News & Analysis as of

Risk Management Dept. of Justice

The Mummy and Compliance: Lessons for Compliance Officers and Corporate Leaders from the Universal Classic Movie

by Thomas Fox on

What compliance lessons to be learned from the classic Universal Pictures movie, the Mummy?...more

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

Everything Compliance Reports from the SCCE 2017 Compliance & Ethics Institute [eBook]

by Thomas Fox on

In October 2017, nearly 2000 compliance professionals gathered in Las Vegas for the annual Society of Corporate Compliance and Ethics (SCCE) Compliance and Ethics Institute. The event was a great success for all involved, it...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

An Exploration of Soft Skills in Remediation for the Chief Compliance Officer

by Thomas Fox on

Many have focused on the more technical aspects of the remediation component of a potential Foreign Corrupt Practices Act compliance violation. I wanted to explore the soft skills that a CCO must use, both internally and...more

Farewell to The Hawk – Fair and Consistent Application of Discipline

by Thomas Fox on

In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more

Lessons for Compliance Officers from Hurricane Harvey and Other Historic Weather-Related Events

by Thomas Fox on

Lessons for the corporate compliance professional from Hurricane Harvey and other weather-related disasters....more

The Fraud Triangle, Rationalizations and Compliance Programs

by Thomas Fox on

The fraud triangle is well-known to most compliance practitioners. Its third sides are pressure, opportunity and rationalization. When these three factors converge, there is danger of an ethical lapse which could lead to...more

Day 17 of One Month to More Effective Continuous Improvement-Financial Health Monitoring

by Thomas Fox on

Continuous improvement can take many ways, shapes and forms. Typically, when it comes to third-party risks, a Chief Compliance Officer (CCO) or compliance professional will consider the ownership structure to see if there is...more

Soft Skills in Remediation: Part I – The Gatekeepers

by Thomas Fox on

Many Chief Compliance Officers (CCOs) came to the position from the legal department, internal audit or another professional discipline. These professions are technically focused and their training provides little to no soft...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

Voluntary Monitoring – Multiple Purpose Tool in Compliance

by Thomas Fox on

Alan Peckolick, died last week. According to his obituary in the New York Times, he “overcame a failed art school career to emerge as a leading designer of some the world’s most distinctive logos”. In an interview with the...more

Evolution of Your Compliance Program

by Thomas Fox on

One of the most consistent themes from the Department of Justice (DOJ) regarding Foreign Corrupt Practices Act (FCPA) compliance programs has been continuous evolution. As far back as 2009, I heard Lanny Breuer say that your...more

It's Not Reefer Madness, It's Risk Management: Providing Investment Services to the Marijuana-Related Industry

by Baker Donelson on

Investment advisors and broker-dealers ask more and more whether they can safely provide investment services to prospective customers in the marijuana industry. The answer is still that there is a risk of liability under...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

Updated U.S. Civil Penalties Raise the Cost of Noncompliance

In 2016, we let you know about the redundantly titled “Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015,” which required that heads of government agencies adjust civil penalties yearly to account for...more

Preparing for an Investigation

by Thomas Fox on

The Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation), under Prong 7 Confidential Reporting and Investigation asks the following: Properly Scoped Investigation by Qualified Personnel – How...more

Compliance into the Weeds-Episode 40, COSO ERM Framework Update

by Thomas Fox on

In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM...more

Unfair and Unbalanced-Episode 18

by Thomas Fox on

In this episode, Roy Snell and myself discuss how incentives are integral to the compensation plans of a wide range of workers. Many experts point to their value in rewarding behavior that is in the interest of the...more

The ‘Way of Compliance' Adds Value Regardless of Who's in the White House

I am astonished there are still so many articles out there advising readers on how to establish the imperative for compliance. Nearly 15 years after the rise of compliance to an officer-level position, with significant...more

Trump Administration Takes Aim at H-1Bs

by Davis Brown Law Firm on

Besides the wall, another immigration-related theme made a frequent appearance in the presidential campaign: the H-1B visa. This program allows foreign nationals with a bachelor’s degree or higher (or the equivalent in...more

AML Enforcement and Compliance Trends

by Michael Volkov on

Law enforcement focus on anti-money laundering appears to be increasing. While the last ten years has seen a marked increase in AML regulatory obligations, the new administration is likely to return to some of the more...more

Operationalizing Compliance – Natural Partners and Breaking Down Walls (Part I of IV)

by Michael Volkov on

An effective compliance program is built on internal coordination and relationships. Applying the Justice Department’s terminology, an effective compliance program is one that is operationalized. At first glance, you may...more

The DOJ Expects “Third-Party Management” from Compliance Programs

2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more

Creation of Roundabout and Operationalization of Compliance

by Thomas Fox on

Readers of this blog know of my love for progressive rock music and that my favorite prog rock group is Yes. You might understand how thrilled I was when the Wall Street Journal (WSJ), of all places, ran an interview with...more

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