Implications of the SEC Cybersecurity Disclosure Rule
The Privacy Insider Podcast Episode 4: Don't Be Evil: In the Hot Seat of Data Privacy, Part 1
Privacy Issues from Third-Party Website Tags
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Managing Social Media Risk
Compliance Lessons from Dating in Your 50s
Managing Compliance Risk for Human Trafficking and Modern Slavery
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
Preparing for a Government Healthcare Audit
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Understanding the HHS OIG’s General Compliance Program Guidance
Climate Risk, the emerging risk
What's Going on with FCPA?
Compliance, Project Management, and Process Improvement
Leaning in on AI in Compliance Programs
PODCAST: Williams Mullen's Gavels & Gowns - Title IX Regulations - Changes on the Horizon
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Behavioral Health Compliance
The US Department of Justice (DOJ) announced on June 8, 2023 that Steven King, a compliance executive of pharmacy holding company A1C Holdings LLC, was convicted of defrauding Medicare out of more than $50 million in a scheme...more
Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more
On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more
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
Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more
We continue our exploration of the latest resolution of a Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. The most obvious significance is from the fact that ABB is now the...more
The compliance certification policy was first announced by Assistant Attorney General (Assistant AG) Kenneth Polite in March 2022, when he stated that for all criminal division “corporate resolutions (including guilty pleas,...more
Learning objectives: - Define the overarching purpose of Compliance Programs - From a practical perspective in detecting, correcting, and preventing wrongdoing, and; - From the perspective of increasing the chances...more
The week of September 12 was an important one for corporate compliance professionals. We saw two high-ranking officials at the U.S. Justice Department give back-to-back speeches outlining ambitious plans to transform the...more
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
Over this series, I am reviewing the corruption enforcement action Involving the company formerly known as Chrysler Group LLC, now FCA US LLC (Chrysler or the company herein) which was criminally sentenced to pay a fine of...more
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 Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to...more
On April 20, 2022, the U.S. Department of Justice (DOJ) announced it had entered a three-year deferred prosecution agreement (DPA) with Stericycle Inc. to resolve allegations that it violated the Foreign Corrupt Practices Act...more
Chief compliance officers have plenty of things to do and risks to manage. CCOs have a unique remit and a set of skills that should be applied whenever needed. While I am not trying to increase CCO workload (and forgive me...more
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
Our one-day Regional Compliance Conferences provide attendees with a forum to interact with local compliance professionals, share information about your compliance successes and challenges, and create educational...more
The Justice Department’s Antitrust Division has targeted collusion in labor markets for criminal prosecution. This was not unexpected. Indeed, the Antitrust Division gave plenty of warning to companies that criminal...more
Compliance teams looking to stay ahead of the changing landscape need to be up to date on the latest developments. Join us for Global Compliance Updates in collaboration with the DIFC Academy, on 2–3 November 2021. This...more
Clinical laboratories such as respiratory and clinical labs that bill Medicare, Department of Health and Human Services (“DHHS”) programs, and other federal programs are subject to oversight by the Office of Inspector General...more
Ten years have passed since the introduction of the UK’s primary anti-corruption law, the Bribery Act 2010 (“the Act”). This article examines the extent to which the Act has lived up to its billing as the international “gold...more
The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more
In the latest episode of the Compliance Perspectives podcast we are joined by Daniel Kahn, the Acting Chief of the Fraud Section at the Department of Justice. We begin the conversation with a discussion of the latest...more
For the first time in six years, the Department of Justice (DOJ) has released an Opinion Release, denominated 20-01. At first blush it appears to be a straight-forward recitation of the equivalent of black letter law in the...more
On June 1, 2020, the United States Department of Justice (DOJ) released revised guidelines that it will use when its prosecutors evaluate your corporate compliance program and make corporate charging decisions, including...more