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Episode 89 -- DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
Over the past few weeks, the Trump administration has introduced sweeping changes across the federal government that have impacted the federal grantee and contractor community. Adding to these changes, the National Institutes...more
Last month, the U.S. Department of Justice (“DOJ”) quietly updated its March 2023 guidance on the evaluation of corporate compliance programs. Of course, DOJ did not conduct a major rewrite, but interestingly, the updated...more
On September 23, 2024, the U.S. Department of Justice (“DOJ”) released updates to its Evaluation of Corporate Compliance Programs (“ECCP”) guidance. In a move that surprised no one (especially if companies have been reading...more
In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more
Following industry consultation, on 30 August 2023 the Cayman Islands Monetary Authority ("CIMA") issued updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation...more
On March 22, 2023, the Centers for Medicare & Medicaid Services (CMS) issued updated guidance for home dialysis services performed in a skilled nursing facility or nursing home (the Updated Guidance). CMS first issued...more
On Friday, March 3, 2023, the Department of Justice (DOJ) Criminal Division released updated guidance regarding the “Evaluation of Corporate Compliance Programs.” Now in its fourth iteration, this guidance replaces the June...more
The Occupational Safety and Health Administration (OSHA) updated general industry guidance for COVID-19 that is applicable to all workplaces. OSHA’s June 10, 2021, general industry guidance, which is advisory and creates no...more
Today, the Department of Labor’s Occupational Safety and Health Administration (OSHA) issued a COVID-19 Emergency Temporary Standard (ETS) for the healthcare industry. This ETS mandates the development and implementation of a...more
With COVID-19 vaccines now being distributed in the United States, there have been a number of questions about the responsibilities and rights of employers and employees. On Wednesday, December 16, 2020, the U.S. Equal...more
On June 1, 2020, the Department of Justice (“DOJ”) issued an updated version of its “Evaluation of Corporate Compliance Programs” (the “DOJ Guidance”), available here. The DOJ Guidance is an update to guidance first issued by...more
On June 1, 2020, the US Department of Justice ("DOJ") published an updated version of its guidance on the "Evaluation of Corporate Compliance Programs" (the "Guidance"), which was first published in February 2017. When...more
The Department of Justice issued additional clarification and revised guidance on June 1, 2020, for corporate program compliance programs. The additional guidance doesn’t introduce substantive changes; however, it emphasizes...more
If anyone thought that DOJ was planning to relax its expectations regarding corporate compliance programs, forget it – DOJ has removed all doubt. In an announcement on Monday, June 1, 2020, DOJ released revised guidance,...more
On Monday, March 9, the Centers for Medicare & Medicaid Services (CMS) issued revised guidance for nursing homes relating to COVID-19. The new guidance confirms nursing homes should be implementing visitor restrictions,...more
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more
We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document(2019 Guidance), which was announced(ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more
• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more
Dear clients and friends, For this edition of the Corporate Communicator, we summarize key considerations of an interpretative release from the SEC about the SEC’s views on companies’ disclosure obligations relating to...more
On February 21, 2018, the Securities and Exchange Commission (SEC) issued an interpretive Commission Statement and Guidance on Public Company Cybersecurity Disclosures (the "Guidance") to assist public companies in meeting...more
The Securities and Exchange Commission (“SEC”) released expansive interpretive guidance (“2018 Guidance”), posted February 21, 2018, further building upon its far-reaching cybersecurity guidance provided in 2011. Below are...more
The U.S. Securities and Exchange Commission has issued guidance on cybersecurity disclosure. Companies must establish and maintain appropriate disclosure controls and procedures to make accurate and timely disclosures of...more
The Securities and Exchange Commission (SEC) expanded its warnings to public companies that generic disclosures identifying cybersecurity risk factors may be insufficient. Rather, the SEC seems to expect companies to conduct...more
• The U.S. Securities and Exchange Commission (SEC) released, on Feb. 21, 2018, updated guidance regarding public company cybersecurity disclosures. The guidance updates the Commission's 2011 non-binding guidance and...more
...The Securities and Exchange Commission (the “Commission”) Wednesday announced updated cybersecurity guidance for public companies. This guidance reinforces the Division of Corporation Finance guidance issued in October...more