Updated DOJ Guidance calls on corporations to devote additional resources and attention to detect and prevent misconduct.
A well-structured and effective compliance program must evolve with lessons learned, be understood...more
Companies must now address three questions proactively.
On April 30, 2019, the DOJ’s Criminal Division issued updated guidance on how it will evaluate corporate compliance programs in its charging decisions going forward....more
5/14/2019
/ Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Department of Justice (DOJ) ,
Employee Training ,
Guidance Update ,
Internal Controls ,
Risk Assessment ,
Risk Management ,
Third-Party Risk ,
Training ,
Whistleblower Protection Policies ,
Whistleblowers
Continuing its efforts to deter the use of real estate as a vehicle to launder proceeds of criminal activity, the Financial Crimes Enforcement Network (FinCEN) recently announced its plan to extend the reach and time frame of...more
8/22/2016
/ Anti-Money Laundering ,
Cash Transactions ,
Compliance ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
FinCEN ,
Geographic Targeting Order ,
Real Estate Market ,
Shell Corporations ,
Title Insurance ,
Transparency
On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more
4/15/2016
/ Bribery ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Internal Investigations ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes ,
Yates Memorandum
On November 14, 2012, the Foreign Corrupt Practices Act “Resource Guide” (the “Guidance”) was finally published, and at well over 100 pages, it constitutes a “non-binding informal summary” of various statutes, U.S. Department...more