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Compliance Management Systems Department of Justice (DOJ) White Collar Crimes

DLA Piper

Cadence Case Signals DOJ and BIS Priorities in Export Control Compliance

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Cadence Design Systems Inc. (Cadence) simultaneously resolved criminal charges brought by the Department of Justice’s (DOJ) National Security Division (NSD) and the United States Attorney for the Northern District of...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

AI in Compliance: Part 1, Use in a Best Practices Compliance Program

Leveraging advanced technologies like artificial intelligence (AI) is no longer a luxury; it is quickly becoming necessary. For compliance professionals, AI offers a transformative tool to enhance program efficiency, improve...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

Fenwick & West LLP

Don’t Wait for the DOJ to Come Knocking: Important Whistleblower Protection and AI Risk Management Updates

Fenwick & West LLP on

In September 2024, the DOJ’s Criminal Division released an updated Evaluation of Corporate Compliance Programs (ECCP) guidance document to address emerging risks. The ECCP serves as a roadmap for how DOJ evaluates a company’s...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

Thomas Fox - Compliance Evangelist

The 2024 ECCP: Complying with the 2024 ECCP on Whistleblowers

The Department of Justice (DOJ), in its 2024 Update, has explicitly directed companies to ensure they have robust processes in place to identify, manage, and mitigate emerging risks related to new technologies, including AI....more

Thomas Fox - Compliance Evangelist

The Argentieri Speech: Mid-Point Reflections on the DOJ’s Compensation Clawback Pilot Program

Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. She reiterated the long-stated policy that compliance...more

Thomas Fox - Compliance Evangelist

Argentieri Speech and 2024 ECCP: Whistleblowers and Anti-Retaliation

Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the Department of Justice’s (DOJ) approach to evaluating corporate compliance programs. As outlined in the updated 2024...more

Thomas Fox - Compliance Evangelist

Argentieri Speech and 2024 ECCP: Argentieri on Navigating AI Risks

Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the Department of Justice’s (DOJ) approach to evaluating corporate compliance programs. As outlined in the updated 2024...more

Thomas Fox - Compliance Evangelist

Argentieri Speech and 2024 ECCP: Data Access and Data Analytics

Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the DOJ’s approach to evaluating corporate compliance programs. As outlined in the updated 2024 Evaluation of Corporate...more

Health Care Compliance Association (HCCA)

So many reporting systems!

By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more

Thomas Fox - Compliance Evangelist

Auditing Culture

Why should you audit your culture? In doing so, a compliance professional can utilize a comprehensive approach designed to evaluate various aspects of a company’s culture, including ethics, engagement, accountability, and...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

Akerman LLP

Enactment of the Foreign Extortion Prevention Act Expands the U.S. Department of Justice’s Ability to Prosecute International...

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The breadth of the recently enacted FEPA presents pitfalls for U.S. companies dealing with foreign governments and state-owned entities requiring significant caution and effective compliance controls....more

DarrowEverett LLP

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

DarrowEverett LLP on

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

Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export...

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In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated criminal and civil prosecutions for sanctions and export control violations.  The last piece in...more

The Volkov Law Group

Episode 284 -- How to Implement a Compliance Compensation System

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

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

Burr & Forman

Department of Justice Expectations on Corporate Compliance Programs Concerning Use of Personal Device and Messaging Applications...

Burr & Forman on

Are your employees conducting business by exchanging text messages on personal devices or communicating using messaging applications? If so, it may be time to evaluate your compliance and document retention policies....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

The Volkov Law Group

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

The Volkov Law Group on

The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s...more

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