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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

The Volkov Law Group

Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks

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Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable and to protect the organization from potential private and government claims or investigations that...more

DarrowEverett LLP

How DOJ's Safe Harbor Policy Rewards Honesty Within M&A Deals

DarrowEverett LLP on

Be you a merger and acquisition attorney, corporate compliance officer, or counsel to an acquiring entity or target entity, you should review the Department of Justice’s new Merger and Acquisition Safe Harbor Policy...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

Society of Corporate Compliance and Ethics...

Compliant Business Communications Through Messaging Apps

Email isn’t enough anymore, if it ever really was. Employees are communicating with each other, clients and prospects via texts, WhatsApp, Teams, Slack and many, many more tools. Much attention has been paid to the US...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

The Volkov Law Group

Corporate Culture: Monitor, Intervene and Remediate (Part III of III)

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Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone.  To the contrary, as the business adapts through growth, innovation or in response to outside market and...more

Jenner & Block

Client Alert: Key Insights from Updated DOJ Guidance Regarding the “Evaluation of Corporate Compliance Programs” and New...

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On Friday, March 3, 2023, the Department of Justice (DOJ) Criminal Division released updated guidance regarding the “Evaluation of Corporate Compliance Programs.” Now in its fourth iteration, this guidance replaces the June...more

Goodwin

DOJ Revises Corporate Compliance Guidance to Take on Compensation Incentives and Communications Preservation - With a Continued...

Goodwin on

As part of a recent series of announcements regarding updates to its corporate compliance policies, the Department of Justice (DOJ) announced significant revisions to its evaluation criteria for corporate compliance programs,...more

WilmerHale

DOJ Announces Significant Guidance on Compliance, Compensation, Communications and Cooperation

WilmerHale on

On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more

Goodwin

DOJ Announces Nationwide Voluntary Corporate Self-Disclosure Policy in Effort to Standardize and Incentivize Timely Self-Reporting

Goodwin on

On February 22, 2023, the US Department of Justice (DOJ) announced a Voluntary Self-Disclosure Policy (VSD Policy) to formalize DOJ’s efforts to incentivize companies to voluntarily self-report criminal misconduct to the...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

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

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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

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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

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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

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

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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

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

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

The Volkov Law Group

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

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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

The Volkov Law Group

Insights from Recent NAVEX Global and KPMG Surveys

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Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry.  Compliance...more

The Volkov Law Group

Remediating the Organization’s Culture (Part IV of IV)

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“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more

The Volkov Law Group

Measuring and Reporting on the Organization’s Culture (Part III of IV)

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While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures....more

The Volkov Law Group

When a CCO Fails to Speak Up

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We often discuss the importance of a “Speak Up” culture.  We encourage employees to report their concerns, we emphasize the important of such reporting to the life of an organization....more

Latham & Watkins LLP

White Collar & Compliance Academy 2021 - Die Zukunft

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Compliance & Investigations im Jahr 2025 - „Wirksame Compliance erfordert ganzheitliche Ansätze.“ Was ist für die Themen „Compliance & Investigations“ im Jahr 2025 zu erwarten? Fünf Thesen von Prof. Dr. Thomas Grützner...more

The Volkov Law Group

The Future of Compliance: Building Bridges (Part II of III)

The Volkov Law Group on

As a passionate supporter of the compliance function, I continue to advocate for compliance officers and the importance of compliance to overall governance.  Good compliance means good business – we all know that....more

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