Daily Compliance News: August 6, 2025, The Spanking Banks Edition
FCPA Compliance Report: Navigating Corporate Scandals: Insights on Governance, Compliance, and Recovery with Steve Vincze
FCPA Compliance Report: 10 Core Principles for Effective Internal Investigations with Michelle Peirce
Data Driven Compliance: Understanding the UK’s New Failure to Prevent Fraud Offense with Sam Tate
Daily Compliance News: July 25, 2025, The New Sheriff in Town Edition
Daily Compliance News: July 23, 2025 the Pardon in the Wind? Edition
Daily Compliance News: July 21, 2025, The More Reasons Not to Go to China Edition
All Things Investigation: Due Diligence and Drama: A Deep Dive into Art World with Daniel Weiner
Compliance Tip of the Day: Lessons from Internal Control Failures
Daily Compliance News: July 7, 2025 the Disaster on the River Edition
10 For 10: Top Compliance Stories For the Week Ending June 28, 2025
The Dark Patterns Behind Corporate Scandals
Compliance into the Weeds: Boeing’s New Safety Initiatives and Compliance Reforms
10 For 10: Top Compliance Stories For the Week Ending June 21, 2025
Daily Compliance News: June 13, 2025. The All Boeing Edition
Adventures in Compliance: The Novels: The Sign of Four – Applying Sherlock Holmes’ Methods to Modern Corporate Compliance
2 Gurus Talk Compliance: Episode 53 – The AI as a Whistleblower Edition
Great Women in Compliance: From Hotline to Headline: The DOJ’s Whistleblower Awards Reboot with Mary Inman and Liz Soltan
Compliance into the Weeds: Autonomous AI Whistleblowing Misconduct
Compliance into the Weeds: Boeing, a NPA and the End of Monitors
In today's corporate governance landscape, clawback and malus provisions have become key tools for promoting accountability and integrity. By incorporating these provisions, companies aim to align executive actions with the...more
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
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
Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action. We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more
Executives at public and private companies will soon run the risk of having their compensation subject to forfeiture for financial misstatements and corporate criminal misconduct under their watch thanks to new “clawback”...more
We often read about lucrative bonus payments made to CEOs and other senior executives. With refinements in corporate governance structures, shareholders and investors are raising concerns over executive bonuses. To bring...more
A new voluntary self-disclosure policy issued by the United States Department of Justice (DOJ) provides incentives for companies that voluntarily report criminal misconduct by their employees or agents....more
On March 15, 2023, the U.S. Department of Justice (DOJ or the Department) launched a three-year Compensation Incentives and Clawbacks Pilot Program (Clawback Program) intended to incentivize companies to create more robust...more
The U.S. Department of Justice (DOJ) on March 3, 2023, unveiled a new pilot program and announced several important updates to its Evaluation of Corporate Compliance Programs (ECCP) regarding corporate compensation incentives...more
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
Key Points - The DOJ recently announced several policy updates tethering resolution of criminal investigations to a company’s compensation and bonus programs. These updates include executive compensation focused...more
During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more
On March 2, 2023 and March 3, 2023, in a pair of speeches by Deputy Attorney General (DAG) Lisa Monaco and Criminal Division Assistant Attorney General (AAG) Kenneth Polite, the U.S. Department of Justice (DOJ) announced...more
On Friday, March 3, 2023, the Department of Justice (DOJ) Criminal Division released updated guidance regarding the “Evaluation of Corporate Compliance Programs.” Now in its fourth iteration, this guidance replaces the June...more
In early March 2023, the Department of Justice (DOJ) released several important updates to its policies related to corporate crime enforcement and compliance programs. We discuss below the following key topics: (i) The DOJ...more
The Justice Department promised that it would flesh out compliance program incentives requirements and preservation of business data as part of its revision of its Corporate Enforcement Policy. In a pair of important...more
Executive compensation and the use of personal devices and ephemeral messaging are the key focus areas of new U.S. Department of Justice policies and guidance. We consider the changes and how companies should respond....more
Employers will not be able to take full advantage of the DOJ’s new program if their compensation systems do not permit clawbacks from wrongdoer employees. Companies should review their existing compensation systems and...more
In back-to-back speeches to the American Bar Association's National Institute on White Collar Crime on March 2-3, 2023, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco and Assistant Attorney General...more
As part of a recent series of announcements regarding updates to its corporate compliance policies, the Department of Justice (DOJ) announced significant revisions to its evaluation criteria for corporate compliance programs,...more
As part of a sweeping revamp of its white-collar criminal enforcement policies that began last year, the Department of Justice (DOJ) announced two significant changes last week. The first is a new three-year pilot program...more
During speeches on March 2 and 3, 2023, at the American Bar Association (ABA) National Institute on White Collar Crime (the 2023 White Collar Conference), Deputy Attorney General (DAG) Lisa Monaco, Assistant Attorney General...more
On March 3, the Criminal Division of the Department of Justice announced a two-part pilot program to encourage corporations to implement compliance programs with provisions for employee compensation incentives and clawbacks...more
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
On February 22, 2023, the U.S. Department of Justice (DOJ) announced and implemented a new Voluntary Self-Disclosure Policy specific to the 93 United States Attorney’s Offices (USAOs) throughout the nation. Before...more