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Training Foreign Corrupt Practices Act (FCPA) Department of Justice (DOJ)

Thomas Fox - Compliance Evangelist

Training and Communications Lessons from Star Trek: The Trouble with Tribbles

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

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...more

Thomas Fox - Compliance Evangelist

Measuring Compliance Training Effectiveness - Compliance Report

Since at least 2017, the Department of Justice (DOJ) has emphasized the need for a determination of compliance training effectiveness. In the 2020 Update, it stated under the section entitled “Form/Content/Effectiveness of...more

Thomas Fox - Compliance Evangelist

Training Frequency

What should be your organization’s compliance training frequency? How does the amount of training positively or negatively impact an overall training strategy? Unfortunately, these are not questions answered by the 2020...more

Thomas Fox - Compliance Evangelist

Compliance Training Governance Committee

One issue not often considered by compliance professionals around compliance training is that of compliance training governance. Yet a multinational organization subject to the Foreign Corrupt Practices Act (FCPA) faces many...more

Thomas Fox - Compliance Evangelist

Ten Compliance Training Program Design Objectives

Shawn Rogers, Senior Director, Global Training & Awareness, Walmart, has developed ten design objectives for establishing your compliance program training design objectives. You should consider doing the same for your...more

Thomas Fox - Compliance Evangelist

Evaluating Compliance Programs For Continuous Improvement

I recently had the opportunity to visit with Stephen Martin, Partner at StoneTurn, to consider some of the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ)...more

NAVEX

3 Ways to Apply New DOJ Guidance to Antitrust Compliance

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The Justice Department gave compliance officers a significant piece of guidance in June with its latest update to the evaluation of corporate compliance programs. The guidance begs the fundamental question: Is the compliance...more

McDermott Will & Emery

[Webinar] Anti-Corruption and Compliance Training - May 28th, 10:00 am - 11:30 am EDT

McDermott Will & Emery on

Please join McDermott and Grant Thornton on Thursday, May 28, for a webinar training on anti-corruption and compliance. This training will discuss the auditing standards on illegal acts by clients and the auditor’s...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...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

Thomas Fox - Compliance Evangelist

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 4 – Effective Training

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

King & Spalding

Corporate Compliance Programs: DOJ Issues Updated Guidance

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.[i] In issuing the new document...more

Thomas Fox - Compliance Evangelist

Compliance Man Goes Global-Episode 4-Training

Welcome to Episode 4 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on typical myths and mistakes regarding compliance trainings. In each podcast, we take...more

Jones Day

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

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

NAVEX

New Guidance from the DOJ on Your Compliance Program

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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

Thomas Fox - Compliance Evangelist

Dave Edwards, the Doomsday Defense and Execution in Compliance

Baker Hughes Inc. Chief Compliance Officer (CCO), Jay Martin, often says that execution is where the rubber meets the road in compliance. I thought about all of that in the context of some of the pronouncements the Department...more

Thomas Fox - Compliance Evangelist

Compliance Training, Part I

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

The Volkov Law Group

3 Ways to Improve Compliance Training

The Volkov Law Group on

As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

Dechert LLP

FLIR FCPA Action Highlights: Continued Focus on Penalizing Improper Expenditures for Government Officials

Dechert LLP on

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more

NAVEX

Waking Up to Massive Third Party Risk Exposure: Critical Issues To Address

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A little over a year ago the Rana Plaza factory collapsed and 1,100 garment workers died. This human disaster resulting from questionable construction practices and workplace safety issues focused the eyes of the world on the...more

The Volkov Law Group

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM

The Volkov Law Group on

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance programs. ...more

Thomas Fox - Compliance Evangelist

The Mann Gulch Fire and How Far Down the Chain Do You Need to Go?

Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...more

Thomas Fox - Compliance Evangelist

Gehrig’s Streak Ends And Compliance Week 2014 Is Near

Today we celebrate greatness in two areas. The first is in baseball as on this day in 1939, “New York Yankees first baseman Lou Gehrig benches himself for poor play ending his streak of consecutive games played at 2,130....more

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