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Morrison & Foerster LLP

Commerce Issues First-Ever ICTS “Final Determination” Banning Kaspersky Cybersecurity Products

On June 24, 2024, the Commerce Department published a Final Determination under its Information and Communications Technology and Services (ICTS) authorities. The determination prohibits the Russian-controlled cybersecurity...more

StoneTurn

A Primer in Root Cause Analysis: A Critical Step in the Remediation of Compliance Violations

StoneTurn on

Just as risk assessment is the bedrock for an effective compliance program, root cause analysis (“RCA”) similarly underpins successful remediation of compliance violations. The DOJ’s March 2023 Evaluation of Corporate...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

ArentFox Schiff on

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

ArentFox Schiff

What Does the New FEPA Legislation Mean for FCPA and Anti-Corruption Compliance Programs?

ArentFox Schiff on

On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more

Society of Corporate Compliance and Ethics...

[Webinar] Antitrust Compliance 2.0: Tackling the Toughest Parts of the DOJ Compliance Program Guidance - March 18th, 12:00 pm -...

Learning Objectives: - Examine in detail the latest U.S. Department of Justice Antitrust Division compliance guidance - Understand the DOJ’s expectations with respect to risk assessments, auditing and monitoring,...more

Thomas Fox - Compliance Evangelist

The Memoirs of Sherlock Holmes – The Gloria Scott and Seeing Around Corners

Today, we conclude our week of Sherlock Holmes-themed blog posts. We finished the review of The Adventures of Sherlock Holmes and moved on to The Memoirs of Sherlock Holmes. Today we conclude with The Adventure of the Gloria...more

Dechert LLP

DOJ Releases Revised Guidance on Corporate Compliance Programs and in Doing so Takes a More Nuanced Approach to Compliance...

Dechert LLP on

On June 1, 2020, the Department of Justice Criminal Division published updated guidance on an important piece of DOJ literature, the “Evaluation of Corporate Compliance Programs” (“Guidance”), which for many is...more

Morgan Lewis

DOJ Updates Corporate Compliance Evaluation Guidance: New Refinements Stress that Programs Need to be 'Empowered to Function...

Morgan Lewis on

The US Department of Justice’s (DOJ’s) Criminal Division published an update on June 1 to its Evaluation of Corporate Compliance Programs guidance, which is used by its prosecutors to assess the adequacy and effectiveness of...more

Morgan Lewis

UK Serious Fraud Office Emphasizes Importance of Compliance Programs

Morgan Lewis on

In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more

Akin Gump Strauss Hauer & Feld LLP

[Podcast] DOJ’s New Guidance on Evaluating Compliance Programs: What You Need to Know

In this episode, Akin Gump health care and life sciences counsel Taylor Jones and Matt Wetzel discuss the Justice Department’s recent guidance on evaluation of corporate compliance programs. Among the topics covered: •...more

Dechert LLP

Revised DOJ Policy on Antitrust Compliance Offers New Opportunities for In-House Counsel to Protect Their Companies

Dechert LLP on

Question: Can a company have both an effective antitrust compliance program and an antitrust violation? DOJ before June 11, 2019: Nope. DOJ today: Yes, and your company may even get a deferred prosecution agreement if...more

King & Spalding

Corporate Compliance Programs: DOJ Issues Updated Guidance: Ten Takeaways for In-House Legal and Compliance Leaders

King & Spalding on

On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more

Bradley Arant Boult Cummings LLP

DOJ Evaluation of Corporate Compliance Programs - Government Enforcement Update

On April 30, 2019, the Department of Justice (DOJ), Criminal Division released a new guidance document intended to assist prosecutors in evaluating corporat­­­e compliance programs and guide corporations in creating them. The...more

Wilson Sonsini Goodrich & Rosati

DOJ Criminal Division Releases Updated Guidance for Prosecutors Evaluating Corporate Compliance Programs

On April 30, 2019, Assistant Attorney General Brian A. Benczkowski announced the release of an updated version of the Criminal Division's "The Evaluation of Corporate Compliance Programs" during a keynote address at the...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Risk Assessments and Policies and Procedures (Part II of IV)

The Volkov Law Group on

Part 1 of the Corporate Compliance Guidance addresses the following elements of a well-designed compliance program: risk assessment, policies and procedures, training and communications, confidential reporting structure and...more

The Volkov Law Group

DOJ Issues New and More Robust Guidance on Evaluation of Corporate Compliance Programs (Part I of IV)

The Volkov Law Group on

In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs....more

Foley & Lardner LLP

The Twelve Compliance Steps Every Multinational Corporation Should Undertake in Light of Recent Trump Administration Enforcement...

Foley & Lardner LLP on

Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

Foley & Lardner LLP

DOJ Issues New FCPA Policy Offering Incentives to Encourage Disclosure of Foreign Bribery and Corruption Misconduct

Foley & Lardner LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more

McDermott Will & Emery

Breaking Down the 2017 DOJ and OIG Compliance Guides

McDermott Will & Emery on

Earlier this year, DOJ and OIG independently issued guides focused on evaluating compliance program effectiveness. The guides approach the topic from different perspectives but cover overlapping themes and work well in...more

NAVEX

Reflections on My Interview with Hui Chen on Compliance Program Effectiveness

NAVEX on

Hui Chen left her job as in-house compliance counsel for the Justice Department at the end of June, and I had the good fortune to be the first person to interview her post-departure....more

Blank Rome LLP

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

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

Thomas Fox - Compliance Evangelist

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part I

I guess Matt Kelly cannot leave his journalist roots for it was he who broke the story within the greater compliance community that the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of...more

Perkins Coie

SEC’s Increased Cybersecurity Enforcement and How to Reduce Your Risks

Perkins Coie on

The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more

Thomas Fox - Compliance Evangelist

Economic Downturn Week, Part III – The Desktop Risk Assessment

I continue my exploration of actions you can take to improve your compliance program during an economic downturn with a review of what my colleague Jan Farley, the Chief Compliance Officer (CCO) at Dresser-Rand, called the...more

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