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Chief Compliance Officers Department of Justice (DOJ) Corruption

Society of Corporate Compliance and Ethics...

What's Going on with FCPA?

The FCPA sure isn’t what it used to be, or is it? While the headline grabbing Foreign Corrupt Practices Act cases are much less frequent than they once were, there is still substantial risk both for individuals and...more

NAVEX

Risk & Compliance as a Strategic Imperative for the Board

NAVEX on

In an era marked by heightened global regulatory scrutiny and enforcement, the landscape of risk and compliance is undergoing an evolution making the strategic imperative for effective, risk-based compliance initiatives...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

Husch Blackwell LLP

DOJ Updates FCPA Corporate Enforcement Policy

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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

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

Thomas Fox - Compliance Evangelist

Using Data Analytics to Create an Effective Compliance Program - Part 1

I recently had the opportunity to visit with Vince Walden for the inaugural episode of the newest podcast on the Compliance Podcast Network, Data Driven Compliance. Walden is a compliance professional with 15 years of...more

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

Latham & Watkins LLP on

Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...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

Dorsey & Whitney LLP

DOJ Announces Additional Incentives for Corporate Cooperation in Criminal Enforcement

Dorsey & Whitney LLP on

On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 1 – Introduction

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) both announced settlements of FCPA enforcement actions with Honeywell...more

Thomas Fox - Compliance Evangelist

What 2022 Brought to Compliance

2022 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate FCPA enforcement actions, there were three enforcement actions were significant with multiple...more

Thomas Fox - Compliance Evangelist

ABB FCPA Resolution: Part 1 – Introduction

Late last week, the Department of Justice (DOJ) announced a highly anticipated resolution of Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. The most obvious significance is...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

Paul Hastings LLP

Sign on the Dotted Line: Compliance Certifications by CEOs and CCOs A Likely Requirement

Paul Hastings LLP on

As it continues its focus not just on enforcement, but on compliance, members of the U.S. Department of Justice have foreshadowed a sea change for Chief Executive Officers and Chief Compliance Officers in corporate...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

Thomas Fox - Compliance Evangelist

The Fall of the Alamo and Empowerment of the Compliance Professional (UPDATED)

Yesterday, March 6 was the anniversary of the most historic day of many in the history of the great state of Texas, the date of the fall of the Alamo. While March 2, Texas Independence Day, is when Texas declared its...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

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Join the Go-To Event of the Year for Mexico’s Anti-Corruption Community. The annual ACI’s Anti-Corruption Summit in Mexico is back to Mexico City on March 22-23, 2022! This is the most important anti-corruption compliance...more

Thomas Fox - Compliance Evangelist

2021 – The Year in FCPA Enforcement

There was a paucity of Foreign Corrupt Practices Act (FCPA) enforcement actions in 2021. However, the few enforcement actions announced did provide significant lessons for every compliance professional....more

Thomas Fox - Compliance Evangelist

What 2021 Brought to Compliance

2021 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate FCPA enforcement actions, the three enforcement actions were significant with multiple lessons...more

The Volkov Law Group

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

The Volkov Law Group on

On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more

Thomas Fox - Compliance Evangelist

Foster Wheeler Settles Corruption Allegations – Silk Shirts and Corruption

I am continuing my review of the Amec Foster Wheeler (Foster Wheeler) international corruption enforcement action. Today, I want to focus on the underlying facts of the corruption. These facts are laid out in the Department...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

500th Anniversary Episode

We are here and today I am extraordinarily honored to post my 500th Anniversary podcast. Now, I switch seats to be the guest as I am interviewed by Gregg Greenberg, the General Manager of C-Suite Radio. We take a look back at...more

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