Episode 333 -- The Boeing Proposed Plea Agreement
Learning Objectives: - Participants will have a better understanding of how the CEO and CCO certification of compliance program effectiveness came to be. - Participants will learn about example cases where DOJ and SEC...more
The compliance certification policy was first announced by Assistant Attorney General (Assistant AG) Kenneth Polite in March 2022, when he stated that for all criminal division “corporate resolutions (including guilty pleas,...more
The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers. In Part I of this series, I outlined the specific language and the Plea Agreement...more
The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to...more
Recent actions by the United States Department of Justice (DOJ) clearly demonstrate its focus on ensuring the effectiveness of both a corporation’s compliance program and its compliance officer....more
• Assistant Attorney General Brian A. Benczkowski's recent Memorandum on "Selection of Monitors in Criminal Division Matters" provides new direction to U.S. Department of Justice (DOJ) prosecutors regarding when to require...more
The decision highlights the US government’s focus on effective compliance programs. The US Department of Justice (DOJ) is creating a new compliance counsel position in the Criminal Division to assess the effectiveness of...more
On this day, 203 years ago, President James Madison signed a Declaration of War against Great Britain inaugurating the War of 1812. The cause of the war was multi-faceted; the formal reason given was the British impressment...more
In April 2015, the UK Bribery Act (UKBA) celebrated its fifth birthday. In the same month, the Serious Fraud Office brought a third round of corruption charges under the UKBA in the Alstom case. Those allegations, brought...more