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Criminal Liability Internal Controls

BCLP

Personal Matters - How will the risks to firms from individuals’ behaviour increase in 2024?

BCLP on

Financial regulators in the UK have been interested for some years in the question of how personal behaviour can affect the risk profile of a financial institution. A recent SEC case suggests that US regulators may now be...more

Hogan Lovells

Zaostrzenie odpowiedzialności podmiotów zbiorowych – nowe plany rządu

Hogan Lovells on

W ostatnim czasie rząd zaprezentował założenia nowelizacji ustawy o odpowiedzialności podmiotów zbiorowych za czyny zabronione pod groźbą kary. Jest to akt nakładający odpowiedzialność na korporacje za czyny popełnione przez...more

Hogan Lovells

Tightening the liability of collective entities - new government plans

Hogan Lovells on

The government recently presented the assumptions of the amendment to the Act on the Liability of Collective Entities for Criminal Offences. This is an act that imposes liability on corporations for acts committed by persons...more

American Conference Institute (ACI)

DOJ CCO Certification Requirement Will Up the Ante of CCO Oversight

Officials with the U.S. Department of Justice have portended a sea change in the oversight responsibilities of chief compliance officers (CCOs) as it concerns corporate resolutions going forward. In public remarks made March...more

BCLP

Potential reforms to the UK’s model for criminal liability: should we be concerned?

BCLP on

On 10 June 2022, the Law Commission published its long awaited paper setting out ten options that are available to the Government for reform of the common law principles governing corporate criminal liability in the UK. In...more

WilmerHale

Bribery Act 2010: Ten Years On

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Ten years have passed since the introduction of the UK’s primary anti-corruption law, the Bribery Act 2010 (“the Act”). This article examines the extent to which the Act has lived up to its billing as the international “gold...more

Oberheiden P.C.

Corporate Intelligence & Investigations

Oberheiden P.C. on

Today’s modern world enables complex business transactions to occur both within the United States as well as abroad in cross-border activities. Many of these transactions pose significant risks to business operations and the...more

The Volkov Law Group

Revised FCPA Guidance: Effective Compliance Program and Internal Controls (Part V of V)

The Volkov Law Group on

The initial FCPA Guidance included valuable compliance program guidance keyed to the heading, “Hallmarks of an Effective Compliance Program.”  Issued in 2012, the outline of an effective compliance program was an important...more

Jones Day

Italian Supreme Court: Crimes Benefiting Foreign Companies Trigger Administrative (Quasi-Criminal) Liability

Jones Day on

Multinationals operating in Italy should develop and implement a compliance system in line with the requirements and standards provided for by Decree No. 231/01. The Italian Supreme Court, in a decision of April 2020,...more

Barnea Jaffa Lande & Co.

Israel's Prosecution Policy for the Criminal Prosecution and Punishment of Corporations

Barnea Jaffa Lande & Co. on

In October 2019, the Israel State Attorney published a new guideline on its office’s policy when considering the prosecution of a corporation, as well as on how it should determine its position on the manner of punishing...more

Foodman CPAs & Advisors

Did you know that there is FCPA Individual Compliance Responsibility?

Foodman CPAs & Advisors on

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It also requires companies whose securities are listed in the US to make and keep...more

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