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Epiq

The New DOJ Position on Self-Disclosure Demands High-Functioning Compliance

Epiq on

In remarks to an industry group, Matthew R. Galeotti, head of the Department of Justice (DOJ) Criminal Division, emphasized that companies may avoid criminal resolutions if they voluntarily self-disclose misconduct, fully...more

Foley & Lardner LLP

‘Twas the Night of Compliance

Foley & Lardner LLP on

So, a lot of readers — well, a couple of people . . . okay, one person, and it might have been my mom — have asked for a third Christmas compliance parody article. And since we are nothing but compliant (sorry, we couldn’t...more

Latham & Watkins LLP

Antitrust Division’s Updated Guidance on Evaluating Corporate Compliance Programs - Key Features and Takeaways

Latham & Watkins LLP on

The guidance stresses heightened focus on emerging antitrust risks, enhanced support and incentives, and proactive monitoring. On November 12, 2024, the Antitrust Division of the US Department of Justice (the Antitrust...more

DLA Piper

DOJ's Revised ECCP Signals Expectations of a Data-driven Compliance Program

DLA Piper on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced much-anticipated revisions to the US Department of Justice (DOJ)’s Evaluation of Corporate Compliance Programs (Revised ECCP)...more

The Volkov Law Group

The Evolution of the Compliance Profession

The Volkov Law Group on

One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more

The Volkov Law Group

Corporate Culture: Monitor, Intervene and Remediate (Part III of III)

The Volkov Law Group on

Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone.  To the contrary, as the business adapts through growth, innovation or in response to outside market and...more

BakerHostetler

DOJ Announces Major Corporate Enforcement Policies

BakerHostetler on

Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

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Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more

NAVEX

The Justice Department’s New Emphasis on a Culture of Compliance

NAVEX on

The week of September 12 was an important one for corporate compliance professionals. We saw two high-ranking officials at the U.S. Justice Department give back-to-back speeches outlining ambitious plans to transform the...more

NAVEX

Another Reminder About a Commitment to Compliance

NAVEX on

The U.S. Justice Department has long said (and compliance officers have said it too) that a culture of compliance is what matters in regulatory enforcement actions, and can pay dividends in the form of smaller monetary...more

The Volkov Law Group

Assessing Your Audit and Testing Program (Part IV of IV)

The Volkov Law Group on

Continuous improvement of a compliance program requires robust auditing and testing.  The Justice Department and regulatory agencies have articulated a number of key issues and principles to assist CCOs and Internal Auditors...more

The Volkov Law Group

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

The Volkov Law Group on

On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more

NAVEX

Mitigating Conduct Risks in Strategic Objectives & Performance Metrics

NAVEX on

Corporations depend on strategic objectives and performance metrics. Senior executives declare the objectives and the metrics they’ll use to measure employees’ progress toward those goals, and employees get to work achieving...more

The Volkov Law Group

Insights from Recent NAVEX Global and KPMG Surveys

The Volkov Law Group on

Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry.  Compliance...more

The Volkov Law Group

Remediating the Organization’s Culture (Part IV of IV)

The Volkov Law Group on

“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more

The Volkov Law Group

Measuring and Reporting on the Organization’s Culture (Part III of IV)

The Volkov Law Group on

While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures....more

The Volkov Law Group

When a CCO Fails to Speak Up

The Volkov Law Group on

We often discuss the importance of a “Speak Up” culture.  We encourage employees to report their concerns, we emphasize the important of such reporting to the life of an organization....more

Latham & Watkins LLP

White Collar & Compliance Academy 2021 - Die Zukunft

Latham & Watkins LLP on

Compliance & Investigations im Jahr 2025 - „Wirksame Compliance erfordert ganzheitliche Ansätze.“ Was ist für die Themen „Compliance & Investigations“ im Jahr 2025 zu erwarten? Fünf Thesen von Prof. Dr. Thomas Grützner...more

Brownstein Hyatt Farber Schreck

Have You Thought About ... Ensuring Pandemic Fatigue Doesn’t Decrease Compliance?

Companies have drafted myriad new policies in order to continue pandemic-era operations, whether required by law or to accommodate new ways of doing business. However, simply having a policy is only the first step to...more

NAVEX

Beyond the Moment: Creating Sustainable Diversity, Equality and Inclusion (DEI) Programs

NAVEX on

On October 22, 2020, NAVEX Global hosted NAVEX Next, our annual virtual conference featuring 26 speakers across 11 sessions exploring issues and informing audiences on a wide variety of risk and compliance topics and trends....more

NAVEX

3 Ways to Apply New DOJ Guidance to Antitrust Compliance

NAVEX on

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

The Volkov Law Group

The Future of Compliance: Re-Branding Compliance from Reactive to Proactive (Part I of III)

The Volkov Law Group on

As everyone knows, I am an eternal optimist.  Being a cynic always leads to negative energy and results.  As a former federal prosecutor, I am deeply committed to the idea of doing the right thing....more

Thomas Fox - Compliance Evangelist

CCO Lessons from A Charlie Brown Christmas

Delegation is always a key technique in improving productivity. However, you should not simply “shove things off your plate” but use the opportunity to give specific and new challenges to employees to help in their own career...more

Thomas Fox - Compliance Evangelist

Casebook of Sherlock Holmes: The Creeping Man and Risk Management by the Board

CCO reporting to the Audit/Compliance Committee must be structured carefully to promote ethics and compliance. Here are five best practices to help guide the reporting....more

McDermott Will & Schulte

Corporate Law & Governance Update - May 2019

IMPORTANT BOARD COMPOSITION DEVELOPMENT - The board’s nominating committee will benefit from an overview of The Conference Board’s important new survey on board composition, turnover and refreshment. According to the...more

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