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The Increasing Importance – and Visibility – of Internal Investigations 

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New DOJ whistleblower incentives. Investigation-related KPIs. Accountability demands from stakeholders of all stripes.    A combination of hard work by ethics and compliance professionals, high profile internal system...more

Akin Gump Strauss Hauer & Feld LLP

DOJ National Security Division Updates Corporate Crime Enforcement Policy and Issues Whistleblower Policy

Executive Summary - - On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions. - These updates follow repeated...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

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Another Reminder About a Commitment to Compliance

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The U.S. Justice Department has long said (and compliance officers have said it too) that a culture of compliance is what matters in regulatory enforcement actions, and can pay dividends in the form of smaller monetary...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ to Coordinate FCPA Enforcement With Foreign Law Enforcement Agencies

New policy seeks to reduce the burden of navigating anti-corruption investigations and enforcement actions by multiple authorities. The new DOJ policy seeks to increase coordination on FCPA and related anti-corruption...more

Proskauer - The Capital Commitment

Voluntary Remediation and the SEC: Six Key Elements and Three Potential Pitfalls

A recent settled SEC order, In re Arlington Capital Management, Inc. and Joseph F. LoPresti, highlights the potential benefits of voluntarily taking steps to remediate conduct or practices that could run afoul of the SEC’s...more

Holland & Knight LLP

Justice Department Reveals How It Evaluates Corporate Compliance Programs

Holland & Knight LLP on

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

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