Government Investigations Chief Compliance Officers

News & Analysis as of

Brother Can You Spare Some (Compliance) Advice?

Usually I have Houston professional sports teams to hold high as example of true bone headedness around compliance issues. However, as my beloved Houston Astros took the World Series Champions, KC Royals, to the 7th inning of...more

DOJ Announces New Compliance Counsel and Outlines Metrics for Evaluating Corporate Compliance Programs Under Scrutiny

In July 2015, the U.S. Department of Justice’s Criminal Division revealed that it was hiring a Compliance Counsel to assist in assessing the quality and effectiveness of companies’ corporate compliance programs under scrutiny...more

DOJ’s Pursuit of Individual Liability for Corporate Misconduct: The Yates Memo

Cooperation credit is a critical issue for corporations that become embroiled in investigations or enforcement activity. In both the criminal and civil contexts, it is the only way to mitigate the financial impact of...more

Foreign Bribery: The Inquiry Briefing Paper on the Senate into Australia's Foreign Bribery Scheme

The Commonwealth Senate Standing Committee on Economics is conducting an inquiry into the scope and effectiveness of existing Australian measures to address foreign bribery. It is due to deliver its report in July 2016....more

Department of Justice Issues Guidance on Corporate Investigations and Executive Accountability

On September 9, 2015, Sally Quillar Yates, Deputy Attorney General of the Department of Justice (DOJ) issued a memo entitled “Individual Accountability for Corporate Wrongdoing” to address the issue of incentivizing...more

DOJ Sets Its Sights on Directors and Officers

Whether publicly traded or privately held, corporate boards have been put on notice – the Department of Justice (Justice or DOJ) is after you! On September 9th, DOJ issued a memo entitled: Individual Accountability for...more

How Can the Automotive Industry Strengthen Its Regulatory Compliance Process and Reduce Its Compliance Risks?

Many Americans listened last week to the admissions by the now former President of Volkswagen that the company had been “dishonest” and had cheated on the U.S. emissions tests. How was this happening at the world’s #1...more

Five Ways to Ensure Board Support for Compliance

A Chief Compliance Officer has a number of important relationships to maintain in an organization. Aside from the support of senior level executives, the CCO has to build an effective working relationship with the board and...more

DOJ Focuses on Individual Accountability: New Guidance for Corporate Investigations Places Pressure on Companies and Boards to Put...

On September 9, 2015, the Department of Justice (“DOJ”) issued new guidance on individual accountability for corporate wrongdoing. In the memorandum and an accompanying speech by the Deputy Attorney General Sally Q. Yates,...more

Corporate Executives in the Cross-Hairs: U.S Department of Justice Amps Up Quest for Individual Accountability for Corporate...

This month, the United States Department of Justice issued an unambiguous directive to its army of white-collar prosecutors – hold individuals accountable. By publishing its “new” internal policies to the New York Times, it...more

Justice Department Issues New Policy Prioritizing Prosecution of Individuals in Corporate Cases

On September 9, 2015, the U.S. Department of Justice issued guidance regarding the prosecution of individuals in cases involving criminal and civil corporate wrongdoing. The first major policy memorandum issued since Attorney...more

When the Government Comes Knocking

This article will provide an outline of some of the most significant points for hospitals to use when confronted with a formal government investigation under the Criminal or Civil False Claims Act. As noted below, you should...more

Latin America Corruption: Keep Calm, Carry On?

Recently, governmental authorities have pursued corruption investigations in Latin America with a vigor traditionally not seen. One potential result is a significant disruption of business. While there are inherent risks in...more

FCPA Compliance and Ethics Report-Episode 171-FCPA Enforcement in the Energy Industry [Video]

In this episode I discuss enforcement of the FCPA in the energy industry, it genesis and the business response by the energy industry. ...more

Financial Industry Compliance: Enforcement Challenges in the US and Europe

“If you look at the landscape pre-financial crisis, i.e. in 2006-2007, compliance looked very different than it does now,” said Latham & Watkins partner Dr. Finn Zeidler. “In the meantime, compliance in the financial services...more

Blog: Key Takeaways from Government Enforcement Panel at ACI Sunshine Conference

Recently, representatives from the United States Attorney’s Office for the Northern District of Georgia, United States Attorney’s Office for the District of New Jersey, and Medicaid Fraud Control Unit (MFCU) for the Office of...more

FCPA Compliance and Ethics Report-Episode 167-Mara Senn on the Top 10 Practices in a Cross-Border Investigation [Video]

In this episode I visit with noted white collar practitioner Mara Senn who discusses her top 10 best practices when conducting cross-border investigations. ...more

Senn on 10 Best Practices in a Cross-Border Investigation – Part II

Today I conclude a two-part series on how to formulate an effective best practices cross-border investigation based upon an interview I did with Mara Senn, a partner at Arnold & Porter LLP, who specializes in white collar...more

They Grow Up So Fast: Alstom and the UK Bribery Act at Five Years

In April 2015, the UK Bribery Act (UKBA) celebrated its fifth birthday. In the same month, the Serious Fraud Office brought a third round of corruption charges under the UKBA in the Alstom case. Those allegations, brought...more

DOJ Criminal Investigations: “Boiling the Ocean” and Other Fish Tales (Part II of IV)

The old maxim – “Justice delayed is justice denied” – is a powerful statement relating to our criminal justice system. A subject of a criminal investigation – corporate or individual — undergoes enormous stress from a...more

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose [Video]

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

Assuring Regulatory Compliance Doesn’t Get Lost in Translation

With the expansion of large multinational corporations into developing countries such as Russia, Brazil, India, Mexico and China, a proliferation of global regulatory enforcement actions, including anti-bribery and...more

Bribery at the “Sharp End.” Lessons from the field.

To many, an understanding of corruption, bribery and compliance comes from the field of regulators, auditors, investigators and attorneys. Each one of these practices brings an important perspective and set of compliance...more

Beyond Switzerland: Preparing for the Fallout from FATCA and Other Global Transparency Initiatives

You have implemented FATCA; what comes next? Will your company be the next witness in a US tax investigation? Financial institutions around the world must now prepare to respond to anticipated inquiries and investigations as...more

10 Tips for Responding to a False Claims Act Investigation

An increase in government investigations and enforcement actions under the False Claims Act (FCA) and other federal laws can subject healthcare organizations, financial services firms, government contractors and others to...more

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