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Perkins Coie

DOJ Signals Renewed Prioritization of Corporate Enforcement with New Policies Regarding Voluntary Disclosure, Monitors, &...

Perkins Coie on

On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal...more

Seyfarth Shaw LLP

Curiosity may kill the cat, but is indispensable for workplace health and safety

Seyfarth Shaw LLP on

“Curiosity killed the cat” is a proverb “used to warn of the dangers of unnecessary investigation or experimentation” (Wikipedia) or is an idiom “said to warn someone not to ask too many questions about something” (Cambridge...more

Ankura

Beyond Internal Controls: The Importance of Culture in “Failure to Prevent Fraud” Preparation

Ankura on

The Failure to Prevent Fraud (FTPF) offence will officially come into force as part of the Economic Crime and Corporate Transparency Act in September 2025. In a previous article, we explored the government’s guidance around...more

Ropes & Gray LLP

[Podcast] Culture & Compliance Chronicles: Building a Culture of Fairness and Transparency with Danny Mayhew of Sanofi

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 Danny Mayhew, the global head of...more

Thomas Fox - Compliance Evangelist

Lisa and Mary Changed the World: The Great Women in Compliance Community

In the world of compliance, where incremental victories often measure progress against pervasive risks, it’s rare to witness a revolution. Yet Lisa Fine and Mary Shirley have achieved just that. Through their groundbreaking...more

Thomas Fox - Compliance Evangelist

FT Business Book of the Year, Alison Taylor and Higher Ground

The Financial Times (FT) and Schroders Business Book of the Year Award is the most prestigious accolade in business publishing, recognizing exceptional insight, research, and storytelling in books addressing current business,...more

Thomas Fox - Compliance Evangelist

Why Data-Driven Culture is the Future of Compliance

The DOJ’s message from the 2024 ECCP is clear: if companies want to maintain credibility, mitigate risks, and avoid scrutiny, they must embrace data analytics to support and document their compliance efforts. This evolution...more

Thomas Fox - Compliance Evangelist

Creating, Strengthening, and Maintaining Corporate Culture: Lessons from The Mummy

Ed. Note: This week, leading up to Halloween, I will examine lessons for compliance professionals through the lens of the great Universal Movie Monsters: Frankenstein, Wolfman, Dracula, and The Mummy. Our final offer is Boris...more

The Volkov Law Group

Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review

The Volkov Law Group on

How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges? In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more

Thomas Fox - Compliance Evangelist

Compliance Lessons from Boris Karloff’s Frankenstein

Ed. Note: This week, leading up to Halloween, I will examine lessons for compliance professionals through the lens of the great Universal Movie Monsters: Frankenstein, Wolfman, Dracula, and The Mummy. First up is Boris...more

Thomas Fox - Compliance Evangelist

2024 ECCP-Embracing Continuous Improvement

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute, Principal Deputy Assistant Attorney General Nicole M. Argentieri discussed the Evaluation of Corporate...more

DLA Piper

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

DLA Piper on

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

The 2024 ECCP – Using Data Analytics to Determine Employee Engagement, Trust, and Corporate Culture

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke about the CWA and reviewed its early...more

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 5 – CCOs Using Town Halls to Build Compliance

This week we have been exploring how Chief Executive Officers and other senior executives can set an appropriate Tone at the Top by actually walking-the-walk of compliance rather than simply talking-the-talk of compliance....more

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 3-Email as a Strategic Compliance Tool

We continue our exploration of how CEOs and senior executives are uniquely positioned to drive home the importance of ethical behavior and adherence to compliance regulations. Today, we consider the humble email and how it...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 5- A Case Study for Compliance

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 2-Lessons Learned for Compliance

As compliance professionals, it is imperative to not just address the symptoms of such crises but to dig deeper and identify the root causes. In this case, it’s clear that the root cause is a toxic corporate culture that...more

Thomas Fox - Compliance Evangelist

Bridging The Speak-Up Gap: Insights from The 2024 Ethisphere Ethical Culture Report

In a recent episode of the FCPA Compliance Podcast, we discussed the 2024 Ethisphere Ethical Culture Report, “Closing the Speak Up Gap,” with Erica Salmon Byrne. As an expert in ethical culture and a familiar voice to our...more

The Volkov Law Group

LRN’s Call to Action: 5 Steps Every Company Should Take to Promote an Ethical Culture (Part II of II)

The Volkov Law Group on

LRN’s  research consistently paints a picture that every board member, senior executive and middle manager should view — corporate culture is an organization’s most valuable intangible asset and is a significant determinant...more

The Volkov Law Group

LRN Report Highlights (Again) the Importance of Ethical Culture (Part I of II)

The Volkov Law Group on

In its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture.  LRN is a pacesetter and the leader in reliable studies on complex ethics and compliance issues....more

Thomas Fox - Compliance Evangelist

Making Ethics & Compliance Training Memorable: Part 4 – How Social Learning Can Engage Employees

There is not much I enjoy more than sitting down with one of the innovative thinkers in compliance, Carsten Tams, to find out what is on his mind regarding compliance. I recently had the opportunity to do so on making Ethics...more

Thomas Fox - Compliance Evangelist

Making Ethics & Compliance Training Memorable: Part 3 – How Experiential Learning Can Engage Employees

There is not much I enjoy more than sitting down with one of the innovative thinkers in compliance, Carsten Tams, to find out what he is thinking about compliance. I recently had the opportunity to make Ethics and Compliance...more

Thomas Fox - Compliance Evangelist

Making Ethics & Compliance Training Memorable: Part 2 – What is Strength Based Training?

There is not much I enjoy more than sitting down with one of the innovative thinkers in compliance, Carsten Tams, to find out what is on his mind regarding compliance. I recently had the opportunity to do so on the topic of...more

Dentons

Ep. 16 - Creating a Compliance Culture: Including Compliance in Performance Reviews

Dentons on

One thing that can make or break the success of your compliance program is your organization’s culture. Having a “compliance culture” means that compliance is a central, unalterable, and pervasive part of the organization,...more

Thomas Fox - Compliance Evangelist

Transforming Culture: Part 5 – Ongoing Monitoring and Continuous Improvement of Culture

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other...more

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