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Criminal Prosecution Policies and Procedures

Dunlap Bennett & Ludwig PLLC

Can You Prove It? Evidence Of Compliance Is Critical For Government Contractors

The Department of Justice has been clamping down on false certifications in the System for Award Management (“SAM”), in government contracts, and on invoice submissions. New laws are being created, new frameworks are being...more

Jenner & Block

Client Alert: Attorney General's December 2022 Revisions to DOJ’s Charging, Pleas, and Sentencing Policies

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On December 16, 2022, Attorney General Merrick Garland issued a memorandum announcing important revisions to the Department of Justice (DOJ)’s policies on charges, pleas, and sentencings. These revisions align DOJ’s policies...more

Oberheiden P.C.

When Is a Trade Considered “Unauthorized”?

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Allegations of unauthorized trading claims present significant risks for investment brokers and brokerage firms. In addition to investor arbitration with the Financial Industry Regulatory Authority (FINRA), brokers and...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

MIOSHA Issues Agency Instruction, Clarifying Procedures for Conducting Interviews During Enforcement Investigations

On October 17, 2022, the Michigan Occupational Safety and Health Administration (MIOSHA) issued an agency instruction, the subject of which is “Interviews in Health and Safety Investigations.” The stated purpose of that...more

Health Care Compliance Association (HCCA)

[Webinar] The 7 Elements Made Easy: Translating Compliance Speak for New Professionals - November 16th, 12:00 pm - 1:30 pm CST

Learning objectives: - Define the overarching purpose of Compliance Programs - From a practical perspective in detecting, correcting, and preventing wrongdoing, and; - From the perspective of increasing the chances...more

Troutman Pepper

New DOJ Guidance Tightens Corporate Enforcement Strategy

Troutman Pepper on

Join Troutman Pepper White Collar and Government Investigation Partners Callan Stein, Miranda Hooker, and Allison DeLaurentis for a podcast discussion on the DOJ’s updated guidelines regarding corporate criminal enforcement....more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Policies on Corporate Ethics and Compliance

Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more

Hogan Lovells

Market abuse surveillance: How to get it right

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Identifying and reporting instances of potential market abuse is required under the Market Abuse Regulation ('MAR'). A firm must have effective arrangements, systems and procedures in place to detect and report suspicious...more

BakerHostetler

$3.6 Billion Reasons to Up Cryptocurrency Compliance: FBI Cracking Down on Crypto Criminals

BakerHostetler on

Key Takeaways - ..Banks and cryptocurrency exchanges need to update their BSA programs to account for the unique aspects of cryptocurrencies, detect and report related suspicious activity, and minimize the risk of...more

Health Care Compliance Association (HCCA)

Report on Research Compliance Volume 18, Number 10. In This Month’s E-News: October 2021

Report on Research Compliance 18, no. 10 (October, 2021) - An audit by the HHS Office of Inspector General (OIG) of the National Human Genome Research Institute’s (NHGRI) pre-award risk assessment process concluded that...more

Steptoe & Johnson PLLC

Ohio Passes Sweeping Anti-Hazing Law Aimed at Colleges and Universities

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In the wake of hazing-related deaths at two Ohio universities, Governor Mike DeWine signed Collin’s Law: The Ohio Anti-Hazing Act on July 6, 2021. That law—which goes into effect in early October and is named after Collin...more

Oberheiden P.C.

Key Elements of an OIG Compliance Program That Respiratory and Clinical Labs Need to Know

Oberheiden P.C. on

Clinical laboratories such as respiratory and clinical labs that bill Medicare, Department of Health and Human Services (“DHHS”) programs, and other federal programs are subject to oversight by the Office of Inspector General...more

Oberheiden P.C.

5 Anti-Money Laundering Compliance and Defense Tips

Oberheiden P.C. on

1. AML Laws - Federal anti-money laundering (“AML”) laws are complex in nature and apply to a broad category of institutions and businesses. One of the most important AML laws is the Bank Secrecy Act, which obligates...more

Goodwin

Biogen Inc. Wins Some, Loses Some, in Delaware Chancery Court Corporate Records Suit

Goodwin on

Biogen Inc. Wins Some, Loses Some, In Delaware Chancery Court Corporate Records Suit; Southern District of Florida Dismisses Securities Fraud Class Action Against Norwegian Cruise Lines Stemming From Alleged Impacts of...more

Saul Ewing LLP

The Responsible Corporate Officer Doctrine and the Food, Beverage and Agribusiness Industry — What You Need to Know

Saul Ewing LLP on

In this episode, host Jonathan Havens, co-chair of Saul Ewing Arnstein & Lehr’s Food, Beverage and Agribusiness (FBA) Practice, speaks with colleague Justin Danilewitz, a litigator in the Firm’s White Collar and Government...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

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

Epstein Becker & Green

SEC Sanctions Broker-Dealer and Its CEO for Failing to Supervise an Employee Who Committed Securities Fraud

Epstein Becker & Green on

On August 20, 2019, the Securities and Exchange Commission (“SEC”) charged Mosaic Capital, LLC, formerly known as AOC Securities, LLC (“AOC”), and its CEO with failing to adequately supervise an employee who engaged in...more

Katten Muchin Rosenman LLP

Bridging The Week - September 2019

A clearing organization for futures and securities was sanctioned US $20 million in aggregate by the Commodity Futures Trading Commission and the Securities and Exchange Commission for allegedly not having and following...more

Robinson+Cole Manufacturing Law Blog

EPA Formalizes Policy to Partner with States on Environmental Compliance and Enforcement

Over the summer, EPA published a policy document to enhance cooperation between it and the many state agencies that enforce federal environmental programs. ...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Holland & Knight LLP

DOJ's Updated Compliance Guidance is Important for Healthcare Entities

Holland & Knight LLP on

• The U.S. Department of Justice (DOJ) recently updated its guidance to Criminal Division prosecutors in evaluating a corporation's compliance program when making charging decisions (Guidance). • The Guidance directs...more

McDermott Will & Emery

DOJ Guidance on Evaluation of Corporate Compliance Programs: Key Takeaways

Boards and management should make use of recent expanded guidance from the US Department of Justice to ensure that their compliance programs are considered “effective” if and when an investigation arises. Companies should...more

Bradley Arant Boult Cummings LLP

DOJ Evaluation of Corporate Compliance Programs - Government Enforcement Update

On April 30, 2019, the Department of Justice (DOJ), Criminal Division released a new guidance document intended to assist prosecutors in evaluating corporat­­­e compliance programs and guide corporations in creating them. The...more

Mitratech Holdings, Inc

Policy & Procedure Management - Linchpin of a Defensible Compliance Program

The communication of policies and procedures to employees by disseminating publications that explain in a practical manner what is required is considered the cornerstone of an effective compliance program and...more

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