News & Analysis as of

Human Resources Professionals Compliance Department of Justice (DOJ)

Thomas Fox - Compliance Evangelist

Corruption, Crime and Compliance - DOJ Mandates Increased HR and Compliance Cooperation

The relationship between compliance and HR can make or break a company’s culture of ethics and integrity. The DOJ’s revised Evaluation of Corporate Compliance Program requirements pushes for greater cooperation and...more

The Volkov Law Group

DOJ’s New Compliance Requirements Mandate Increased Compliance and HR Cooperation (Part I of II)

The Volkov Law Group on

The Justice Department is now taking on the role of marriage counselor.  Not with individual couples, but with a critical corporate relationship – ethics and compliance and human resources.  Normally, compliance and HR is a...more

The Volkov Law Group

DOJ Issues Revised Corporate Compliance Guidance: Consequence Management, Clawbacks and Human Resource Cooperation (Part I of III)

The Volkov Law Group on

The Justice Department is rapidly pushing corporations to a new level of compliance.  We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs.  It would be a...more

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series: Protecting Your Business Against Non-Compliance and DOJ Penalties - March 23rd, 12:00...

McDermott Will & Emery on

During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more

NAVEX

[Virtual Conference] NAVEX Next: Beyond the Moment - October 22nd, 8:00 am - 2:00 pm PDT

NAVEX on

Register for NAVEX Next, our annual risk and compliance virtual conference. Formerly the Ethics & Compliance Virtual Conference (ECVC), the new name recognizes that we must be forward-looking as we face an increasingly...more

Thomas Fox - Compliance Evangelist

Day 9 of One Month to Better Reporting and Investigations-The Investigation Team

Beginning with the Department of Justice’s (DOJ’s) Yates Memo, its Foreign Corrupt Practices Act (FCPA) Pilot Program and then the release of the Evaluation of Corporate Compliance Programs (Evaluation), I believe the DOJ has...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds-Episode 40, COSO ERM Framework Update

In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM...more

Thomas Fox - Compliance Evangelist

Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance

I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more

Thomas Fox - Compliance Evangelist

Day 20 - Compliance Leadership from the Bottom

The key concept from the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Program (Evaluation) is operationalization. For instance, under the query Shared Commitment is the following question - “How is...more

Thomas Fox - Compliance Evangelist

Day 13 of One Month to Better Compliance Thru HR

One of the ways to operationalize compliance and to drive it into the DNA of an organization is through a performance review. Indeed, the 2012 FCPA Guidance states, “DOJ and SEC recognize that positive incentives can also...more

Thomas Fox - Compliance Evangelist

Day 11 of One Month to Better Compliance Through HR-the Fair Process Doctrine

Procedural fairness is one of the things that will bring credibility to your Compliance Program. Today it is called the Fair Process Doctrine and this Doctrine generally recognizes that there are fair procedures, not...more

Thomas Fox - Compliance Evangelist

Day 10 Of One Month to Better Compliance through HR-Sales Incentives and Compliance

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System –How has the company considered the potential negative compliance...more

Thomas Fox - Compliance Evangelist

Day 6 of One Month to Better Compliance Through HR-Incentivizing Compliance

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – How has the company incentivized compliance and ethical behavior? How has...more

Thomas Fox - Compliance Evangelist

“Zen and the Art of Motorcycle Maintenance” – Lessons for Compliance

Robert M. Pirsig died last week. For anyone who went to college in the mid-70s, he was required reading in a variety of classes and disciplines for his seminal work Zen and the Art of Motorcycle Maintenance. There were a...more

Thomas Fox - Compliance Evangelist

Day 1 of One Month to Better Compliance Through HR-the Role of HR in Operationalizing Compliance

This month, I will consider the role of Human Resources (HR) in operationalizing a best practices compliance program. I have long advocated for a greater role of Human Resources (HR) in a compliance program. Indeed, one sign...more

Thomas Fox - Compliance Evangelist

Hallmark 6-Incentives and Disciplinary Measures

The FCPA Guidance states, “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance program...more

Thomas Fox - Compliance Evangelist

Great Structures Week III – The Roman Arch and Resourcing Your Compliance Program

I continue my Great Structures Week with focus on structural engineering innovations from ancient Rome. I am drawing these posts from The Teaching Company course, entitled “Understanding the World’s Greatest Structures:...more

Thomas Fox - Compliance Evangelist

Economic Downturn Week, Part II – The Golden Gate Bridge and Employment Separation – Hotlines and Whistleblowers During Layoffs

I use the Golden Gate Bridge as an entrée to my continued discussion on the series on steps that you can use in your compliance program if you find yourself, your company or your industry in an economic downturn. Whether you...more

Thomas Fox - Compliance Evangelist

Levi Strauss and Auditing of Third Parties

Today we celebrate innovation. On this day in 1873, a patent to create work pants reinforced with metal rivets was granted. This marked the birth of one of the world’s most famous garments: the blue jeans. Jacob Davis, a...more

Thomas Fox - Compliance Evangelist

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

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