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Compliance White Collar Crimes Corporate Culture

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
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

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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

Deere FCPA Enforcement Action: Lessons on Pre-Acquisition Due Diligence in M&A

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...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

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

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 3-The Role of Internal Controls

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

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

Lathrop GPM on

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

Thomas Fox - Compliance Evangelist

The Boeing Plea Agreement-A Major Disconnect

In its proposed Plea Agreement, the Department of Justice (DOJ) lays out the abject failures of Boeing which led the DOJ to conclude the underlying Deferred Prosecution Agreement (DPA) from 2021 has been breached. The DOJ...more

Thomas Fox - Compliance Evangelist

The Boeing Monitorship – Compliance, Accountability, and the Path Forward

When it comes to corporate accountability and the often murky waters of compliance, few cases are as illustrative and significant as the ongoing litigation involving Boeing. Since the 737 MAX safety scandal erupted in 2021,...more

The Volkov Law Group

Boeing’s Failure to Integrate Compliance Anti-Fraud Controls with Quality and Safety Functions (Part III of III)

The Volkov Law Group on

Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...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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