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Anti-Corruption Department of Justice (DOJ) Corporate Culture

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

Thomas Fox - Compliance Evangelist

Lessons on Incentives and Discipline from Star Trek: Mirror Mirror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...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

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

The Volkov Law Group

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

The Volkov Law Group on

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

Guidepost Solutions LLC

The Sky Will Not Fall with New Justice Department CEO / CCO Certifications; Instead, the Sun Will Shine

Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - James Koukios on the Monaco Speech

In this episode of the FCPA Compliance Report, I am joined by fan-favourite James Koukios, a partner at Morrison and Foerster, and we take a deep dive into the Lisa Monaco speech from October and related remarks from other...more

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

Jenner & Block on

Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

Latham & Watkins LLP

US DOJ Emphasises Importance of Corporate Culture

Latham & Watkins LLP on

UK companies should be aware of the increasing focus on corporate culture by regulators on both sides of the Atlantic. In a recent speech that has garnered significant attention, US Deputy Attorney General Lisa Monaco...more

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...more

American Conference Institute (ACI)

[Virtual Event] Foreign Corrupt Practices Act New York - June 2nd - 3rd, 10:00 am - 4:00 pm EDT

ACI’s New York Conference on Foreign Corrupt Practices Act is returning in a virtual format on June 2 – 3, 2021. Once again, this anti-corruption event will gather the key stakeholders: senior government officials, industry...more

NAVEX

3 Ways to Apply New DOJ Guidance to Antitrust Compliance

NAVEX on

The Justice Department gave compliance officers a significant piece of guidance in June with its latest update to the evaluation of corporate compliance programs. The guidance begs the fundamental question: Is the compliance...more

The Volkov Law Group

Novartis Settles False Claims Act Cases and Pays $729 Million for Domestic Bribery Schemes

The Volkov Law Group on

We have a new poster-child for a defective corporate culture of wrongdoing.  Novartis has joined the exclusive club, along with Siemens, General Motors, Wells Fargo, and others in the misconduct Hall of Fame. ...more

Thomas Fox - Compliance Evangelist

Answering DOJ Questions on Confidential Reporting

What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or...more

The Volkov Law Group

Incident Data and Intra-Company Cooperation

The Volkov Law Group on

The Justice Department “listens and learns” from companies and compliance practitioners.  As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more

Barnea Jaffa Lande & Co.

Compliance and Ethics in Corporations

The United States has been the global leader in the enforcement of anti-bribery and anti-corruption laws for several decades. The Foreign Corrupt Practices Act (FCPA) was enacted in the United States in 1977 in order to...more

Robinson+Cole Manufacturing Law Blog

Department of Justice Expands Guidance on Evaluating Corporate Compliance Programs

Earlier this year, the United States Department of Justice (DOJ) issued new guidance regarding how it evaluates corporate compliance programs in the context of civil and criminal enforcement matters....more

Thomas Fox - Compliance Evangelist

Dedication of the Empire State Building and Benefits of an Effective Compliance Program

Today at the Ethics and Compliance Initiative (ECI) Impact 2019 Conference, Assistant Attorney General Brian Benczkowski delivered the afternoon Keynote Address. He gave some significant comments around the corporate...more

Thomas Fox - Compliance Evangelist

The Increased Importance of Compliance Going Forward

In late November, there were two speeches by Department of Justice (DOJ) officials which directly impacted corporate compliance programs going forward. They were a speech by Principal Deputy Assistant Attorney General John P....more

Mitratech Holdings, Inc

Industry Expert Hui Chen on Ethics & Compliance

As the first-ever Compliance Counsel Expert at the United States Department of Justice (DOJ), Hui Chen served as exclusive consultant to the Fraud Section’s white-collar crime federal prosecutors. She reviewed corporate...more

Thomas Fox - Compliance Evangelist

10 Hallmarks of an Effective Compliance Program - #3 CCO Authority & Compliance Function Resources

Episode Three of a ten-part series for compliance professionals. In this new series of audio white papers, Thomas Fox looks at the 10 Hallmarks of an Effective Compliance Program. In this audio white paper, a focus on Chief...more

Thomas Fox - Compliance Evangelist

Use of Social Media In a Best Practices Compliance Program

Why should you integrate social media into your compliance program? In a compliance program, a large portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the...more

Thomas Fox - Compliance Evangelist

The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal...more

Thomas Fox - Compliance Evangelist

Evolving Best Practices in FCPA Compliance Training

As Houston, TX, is the epicenter of Foreign Corrupt Practices Act (FCPA) enforcement, most energy companies in my hometown have mature compliance programs or at least more mature than in other industries, which have not gone...more

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