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Foreign Corrupt Practices Act (FCPA) Monaco Memo

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

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 6, Clawbacks and Holdbacks

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Goodwin

DOJ Announces Nationwide Voluntary Corporate Self-Disclosure Policy in Effort to Standardize and Incentivize Timely Self-Reporting

Goodwin on

On February 22, 2023, the US Department of Justice (DOJ) announced a Voluntary Self-Disclosure Policy (VSD Policy) to formalize DOJ’s efforts to incentivize companies to voluntarily self-report criminal misconduct to the...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - Tom Fox and Mike Volkov with the 2022 Year in Review for the FCPA, Part 2

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this special episode, I am joined by Mike Volkov, founder of the Volkov Law Group, and conclude with Part 2, looking back on...more

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

Womble Bond Dickinson on

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

Thomas Fox - Compliance Evangelist

Monaco Memo – A Jolt for Compliance: Part 5 – The Heat is On for Compliance

Today, we conclude our exploration of the Monaco Memo by considering what all this may mean for compliance professional going forward. Department of Justice (DOJ) officials have emphasized that the changes laid out in the...more

Thomas Fox - Compliance Evangelist

Monaco Memo – A Jolt for Compliance: Part 4 – New Factors in Selecting Monitors

Today, we continue our exploration of the Monaco Memo by considering the sections relating to the evaluation of cooperation during the pendency of the investigation and the evaluation of a company’s compliance program at the...more

Thomas Fox - Compliance Evangelist

Monaco Memo: A Jolt for Compliance: Part 3 – Cooperation and Compliance Program Evaluation

Today, we continue our exploration of the Monaco Memo by considering the sections relating to the evaluation of cooperation during the pendency of the investigation and the evaluation of a company’s compliance program at the...more

Thomas Fox - Compliance Evangelist

Monaco Memo and Polite Speech – A Jolt for Compliance: Part 2 – Swiftly and Without Delay

Today, we continue our exploration of the Monaco Memo by considering the section entitled “Timely Disclosures and Prioritization of Individual Investigations”. This portion of the Monaco Memo re-emphasized the reinstitution...more

Thomas Fox - Compliance Evangelist

Monaco Memo and Polite Speech – A Jolt for Compliance: Part 1 – Introduction

Last seek saw the announcement of two significant and related releases of information from the Department of Justice (DOJ) around Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. They were...more

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