Teaching Moment Inside VimpelCom’s Boardroom

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

The Person (Idea) of the Year – Corporate Ethics and Culture

Each year I have identified the so-called “person” of the year to capture the most significant enforcement and compliance trend. In the past, I have given the award to the Chief Compliance Officer, the Ethics Officer, the...more

Ethics and Compliance Predictions for 2016

The New Year brings new promise for compliance professionals. I always sympathize with compliance officers because of their inevitable conflict – their idealism often is confronted by corporate realities – a CEO who...more

DOJ’s New Compliance Expert Brings Private Practice Insights to the Role

DOJ’s new compliance expert brings private practice insights to the department. The Fraud Section of the Department of Justice (DOJ) announced earlier this month that it has hired Hui Chen as its “full-time compliance...more

Preview of NAVEX Global’s 2015 Ethics and Compliance Virtual Conference

As 2015 draws to a close (where did the time go?), the 2016 planning season is in full swing. You likely already have an idea of initiatives you’ll want to tackle, but taking your ethics and compliance program to the next...more

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

The SEC’s Year of FCPA Enforcement

Say what you will – the SEC is making its mark this year in FCPA enforcement. So far, the SEC has brought nine separate enforcement actions, the latest with Bristol-Myers Squibb. I am sure we will see more before the end of...more

Compliance at the Tipping Point, Part I – The Yates Memo

This is the day that the US government traditionally celebrates Columbus’ discovery of the Americas, in the form of Columbus Day. My grandfather emigrated from Italy so he always took Columbus Day as his heritage day. My...more

HorrorFest 2015 Celebration Part II – The Cat People, the Schrems Decision and FCPA Investigations

It’s the second Friday in October and I am continuing my HorrorFest month. I usually call it Monster Movie Fest but this year I am celebrating the films of Val Lewton who really worked more broadly in the horror genre, rather...more

Despite Criticism, DOJ’s New Policy On Internal Investigations Could Be a Good Thing

While naysayers believe the Department Of Justice's (DOJ’s) memo is going to result in major complications and headaches for companies experiencing government investigations, ethical companies are unlikely to be affected much...more

DOJ Targets Executives and Individuals in Corporate Investigations

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 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

Bribery and Behaviors from the Front-Lines

Tell me a little bit about your background and how you came to be an anti-bribery consultant. My entry point into the defense business was as a fourth generation family member of what at the time (the mid 80's) was one...more

Design Thinking in Compliance

In many ways the migration from Chief Compliance Officer (CCO) 1.0 to 2.0 and beyond is more than simply about the technical aspects of a CCO to the internal and external delivery of a compliance solution by the compliance...more

Misconduct in the C-Suite: The United Airlines Scandal

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

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

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

Give & Take: The Case for a Better G&E Compliance Program

Part One: Setting The Foundation - Why Does G&E Matter? Tony Robbins once said, “Every problem is a gift—without problems we would not grow.” In the compliance arena, the reverse also applies, as many gifts can...more

You Cannot Buy an Ethical Corporate Culture

I do not mean to be facetious or snarky, but I am concerned about organizations that sell or promote their ability to certify or give a seal of approval to a company as an “ethical” company.  Even more troubling (or perhaps...more

DOJ Hires Compliance Counsel to Assist in Charging Decisions

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

DOJ’s Disdain for “Paper” Compliance Programs

As we come to the close of the Obama Administration, the Justice Department will certainly be able to point to its record of aggressive white-collar enforcement in a variety of areas. One glaring claim omission from that list...more

The Kitchen Debate Presages the FCPA Compliance and Ethics Report

On this day in 1959, occurred one of the more iconic events of the Cold War, that being the Kitchen Debate between US Vice President Richard Nixon and Soviet leader Nikita Khrushchev. It was called ‘The Kitchen Debate’...more

3 Ways to Improve Compliance Training

As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as...more

Public Officials Face Greater Scrutiny in Wake of McDonnell Decision

Governor McDonnell’s attorneys put it this way: The Governor’s acts weren’t “official” because “none were any more remarkable than acts that governors unthinkingly take hundreds of times weekly for countless constituents,...more

How Companies Could Avoid “Paper” Compliance in New Ukraine? Try Acting Rather Than Talking

Ed. Note-today we have a guest post from two noted compliance practitioners from Ukraine, Timur Khasanov-Batirov and Andriy Selepey who discuss the dangers of a paper compliance program. Corruption is the main problem...more

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