News & Analysis as of

Training Department of Justice (DOJ) Securities and Exchange Commission (SEC)

Thomas Fox - Compliance Evangelist

Training and Communications Lessons from Star Trek: The Trouble with Tribbles

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Guidepost Solutions LLC

Crypto Crackdown: 8 Key BSA/AML Fundamentals for FinTechs

In June 2024, multiple state regulators took joint action against Plutus Financial, Inc (Abra) ordering Abra to cease and desist certain operations in the U.S. and reimburse customers of virtual assets valued at $81.1 million...more

McDermott Will & Emery

[Webinar] Anti-Corruption and Compliance Training - May 28th, 10:00 am - 11:30 am EDT

McDermott Will & Emery on

Please join McDermott and Grant Thornton on Thursday, May 28, for a webinar training on anti-corruption and compliance. This training will discuss the auditing standards on illegal acts by clients and the auditor’s...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...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

Thomas Fox - Compliance Evangelist

Dave Edwards, the Doomsday Defense and Execution in Compliance

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

Thomas Fox - Compliance Evangelist

Compliance Training, Part I

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 Volkov Law Group

3 Ways to Improve Compliance Training

The Volkov Law Group 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

Thomas Fox - Compliance Evangelist

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

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

Dechert LLP

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

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

Littler

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

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

NAVEX

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

NAVEX 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

The Volkov Law Group

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

The Volkov Law Group 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 programs. ...more

Thomas Fox - Compliance Evangelist

Gehrig’s Streak Ends And Compliance Week 2014 Is Near

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

NAVEX

Mandatory Training for Third Parties – Effective or Protective?

NAVEX 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

The Volkov Law Group

Making Your Training Program Effective

The Volkov Law Group on

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

NAVEX

A Prescriptive Guide To Third Party Risk Management

NAVEX 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

The Volkov Law Group

Improving Your Anti-Corruption Training Program

The Volkov Law Group on

Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance....more

The Volkov Law Group

Anti-Corruption High-Risk Audits

The Volkov Law Group on

The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance...more

Thomas Fox - Compliance Evangelist

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

Thomas Fox - Compliance Evangelist

How To Demonstrate Ethics And Compliance – Earn It, Re-Earn It And Re-Evaluate It

What should your company do if it finds itself in a situation where some of its senior leadership has engaged in conduct which violates its own ethical standards or external legal standard such as the Foreign Corrupt...more

Thomas Fox - Compliance Evangelist

How to Introduce Change into Your FCPA Compliance Program (Without Blowing It Up)

Thucydides or Herodotus; Herodotus or Thucydides. Which is your favorite? I admit to vacillating between the two. Thucydides wrote about the end of the Athenian dynasty from the Peloponnesian War and the debacle of the...more

Thomas Fox - Compliance Evangelist

NFL Replacement Referees-the Lessons of Training Temporary Employees

The short autumn of our discontent is over as the United States has ended one of its greatest national convolutions of recent memory. Am I speaking of the attack on the US Consulate in Libya; the current stalemate of US...more

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