News & Analysis as of

Chief Compliance Officers Criminal Prosecution

Morgan Lewis - Health Law Scan

Chief Compliance Officer Convicted in Healthcare Fraud Case

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

BakerHostetler

DOJ Announces Major Corporate Enforcement Policies

BakerHostetler on

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

Eversheds Sutherland (US) LLP

New nationwide policy marks latest DOJ effort to incentivize voluntary self-disclosure

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

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

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

Womble Bond Dickinson on

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

Thomas Fox - Compliance Evangelist

ABB FCPA Resolution: Part 4 – ABB Shines

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

BakerHostetler

DOJ Corporate Compliance Certifications Appear to Be Here to Stay

BakerHostetler on

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

Health Care Compliance Association (HCCA)

[Webinar] The 7 Elements Made Easy: Translating Compliance Speak for New Professionals - November 16th, 12:00 pm - 1:30 pm CST

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

NAVEX

The Justice Department’s New Emphasis on a Culture of Compliance

NAVEX on

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

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

Thomas Fox - Compliance Evangelist

Would You Buy a New Car From Them? Part 2 – Lessons for Compliance

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

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

DOJ Compliance Program Certification Requirements (Part I of III)

The Volkov Law Group on

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

Hogan Lovells

Stericycle DPA signals more aggressive use of independent compliance monitors

Hogan Lovells on

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

The Volkov Law Group

CCOs and Criminal Cartel Compliance Programs (Part II of III)

The Volkov Law Group on

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

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

Health Care Compliance Association (HCCA)

[Event] Nashville Regional Healthcare Compliance Conference - November 5th, Nashville, TN

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 Volkov Law Group

HR and CCOs Watch Out!! — The Antitrust Division Doubles Down on Labor Market Criminal Cartel Activity

The Volkov Law Group on

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

Society of Corporate Compliance and Ethics...

[Virtual Event] Global Compliance Updates - November 2nd - 3rd, 5:55 pm - 8:15 pm GST

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

Oberheiden P.C.

Key Elements of an OIG Compliance Program That Respiratory and Clinical Labs Need to Know

Oberheiden P.C. on

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

WilmerHale

Bribery Act 2010: Ten Years On

WilmerHale on

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

Miller Canfield

Record Level of FCPA Enforcement in 2020 Highlights Key Risk Areas

Miller Canfield on

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

Society of Corporate Compliance and Ethics...

Compliance Perspectives: The Latest from the Fraud Section at the US Department of Justice

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

Thomas Fox - Compliance Evangelist

The Significance of Opinion Release 20-01

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

Steptoe & Johnson PLLC

U.S. Department of Justice Revises How It Evaluates Your Corporate Compliance Program

Steptoe & Johnson PLLC on

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

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