News & Analysis as of

Risk Assessment Dept. of Justice

The 10 Hallmarks of an Effective Compliance Program: Still the Foundation

by Thomas Fox on

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

Using Strategic Risk to Your Advantage

by Thomas Fox on

I am beginning to feel this week’s theme becoming all-encompassing. As hard as I might try, it looks like it will be the Houston Astros second World Series appearance. During the first one back in 2005, I was in the corporate...more

Breaking Down the 2017 DOJ and OIG Compliance Guides

by McDermott Will & Emery on

Earlier this year, DOJ and OIG independently issued guides focused on evaluating compliance program effectiveness. The guides approach the topic from different perspectives but cover overlapping themes and work well in...more

Day 15 of One Month to More Effective Continuous Improvement-Risk Based Monitoring for Continuous Improvement

by Thomas Fox on

Another mechanism for continuous improvement of your compliance program is through risk-based monitoring. Under Prong 5 of the DOJ’s Evaluation of Corporate Compliance Programs, is the following topic and question: Manifested...more

Chris Froome Wins Tour Again; Maintenance and Compliance

by Thomas Fox on

Just as he did in 2013, in 2015 and in 2016, Kenyan-born British cycling star Chris Froome crossed the finish line in Paris wearing the Yellow Jersey as this year’s winner of the Tour de France. As reported by Chris Chavez,...more

What is the Real Risk of an FCPA Enforcement Action?

by Michael Volkov on

When speaking to clients or potential clients, the question of risk of enforcement is the moose on the table. Sometimes, the question gets asked and other times, the subject is never discussed. To be fair, it is not an easy...more

Department Of Justice “DOJ” Issues Evaluation Of Corporate Compliance Programs

by Locke Lord LLP on

Since DOJ hired Hui Chen, its corporate compliance expert, in November 2015, rumors have circulated that DOJ intended to release a list of questions to ask every company that comes into DOJ to explain the effectiveness of its...more

Tokyo Dispute Resolution & Crisis Management Newsletter – March 2017

by King & Spalding on

US Department of Justice Issues New Corporate Compliance Guidelines - Criteria for the Criminal Division’s Evaluation of Corporate Compliance Programs - Introduction - Recently, and without the fanfare that often...more

Corporate Investigations and White Collar Defense - March 2017

DOJ's New Guidance for Evaluating Corporate Compliance Programs - Why it matters: On February 8, 2017, the DOJ released, to little fanfare, a new guidance document entitled "Evaluation of Corporate Compliance Programs."...more

Corporate Compliance Programs: US and UK Perspectives

by Dechert LLP on

In today’s regulatory environment, companies face mounting pressure from law enforcement agencies to maintain robust compliance programs to deter and detect misconduct by employees, third-party vendors and business partners....more

LRN Compliance Program Effectiveness Report: Part III

by Thomas Fox on

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

LRN Compliance Program Effectiveness Report: Part II

by Thomas Fox on

Yesterday I began a series on the LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report) by outlining some of its general findings. Today, I want to focus on its detailed findings as it...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

by Holland & Knight LLP on

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

DOJ Releases Guidance on Corporate Compliance Programs

by King & Spalding on

On February 8, 2017, and without the fanfare that often accompanies new policy guidance, the Fraud Section of the U.S. Department of Justice (DOJ) issued a new guidance document on corporate compliance programs (Compliance...more

Great Expectations - DOJ holds anti-corruption compliance programs to a high standard in evaluating their credibility

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

New Attorney General Issues Guidance on Corporate Compliance Programs

by Foley & Lardner LLP on

The US Department of Justice (DOJ) Fraud Section has published new guidance for corporate entities on corporate compliance programs. The guidance, titled, “Evaluation of Corporate Compliance Programs” (Compliance Program...more

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

by Jones Day on

On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

DOJ’s Compliance Program Evaluation: Risk Assessment, Policies and Procedures and Third-Party Risk Management (Part III of IV)

by Michael Volkov on

To design and implement an effective ethics and compliance program, companies have to conduct a risk assessment and tailor its policies and programs to its risk profile. DOJ’s Compliance Evaluation reinforces this framework...more

With New Guidance, DOJ Signals What Companies Should Expect to Answer During FCPA Inquiries

Without fanfare or forewarning, the US Department of Justice released new anti-corruption compliance guidance on February 8, 2017. The eight page document provides rare insight into the government’s evaluation of corporate...more

U.S. Department of Justice Issues New Guidance on Corporate Compliance Programs

by Blank Rome LLP on

Action Item: The U.S. Department of Justice Criminal Division, Fraud Section (“DOJ”), recently published new guidance on corporate compliance programs. All corporate counsel, officers, and directors should be aware of this...more

New Guidance from the DOJ on Your Compliance Program

by NAVEX Global on

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part I

by Thomas Fox on

I guess Matt Kelly cannot leave his journalist roots for it was he who broke the story within the greater compliance community that the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of...more

DOJ Fraud Section Unveils Blueprint for Assessing Corporate Compliance Programs

by White & Case LLP on

In the year and a half that has transpired since the DOJ's Fraud Section retained a compliance consultant to assist prosecutors' evaluation of compliance programs, compliance officers, general counsels and white-collar...more

Risk in Compliance Week: Part V – So What?

by Thomas Fox on

This week I have devoted my blog posts to thinking about the management of risk by considering the tools of forecasting, risk assessment and risk-based monitoring. I have been assisted on this journey by Ben Locwin, Director...more

Lessons Learned and Compliance Trends from the VW and Takata Scandals (Part III of III)

by Michael Volkov on

When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more

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