News & Analysis as of

Compliance Department of Justice (DOJ) Internal Reporting

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 -
Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

Holland & Hart LLP on

On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

Thomas Fox - Compliance Evangelist

Internal Reporting and Investigative Lessons from Star Trek: The Conscience of the King

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

NAVEX

Whistleblower Awards Keep Adding New Compliance Pressures

NAVEX on

Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more

Thomas Fox - Compliance Evangelist

Internal Reporting and Triaging of Claims

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin...more

American Conference Institute (ACI)

[Event] Practical Guide to FCPA Data Analytics - November 28th, National Harbor, MD

The U.S. Department of Justice, Criminal Division, updated its Evaluation of Corporate Compliance Program in March 2023, with renewed expectations for companies to use data analytics and testing. However, the government...more

Fisher Phillips

Top 20 Questions to Ensure Your Compliance Program Helps You Minimize Corporate Criminal Risks

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Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more

Thomas Fox - Compliance Evangelist

From the Code of Conduct to Risk Assessment to Continuous Improvement

How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more

The Volkov Law Group

DOJ Revisions to Corporate Compliance Guidance: Training, Third-Party Risk Management, Mergers/Acquisitions and Data (Part II of...

The Volkov Law Group on

DOJ is catching up to compliance officers and evolving best practices.  Say what you want, DOJ is behind the curve of the compliance industry.  But you have to give DOJ credit – they are moving quickly to update its Guidance....more

Thomas Fox - Compliance Evangelist

Answering DOJ Questions on Confidential Reporting

What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or...more

The Volkov Law Group

Incident Data and Intra-Company Cooperation

The Volkov Law Group on

The Justice Department “listens and learns” from companies and compliance practitioners.  As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more

Thomas Fox - Compliance Evangelist

The 10 Hallmarks of an Effective Compliance Program: Still the Foundation

The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more

Thomas Fox - Compliance Evangelist

Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...more

Pillsbury Winthrop Shaw Pittman LLP

Great Expectations - DOJ holds anti-corruption compliance programs to a high standard in evaluating their credibility

On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more

NAVEX

5 Trends in Whistleblower Hotlines and Protections to Be Aware of in 2017

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Every year it’s safe to assume that our list of Top 10 trends will include the latest developments pertaining to helplines, whistleblower reporting and retaliation, and this year is no exception. We begin by examining some...more

Thomas Fox - Compliance Evangelist

The Board of Directors’ Compliance Committee

Yesterday, together with Baker Hughes Inc. (BHI) Chief Compliance Officer (CCO) Jay Martin, I wrote about a new and innovative compliance committee BHI has initiated, the GeoMarket Compliance and Ethics Committee. In...more

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