The Justice Insiders Podcast - Demystifying Sentences for White Collar Crimes: What's Next for SBF
FCPA Compliance Report - Eric Morehead - The US Sentencing Guidelines at 30
The Sentencing Guidelines at Thirty
Elizabeth Holmes, Ghislaine Maxwell, and the Federal Sentencing Guidelines [More with McGlinchey, Ep. 34]
Podcast: Conductive Discussions Episode 2: Criminal Prosecution of Trade Secret Theft, with a Focus on China
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
Legal Risk Management Forum: panel highlights
This Week in FCPA-Episode 55, the Covfefe Edition
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
How do the federal sentencing guidelines work in federal fraud cases?
How do the federal sentencing guidelines work?
How Does A Federal Judge Decide What Sentence To Impose In a Federal Criminal Case?
Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it...more
Board Oversight of the Compliance Program - The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization’s compliance program, and provides that the board shall “be...more
The Organizational Sentencing Guidelines have turned thirty, and what began as an experiment is now an established framework for compliance programs in the US and around the globe. To commemorate the milestone, the United...more
The Federal Sentencing Guidelines for Organizations (FSGO) by the US Sentencing Commission (USSC) turn 30 this year. For compliance officers, this was perhaps the most significant government release. It did not create the...more
2019 was a big year for ethics and compliance. In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more
Once you demonstrate you are ethically challenged or maintain a moral flexibility that allows you to lie, cheat and steal; it is highly likely you will continue to do so....more
I do not think there is much disagreement on the basic purpose of an ethics and compliance program. After all, one of the primary sources for compliance programs continues to be the United States Sentencing Guidelines which...more
In a speech yesterday at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ) revised Foreign Corrupt Practices Act...more
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
Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more
The Justice Department has a lot to be proud about when it comes to its FCPA enforcement program. In one area in particular – promoting effective ethics and compliance strategies – DOJ’s FCPA prosecutors have played a...more
To begin, let’s define “benchmarking.” There is often confusion regarding the difference between benchmarking and assessment. ...the process of benchmarking is a subset of compliance program assessment....more
Once again it’s time for our annual review of trends and events that will impact your Ethics and Compliance (E&C) program in the year ahead. This year presents a unique challenge. We are preparing our predictions...more
Yesterday, together with Baker Hughes Inc. (BHI) Chief Compliance Officer (CCO) Jay Martin, I wrote about a new and innovative compliance committee BHI has initiated, the GeoMarket Compliance and Ethics Committee. In...more
A company that does not back up its words with deeds is doomed to suffer compliance and cultural breakdowns. When a company commits to building a culture of trust and integrity, the company has to keep its word. This is not a...more
I. Autonomy - The DOJ has made clear over the years the importance of this hallmark. In the FCPA Guidance it states, “In appraising a compliance program, DOJ and SEC also consider whether a company has assigned...more
To help with our predictions and recommendations, we’ve talked with industry experts, our colleagues at NAVEX Global, and ethics and compliance professionals from our more than 12,500 client organizations. Based on their...more
It’s the second Friday in October and I am continuing my HorrorFest month. I usually call it Monster Movie Fest but this year I am celebrating the films of Val Lewton who really worked more broadly in the horror genre, rather...more
Those of us working in the ethics and compliance field know that there is no shortage of guidance on best practices for establishing and maintaining an ethics and compliance program. In the U.S., the Federal Sentencing...more
Talk is cheap, especially when it comes to ethics and compliance programs. Words are easy but action and commitment is even harder. The compliance industry needs to put more meat on the bones of compliance. It is not enough...more
We all know the importance of the sentencing guidelines and the impact the revisions, especially the 2010 amendments, have had on corporate governance and compliance. The history behind the sentencing guidelines tracks the...more
Quite simply, any compliance program starts at the top and flows down throughout the company. Before you arrive at tone in the middle and bottom, it must start with a commitment at the top. All regulatory schemes for...more
New guidance for boards of directors on what it means to have “reasonable oversight” for the implementation and effectiveness of corporate compliance programs could signal the beginning of a global trend towards more—and more...more
In This Presentation: - The Board’s Roles and Compliance Responsibilities - The Board Report & Briefing vs. Training - Important Considerations for your Board Report - Case Study - How Can I Tell if my Board is...more
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