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Ethics Federal Pilot Programs

Thomas Fox - Compliance Evangelist

HorrorFest 2019 Celebration – The Films of Val Lewton and Role of the Compliance Function

In the 2017 FCPA Corporate Enforcement Policy, the Department of Justice (DOJ) listed the following factors relating to a corporate compliance function, that it would consider as indicia of an effective compliance and ethics...more

The Volkov Law Group

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

The Volkov Law Group on

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...more

Thomas Fox - Compliance Evangelist

Compliance Under the New FCPA Enforcement Policy – Final Thoughts

Over the past few posts I have been exploring the Department of Justice’s (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Announces Revised FCPA Corporate Enforcement Policy

In a speech yesterday at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ) revised Foreign Corrupt Practices Act...more

Thomas Fox - Compliance Evangelist

Astros Garner First World Series Win – Execution of Compliance in the Middle

In compliance you often times need to be a superior utility player who is good at every job. There are multiple lessons. First and foremost is the problem of siloing in corporate America. This concern of siloing even...more

Thomas Fox - Compliance Evangelist

The Stoic's Guide to Compliance

One thing about successful Chief Compliance Officers (CCOs) and other compliance practitioners is they can take in severe news, keep calm and carry on. In a keynote speech to the SCCE Compliance and Ethics Institute, Jenny...more

Pillsbury Winthrop Shaw Pittman LLP

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

The Volkov Law Group

The FCPA Pilot Program Disciplinary Standards (Part II of II)

The Volkov Law Group 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

The Volkov Law Group

Yikes: The Perils of Remediation and Corporate Monitors

The Volkov Law Group 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

The Volkov Law Group

FCPA Predictions for 2017 (Part III of III)

The Volkov Law Group on

With the new incoming administration, everyone is busy predicting major changes in DOJ FCPA enforcement. I do not share this view. Frankly, FCPA enforcement is more bipartisan than other controversial enforcement programs...more

Thomas Fox - Compliance Evangelist

The Baker Hughes GeoMarket Ethics and Compliance Committee

Two of the most common compliance focused committees for public companies are those at the Board level and those which sit between the Chief Compliance Officer (“CCO”) and the Board, usually consisting of very senior...more

The Volkov Law Group

AAG Caldwell Touts Success of FCPA Enforcement and Pilot Program

The Volkov Law Group on

In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more

Thomas Fox - Compliance Evangelist

Monster Movie Month: Episode III – Son of Frankenstein and Evolution From Yates Memo and FCPA Pilot Program

Welcome to my third installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series. Today I want to explore the final movie where Boris Karloff starred as Frankenstein’s Monster;...more

The Volkov Law Group

Defining “Effective” Ethics and Compliance Programs

The Volkov Law Group on

The compliance profession faces many challenges. Some are more important than others. When it comes to evaluating performance, or measuring compliance programs, the profession has a steep uphill climb....more

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