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Department of Justice (DOJ) Internal Audit Functions

StoneTurn

Meeting DOJ and SEC Post-Settlement Obligations: A Practical Guide

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No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more

Oberheiden P.C.

Ten Things You Should Know if Your Clinical Laboratory is Under Investigation

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Similar to other types of healthcare entities, clinical laboratories have been facing enhanced scrutiny from federal authorities over the past couple of years. While this is due in part to fraud concerns related to COVID-19...more

Oberheiden P.C.

Internal Audit for FCPA Compliance: A Detailed Guide

Oberheiden P.C. on

The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more

Guidepost Solutions LLC

With Enforcement Actions Likely to Increase in 2022, Companies Should Ask Where the Bodies are Buried

In 2022, companies are likely to see an increase in white collar and regulatory investigations and enforcement actions. Here are just a few reasons why this is likely to happen. First, in the late fall, Deputy Attorney...more

McDermott Will & Emery

[Webinar] Compliance AI + Smart Lawyering: Maximizing Data to Stay Ahead of the DOJ’s Key Enforcement Areas - July 20th, 12:00 pm...

The US Department of Justice (DOJ) now has more ammunition and resources than ever to use data analytics in their investigations. The convergence of better technology, increasingly usable data sets, and the ripe combination...more

The Volkov Law Group

The Herbalife FCPA Settlement: Board Oversight and Internal Audit Failures

The Volkov Law Group on

In the enforcement and compliance arena, there are instances of misconduct that underscore important governance principles. But this just sounds like a bunch of mumbo jumbo (the technical term, I know)....more

Thomas Fox - Compliance Evangelist

Talent Mix: Maximizing Your Program’s Reach with Diverse Skillsets

Ed. Note-We welcome back Troy McAlister with another guest post. Troy brings 20 years of experience at both public and private companies, in public accounting and in a variety of industries. Troy has experience in...more

Vinson & Elkins LLP

Recent DOJ Prosecution Declination Supports Its Promise Of Leniency For Self-Reporting Violations Even When “Bags of Money” Are...

Vinson & Elkins LLP on

A recurring question of general counsel and chief compliance officers is whether their proactive investments in compliance programs, voluntary self-disclosure of issues, and cooperation will be meaningfully rewarded. For too...more

Thomas Fox - Compliance Evangelist

Creating an Inventory of Metrics

I recently had the opportunity to visit with Michele Edwards, Partner at StoneTurn, to consider some of the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ)...more

Thomas Fox - Compliance Evangelist

Consistency as a Compliance Best Practice

I recently had the opportunity to visit with Asha Palmer, Convercent Chief Ethics and Compliance Officer (CECO) and Executive Vice President (EVP) of CONVERGE and Rex Homme, Partner at StoneTurn to consider some of the...more

Oberheiden P.C.

A CEO's Guide to FCPA Compliance

Oberheiden P.C. on

- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more

Health Care Compliance Association (HCCA)

[Webinar] How to “draft” the right staff onto your Compliance Team in the League of Healthcare - July 23rd, 12:00 pm CT

Main Points Covered: - Link the US Department of Justice evaluation of Corporate Compliance Programs Guidance Documents updated in April 2019 to the importance of having the right staff on your team - Identify the...more

McDermott Will & Emery

[Webinar] Anti-Corruption and Compliance Training - May 28th, 10:00 am - 11:30 am EDT

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Please join McDermott and Grant Thornton on Thursday, May 28, for a webinar training on anti-corruption and compliance. This training will discuss the auditing standards on illegal acts by clients and the auditor’s...more

Foley & Lardner LLP

Anti-Fraud Enforcement in the Coronavirus Era

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In times of crisis, there are heroes, villains, victims, and everyone in between. Amidst the COVID-19 crisis, many valiant efforts are under immense time pressure—to care for the ill, to protect the vulnerable, to find and...more

A&O Shearman

FCPA Digest - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act - July 2019

A&O Shearman on

Recent Trends And Patterns In FCPA Enforcement - Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more

Baker Donelson

Evaluating the Effectiveness of Corporate Compliance Programs – What the Government is Looking For

Baker Donelson on

The U.S. Justice Department has updated its "Evaluation of Corporate Compliance Programs," a guidance document detailing topics and questions prosecutors should weigh when determining whether a company has demonstrated...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Does Your Compliance Program Work? (Part V of V)

The Volkov Law Group on

The final issue discussed in the new DOJ Corporate Compliance Guidance is the assessment of whether a company’s compliance program is working – at the time of the offense and at the time of the resolution of an enforcement...more

The Volkov Law Group

Five Signs Your Company Lacks Integrity

The Volkov Law Group on

It is always easy to second-guess or look back with 20-20 hindsight on a compliance breakdown and point out all the problems that were ignored or created by corporate actors. There are common factual scenarios that recur in...more

Baker Donelson

DOJ Settlement Highlights False Claims Act Risk for Skilled Nursing Facilities

Baker Donelson on

The Department of Justice (DOJ) recently announced a $10 million settlement in a False Claims Act (FCA) qui tam lawsuit against Southern SNF Management, Inc. (Southern) and related skilled nursing facilities. The lawsuit...more

Foley & Lardner LLP

The Twelve Compliance Steps Every Multinational Corporation Should Undertake in Light of Recent Trump Administration Enforcement...

Foley & Lardner LLP on

Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more

BCLP

Anti-Corruption Enforcement: Analyzing the Enforcement Approaches of the US, the UK and France

BCLP on

Anti-Corruption enforcement is a top priority in France, the UK, and the US. Each of these countries has armed its enforcers with the enforcement tools necessary to investigate and prosecute corporations and individuals. Join...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

Thomas Fox - Compliance Evangelist

Evolution of Your Compliance Program

One of the most consistent themes from the Department of Justice (DOJ) regarding Foreign Corrupt Practices Act (FCPA) compliance programs has been continuous evolution. As far back as 2009, I heard Lanny Breuer say that your...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

Thomas Fox - Compliance Evangelist

Compliance into the Weeds-Episode 40, COSO ERM Framework Update

In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM...more

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