News & Analysis as of

Monaco Memo

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 1 - The Mandate

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Polsinelli

"Please Pay No Attention to the Microphone:” DOJ Announces New Program Offering Protections to Criminal Whistleblowers

Polsinelli on

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

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - June 6th, 8:00 am - 5:00 pm CT

How do enforcement priorities impact your compliance program? Supply chains, tech tools, consumer data, the use of sanctions, the list is long — there are a vast number of organizational processes and procedures under...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 6, Clawbacks and Holdbacks

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Kramer Levin Naftalis & Frankel LLP

DOJ Reinforces Its Focus on Affirmative Corporate Accountability at the ABA’s 38th Annual White Collar Conference

Earlier this month, at the American Bar Association’s (ABA) 38th National Institute on White Collar Crime, Deputy Attorney General Lisa O. Monaco and Assistant Attorney General Kenneth A. Polite, Jr. highlighted the...more

Holland & Knight LLP

DOJ Announces Significant Policy Changes Affecting Corporate Criminal Enforcement

Holland & Knight LLP on

In back-to-back speeches to the American Bar Association's National Institute on White Collar Crime on March 2-3, 2023, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco and Assistant Attorney General...more

Goodwin

DOJ Revises Corporate Compliance Guidance to Take on Compensation Incentives and Communications Preservation - With a Continued...

Goodwin on

As part of a recent series of announcements regarding updates to its corporate compliance policies, the Department of Justice (DOJ) announced significant revisions to its evaluation criteria for corporate compliance programs,...more

BakerHostetler

DOJ Announces Major Corporate Enforcement Policies

BakerHostetler on

Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more

Dorsey & Whitney LLP

Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

Dorsey & Whitney LLP on

On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more

Polsinelli

DOJ Announces New Nationwide Voluntary Self-Disclosure Policy

Polsinelli on

On Wednesday, February 22, 2023, the Department of Justice (“DOJ”) released a new nationwide voluntary self-disclosure policy for corporate criminal enforcement. The policy codifies previous corporate enforcement guidance...more

Goodwin

DOJ Announces Nationwide Voluntary Corporate Self-Disclosure Policy in Effort to Standardize and Incentivize Timely Self-Reporting

Goodwin on

On February 22, 2023, the US Department of Justice (DOJ) announced a Voluntary Self-Disclosure Policy (VSD Policy) to formalize DOJ’s efforts to incentivize companies to voluntarily self-report criminal misconduct to the...more

Eversheds Sutherland (US) LLP

New nationwide policy marks latest DOJ effort to incentivize voluntary self-disclosure

On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more

Holland & Knight LLP

New DOJ Policy Sets High Standards, Offers Strong Incentives for Misconduct Self-Disclosure

Holland & Knight LLP on

The U.S. Attorney's Offices (USAOs) Voluntary Self-Disclosure Policy, announced on Feb. 22, 2023, sets forth a nationwide standard for how USAOs will define and credit corporate self-disclosures of misconduct by employees or...more

WilmerHale

Department of Justice Issues Voluntary Self-Disclosure Policy for Corporate Criminal Enforcement Applicable to U.S. Attorneys’...

WilmerHale on

On February 22, 2023, the Department of Justice (DOJ) issued a Voluntary Self-Disclosure Policy (VSDP) which, effective immediately, applies to all U.S. Attorneys’ Offices (USAOs) nationwide with respect to corporate criminal...more

Womble Bond Dickinson

With Great ‘Empowerment’ Comes Great Responsibility (and Risk) for CCOs Under Monaco Memo

Womble Bond Dickinson on

The Monaco memo’s imposition of CCO certification in DOJ investigations has, reasonably, been a major anxiety-inducer for compliance professionals. And while DOJ officials have said the requirement is designed to “empower”...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - Eric Young on the Evolution of the CCO

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this special episode, I am joined by Eric Young from Guidepost Solutions. Young has worked at prestigious institutions like...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - Tom Fox and Mike Volkov with the 2022 Year in Review for the FCPA, Part 2

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this special episode, I am joined by Mike Volkov, founder of the Volkov Law Group, and conclude with Part 2, looking back on...more

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

Womble Bond Dickinson on

Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - Scott Garland and Zach Hafer - Practice After the DOJ

Welcome to the award-winning FCPA Compliance Report, the most senior podcast in compliance. I have double trouble in this episode as I welcome Scott Garland and Zach Hafer, who worked together for many years at the US...more

Hogan Lovells

You want what back? Key takeaways from DOJ on compensation clawbacks and compliance programs

Hogan Lovells on

On September 15, 2022, Deputy Attorney General Lisa Monaco released a memorandum titled “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group,” known...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Justice Department Memo Raises the Stakes for Workplace Safety–Related Investigations

On September 9, 2015, then U.S. Deputy Attorney General Sally Quillian Yates issued a memo, “Individual Accountability for Corporate Wrongdoing,” that sent shivers down the spines of those in the workplace safety community....more

Thomas Fox - Compliance Evangelist

Corporate Case Management in the Era of the DoJ’s Monaco Memo: Data Drives Prevention

Welcome to a special five-part podcast series, entitled Corporate Case Management in the Era of the DoJ’s Monaco Memo, sponsored by i-Sight Software Solutions (i-Sight). Over this series, Jakub Ficner, Director of Partnership...more

Thomas Fox - Compliance Evangelist

Corporate Case Management in the Era of the DoJ’s Monaco Memo: The Fair Process Doctrine

Welcome to a special five-part podcast series, entitled Corporate Case Management in the Era of the DoJ’s Monaco Memo, sponsored by i-Sight Software Solutions (i-Sight). Over this series, Jakub Ficner, Director of Partnership...more

Baker Donelson

Health Care Companies Can Mitigate Risks by Ensuring Compliance Effectiveness Based on Recent Department of Justice Criminal...

Baker Donelson on

The Department of Justice (DOJ) recently recently made revisions to its corporate criminal enforcement policies that provide useful insights to corporations and their executives regarding establishing policies and procedures...more

Robinson & Cole LLP

With $1.1 Billion Penalty Deal, SEC Joins DOJ in Firing Warning Shot at Financial Services Industry About Outdated Employee...

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Last week, the United States Securities and Exchange Commission (SEC) fined 16 Wall Street firms a total of $1.1 billion for recordkeeping violations based on the failure to maintain employees’ electronic communications, such...more

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