News & Analysis as of

Chief Compliance Officers Corporate Misconduct New Guidance

Venable LLP

DOJ Revises Its Evaluation of Corporate Compliance Policy to Consider How Companies Address Risks Posed by AI

Venable LLP on

The Department of Justice's Criminal Division is "using more tools than ever before to identify corporate misconduct and to encourage companies to be good corporate citizens," according to Nicole Argentieri, Principal Deputy...more

Society of Corporate Compliance and Ethics...

How a code of conduct reflects culture and meets DOJ requirements

Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it...more

WilmerHale

DOJ Announces Significant Guidance on Compliance, Compensation, Communications and Cooperation

WilmerHale on

On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more

Dechert LLP

Measure Twice, Cut Once: New DOJ Compliance Certifications Put CEOs and CCOs at Risk of Individual Criminal Liability

Dechert LLP on

Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...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

ArentFox Schiff

Justice Department Offers New Antitrust Guidance With Lessons for Nonprofits, Associations, and Other Member-Owned and Operated...

ArentFox Schiff on

When was the last time your organization reviewed its antitrust compliance program? The Antitrust Division of the US Department of Justice announced a new policy to incentivize corporate antitrust compliance programs, which...more

BCLP

FCA Defendants and Counsel Beware: New DOJ Guidance on FCA Cooperation Credit May Leave Too Much to Prosecutors’ Discretion

BCLP on

In recent weeks, the United States Department of Justice (“DOJ”) published guidance in the Justice Manual at Section 4-4.112 on how it will award cooperation credit to entities and individuals that are being investigated for...more

McDermott Will & Emery

International Legal Highlights - July 2019

FCPA UPDATES FOR GLOBAL COMPANIES - In recent months, the US Department of Justice (DOJ) has issued important guidance for global companies on corporate compliance programs and the Foreign Corrupt Practices Act (FCPA)...more

McDermott Will & Emery

DOJ Preserves Its Options in Cooperation Credit Guidance

McDermott Will & Emery on

DOJ recently announced the release of formal guidance on how civil attorneys can award “cooperation credit” to defendants who cooperate with DOJ during a False Claims Act investigation. This formal policy provides some new...more

Akin Gump Strauss Hauer & Feld LLP

DOJ’s New Corporate Compliance Evaluation Guidance

Key Considerations and Updates for Life Sciences Companies - On April 30, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) issued updated guidance for white-collar prosecutors on evaluating the...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Holland & Knight LLP

Department of Justice Issues New Guidance on How It Evaluates Compliance Programs

Holland & Knight LLP on

Last week, the DOJ Criminal Division published a guidance document entitled "Evaluation of Corporate Compliance Programs" (ECCP). This document is meant to assist prosecutors in determining what credit should be given to a...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Implementation, Operationalization and Effectiveness (Part IV of V)

The Volkov Law Group on

While I hate to start out a posting with such “mumbo jumbo” terms, I had to come up with short hand descriptions of some otherwise fairly complex and robust topics under the new DOJ Guidance....more

Holland & Knight LLP

DOJ Issues New Guidance on Necessity and Selection of Corporate Monitors

Holland & Knight LLP on

• Assistant Attorney General Brian A. Benczkowski's recent Memorandum on "Selection of Monitors in Criminal Division Matters" provides new direction to U.S. Department of Justice (DOJ) prosecutors regarding when to require...more

Epstein Becker & Green

DOJ Focuses on Individual Accountability: New Guidance for Corporate Investigations Places Pressure on Companies and Boards to Put...

Epstein Becker & Green on

On September 9, 2015, the Department of Justice (“DOJ”) issued new guidance on individual accountability for corporate wrongdoing. In the memorandum and an accompanying speech by the Deputy Attorney General Sally Q. Yates,...more

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