News & Analysis as of

Training Dept. of Justice

The Pull & Push of Compliance Policies & Training

by NAVEX Global on

“…companies used to bring in binders full of their policies….I really don’t care what the policy says….I’m more interested in how the policies actually operate.” That’s a quote from Hui Chen from an interview with...more

Code of Conduct Week: Part V – Operationalization

by Thomas Fox on

I have reviewed the creation and update of a Code of Conduct this week, with a big assist from Eric Morehead, the Principal of Morehead Compliance Consulting. We reviewed the legal requirements, the suggested structure and...more

Code of Conduct Week: Part IV – Training on Your Code of Conduct

by Thomas Fox on

Today focus in the Code of Conduct series is on the aspect of training on your finalized Code of Conduct. Eric Morehead, Principal of Morehead Compliance Consulting, joins me in this series. While there have been criticisms...more

Defining the Duty of the Board of Directors over Compliance Functions

by Ruder Ware on

I recently posted a blog article about a document released by the Department of Justice entitled “Evaluation of Compliance Programs.” As the title of the document might suggest, the DOJ release covers a variety of issues it...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

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

Dave Edwards, the Doomsday Defense and Execution in Compliance

by Thomas Fox on

Baker Hughes Inc. Chief Compliance Officer (CCO), Jay Martin, often says that execution is where the rubber meets the road in compliance. I thought about all of that in the context of some of the pronouncements the Department...more

Compliance Training, Part I

by Thomas Fox on

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

The SEC, CCOs and Compliance Programs

by Dorsey & Whitney LLP on

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Is Your Workplace Violence Plan Ready? 5 Essential Elements of a Comprehensive Plan

According to the U.S. Department of Justice, one out of every six violent crimes occurs in the workplace. These crimes include assaults, rapes, robberies, and—on rare occasions—homicides. Employees, customers, and third-party...more

Skeletons in the Closet? Beware of Potential Enforcement Actions

With Halloween looming, a discussion of skeletons that may be lurking in a health care provider’s closet is timely. Many of our previous posts, as well as the monthly Qui Tam Updates published by our Health Care Enforcement...more

3 Ways to Improve Compliance Training

by Michael Volkov on

As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as...more

What the Government Expects to Find in an Anti-Corruption Compliance Program

by Dentons on

Similar to Foreign Corrupt Practices Act enforcement generally, the federal government has expanded what it expects to find in an anti-corruption compliance program. U.S.-connected companies operating internationally...more

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA

by Thomas Fox on

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

FLIR FCPA Action Highlights: Continued Focus on Penalizing Improper Expenditures for Government Officials

by Dechert LLP on

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more

Government's Message to Corporate America — "We Want Your Whistleblowers!"

by Littler on

On September 22, 2014, the Securities and Exchange Commission's (SEC) Office of the Whistleblower announced that it had issued a $30 million bounty payment to a foreign whistleblower. This award is more than double the...more

Does a Compliance Program Matter to U.S. Antitrust Enforcers?

Two weeks ago Assistant Attorney General Bill Baer and Deputy Assistant Attorney General Brent Snyder of the Department of Justice’s Antitrust Division gave speeches in which they commented on the role of corporate compliance...more

Waking Up to Massive Third Party Risk Exposure: Critical Issues To Address

by NAVEX Global on

A little over a year ago the Rana Plaza factory collapsed and 1,100 garment workers died. This human disaster resulting from questionable construction practices and workplace safety issues focused the eyes of the world on the...more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM

by Michael Volkov on

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

The Mann Gulch Fire and How Far Down the Chain Do You Need to Go?

by Thomas Fox on

Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...more

Gehrig’s Streak Ends And Compliance Week 2014 Is Near

by Thomas Fox on

Today we celebrate greatness in two areas. The first is in baseball as on this day in 1939, “New York Yankees first baseman Lou Gehrig benches himself for poor play ending his streak of consecutive games played at 2,130....more

Mandatory Training for Third Parties – Effective or Protective?

by NAVEX Global on

What is the risk? Third-party liability for contractors, resellers, agents and supply chain partners is an issue that continues to bedevil corporations who need or choose to use third parties. The headlines and DOJ/SEC...more

More Compliance Lessons From The Asiana/SFO Crash Investigation

by Thomas Fox on

I have long been interested in the intersection in the changes in attitude regarding safety in the workplace by corporations and the changing attitudes on doing business through bribery and corruption. As a trial lawyer...more

Making Your Training Program Effective

by Michael Volkov on

Returning to the theme of profound grasps of the obvious, compliance officers face numerous challenges where they need creativity and persistence. ...more

A Prescriptive Guide To Third Party Risk Management

by NAVEX Global on

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

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