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
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
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
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
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
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
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 Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...more
On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more
Every year it’s safe to assume that our list of Top 10 trends will include the latest developments pertaining to helplines, whistleblower reporting and retaliation, and this year is no exception. We begin by examining some...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