Corporate compliance officers might feel like they’ve been put through the whirlwind lately, with the Trump Administration issuing one sweeping announcement about corporate enforcement after another. Except, remember what a...more
2/20/2025
/ Anti-Bribery ,
Anti-Corruption ,
Compliance ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Governments
Sometimes questions about corporate compliance programs can be more complicated than they first seem. Such was the case when a compliance officer recently asked me, “Can you point to anything specific that says why compliance...more
Compliance officers spend lots of time these days worrying about how their own company’s use of artificial intelligence might draw the ire of regulators, but you have another dimension of AI risk to worry about, too. You need...more
Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more
8/9/2024
/ Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Internal Reporting ,
IRS ,
Regulatory Agencies ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers
At the end of June, the U.S. Supreme Court issued major decisions on the enforcement power of the Securities and Exchange Commission, what does or doesn’t qualify as a bribe of government officials, and on federal judges’...more
7/3/2024
/ Anti-Corruption ,
Anti-Kickback Statute ,
Bribery ,
Chevron Deference ,
Civil Monetary Penalty ,
Compliance ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Government Agencies ,
Loper Bright Enterprises v Raimondo ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Snyder v United States
For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more
12/8/2023
/ Board of Directors ,
CCO ,
CEOs ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Healthcare ,
Healthcare Reform ,
OIG ,
Risk Mitigation
In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more
11/30/2023
/ Acquisitions ,
Bribery ,
Clawbacks ,
Compensation ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Mergers ,
Penalties ,
Popular ,
Price-Fixing ,
Sanction Violations