News & Analysis as of

Federal Sentencing Guidelines Ethics

Society of Corporate Compliance and Ethics...

How a code of conduct reflects culture and meets DOJ requirements

Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it...more

The Volkov Law Group

HHS-OIG Guidance — Chock Full of Compliance Best Practices and Strategies (Part II of III)

The Volkov Law Group on

Board Oversight of the Compliance Program - The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization’s compliance program, and provides that the board shall “be...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

Thomas Fox - Compliance Evangelist

Impact of the Federal Sentencing Guidelines at 30

The Federal Sentencing Guidelines for Organizations (FSGO) by the US Sentencing Commission (USSC) turn 30 this year. For compliance officers, this was perhaps the most significant government release. It did not create the...more

The Volkov Law Group

Ethics and Compliance Trends and Predictions for 2020

The Volkov Law Group on

2019 was a big year for ethics and compliance.  In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more

Thomas Fox - Compliance Evangelist

Rosie Ruiz and Ethically Challenged Employees

Once you demonstrate you are ethically challenged or maintain a moral flexibility that allows you to lie, cheat and steal; it is highly likely you will continue to do so....more

The Volkov Law Group

The Purpose of a Compliance Program: To Prevent and Detect

The Volkov Law Group on

I do not think there is much disagreement on the basic purpose of an ethics and compliance program. After all, one of the primary sources for compliance programs continues to be the United States Sentencing Guidelines which...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

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

Robins Kaplan LLP

Insight from the DOJ Fraud Section

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

The Volkov Law Group

Unpacking the Justice Department’s Compliance Remediation Standards (Part I of II)

The Volkov Law Group 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

NAVEX

Understanding the Benefits of Benchmarking & How to Do It Successfully

NAVEX on

To begin, let’s define “benchmarking.” There is often confusion regarding the difference between benchmarking and assessment. ...the process of benchmarking is a subset of compliance program assessment....more

NAVEX

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

NAVEX on

Once again it’s time for our annual review of trends and events that will impact your Ethics and Compliance (E&C) program in the year ahead. This year presents a unique challenge. We are preparing our predictions...more

Thomas Fox - Compliance Evangelist

The Board of Directors’ Compliance Committee

Yesterday, together with Baker Hughes Inc. (BHI) Chief Compliance Officer (CCO) Jay Martin, I wrote about a new and innovative compliance committee BHI has initiated, the GeoMarket Compliance and Ethics Committee. In...more

The Volkov Law Group

Shortchanging the Compliance Function

The Volkov Law Group on

A company that does not back up its words with deeds is doomed to suffer compliance and cultural breakdowns. When a company commits to building a culture of trust and integrity, the company has to keep its word. This is not a...more

Thomas Fox - Compliance Evangelist

Hallmark 3 – Oversight, Autonomy and Resources

I. Autonomy - The DOJ has made clear over the years the importance of this hallmark. In the FCPA Guidance it states, “In appraising a compliance program, DOJ and SEC also consider whether a company has assigned...more

NAVEX

Top Ten Ethics & Compliance Predictions & Recommendations for 2016

NAVEX on

To help with our predictions and recommendations, we’ve talked with industry experts, our colleagues at NAVEX Global, and ethics and compliance professionals from our more than 12,500 client organizations. Based on their...more

Thomas Fox - Compliance Evangelist

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

NAVEX

New International Standard, ISO 19600:2014, Makes Few Headlines But May Have Huge Impact

NAVEX on

Those of us working in the ethics and compliance field know that there is no shortage of guidance on best practices for establishing and maintaining an ethics and compliance program. In the U.S., the Federal Sentencing...more

The Volkov Law Group

Meaningful Measurement of the Effectiveness of an Ethics and Compliance Program

The Volkov Law Group on

Talk is cheap, especially when it comes to ethics and compliance programs. Words are easy but action and commitment is even harder. The compliance industry needs to put more meat on the bones of compliance. It is not enough...more

The Volkov Law Group

The Time is Now to Amend the US Sentencing Guidelines on Corporate Ethics and Compliance Programs

The Volkov Law Group on

We all know the importance of the sentencing guidelines and the impact the revisions, especially the 2010 amendments, have had on corporate governance and compliance. The history behind the sentencing guidelines tracks the...more

Thomas Fox - Compliance Evangelist

The All-Star Game and Tone at the Top

Quite simply, any compliance program starts at the top and flows down throughout the company. Before you arrive at tone in the middle and bottom, it must start with a commitment at the top. All regulatory schemes for...more

NAVEX

Real Guidance (Finally) On the Compliance Oversight Role of Boards

NAVEX on

New guidance for boards of directors on what it means to have “reasonable oversight” for the implementation and effectiveness of corporate compliance programs could signal the beginning of a global trend towards more—and more...more

NAVEX

Board Reporting: Elevating Your E&C Program & Engaging the Board

NAVEX on

In This Presentation: - The Board’s Roles and Compliance Responsibilities - The Board Report & Briefing vs. Training - Important Considerations for your Board Report - Case Study - How Can I Tell if my Board is...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

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