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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

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

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

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

StoneTurn on

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)

The Volkov Law Group on

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)

The Volkov Law Group on

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

J.S. Held on

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)

The Volkov Law Group on

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

The Volkov Law Group

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

The Volkov Law Group on

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

Torres Trade Law, PLLC

There’s A New Compliance Sheriff In Town, And She’s Cracking Down On Corporate Misconduct

Torres Trade Law, PLLC on

The U.S. Department of Justice ("DOJ") is making it harder on companies that commit corporate crimes. A lot harder. That’s the message that Deputy Attorney General Lisa Monaco recently gave attendees at the American Bar...more

Proskauer - Corporate Defense and Disputes

DOJ Announces New Guidance for Prosecuting Corporate Crime in Speech by Deputy Attorney General Lisa Monaco

Late last month, Deputy Attorney General Lisa O. Monaco delivered a keynote speech at the ABA’s National Institute on White Collar Crime event in Washington, DC.  Her remarks outlined observed trends in white collar crime as...more

Hogan Lovells

The U.S. Department of Justice updates roadmap to an effective compliance program

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On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more

Thomas Fox - Compliance Evangelist

Introducing New 2020 Podcast Series – 31 Days to a More Effective Compliance Program

2019 has been a very significant year for every compliance practitioner and compliance program. There were three significant releases of information by the federal government which directly impacted compliance professionals...more

Thomas Fox - Compliance Evangelist

Antitrust Compliance Programs: Part 2 – Elements of an Effective Compliance Program (Elements 1-4)

As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division, in July the released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations...more

Troutman Pepper Locke

New DOJ Policy on Corporate Antitrust Compliance Programs Provides Guidance for In-House Counsel and Compliance Officers

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On July 11, the U.S. Department of Justice rolled out a new policy to encourage stronger corporate antitrust compliance efforts. Announced by DOJ Antitrust Division head Makan Delrahim in remarks at the New York University...more

Orrick - Antitrust Watch

DOJ Changes Course and Announces That It Will Favorably Consider “Robust” Antitrust Compliance Programs at Both the Charging and...

Benjamin Franklin once observed that “an ounce of prevention is worth a pound of cure.” In the antitrust context, this means that most, if not all, companies will want as a matter of course to adopt and maintain an antitrust...more

Robinson+Cole Manufacturing Law Blog

Department of Justice Expands Guidance on Evaluating Corporate Compliance Programs

Earlier this year, the United States Department of Justice (DOJ) issued new guidance regarding how it evaluates corporate compliance programs in the context of civil and criminal enforcement matters....more

The Volkov Law Group

Watching the River Flow: The Evolution and Future of Compliance (Part I of III)

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Bob Dylan, Watch the River FlowI have to admit it – I still love to listen to Bob Dylan.  With age, his lyrics resonate more and more.  HERE is a nice version of Watch the River Flow in case you want to listen while reading...more

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