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Policies and Procedures Department of Justice (DOJ) Ethics

Ankura

Balancing Courtesy and Compliance: Best Practices in Corporate Hospitality

Ankura on

Whether part of local customs, relationship building or ways to give thanks, gift giving and hospitality (collectively referred to here as “Hospitality”) is a sizable business, with the global market being estimated at USD839...more

NAVEX

The Increasing Importance – and Visibility – of Internal Investigations 

NAVEX on

New DOJ whistleblower incentives. Investigation-related KPIs. Accountability demands from stakeholders of all stripes.    A combination of hard work by ethics and compliance professionals, high profile internal system...more

Health Care Compliance Association (HCCA)

Beyond surveys: Rethinking traditional approaches to ethical culture assessments

To build a robust ethical culture, ethics and compliance professionals need effective culture assessments to pinpoint vulnerabilities and proactively address them. The U.S. Department of Justice’s (DOJ) update to the...more

Society of Corporate Compliance and Ethics...

How a code of conduct reflects culture and meets DOJ requirements

Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

ArentFox Schiff on

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

Reveal

How to Conduct Compliance Risk Assessment Efficiently (+Compliance Risk Assessment Template)

Reveal on

Is your business in compliance with every law, rule, and regulation that it should be? If you can’t confidently say yes, it’s time for a compliance risk assessment. And even if you could confidently say yes six months ago,...more

Society of Corporate Compliance and Ethics...

What DAG Lisa Monaco's Speech Means for Compliance Programs

United States Deputy Attorney General (DAG) Lisa Monaco recently gave a speech in which she outlined both new policies at the Department of Justice (DOJ) as well as enhancements to existing ones that can have a profound...more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Policies on Corporate Ethics and Compliance

Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more

StoneTurn

Beyond Whistleblowing: Five Steps to Establish an Effective Speak-Up Program

StoneTurn on

"Whistleblowing," a fundamental component of any compliance program, refers to specific allegations of misconduct raised typically through an anonymous hotline or similar mechanism. "Speak-Up" is broader and refers to a...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Washington DC Regional Compliance & Ethics Conference - October 8th, 8:25 am - 4:30 pm EDT

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...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

A Tribute to Bill Yeoman: Compliance Metrics For a Board

Bill Yeoman died this week. You have to be a knowledgeable fan of college football to recognize that name as he retired in 1986. He was the head coach for the University of Houston (UH) Cougars for 25 years. His contributions...more

Oberheiden P.C.

A CEO's Guide to FCPA Compliance

Oberheiden P.C. on

- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more

Holland & Knight LLP

Small Businesses: Why and How to Set-up or Enhance Your Ethics and Compliance Program

Holland & Knight LLP on

It's been ten years since the Federal Acquisition Regulation (FAR) was amended to require government contractors to have a business ethics and compliance program – that's right, it's a requirement in every government contract...more

King & Spalding

Corporate Compliance Programs: DOJ Issues Updated Guidance: Ten Takeaways for In-House Legal and Compliance Leaders

King & Spalding on

On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more

WilmerHale

DOJ Issues Updated Guidance on Evaluation of Corporate Compliance Programs

WilmerHale on

On April 30, 2019, the Assistant Attorney General for the Criminal Division, Brian A. Benczkowski, announced an update to the Department of Justice’s (“DOJ”) 2017 guidance document entitled Evaluation of Corporate Compliance...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Implementation, Operationalization and Effectiveness (Part IV of V)

The Volkov Law Group on

While I hate to start out a posting with such “mumbo jumbo” terms, I had to come up with short hand descriptions of some otherwise fairly complex and robust topics under the new DOJ Guidance....more

A&O Shearman

DOJ Criminal Division Announces Updated Corporate Compliance Program Guidance

A&O Shearman on

On April 30, 2019, the United States Department of Justice, Criminal Division (“DOJ”), released an updated version of its guidance on “Evaluation of Corporate Compliance Programs” (“Compliance Program Guidance”). This...more

Thomas Fox - Compliance Evangelist

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 3 – Policies and Procedures

We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document(2019 Guidance), which was announced(ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more

Wilson Sonsini Goodrich & Rosati

DOJ Criminal Division Releases Updated Guidance for Prosecutors Evaluating Corporate Compliance Programs

On April 30, 2019, Assistant Attorney General Brian A. Benczkowski announced the release of an updated version of the Criminal Division's "The Evaluation of Corporate Compliance Programs" during a keynote address at the...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Risk Assessments and Policies and Procedures (Part II of IV)

The Volkov Law Group on

Part 1 of the Corporate Compliance Guidance addresses the following elements of a well-designed compliance program: risk assessment, policies and procedures, training and communications, confidential reporting structure and...more

The Volkov Law Group

DOJ Issues New and More Robust Guidance on Evaluation of Corporate Compliance Programs (Part I of IV)

The Volkov Law Group on

In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs....more

Thomas Fox - Compliance Evangelist

Code of Conduct Week: Part V – Operationalization

I have reviewed the creation and update of a Code of Conduct this week, with a big assist from Eric Morehead, the Principal of Morehead Compliance Consulting. We reviewed the legal requirements, the suggested structure and...more

Thomas Fox - Compliance Evangelist

Code of Conduct Week: Part I – Introduction

I am joined by Eric Morehead as we begin a five-part series on the Code of Conduct, which serves as the foundational document of a compliance program. Morehead is well-known within the compliance community, having worked at...more

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