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Anti-Corruption Chief Compliance Officers White Collar Crimes

The Volkov Law Group

The Compliance “Curse” — Learning to Compromise Principles

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Compliance lessons are life lessons.  Compliance professionals are, by their nature, optimistic people. They see challenges as new opportunities to strive closer to an ideal.  Compliance professionals live in the shadow of...more

Dentons

Ep. 9 - Building a Compliance Dream Team

Dentons on

Most healthcare providers understand the importance of having a designated Compliance Officer.  Someone needs to lead the organization’s compliance initiatives and be responsible for advising the CEO and governing body of...more

Thomas Fox - Compliance Evangelist

Compliance Leadership in the 2025 and Beyond

All leadership in the 21st century is undergoing a significant transformation. Traditional leadership styles and models are no longer adequate for the complex and rapidly changing world we find ourselves in. This was the key...more

Thomas Fox - Compliance Evangelist

Compliance Lessons from The Adventure of the Crooked Man

One of the great things about having a podcast network is that I get to not only explore topics that I love but I get to tie them into compliance. Perhaps the best example is my award-winning series, Trekking Through...more

The Volkov Law Group

The Evolution of the Compliance Profession

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One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more

The Volkov Law Group

Episode 284 -- How to Implement a Compliance Compensation System

The Volkov Law Group on

The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management.  The theoretical...more

The Volkov Law Group

Fasten Your Seatbelt: An Important Message on Proactive Compliance

The Volkov Law Group on

I’m old enough to remember when seat belts were optional. And I remember people up in arms when seatbelt laws first passed. But now, my young adult children and their friends simply get in the car and buckle up without...more

The Volkov Law Group

A Compliance Imperative – Breaking Down Silos

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The famous swashbuckling adventure of The Three Musketeers should inspire chief compliance officers to pursue an important concept – the need for teamwork and collaboration is imperative for all compliance programs.  We all...more

Husch Blackwell LLP

DOJ Updates FCPA Corporate Enforcement Policy

Husch Blackwell LLP on

On January 17, 2023, Assistant Attorney General (AAG) Kenneth Polite, Jr. announced updates to the Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. Since the inception of the FCPA Corporate Enforcement...more

BakerHostetler

DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

BakerHostetler on

On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

StoneTurn

5 Tips For Meeting DOJ’s New CCO Certification Requirements

StoneTurn on

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

Wilson Sonsini Goodrich & Rosati

DOJ Announces New Guidance on Corporate Criminal Enforcement

On September 15, 2022, Deputy Attorney General of the Department of Justice (DOJ) Lisa Monaco announced pivotal new guidance about the DOJ’s corporate criminal enforcement efforts. Her speech, accompanied by a more...more

Brownstein Hyatt Farber Schreck

DOJ Introduces a Mix of ‘Carrots and Sticks’ to Combat Corporate Crime

The Department of Justice is sending a clear message to companies when it comes to corporate crime: invest in strong compliance structures and culture and come forward quickly with information about misconduct—or suffer the...more

The Volkov Law Group

Building a Compliance Dashboard (Part I of II)

The Volkov Law Group on

This is a topic that every compliance professional has to address in one form or another.  Chief compliance officers are so busy that they often cannot even take the time to tackle this difficult issue.  This is a real...more

The Volkov Law Group

Compliance Program Monitoring, Testing, Audits, Assessments and Continuous Improvement (Part I of IV)

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Chief compliance officers have a lot of issues to balance on their plate.  Experienced CCOs know that it is not possible to complete every objective, balance every changing risk, and continuously improve their respective...more

The Volkov Law Group

The Importance of Ethics and Compliance to the Overall Corporate Mission (Part II of IV)

The Volkov Law Group on

There are lots of sources for compliance guidance — prosecutors, regulators, compliance organizations, and many others have set forth important and valuable guidance for the design and implementation of an effective ethics...more

Dechert LLP

Measure Twice, Cut Once: New DOJ Compliance Certifications Put CEOs and CCOs at Risk of Individual Criminal Liability

Dechert LLP on

Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more

Guidepost Solutions LLC

The Sky Will Not Fall with New Justice Department CEO / CCO Certifications; Instead, the Sun Will Shine

Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more

The Volkov Law Group

CCOs and Execution of Compliance Certification: A Significant Risk? (Part III of III)

The Volkov Law Group on

CCOs, by definition, are careful and deliberate.  It comes with the profession.  As risk managers, CCOs are skilled in identifying, assessing and acting in a risk environment....more

The Volkov Law Group

DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)

The Volkov Law Group on

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement...more

Society of Corporate Compliance and Ethics...

Salvador Dahan on the Journey of Petrobras

Operation Lava Jato (Carwash) had a profound effect on business in Brazil, with countless companies caught up in one way or another in the corruption scandal. State oil company Petrobras was no exception, but, as is the case...more

The Volkov Law Group

Monitoring and Measuring A Company’s Ethical Culture: Relevant Survey Strategies (Part I of II)

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Chief compliance officers play a key role in managing a company’s ethical culture. Most companies fail to pay proper attention to its culture because it is difficult to define, measure and monitor. Such an approach is...more

Thomas Fox - Compliance Evangelist

Monaco Speech: Part 5 – What Does It All Mean?

This week I have been writing about the speech Deputy Attorney General (DAG) Lisa O. Monaco gave as a Keynote Address at ABA’s 36th National Institute on White Collar Crime last week (Monaco Speech). Her remarks were noted by...more

Womble Bond Dickinson

Biden Administration Prioritizes Corporate Criminal Enforcement

Womble Bond Dickinson on

Takeaways: ..In recent remarks, top DOJ officials stated that DOJ will “surge resources” and “redouble efforts” for corporate enforcement. ..Areas of particular concern include Foreign Corrupt Practices Act,...more

McDermott Will & Emery

[Ongoing Program] 2021 Latin American Compliance Conference - Day 2 - September 30th, 12:00 pm - 1:00 pm EDT

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Join us virtually for our second annual Latin American Compliance Conference. During this two-day webinar series, attendees will hear from McDermott White Collar litigators and compliance specialists, as well as industry and...more

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