Internal Investigations Compliance

News & Analysis as of

When Your Internal Investigator Fails to “Investigate”

A number of recent FCPA enforcement actions have cited common compliance program failures relating to internal investigations. For example, PTC settled FCPA charges with the DOJ and SEC for $28 million. According to the...more

When Managing Whistleblower and Retaliation Risk, Tools are Important – Processes and People are Critical

One collection of terms I hear a lot is “tools, processes and people.” All three need to be successfully deployed to make a compliance program run properly while also creating an organizational culture that supports...more

Building a global team for cross-border investigations: key points

With many internal investigations today involving multiple markets, it is crucial for companies to build cross-border investigation teams that can efficiently and effectively address a multitude of issues. The ideal...more

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

Lessons Learned from the FCPA Pilot Program's First Six Months

The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more

Match Made in Heaven: Compliance and Human Resources

The corporate compliance function is only as successful as its partnerships with key internal constituencies. Depending on the company and the personnel involved, compliance has to establish and maintain effective working...more

For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives

Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more

Hallmark 8-Confidential Reporting and Internal Investigations

The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a mechanism for an...more

Yates, Whistleblowers and FCPA Pilot Project: Re-Examining Your Internal investigation Protocols

Companies face an ever-changing constellation of risks, enforcement priorities and demands for internal controls and compliance program elements. As more resources are poured into government enforcement programs, companies...more

Froome Ends Tour With Win; JP Morgan to End Sons and Daughters Case?

I begin today’s post with a tip of the (cycling) helmet to Englishman Chris Froome who yesterday won his third Tour de France championship. Froome overcame a great many obstacles, not the least of which was being involved a...more

Con Men, Criminals, and Compliance

What does it take (or not take) to be a con artist and/or a white collar criminal? Do not kid yourself — white collar criminals can be “dangerous,” in that they usually suffer from significant personality disorders. Many are...more

The UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

Is Your Organization Prepared for Ontario Bill 132?

On September 8, 2016, new legislation in Ontario will go into effect requiring employers to investigate incidents or complaints of harassment or sexual harassment in the workplace. Employers with employees in Ontario will...more

Are You Leaving Whistleblowers Waiting?

One of the troubling findings in our most recent Ethics and Compliance Hotline Benchmark Report is that organizations are taking longer and longer to close cases, continuing a trend we’ve seen throughout this decade....more

Incident Management – The New Frontier

Compliance programs are required to create and manage case investigation systems to handle potential misconduct, investigate allegations of wrongdoing and then dispense discipline. Lessons learned from these investigations...more

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

New FEHA Regulations: Understanding California’s New Requirements for How Employers Handle Employee Complaints

New California regulations require that employers write discrimination, harassment and anti-retaliation policies which include extensive complaint management and investigation procedures. Snapshot - - What has...more

New DOJ Guidance and FCPA Pilot Program – Part II: Cooperation

Today, I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement (herein “Pilot Program”)....more

Is Confession Good for the Corporate Soul?: DOJ announces new mitigation credit for self-disclosure of FCPA violations

On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more

DOJ Fraud Section Offers Super Credit in FCPA Pilot Program

This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more

Derailing Internal Reviews, Audits, Assessments and Investigations

Following FCPA enforcement actions provides important insights that can be translated into corporate compliance program best practices. One key element of an effective ethics and compliance program is conducting periodic...more

Rubik’s Cube and the Intersections of Compliance

It is generally believed that the world’s single best selling toy is the Rubik’s Cube, invented in 1974 by the Hungarian Erno Rubik. Although it was initially believed that Rubik’s Cube was built as a teaching tool to help...more

The Year 2016 in Compliance

Greetings from Venice where my wife and I are spending the next few days so this blog post is my first Travel Edition of 2016. Last week I wrote about my thoughts on some of the significant Foreign Corrupt Practices Act...more

Tribute to Bob Fox-The Fair Process Doctrine in Compliance

Today’s is a personal blog post. My father, Dr. Milden Jean Fox, Jr. “Bob” passed away last week. He was born in 1926 and was part of what we rightfully call the “Greatest Generation”. We call them this for a whole host of...more

Creating an Ombudsman’s Office

If your company is big enough and has the resources to consider establishing an internal ombudsman’s function, consider yourself lucky. When compliance professionals and lawyers use the term “ombudsman,” it is important to...more

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