News & Analysis as of

Fraud Compliance

Fraud is the making of false representations or engaging in deceptive behavior in order to unlawfully secure financial or personal gain. 

Department Of Justice “DOJ” Issues Evaluation Of Corporate Compliance Programs

by Locke Lord LLP on

Since DOJ hired Hui Chen, its corporate compliance expert, in November 2015, rumors have circulated that DOJ intended to release a list of questions to ask every company that comes into DOJ to explain the effectiveness of its...more

Termination of a Third-Party – Planning Can Reduce the Pain

by Thomas Fox on

The European concern Airbus has been in the news recently for corruption issues. According to an article in the Financial Times (FT), entitled “Airbus sued by middlemen fired following fraud inquiry”, its annual report lists...more

Tokyo Dispute Resolution & Crisis Management Newsletter – April 2017

by King & Spalding on

US Department of Justice Issues New Corporate Compliance Guidelines - Criteria for the Criminal Division’s Evaluation of Corporate Compliance Programs - Introduction - Recently, and without the fanfare that often...more

Farewell to J. Geils – Final Compliance Function Lessons from Wells Fargo

by Thomas Fox on

You may not recognize the full name, John Warren Geils Jr., but you probably do recognize the name J. Geils, as in the J. Geils Band, who died this week. J. Geils was ubiquitous in the 70s and early 80s with, as noted by an...more

Sunshine Superman – When Culture is Not My Problem

by Thomas Fox on

Today we honor folk-rocker Donovan and his signature song Sunshine Superman, which was profiled in the Wall Street Journal (WSJ) column Anatomy of a Song. The song was a love paean by the singer to “Linda Lawrence, his love...more

Hotel California and Wells Fargo-You Can Check Out, But Can You Leave?

by Thomas Fox on

Today, we celebrate The Eagles most famous song, Hotel California. It all started with a Don Felder cord progression and according to the Financial Times (FT) column The Life of a Song, it had a “fusion of Hispanic melody and...more

ASLMS Annual Meeting Special Coverage: Legal and Compliance Issues Impacting Medical Practices Using Laser Technology

by Ruder Ware on

Medical practices that routinely use laser technology are subject to some of the same legal issues as other types of practices. Use of lasers creates additional compliance issues and highlights certain compliance risk areas....more

Three Recent Fraud Cases Involving Dermatologists Illustrate Primary Compliance Risks in Dermatology Practices

by Ruder Ware on

Three relatively recent cases involving dermatology billing practices illustrate some of the main compliance risks faced by dermatology practices...more

Top Ten International Anti-Corruption Developments for February 2017

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Brazilian Corruption Scandals Continue

by Thomas Fox on

The stench of corruption continues to bedevil Brazil, even as the clean-up initiated with Operation Car Wash is ongoing. This time, allegations of bribery and corruption have reached one of Brazil’s most prestigious exports,...more

DOJ Releases Guidance on Compliance Programs

by Alston & Bird on

In February 2017, the Fraud Section of the Department of Justice’s Criminal Division published guidance on how it assesses corporate compliance programs. This is the first formal guidance issued by the Fraud Section under the...more

Corporate Compliance Programs: US and UK Perspectives

by Dechert LLP on

In today’s regulatory environment, companies face mounting pressure from law enforcement agencies to maintain robust compliance programs to deter and detect misconduct by employees, third-party vendors and business partners....more

Understanding the New DOJ Guidance: Part 1 – Tone at the Top

In February, the Department of Justice’s Fraud Section offered a new perspective on what the government expects in a compliance program in the form of a series of questions that companies should be prepared to answer about...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

by Holland & Knight LLP on

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

DOJ Releases Guidance on Corporate Compliance Programs

by King & Spalding on

On February 8, 2017, and without the fanfare that often accompanies new policy guidance, the Fraud Section of the U.S. Department of Justice (DOJ) issued a new guidance document on corporate compliance programs (Compliance...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

New Attorney General Issues Guidance on Corporate Compliance Programs

by Foley & Lardner LLP on

The US Department of Justice (DOJ) Fraud Section has published new guidance for corporate entities on corporate compliance programs. The guidance, titled, “Evaluation of Corporate Compliance Programs” (Compliance Program...more

DOJ Issues New Guidance on the Evaluation of Corporate Compliance Programs in Federal Fraud Investigations

On February 8th, the U.S. Department of Justice (DOJ) quietly issued new guidance on how the agency evaluates corporate compliance programs during fraud investigations. The guidance, published on the agency’s website as the...more

DOJ Fraud Section Provides Essential Insight into How Corporate Compliance Programs Are Evaluated

On February 8, 2017, the Criminal Fraud Section of the Department of Justice published a document titled “Evaluation of Corporate Compliance Programs,” providing guidance on how the DOJ evaluates the effectiveness of a...more

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

by Jones Day on

On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

DOJ Issues New Corporate Compliance Guidelines; Document Outlines Criteria for the Criminal Division’s Evaluation of Corporate...

by King & Spalding on

Recently, and without the fanfare that often accompanies new policy guidance regarding corporate fraud, the Fraud Section of the Department of Justice posted a document on its website entitled “Evaluation of Corporate...more

U.S. Department of Justice Issues New Guidance on Corporate Compliance Programs

by Blank Rome LLP on

Action Item: The U.S. Department of Justice Criminal Division, Fraud Section (“DOJ”), recently published new guidance on corporate compliance programs. All corporate counsel, officers, and directors should be aware of this...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

New Guidance from the DOJ on Your Compliance Program

by NAVEX Global on

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

When Will Shareholders Force Boards to Do Compliance?

by Thomas Fox on

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

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