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Corporate Culture Department of Justice (DOJ) White Collar Crimes

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

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

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

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

The Volkov Law Group

Deep Dive into Proposed Boeing Plea Agreement (Part II of III)

The Volkov Law Group on

DOJ and Boeing have entered into a proposed plea agreement that will require judicial scrutiny and determinations of the public interest and the victims’ rights under the Crime Victims’ Rights Act, 18 U.S.C. § 3771 [“CVRA”]. ...more

Thomas Fox - Compliance Evangelist

The Omnibus Monitor for Boeing: Representing all Stakeholders

In probably a move that will surprise no one, the families of the victims of the two Boeing 737 MAX crashes have objected to the Department of Justice’s (DOJ) announced approach to a monitorship for Boeing. Having been so...more

Thomas Fox - Compliance Evangelist

The DOJ Boeing Conundrum

The Department of Justice (DOJ) is currently in a conundrum over its Deferred Prosecution Agreement (DPA) for the Boeing 737 Max crashes. Understanding the implications of the DOJ’s upcoming decision on whether to prosecute...more

Thomas Fox - Compliance Evangelist

Culture Week: Part 1- Redesigning Culture

In the FCPA Compliance and Ethics Blog this week, I will explore corporate culture from various angles. Since at least October 2021, the Department of Justice (DOJ) has made corporate culture part of its review for any...more

Thomas Fox - Compliance Evangelist

Auditing Culture

Why should you audit your culture? In doing so, a compliance professional can utilize a comprehensive approach designed to evaluate various aspects of a company’s culture, including ethics, engagement, accountability, and...more

Thomas Fox - Compliance Evangelist

Argentieri at ABA White Collar Conference: Compliance Programs, Part 2

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco....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”

BakerHostetler on

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

Latham & Watkins LLP

DOJ Announces New Whistleblower Program

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DOJ unveils a new whistleblower incentive program to complement the Department’s continued efforts to encourage self-reporting of criminal violations. On Thursday, March 7, 2024, US Deputy Attorney General Lisa Monaco...more

Miles & Stockbridge P.C.

DOJ Provides a Contemporary Spin on ‘Wanted’ Posters: New Whistleblower Rewards Program Announced

U.S. Deputy Attorney General Lisa Monaco delivered keynote remarks March 7 at the American Bar Association’s 39th National Institute on White Collar Crime. Emphasizing the need for a culture of compliance, Monaco highlighted...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

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

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 3 – The Comeback

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

The Volkov Law Group

A Five Step Program for Every Company to Address the New Enforcement Threats

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Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized...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

Fisher Phillips

Top 20 Questions to Ensure Your Compliance Program Helps You Minimize Corporate Criminal Risks

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Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more

The Volkov Law Group

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

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The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s...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

The Volkov Law Group

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

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This is not your typical FCPA enforcement action Lessons Learned column.  Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...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

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