On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more
On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more
To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more
The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively...more
A corporate compliance program can be thought of as a magnet that brings a company’s compliance efforts together. It is an operational program, not simply a code of expected ethical behavior. An effective compliance...more
The Justice Department is rapidly pushing corporations to a new level of compliance. We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs. It would be a...more
The U.S. Department of Justice (DOJ) recently announced several new policies and programs aimed at incentivizing corporate compliance. These programs underscore the need for companies to investigate, mitigate and resolve...more
Self-Reporting Remains a Major Focus - Few executives expect to interact with the Department of Justice (DOJ) during their careers, but the current DOJ has given companies some homework, and the assignment applies to...more
CEP Magazine - December 2022 - In September, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco announced new guidelines the department will use in connection with criminal enforcement. Those...more
On September 15, Deputy Assistant General of the United States ("DAG") Lisa Monaco announced new U.S. Department of Justice ("DOJ") policy changes during a speech on corporate criminal enforcement at New York University Law...more
As the leading hotline provider in the global market, NAVEX is in the unique position of collecting and analyzing employee reporting trends. Each year, NAVEX issues an important report on current trends in employee...more
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
In June 2020, the US Department of Justice Criminal Division (DOJ) released an updated “Evaluation of Corporate Compliance Programs” notification. Our (and maybe your) first reaction upon hearing of this doctrine was likely,...more
On September 10, 2020, the Commodity Futures Trading Commission (the CFTC) issued a new guidance memorandum outlining factors that the Division of Enforcement (the division) will consider when evaluating compliance programs...more
On September 10, 2020, the Commodity Futures Trading Commission’s (“CFTC” or “the Commission”) Division of Enforcement (“the Division”) issued guidance for CFTC staff on the factors to be considered when evaluating compliance...more
El 1 de junio de 2020, la División Criminal del Departamento de Justicia (“DOJ”) publicó una actualización de la Evaluación de Programas de Cumplimiento Corporativo de la División Criminal del Departamento de Justicia de los...more
The U.S. Department of Justice recently updated its extensive guidance to federal prosecutors across the country regarding how to evaluate corporate compliance programs. This document is a must-read for company leadership,...more
On June 1, the DOJ updated its guidance for evaluating a company’s compliance program when resolving corporate investigations. The updated guidance makes clear that prosecutors should consider a company’s particular...more
On Monday, June 2, 2020, the DOJ’s Criminal Division announced updates to its guidance for Evaluation of Corporate Compliance Programs (the “Guidance”). The Guidance is a tool for federal prosecutors to evaluate the...more
On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more
On April 30, 2018, the Criminal Division of the US Department of Justice (DOJ) released a guidance document regarding corporate compliance programs. The guidance looks at the adequacy and effectiveness of compliance programs...more
On April 30, the Criminal Division of the Department of Justice released an update to the Fraud Section’s February 2017 guidance document titled “Evaluation of Corporate Compliance Programs.” ...more
On April 30, 2019, the U.S. Department of Justice (DOJ) released updated guidance detailing how prosecutors will evaluate corporate compliance programs in charging and resolving criminal cases....more
On May 1, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) released updated guidance for prosecutors to utilize in assessing whether an organization had in place “an adequate and effective corporate...more
The Department of Justice Criminal Division revised and shuffled two-year-old guidance to help prosecutors evaluate corporate compliance policies when making charging decisions. Our White Collar, Government & Internal...more