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Corporate Officers Department of Justice (DOJ) Chief Compliance Officers

Venable LLP

New Certification Requirements on the Horizon for CCOs: Certifying the Efficacy of Compliance Programs at the Conclusion of...

Venable LLP on

On Tuesday, March 22, 2022, Assistant Attorney General Kenneth Polite of the Department of Justice (DOJ) told an audience of compliance professionals that DOJ will direct prosecutors to "consider requiring" chief compliance...more

Ruder Ware

The Essence of Compliance - Compliance Officer Authority and Resource Allocation

Ruder Ware on

How Are Compliance Budgeting and Compliance Officer Autonomy Tied Together When Assessing Compliance Effectiveness? The Department of Justice (“DOJ”)’s compliance program evaluation identifies the need to allocate...more

Holland & Knight LLP

Department of Justice Issues New Guidance on How It Evaluates Compliance Programs

Holland & Knight LLP on

Last week, the DOJ Criminal Division published a guidance document entitled "Evaluation of Corporate Compliance Programs" (ECCP). This document is meant to assist prosecutors in determining what credit should be given to a...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Implementation, Operationalization and Effectiveness (Part IV of V)

The Volkov Law Group on

While I hate to start out a posting with such “mumbo jumbo” terms, I had to come up with short hand descriptions of some otherwise fairly complex and robust topics under the new DOJ Guidance....more

Wilson Sonsini Goodrich & Rosati

DOJ Criminal Division Releases Updated Guidance for Prosecutors Evaluating Corporate Compliance Programs

On April 30, 2019, Assistant Attorney General Brian A. Benczkowski announced the release of an updated version of the Criminal Division's "The Evaluation of Corporate Compliance Programs" during a keynote address at the...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Risk Assessments and Policies and Procedures (Part II of IV)

The Volkov Law Group on

Part 1 of the Corporate Compliance Guidance addresses the following elements of a well-designed compliance program: risk assessment, policies and procedures, training and communications, confidential reporting structure and...more

The Volkov Law Group

DOJ Issues New and More Robust Guidance on Evaluation of Corporate Compliance Programs (Part I of IV)

The Volkov Law Group on

In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs....more

Lowndes

How Effective is Your Corporate Compliance Program?

Lowndes on

On February 8, the Fraud Section of the United States Department of Justice (DOJ) posted on its website a document entitled “Evaluation of Compliance Programs” (the “Guidance”). This is the first formal guidance issued by the...more

Foley & Lardner LLP

Spain Sets a New Milestone with its Corporate Compliance Statute

Foley & Lardner LLP on

As of July 1 of this year, Spain becomes the latest in a string of nations with a corporate compliance defense. Article 33 of Spain’s criminal code will provide an exemption from corporate criminal liability where the company...more

Dorsey & Whitney LLP

DOJ–Louis Berger, Two Executives Resolve FCPA Charges

Dorsey & Whitney LLP on

The DOJ resolved another FCPA action with the company entering into a deferred prosecution agreement, paying a criminal fine and agreeing to the imposition of a monitor after self reporting and cooperating. Two of the firm’s...more

Thomas Fox - Compliance Evangelist

Good Bye to Mr. Cub, the Siege of Vienna and Doing More Compliance with Less

Let’s play two! That was perhaps the most famous maxim from Ernie Banks, who died this past weekend at the age of 83. As for a sobriquet, it does not get much better than being known as ‘Mr. Cub’ from any baseball fan from 9...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 117-the Avon FCPA Enforcement Action

In this episode I take a deep dive into the recent concluded Avon FCPA enforcement action. ...more

Thomas Fox - Compliance Evangelist

The Avon FCPA Settlement – Part III

Today I conclude my 2014 blog posts with a final look at the Avon Foreign Corrupt Practices Act (FCPA) enforcement action. Before getting to the key lessons that a compliance practitioner may draw from this enforcement...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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