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Secretariat

Navigating New Rules of the Road: How Companies Can Adapt to Revised DOJ Guidance on Criminal Prosecutions

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Since the election in November 2024, there have been many changes to DOJ’s enforcement policies. Earlier this year, now-Acting Assistant Attorney General of the Criminal Division, Matthew R. Galeotti, announced at the...more

Thomas Fox - Compliance Evangelist

2 Gurus Talk Compliance: Episode 57 — The Tom on His Highhorse Edition

What happens when two top compliance commentators get together? They talk compliance of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s...more

Ropes & Gray LLP

[Podcast] Culture & Compliance Chronicles: Beyond Bad Apples—How Context Shapes Corporate Misconduct with Professor Guido Palazzo

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On this episode of Culture & Compliance Chronicles, Amanda Raad and Nitish Upadhyaya from Ropes & Gray’s Insights Lab, and Richard Bistrong of Front-Line Anti-Bribery are joined by Professor Guido Palazzo, co-author of The...more

Thomas Fox - Compliance Evangelist

2 Gurus Talk Compliance: Episode 47 – The Chaos Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s...more

Troutman Pepper Locke

Making Compliance Your New Year's Resolution

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As we begin a new year, it is the perfect time for companies subject to any government agreement to renew their focus on compliance. These binding resolutions require ongoing diligence to avoid civil and potentially criminal...more

Thomas Fox - Compliance Evangelist

Auditors and Compliance: Part 2-Ten Key Takeaways for Compliance Professionals

The PCAOB’s recent information release, SPOTLIGHT Auditor Responsibilities for Detecting, Evaluating, and Making Communications About Illegal Acts, is a critical guide for compliance professionals. The SPOTLIGHT sets out the...more

Thomas Fox - Compliance Evangelist

Auditors and Compliance: Part 1-Auditors and Illegal Acts

Regarding compliance, one area that requires heightened attention is the role of auditors in detecting, evaluating, and communicating illegal acts. Recently, the PCAOB issued a document entitled SPOTLIGHT Auditor...more

Thomas Fox - Compliance Evangelist

Navigating Compliance in Interesting Times

I once had a boss whose catchphrase was ‘May you live in interesting times’. That applied back in the first decade of this century and I think it is even more appropriate now. In a world that often feels as if it is...more

The Volkov Law Group

DOJ Updates Evaluation of Corporate Compliance Programs

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The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs.  As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more

StoneTurn

Sweeping Skeletons Out of the Corporate Closet: “Read Across” and Remediation

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It is tempting for organizations to downplay compliance violations as an isolated event attributable to a few bad apples. However, experience teaches that misconduct is often worse than initially thought. Wrongdoers who...more

Dentons

Ep. 2 - Why Anonymous Reporting is the Cornerstone of Your Compliance Program

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When was the last time your organization received an anonymous compliance concern?  Has it been so long you can’t recall? Maybe you consider yourself lucky that the organization has never received a concern on your watch, or...more

DarrowEverett LLP

How DOJ's Safe Harbor Policy Rewards Honesty Within M&A Deals

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Be you a merger and acquisition attorney, corporate compliance officer, or counsel to an acquiring entity or target entity, you should review the Department of Justice’s new Merger and Acquisition Safe Harbor Policy...more

Thomas Fox - Compliance Evangelist

DAG Monaco on Cooperation and Compliance Incentives for M&A

Early in October at the 2023 SCCE Compliance and Ethics Institute, Deputy Attorney General Lisa Monaco delivered a long-anticipated speech expanding and formalizing the Department of Justice’s (DOJ’s) new Safe Harbor for...more

StoneTurn

Meeting DOJ and SEC Post-Settlement Obligations: A Practical Guide

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No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more

The Volkov Law Group

How to Build a Compliance Compensation System (Part I of II)

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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

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

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Let’s move beyond the headline – trade compliance is the new FCPA.  We get it.  The next step is to do something about it.  The Justice Department has repeated this refrain – it is one of its greatest hits.  In addition, DOJ,...more

J.S. Held

Building a Strong Compliance Program That Meets the Revised DOJ Corporate Enforcement Policy

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A corporate compliance program can be thought of as a magnet that brings a company’s compliance efforts together. It is an operational program, not simply a code of expected ethical behavior. An effective compliance...more

The Volkov Law Group

DOJ’s Criminal Division Issues Three-Year Pilot Program for Corporate Compensation Systems and Clawbacks (Part II of III)

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The Justice Department is focusing with a laser beam on corporate incentives and disincentives.  This truly is a remarkable initiative and companies should undertake their own holistic review of internal incentives and...more

WilmerHale

DOJ Announces Updates to Corporate Enforcement Policy

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Assistant Attorney General Kenneth A. Polite, Jr. Announces Changes to Department of Justice Criminal Division’s Corporate Enforcement Policy - On January 17, 2023, Assistant Attorney General for the Criminal Division...more

NAVEX

NAVEX R&C Benchmark Finding: Programs Still Have Opportunities to Better Utilize Data

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NAVEX publishes the Definitive Risk and Compliance Benchmark Report each year, surveying over 1,100 industry professionals. The purpose of this report is to provide insight into the effectiveness of R&C programs and enable...more

NAVEX

Expanded Japanese Whistleblowing Rules Reach Small & Medium Business

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Expanded Japanese whistleblowing rules are among the latest to come into effect as part of a broad trend of increasing regulatory requirements for incident reporting across the globe. Previously in effect for large...more

Health Care Compliance Association (HCCA)

Ethikos Volume 36, Number 4. October 2022. Culture and code of ethics: Connecting the dots through measurement

Ethikos Volume 36, Number 4. October 2022 - Organizational culture seems to be discussed daily, yet few can define it. For our purpose, we can use a simple definition: the way we do things around here. Edgar Schein’s...more

The Volkov Law Group

DOJ Imposes New Standards for Evaluation of Corporate Compliance Programs: Compensations Structures that Promote Compliance (Part...

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The Monaco Memo is a watershed moment as part of DOJ’s evolution and advocacy for effective ethics and compliance programs.  We have seen prior moments of significant action — DOJ’s adoption of the FCPA Guidance, DOJ’s...more

The Volkov Law Group

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

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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

Compliance Program Monitoring, Testing, Audits, Assessments and Continuous Improvement (Part I of IV)

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Chief compliance officers have a lot of issues to balance on their plate.  Experienced CCOs know that it is not possible to complete every objective, balance every changing risk, and continuously improve their respective...more

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