News & Analysis as of

Compliance Department of Justice (DOJ) Corporate Management

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Thomas Fox - Compliance Evangelist

Culture Week: Part 1- Redesigning Culture

In the FCPA Compliance and Ethics Blog this week, I will explore corporate culture from various angles. Since at least October 2021, the Department of Justice (DOJ) has made corporate culture part of its review for any...more

Thomas Fox - Compliance Evangelist

Auditing Culture

Why should you audit your culture? In doing so, a compliance professional can utilize a comprehensive approach designed to evaluate various aspects of a company’s culture, including ethics, engagement, accountability, and...more

The Volkov Law Group

DOJ Revises Standard Ethics and Compliance Requirements Used in Settlements

The Volkov Law Group on

As The Volkov Law Group previously noted in the context of a blog post authored by Michael Volkov,  the U.S. Department of Justice (“DOJ”)—at the behest of Deputy Attorney General Lisa Monaco—recently updated the requirements...more

Thomas Fox - Compliance Evangelist

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 3-Defining the Effectiveness of Compliance...

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...more

The Volkov Law Group

Promoting Your Corporate Culture – Accountability and Messaging (Part II of III)

The Volkov Law Group on

As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture.  In these...more

NAVEX

NAVEX Top 10 Trends in Risk & Compliance Preview

NAVEX on

Each year, NAVEX releases the Top 10 Trends in Risk and Compliance to provide leaders with guidance and insights on where to focus their initiatives and resources. Staying ahead of global trends in risk and compliance has...more

NAVEX

A Review of Risk & Compliance in 2022

NAVEX on

As 2022 comes to a close, now is an ideal time to reflect on the developments and challenges this year held for the risk and compliance profession – and there was no shortage of either. The complexity of maintaining...more

Society of Corporate Compliance and Ethics...

Updated guidance document reflects new perspectives on compliance programs

Report on Supply Chain Compliance 3, no. 14 (July 23, 2020)  - The United States Department of Justice (DOJ) released an update to its guidance document, Evaluation of Corporate Compliance Programs, which is based on...more

Thomas Fox - Compliance Evangelist

Measuring, Assessing and Improving Culture

As most compliance practitioners know, the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs, 2019 Guidance, concentrated focus on culture in a way the DOJ has not done previously. This concentrated...more

Latham & Watkins LLP

Prioritizing Corporate Culture: Lessons for Companies from the Major League Baseball Sign-Stealing Investigation

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The MLB Commissioner held senior leadership accountable for illegal sign stealing - even though the conduct generally involved players and low-level operations employees. On January 13, 2020, Major League Baseball (MLB)...more

Saul Ewing LLP

DOJ’s Criminal Division Updates Guidance for Evaluation of Corporate Compliance Programs

Saul Ewing LLP on

When the Department of Justice takes aim at a corporation, the effectiveness of the corporation’s compliance program at the time of corporate wrongdoing and afterwards can be key to federal prosecutors’ decision-making. ...more

King & Spalding

Corporate Compliance Programs: DOJ Issues Updated Guidance: Ten Takeaways for In-House Legal and Compliance Leaders

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On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more

Pillsbury Winthrop Shaw Pittman LLP

Time to Update Corporate Compliance Programs Following DOJ Guidance

Companies must now address three questions proactively. On April 30, 2019, the DOJ’s Criminal Division issued updated guidance on how it will evaluate corporate compliance programs in its charging decisions going forward....more

Thomas Fox - Compliance Evangelist

Astros Garner First World Series Win – Execution of Compliance in the Middle

In compliance you often times need to be a superior utility player who is good at every job. There are multiple lessons. First and foremost is the problem of siloing in corporate America. This concern of siloing even...more

NAVEX

Seven Things DOJ Insiders Expect Organizations To Know (and Do) About Antitrust Compliance

NAVEX on

For most organizations, the risk of violating antitrust laws is real. But when it comes to the most serious of antitrust violations, such as cartels and significant price fixing schemes, there is often an “it won’t happen...more

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