In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more
The Justice Department has touted its efforts to bring greater transparency to FCPA enforcement. There is no question that in the last five years the Justice Department has moved the needle – the FCPA Guidance issued in 2012;...more
I am astonished there are still so many articles out there advising readers on how to establish the imperative for compliance. Nearly 15 years after the rise of compliance to an officer-level position, with significant...more
On February 8th, the U.S. Department of Justice (DOJ) quietly issued new guidance on how the agency evaluates corporate compliance programs during fraud investigations. The guidance, published on the agency’s website as the...more
The DOJ Fraud Section’s “Evaluation of Corporate Compliance Programs” puts chief compliance officers on notice about how the adequacy of their companies’ compliance programs is evaluated by prosecutors....more
There has been a change in the US Department of Justice regarding corporate disclosures. The recently updated United States Attorney’s Manual has revised its provisions called the “Principles of Federal Prosecution of...more
Speaking to a November 16 Money Laundering conference jointly sponsored by the American Banking and Bar Associations, Deputy AG Sally Yates unveiled revisions to the Department of Justice’s U.S. Attorneys’ Manual (“USAM”)....more