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Anti-Corruption White Collar Crimes Compliance

Thomas Fox - Compliance Evangelist

Deere’s FCPA Case: Lessons on Gifts, Travel and Entertainment

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

The Volkov Law Group

DOJ Updates Evaluation of Corporate Compliance Programs

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The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs.  As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more

Mayer Brown

DOJ’s Criminal Division Updates Policy on 3 Key Topics: Artificial Intelligence, Whistleblower Programs, and Compliance Program...

Mayer Brown on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri (PDAAG), speaking at the Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute, announced three key updates to...more

Thomas Fox - Compliance Evangelist

The 2024 ECCP: Complying with the 2024 ECCP on Whistleblowers

The Department of Justice (DOJ), in its 2024 Update, has explicitly directed companies to ensure they have robust processes in place to identify, manage, and mitigate emerging risks related to new technologies, including AI....more

Thomas Fox - Compliance Evangelist

The Argentieri Speech: Mid-Point Reflections on the DOJ’s Compensation Clawback Pilot Program

Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. She reiterated the long-stated policy that compliance...more

Thomas Fox - Compliance Evangelist

Argentieri Speech and 2024 ECCP: Whistleblowers and Anti-Retaliation

Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the Department of Justice’s (DOJ) approach to evaluating corporate compliance programs. As outlined in the updated 2024...more

Thomas Fox - Compliance Evangelist

Argentieri Speech and 2024 ECCP: Argentieri on Navigating AI Risks

Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the Department of Justice’s (DOJ) approach to evaluating corporate compliance programs. As outlined in the updated 2024...more

Thomas Fox - Compliance Evangelist

Argentieri Speech and 2024 ECCP: Data Access and Data Analytics

Deputy Assistant Attorney General Nicole M. Argentieri’s speech highlighted a critical shift in the DOJ’s approach to evaluating corporate compliance programs. As outlined in the updated 2024 Evaluation of Corporate...more

The Volkov Law Group

The Compliance “Curse” — Learning to Compromise Principles

The Volkov Law Group on

Compliance lessons are life lessons.  Compliance professionals are, by their nature, optimistic people. They see challenges as new opportunities to strive closer to an ideal.  Compliance professionals live in the shadow of...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

The Volkov Law Group on

While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

Thomas Fox - Compliance Evangelist

CCO Resources, Authority and Expertise Lessons from Star Trek: The Galileo Seven

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. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

Thomas Fox - Compliance Evangelist

The Foreign Corrupt Practices Handbook: Interview with the Authors

I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more

The Volkov Law Group

Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine

The Volkov Law Group on

Listen to this conversation between Michael Volkov and Halyna Senyk in which they focus on Ukraine's anti-corruption efforts amidst the backdrop of its ongoing war with Russia. Halyna Senyk, an expert from the CEELI...more

The Volkov Law Group

European Council Officially Adopts New AML/CFT Package

The Volkov Law Group on

On May 30, 2024, following passage by the European Parliament in late April, the European Council officially adopted a set of rules that modernizes and harmonizes money laundering and terrorist financing (“AML/CFT”)...more

Thomas Fox - Compliance Evangelist

The Intersection of Creativity and Compliance: Lessons from Improv

In the most recent episode of the Creativity and Compliance podcast, Tom Fox and Ronnie Feldman delved into the fascinating intersection of improvisation and compliance with our special guest, Marla Caceres, an expert in...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory

Fox Rothschild LLP on

How can you pinpoint employee behaviors that signal a potential risk of fraud in your company, especially if you operate in a highly regulated industry? Join host Matt Adams for this insightful episode featuring Nicole...more

The Volkov Law Group

The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV)

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It may seem like a Herculean task — but it can be done.  I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks.  One big reason —...more

The Volkov Law Group

Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation

The Volkov Law Group on

NAVEX continues to produce high-quality compliance reports, many of which are a must-read in the compliance industry.  Its annual Whistleblower Report is of particular note -- NAVEX is the leading provider of hotline services...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the...

Fox Rothschild LLP on

In a single decade, the prosecutions of those accused of white-collar crime underwent a radical transformation. This thought-provoking episode will take you back in time to explore the DOJ's approach in the early 2000s Enron...more

Thomas Fox - Compliance Evangelist

The NBA, Data Driven Compliance and Jontay Porter

One of the best examples I have recently seen on the power of data driven compliance is playing out in real time in the NBA. It is the Jontay Porter betting scandal. This event had driven home why transparency, coupled with...more

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

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As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

Benesch

White Collar Quarterly Report | Q1 2024

Benesch on

We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 1 – Introduction

In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more

The Volkov Law Group

LRN 2024 Program Effectiveness Report Underscores Importance of Values, Adaptation and Accountability

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LRN’s latest report was based on a survey of more than 1,400 ethics and compliance professionals, most of whom were employed at organizations with at least 1000 employees in 19 different countries and 26 industries across...more

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