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Ethics Deferred Prosecution Agreements

StoneTurn

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

StoneTurn on

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

Society of Corporate Compliance and Ethics...

What DAG Lisa Monaco's Speech Means for Compliance Programs

United States Deputy Attorney General (DAG) Lisa Monaco recently gave a speech in which she outlined both new policies at the Department of Justice (DOJ) as well as enhancements to existing ones that can have a profound...more

Thomas Fox - Compliance Evangelist

Wells Fargo Settlement: Part 1 – It’s Even Worse Than Imagined

I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more

WilmerHale

DOJ Issues Updated Guidance on Evaluation of Corporate Compliance Programs

WilmerHale on

On April 30, 2019, the Assistant Attorney General for the Criminal Division, Brian A. Benczkowski, announced an update to the Department of Justice’s (“DOJ”) 2017 guidance document entitled Evaluation of Corporate Compliance...more

Thomas Fox - Compliance Evangelist

Code of Conduct Week: Part I – Introduction

I am joined by Eric Morehead as we begin a five-part series on the Code of Conduct, which serves as the foundational document of a compliance program. Morehead is well-known within the compliance community, having worked at...more

NAVEX

2017 EMEA & APAC Culture and Compliance Benchmark Report - Data And Insights To Put To Work In Your Programme Today

NAVEX on

NAVEX Global partnered with an independent research agency to investigate how companies headquartered across Europe, Middle East and Africa (EMEA) and Asia Pacific (APAC) develop and execute their ethics and compliance (E&C)...more

Thomas Fox - Compliance Evangelist

The Compliance Oversight Review Committee

This week has evolved into an exploration of different types of compliance committees a company might employ to make their compliance function more effective. On Monday, together with Baker Hughes Incorporated (BHI) Chief...more

The Volkov Law Group

A Teaching Moment Inside VimpelCom’s Boardroom

The Volkov Law Group on

The VimpelCom FCPA settlement underscored the importance of Compliance 2.0 and the need to reform board deliberations and governance. No one can read the facts without shaking their heads and asking – what was the VimpelCom...more

Thomas Fox - Compliance Evangelist

The Defeat Device: Compliance and Ethics in the Auto Industry

Things are seriously bad when one of the world’s most respected business focused publications, the Financial Times (FT), asks if the auto “industry faces ‘Libor moment’”? Yet that was a headline yesterday in the lead article...more

NAVEX

Top Ten Ethics & Compliance Predictions and Recommendations for 2015

NAVEX on

Get the inside track on the key ethics and compliance industry trends that will impact your business in 2015—and get the resources you need to help you plan for the year ahead—in our annual Top Ten Predictions and...more

The Volkov Law Group

Future of Corporate Monitors

The Volkov Law Group on

No company wants a corporate monitor. If you ask any General Counsel, Chief Compliance Officer or Chief Executive Officer, they can list an infinite number of alternative punishments they would rather suffer than have a...more

NAVEX

2015 Trends: #7 Crime and Punishment

NAVEX on

On the accountability and punishment front, three trends bear watching: 1) Deferred Prosecution Agreements (DPAs) DPAs and Non-Prosecution Agreements (NPAs) allow prosecutors to require corporate reforms and...more

Thomas Fox - Compliance Evangelist

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

Thomas Fox - Compliance Evangelist

Code of Conduct, Compliance Policies and Procedures-Part I

For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more

Thomas Fox - Compliance Evangelist

Commitment To Compliance: The Compliance Committee

Sunday was the 69th anniversary the most iconic photo of World War II, at least from the American perspective. Of course it was the raising of the American flag at Mt. Suribachi on Iwo Jima. To say that one photo cannot...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 29-Interview with the FCPA Professor-Part 1

In this episode 29 of the FCPA Compliance and Ethics Report, I have Part 1 of a 2 part visit with the FCPA Professor about some things on his mind. In this episode, we discuss SEC Chair Mary Jo White's comments about the need...more

Thomas Fox - Compliance Evangelist

Are DPAs Morally Suspect?

You know it is going to be a bad day when you are excoriated in public by a sitting federal district judge. It is even worse when the comments of that federal judge make it into one of the most prominent international...more

Thomas Fox - Compliance Evangelist

It’s The Great Pumpkin: Lessons In Process Validation And Oversight

Today is Halloween and we celebrate the greatest Halloween cartoon in the history of the world, ever, “It’s the Great Pumpkin, Charlie Brown”, which premiered in 1966. As usual, the story revolves around the Peanuts gang, who...more

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