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Risk Management Department of Justice (DOJ) White Collar Crimes

Thomas Fox - Compliance Evangelist

Risk Assessment Lessons from Star Trek: Balance of Terror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

The Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

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Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

Skadden, Arps, Slate, Meagher & Flom LLP

AI-Enabled Compliance: Keeping Pace With the Feds

The potential for artificial intelligence (AI) to transform business has commanded enormous attention over the past year. Little noted, however, is the U.S. government’s increasing — and increasingly sophisticated — use of AI...more

Jenner & Block

DOJ Announces New Whistleblower Rewards Program and Enhanced Focus on AI-Related Risks

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The Department of Justice (DOJ) recently announced two new measures to enhance its corporate criminal enforcement efforts: a whistleblower rewards program and updated guidance under which federal prosecutors will assess risks...more

J.S. Held

INDEPTH FEATURE: Corporate Fraud & Corruption 2024

J.S. Held on

To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more

Ballard Spahr LLP

DOJ launches whistleblower pilot program and cracks down on artificial intelligence misuse

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Following a year of new DOJ policies and guidance designed to incentivize companies to self-report misconduct and to cooperate with government investigations, the DOJ has added a new pilot whistleblower rewards program. In...more

Jenner & Block

Client Alert: DOJ Announces New Whistleblower Rewards Program and Enhanced Focus on AI-Related Risks

Jenner & Block on

Continuing to prioritize corporate criminal enforcement, the Department of Justice (DOJ) announced two new steps it is taking to identify potential corporate misconduct and evaluate companies’ compliance programs. Deputy...more

Ballard Spahr LLP

DOJ Launches Whistleblower Pilot Program and Cracks Down on AI Misuse

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The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 8, Enhancing Your Compliance Program

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

The Volkov Law Group

Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks

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Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable and to protect the organization from potential private and government claims or investigations that...more

Mintz

EnforceMintz — DOJ and OIG Guidance Emphasizes the Importance of a Robust and Dynamic Compliance Program

Mintz on

2023 was a busy year across several federal agencies in terms of issuing compliance guidance for corporations, including health care companies. For example, the Department of Justice (DOJ) issued significant compliance...more

Thomas Fox - Compliance Evangelist

Managing Third Parties

The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a...more

Littler

Proper Planning and Swift Action Can Help Employers Avoid Foreign Corrupt Practices Act Prosecution

Littler on

While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more

American Conference Institute (ACI)

[Event] 11th Annual Advanced Forum on False Claims and Qui Tam Enforcement - January 23rd - 24th, New York, NY

Hosted by American Conference Institute, the 11th Annual Advanced Forum on False Claims and Qui Tam Enforcement returns for another exciting year for lively discussions on FCA enforcement including the ramifications of two...more

The Volkov Law Group

Episode 284 -- How to Implement a Compliance Compensation System

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The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management.  The theoretical...more

Thomas Fox - Compliance Evangelist

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 3-Defining the Effectiveness of Compliance...

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...more

Fisher Phillips

Top 20 Questions to Ensure Your Compliance Program Helps You Minimize Corporate Criminal Risks

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Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more

Perkins Coie

DOJ Issues New Guidance on Use of Personal Devices and Third-Party Messaging Applications

Perkins Coie on

The U.S. Department of Justice (DOJ) announced significant new guidance on March 3, 2023, regarding the use of personal devices and the retention of corporate communications. The DOJ’s concern regarding the use of personal...more

Pillsbury Winthrop Shaw Pittman LLP

New DOJ Clawback Policy Brings Compensation and Employment Questions Front and Center for Companies

Can a new Department of Justice enforcement approach make clawback policies covering criminal activities a best practice? The DOJ is implementing a new policy under which prosecutors will make clawback policies for...more

Skadden, Arps, Slate, Meagher & Flom LLP

Variable Remuneration and Ethical Behavior: A Toolkit for Companies

Governmental authorities in the U.K. and the U.S. want companies to align employment incentives with ethical conduct. In 2022, the U.K. government undertook a consultation on this topic and in May 2022 published a paper —...more

Polsinelli

No Agreement? No Worries: Justice Department Secures Historic Criminal Attempted Monopolization Conviction

Polsinelli on

In yet another signal in support of the notion that “the era of lax enforcement is over, and the new era of vigorous and effective antitrust law enforcement has begun,” on October 31 the Antitrust Division of the Department...more

Dechert LLP

Measure Twice, Cut Once: New DOJ Compliance Certifications Put CEOs and CCOs at Risk of Individual Criminal Liability

Dechert LLP on

Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more

The Volkov Law Group

CCOs and Execution of Compliance Certification: A Significant Risk? (Part III of III)

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CCOs, by definition, are careful and deliberate.  It comes with the profession.  As risk managers, CCOs are skilled in identifying, assessing and acting in a risk environment....more

Womble Bond Dickinson

[Webinar] Corporate Enforcement Under the Biden Administration - March 11th, 12:00 pm - 1:00 pm EST

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At the 36th Annual American Bar Association National Institute on White Collar Conference on October 28, 2021, Deputy Attorney General Lisa Monaco announced significant changes to Department of Justice policies on corporate...more

Holland & Knight LLP

DOJ Prioritizes Compliance; Boards of Directors Should Heed Warnings

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In the early months of a new presidential administration, the nation and the world scramble to predict where the White House and federal agencies will focus their energy and attention. Thanks to recent talks given by two top...more

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