Compliance into the Weeds: A Deep Dive into Employee Leaks and Corporate Culture
The EU Whistleblowing Directive
Six Steps Companies Can Take to Manage the Risk of Using Generative AI
Helpline Usage (or Lack Thereof)
Corporate Compliance and Enforcement Hot Topics with IBM VP, Una Dean
Encouraging Internal Whistleblowers
Encouraging Employee Feedback and Internal Whistleblowing
Integrity Matters: Fraud Trends for 2022, Ep. 1
JONES DAY TALKS®: The eBay Cyberstalking Case: Mitigating the Compliance Risks of Employee Misconduct
Doing Business in the European Union | Reporting Systems and the Importance of Culture & Language
Doing Business in the European Union | EU Directive, Following Up With The Whistleblower
Susan Roberts on Creating a Compliance Program Book
Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting
ACI's Global Anti-Corruption, Ethics & Compliance – New York is your best opportunity to hear how companies are addressing the status of DOJ and SEC priorities, effective compliance and risk strategies, strengthening...more
In recently released updated guidance, the Antitrust Division (“Antitrust Division”) of the U.S. Department of Justice (“DOJ”) outlined how its prosecutors will assess corporate compliance programs when conducting criminal...more
On September 23, 2024, the U.S. Department of Justice (DOJ) released an updated version of its guidance to prosecutors on the Evaluation of Corporate Compliance Programs (“ECCP”)....more
In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more
On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
DOJ Launches Corporate Whistleblower Awards Pilot Program - On August 1, the US Department of Justice (DOJ) announced the details of its new Corporate Whistleblower Awards Pilot Program. According to the DOJ, the...more
Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more
On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin...more
The U.S. Department of Justice, Criminal Division, updated its Evaluation of Corporate Compliance Program in March 2023, with renewed expectations for companies to use data analytics and testing. However, the government...more
Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more
On June 28, 2021, the United States District Court for the Northern District of California granted the Company’s Rule 12(b)(6) motion to dismiss after an executive claimed he was discharged in violation of the Dodd-Frank...more
Bernie Madoff died yesterday. I cannot think of one person who embodied so many of the things that the compliance profession stands against than Madoff. From fraud, to lying, to ruining lives and about everything in between;...more
In this fourth edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Evil of Frankenstein which was released in 1963. There are several interesting aspects to...more
Companies should consider review of their compliance programs and procedures for addressing internal complaints or tips of potential misconduct. On September 23, 2020, the Securities and Exchange Commission ("SEC") adopted...more
How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more
DOJ is catching up to compliance officers and evolving best practices. Say what you want, DOJ is behind the curve of the compliance industry. But you have to give DOJ credit – they are moving quickly to update its Guidance....more
What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or...more
The Justice Department “listens and learns” from companies and compliance practitioners. As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more
This edition of Employment Flash looks at recent court decisions, including the U.S. Supreme Court's rulings on cases relating to the definition of a whistleblower and exemptions from the overtime pay provisions. This edition...more
ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more
The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more