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Corporate Misconduct Department of Justice (DOJ) Corporate Culture

Epiq

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

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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

Alston & Bird

Collaborating Effectively Within Your Organization During Internal Investigations

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Our White Collar, Government & Internal Investigations Team offers effective and actionable best practices for companies to follow in conducting their internal investigations....more

Dorsey & Whitney LLP

DOJ Antitrust Division Issues Updated Guidance on Evaluating Corporate Compliance Programs

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In recently released updated guidance, the Antitrust Division (“Antitrust Division”) of the U.S. Department of Justice (“DOJ”) outlined how its prosecutors will assess corporate compliance programs when conducting criminal...more

Latham & Watkins LLP

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

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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

Thomas Fox - Compliance Evangelist

Why the 2024 ECCP Update is a Game-Changer for Compliance

In the DOJ’s 2024 update to the Evaluation of Corporate Compliance Programs (2024 ECCP), compliance professionals face new expectations that could reshape how we approach compliance programs. In this latest update, the DOJ...more

The Volkov Law Group

Raytheon’s Defective Pricing Fraud and Resolution (Part II of IV)

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Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws. Like most cases, I always...more

DLA Piper

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

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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

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 1 - The Mandate

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Health Care Compliance Association (HCCA)

Beyond surveys: Rethinking traditional approaches to ethical culture assessments

To build a robust ethical culture, ethics and compliance professionals need effective culture assessments to pinpoint vulnerabilities and proactively address them. The U.S. Department of Justice’s (DOJ) update to the...more

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

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In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more

Holland & Knight LLP

DOJ Announces New Whistleblower Financial Rewards Program in Effort to Combat Corporate Crime

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U.S. Deputy Attorney General Lisa Monaco announced the creation of a new U.S. Department of Justice (DOJ or Department) Whistleblower Rewards Program at the 39th Annual ABA White Collar National Institute in San Francisco...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

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At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Thomas Fox - Compliance Evangelist

Leadership’s Conduct at the Top

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Thomas Fox - Compliance Evangelist

Categories Key Compliance Speeches from 2023-DAG Monaco on a Culture of Compliance

In March 2023 there were two days of speeches from the DOJ which added to the compliance complexity.  The speeches were made by Deputy Attorney General (DAG) Lisa Monaco (2023 Monaco Speech) and Assistant Attorney General...more

Axinn, Veltrop & Harkrider LLP

Warning - Corporate Compensation Clawbacks Are Coming!

On October 4, 2023, Deputy Attorney General Lisa O. Monaco announced a new "safe harbor" policy for voluntary self-disclosures in the context of mergers and acquisitions, whereby the Department of Justice will decline to...more

The Volkov Law Group

Promoting Your Corporate Culture – Accountability and Messaging (Part II of III)

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As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture.  In these...more

Robinson & Cole LLP

DOJ Announces Significant Corporate Compliance Initiatives

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The U.S. Department of Justice (DOJ) recently announced several new policies and programs aimed at incentivizing corporate compliance. These programs underscore the need for companies to investigate, mitigate and resolve...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

Conn Kavanaugh

“Corporate Citizen, Police Thyself”: How the DOJ Is Changing Its Corporate Enforcement Policy to Encourage Self-Policing

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Self-Reporting Remains a Major Focus - Few executives expect to interact with the Department of Justice (DOJ) during their careers, but the current DOJ has given companies some homework, and the assignment applies to...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

Snell & Wilmer

DOJ Updated Corporate Criminal Enforcement Policies

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In a highly anticipated speech, Deputy Attorney General Lisa O. Monaco delivered remarks outlining updates to the U.S. Department of Justice (“DOJ”) perspective on the Corporate Crime Enforcement policy. These updates are the...more

Ankura

DAG Monaco Defines DOJ Guidance for Corporate Criminal Enforcement

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New Requirements Place Onus on Corporations to Demonstrate more Compliance Capabilities to Receive Consideration from Prosecutors On September 15, 2022, Deputy Attorney General (“DAG”) Lisa Monaco spoke at New York...more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Policies on Corporate Ethics and Compliance

Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more

NAVEX

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

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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

Bracewell LLP

DOJ to Companies: If You Step Up & Own Up, You Might Not Have to Pay Up

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Late last year, the Department of Justice (DOJ) announced material changes to the way it intended to investigate, prosecute, and resolve corporate cases. The changes were aggressive, leading us to title our update “DOJ’s...more

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