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Corporate Governance Compliance Management Systems Department of Justice (DOJ)

Compliance and Ethics: Ideas & Answers

Sony’s practical example of how to measure your program

Is your compliance program working?  Measurement is one of the challenges everyone in our field faces. A few years ago, in the monthly interview article in SCCE’s Compliance & Ethics Professional magazine, Adam Turteltaub...more

Carlton Fields

DOJ Updates Evaluation of Corporate Compliance Programs Guidance: What Companies Need to Know

Carlton Fields on

On September 23, 2024, the U.S. Department of Justice (DOJ) released updates to its Evaluation of Corporate Compliance Programs (ECCP) guidance — the framework prosecutors use to evaluate corporate compliance programs during...more

Troutman Pepper Locke

Making Compliance Your New Year's Resolution

Troutman Pepper Locke on

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

Reimagining Compliance as a Product

In the modern corporate environment, compliance must transcend its traditional role as a set of rules and regulations. Instead, it should be reimagined as a product—something employees actively choose to engage with daily....more

Ropes & Gray LLP

[Podcast] Culture & Compliance Chronicles: Innovative Compliance Strategies with Katie Daniels

Ropes & Gray LLP on

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 Katie Daniels, managing director and head...more

Thomas Fox - Compliance Evangelist

5 Practical Steps for Conducting a Culture Audit that Meets DOJ Standards

The  2024 ECCP demands data-backed evidence of a genuine, embedded compliance culture. The DOJ’s stance is clear: a company’s commitment to compliance is only credible if it’s supported by data that reflects employee...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

White & Case LLP

DOJ to Evaluate AI Risk Management and Whistleblower Protections in Corporate Compliance Programs

White & Case LLP on

Over the past year, the Department of Justice ("DOJ") has warned that it will seek stiffer sentences for offenses made significantly more dangerous by the misuse of artificial intelligence ("AI") and has asked the US...more

The Volkov Law Group

DOJ Updates Evaluation of Corporate Compliance Programs

The Volkov Law Group on

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

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

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

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

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 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

NAVEX

A Review of Risk & Compliance in 2022

NAVEX on

As 2022 comes to a close, now is an ideal time to reflect on the developments and challenges this year held for the risk and compliance profession – and there was no shortage of either. The complexity of maintaining...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

The Volkov Law Group

Where Does Your Compliance Program and CCO Fall Under DOJ’s Independence, Authority and Resources Test? (Part IV of IV)

The Volkov Law Group on

As we enjoy the remainder of the summer and get ready to launch into a new fall season (no, not football) but a time for renewal and recommitment, this may be a good opportunity to examine and analyze your own compliance...more

The Volkov Law Group

CCOs and Execution of Compliance Certification: A Significant Risk? (Part III of III)

The Volkov Law Group on

CCOs, by definition, are careful and deliberate.  It comes with the profession.  As risk managers, CCOs are skilled in identifying, assessing and acting in a risk environment....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

Orrick, Herrington & Sutcliffe LLP

Thoughts on Revised DOJ Corporate Compliance Guidance, and New Emphasis on Real-Time Risk Assessment, Use of Data, and More

New guidance for prosecutors from the U.S. Department of Justice (“DOJ”), Criminal Division, highlights increasing expectations that companies continuously and in real-time reassess fraud and corruption risk and adjust their...more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Guidance on Evaluating Corporate Compliance Programs

Earlier this month, the Criminal Division of the United States Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. In considering enforcement actions against companies, prosecutors...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways From Updated DOJ Corporate Compliance Evaluation Guidance

On June 1, 2020, the Criminal Division of the U.S. Department of Justice (DOJ) released updates to its Evaluation of Corporate Compliance Programs guidance (Guidance), last revised in April 2019. ...more

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