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Foreign Corrupt Practices Act (FCPA) Chief Compliance Officers White Collar Crimes

Society of Corporate Compliance and Ethics...

What's Going on with FCPA?

The FCPA sure isn’t what it used to be, or is it? While the headline grabbing Foreign Corrupt Practices Act cases are much less frequent than they once were, there is still substantial risk both for individuals and...more

Husch Blackwell LLP

DOJ Updates FCPA Corporate Enforcement Policy

Husch Blackwell LLP on

On January 17, 2023, Assistant Attorney General (AAG) Kenneth Polite, Jr. announced updates to the Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. Since the inception of the FCPA Corporate Enforcement...more

Thomas Fox - Compliance Evangelist

The Week That Was in Compliance – The Monaco Speech

We are in the midst of a multipart review of last week’s speeches from the Department of Justice (DOJ) at the recently concluded ABA’s 38th Annual National Institute on White Collar Crime, held in Miami. Compliance...more

WilmerHale

DOJ Announces Significant Guidance on Compliance, Compensation, Communications and Cooperation

WilmerHale on

On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more

Goodwin

DOJ Announces Nationwide Voluntary Corporate Self-Disclosure Policy in Effort to Standardize and Incentivize Timely Self-Reporting

Goodwin on

On February 22, 2023, the US Department of Justice (DOJ) announced a Voluntary Self-Disclosure Policy (VSD Policy) to formalize DOJ’s efforts to incentivize companies to voluntarily self-report criminal misconduct to the...more

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

Latham & Watkins LLP on

Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more

Dorsey & Whitney LLP

DOJ Announces Additional Incentives for Corporate Cooperation in Criminal Enforcement

Dorsey & Whitney LLP on

On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

Womble Bond Dickinson on

Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more

StoneTurn

5 Tips For Meeting DOJ’s New CCO Certification Requirements

StoneTurn on

The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more

Thomas Fox - Compliance Evangelist

Monaco Memo – A Jolt for Compliance: Part 4 – New Factors in Selecting Monitors

Today, we continue our exploration of the Monaco Memo by considering the sections relating to the evaluation of cooperation during the pendency of the investigation and the evaluation of a company’s compliance program at the...more

Thomas Fox - Compliance Evangelist

Monaco Memo: A Jolt for Compliance: Part 3 – Cooperation and Compliance Program Evaluation

Today, we continue our exploration of the Monaco Memo by considering the sections relating to the evaluation of cooperation during the pendency of the investigation and the evaluation of a company’s compliance program at the...more

Thomas Fox - Compliance Evangelist

Monaco Memo and Polite Speech – A Jolt for Compliance: Part 1 – Introduction

Last seek saw the announcement of two significant and related releases of information from the Department of Justice (DOJ) around Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. They were...more

Wilson Sonsini Goodrich & Rosati

DOJ Announces New Guidance on Corporate Criminal Enforcement

On September 15, 2022, Deputy Attorney General of the Department of Justice (DOJ) Lisa Monaco announced pivotal new guidance about the DOJ’s corporate criminal enforcement efforts. Her speech, accompanied by a more...more

Brownstein Hyatt Farber Schreck

DOJ Introduces a Mix of ‘Carrots and Sticks’ to Combat Corporate Crime

The Department of Justice is sending a clear message to companies when it comes to corporate crime: invest in strong compliance structures and culture and come forward quickly with information about misconduct—or suffer the...more

Guidepost Solutions LLC

The Sky Will Not Fall with New Justice Department CEO / CCO Certifications; Instead, the Sun Will Shine

Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more

The Volkov Law Group

DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)

The Volkov Law Group on

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement...more

Thomas Fox - Compliance Evangelist

What 2021 Brought to Compliance

2021 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate FCPA enforcement actions, the three enforcement actions were significant with multiple lessons...more

The Volkov Law Group

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

The Volkov Law Group on

On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more

Thomas Fox - Compliance Evangelist

Monaco Speech: Part 5 – What Does It All Mean?

This week I have been writing about the speech Deputy Attorney General (DAG) Lisa O. Monaco gave as a Keynote Address at ABA’s 36th National Institute on White Collar Crime last week (Monaco Speech). Her remarks were noted by...more

Womble Bond Dickinson

Biden Administration Prioritizes Corporate Criminal Enforcement

Womble Bond Dickinson on

Takeaways: ..In recent remarks, top DOJ officials stated that DOJ will “surge resources” and “redouble efforts” for corporate enforcement. ..Areas of particular concern include Foreign Corrupt Practices Act,...more

Thomas Fox - Compliance Evangelist

Monaco Speech: Part 4 – Some Questions

Deputy Attorney General (DAG) Lisa O. Monaco gave a Keynote Address at ABA’s 36th National Institute on White Collar Crime last week (Monaco Speech). Her remarks were noted by many commentators, including on two Compliance...more

Thomas Fox - Compliance Evangelist

Monaco Speech: Part 1 – Individual Accountability

Deputy Attorney General (DAG) Lisa O. Monaco gave a Keynote Address at ABA’s 36th National Institute on White Collar Crime last week (Monaco Speech). Her remarks were noted by many commentators, including on Compliance Into...more

McDermott Will & Emery

[Ongoing Program] 2021 Latin American Compliance Conference - Day 2 - September 30th, 12:00 pm - 1:00 pm EDT

McDermott Will & Emery on

Join us virtually for our second annual Latin American Compliance Conference. During this two-day webinar series, attendees will hear from McDermott White Collar litigators and compliance specialists, as well as industry and...more

McDermott Will & Emery

[Ongoing Program] 2021 Latin American Compliance Conference - Day 1 - September 28th, 12:00 pm - 1:30 pm EDT

McDermott Will & Emery on

Join us virtually for our second annual Latin American Compliance Conference. During this two-day webinar series, attendees will hear from McDermott White Collar litigators and compliance specialists, as well as industry and...more

The Volkov Law Group

Remediating the Organization’s Culture (Part IV of IV)

The Volkov Law Group on

“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more

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