News & Analysis as of

Publicly-Traded Companies Compliance Department of Justice (DOJ)

Thomas Fox - Compliance Evangelist

Executive Compliance Comp and Compliance: From Incentives to Clawbacks

There are two problems that every company must deal with at the intersection of executive compensation and compliance. The first is the presence of perverse incentives within organizations, where executives are often...more

American Conference Institute (ACI)

Addressing the Jurisdictional Challenges of Compensation Clawbacks

The Department of Justice’s newly launched compensation and clawback pilot program is certain to bring with it numerous implementation hurdles and jurisdictional challenges, but it also incentivizes companies to have in place...more

The Volkov Law Group

DOJ’s Perspective on Clawbacks and Deferred Compensation Systems (Part III of III)

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DOJ’s decision to examine corporate compensation programs as an important part of a compliance program should be welcomed.  DOJ’s initiative asks a very good question – how can incentives and disincentives be used to promote...more

NAVEX

Renewed Focus on SOX 304 Compliance Stresses Need for Culture of Compliance, Executive Accountability

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The Department of Justice and the Securities and Exchange Commission have signaled in recent months that they have reinvigorated their focus on executive compensation claw backs, urging companies to adopt compensation...more

BCLP

SEC approves executive officer incentive compensation clawback rules

BCLP on

On October 26, 2022, the SEC – by a 3-2 vote – approved final rules directing the NYSE, Nasdaq and other stock exchanges to adopt requirements for listed companies to develop and implement clawback, or recovery, policies that...more

Perkins Coie

FTC Announces 2021 Changes to HSR and Clayton Act Thresholds, Temporarily Suspends Early Termination

Perkins Coie on

The U.S. Federal Trade Commission (FTC) recently announced reporting thresholds under Section 7A of the Clayton Act, known as the Hart-Scott-Rodino (HSR) Antitrust Improvements Act of 1976 (the Act), will decrease. The Act...more

Faegre Drinker Biddle & Reath LLP

$125 Million Deutsche Bank Settlement with SEC/DOJ Newest in Line of Several Costly Resolutions

On January 8, 2021, the SEC issued a cease-and-desist order, Release No., 90875 (available here), formally resolving proceedings against Deutsche Bank AG. Deutsche Bank agreed to pay over $125 million as part of a global...more

Society of Corporate Compliance and Ethics...

US Department of Justice updates compliance program evaluation guidance

CEP Magazine (October 2020) - In June, the United States Department of Justice (DOJ) released an update to its Evaluation of Corporate Compliance Programs based on insights from its own ongoing experience and input from...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Compliance Program Guidance Shows Value of a Compliance Committee

Though directed at prosecutors, the June 1, 2020, guidance on corporate compliance programs (Guidance) from the U.S. Department of Justice (DOJ) is a source of practical advice for in-house legal and compliance teams in...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ and SEC Issue Second Edition of the FCPA Resource Guide

On July 3, 2020, the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) jointly released the second edition of the “Resource Guide to the U.S. Foreign Corrupt Practices Act,” which was...more

ArentFox Schiff

Investigations Newsletter: Contractors to Pay Over $2.8 Million to Settle Small Business Contract Fraud Allegations

ArentFox Schiff on

Contractors to Pay Over $2.8 Million to Settle Small Business Contract Fraud Allegations - On June 2, 2020, the Department of Justice announced that Ross Group Construction Corporation and its affiliates agreed to pay...more

Barnea Jaffa Lande & Co.

Compliance and Ethics in Corporations

The United States has been the global leader in the enforcement of anti-bribery and anti-corruption laws for several decades. The Foreign Corrupt Practices Act (FCPA) was enacted in the United States in 1977 in order to...more

Jones Day

SEC Enforcement in Financial Reporting and Disclosure: 2019 Mid-Year Update

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We are pleased to present our annual mid-year update on financial reporting and issuer disclosure enforcement activity for 2019. This White Paper primarily focuses on the U.S. Securities and Exchange Commission's enforcement...more

BCLP

FCPA Investigations – Competitors Dropping the Dime

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We often are asked how the U.S. government finds out about potential Foreign Corrupt Practices Act (FCPA) violations. Internal company whistleblowers are perhaps the main source....more

NAVEX

DOJ Issues New Compliance Program Evaluation Guidance

NAVEX on

Earlier this month, the Fraud Section of the US Department of Justice (DOJ) published its Evaluation of Corporate Compliance Programs (Evaluation Guidance). Although issued without fanfare, the Evaluation Guidance represents...more

Jones Day

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

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

NAVEX

Compliance Paid for Itself in Many Ways in 2016

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“A culture of ethics ties long-term performance to the interests of long-term stakeholders.” — Larry Fink, Chief Executive of Blackrock The quote above was mentioned by Timothy Erblich, CEO of Ethisphere, at the...more

Thomas Fox - Compliance Evangelist

Reflections on the Hitachi FCPA Enforcement Action

Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more

Dechert LLP

DOJ Hires Corporate Compliance Program Expert

Dechert LLP on

In a somewhat surprising development, press outlets reported last week that the U.S. Department of Justice (“DOJ”) has hired a corporate compliance program expert who will work alongside federal prosecutors evaluating whether...more

K&L Gates LLP

Are Public Companies Required to Disclose that the Government is Investigating Them?

K&L Gates LLP on

For many public companies, the first issue they have to confront after they receive a government subpoena or Civil Investigative Demand (“CID”) is whether to disclose publicly that they are under investigation. Curiously, the...more

Thomas Fox - Compliance Evangelist

Byzantium and the Alstom FCPA Settlement – Part III

Porphyry is a type of stone that was much favored in the Roman world. In a review of several books in the New York Review of Books, entitled “The Purple Stone of Emperors”, Peter Brown looked into the history of the lithic in...more

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