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
No Longer Just a Matter of Paying the Fine and Moving On.
Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
9/12/2023
/ Breach of Duty ,
Compliance Management Systems ,
Corporate Misconduct ,
Corporate Monitoring ,
Corrective Action Plans (CAPs) ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Forensic Examination ,
Government Investigations ,
Internal Audit Functions ,
Remediation ,
Risk Assessment ,
Sarbanes-Oxley ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
White Collar Crimes
Turbulence in the financial services sector is proving to have a significant impact on the global financial ecosystem. For organizations large and small, now is the time to reflect on key questions to solidify risk management...more
The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more
11/10/2022
/ Anti-Corruption ,
Anti-Money Laundering ,
CEOs ,
Certifications ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Incident Response Plans ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Third-Party ,
White Collar Crimes
"Whistleblowing," a fundamental component of any compliance program, refers to specific allegations of misconduct raised typically through an anonymous hotline or similar mechanism. "Speak-Up" is broader and refers to a...more
6/24/2022
/ Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Ethics ,
Individual Accountability ,
Policies and Procedures ,
Speak-up Cultures ,
Stakeholder Engagement ,
Training ,
Whistleblower Awards ,
Whistleblowers ,
Workplace Communication