News & Analysis as of

Chief Compliance Officers Ethics Federal Sentencing Guidelines

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

The Volkov Law Group

Ethics and Compliance Trends and Predictions for 2020

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2019 was a big year for ethics and compliance.  In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more

The Volkov Law Group

Unpacking the Justice Department’s Compliance Remediation Standards (Part I of II)

The Volkov Law Group on

The Justice Department has a lot to be proud about when it comes to its FCPA enforcement program. In one area in particular – promoting effective ethics and compliance strategies – DOJ’s FCPA prosecutors have played a...more

The Volkov Law Group

Shortchanging the Compliance Function

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A company that does not back up its words with deeds is doomed to suffer compliance and cultural breakdowns. When a company commits to building a culture of trust and integrity, the company has to keep its word. This is not a...more

Thomas Fox - Compliance Evangelist

Hallmark 3 – Oversight, Autonomy and Resources

I. Autonomy - The DOJ has made clear over the years the importance of this hallmark. In the FCPA Guidance it states, “In appraising a compliance program, DOJ and SEC also consider whether a company has assigned...more

The Volkov Law Group

Meaningful Measurement of the Effectiveness of an Ethics and Compliance Program

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Talk is cheap, especially when it comes to ethics and compliance programs. Words are easy but action and commitment is even harder. The compliance industry needs to put more meat on the bones of compliance. It is not enough...more

The Volkov Law Group

The Time is Now to Amend the US Sentencing Guidelines on Corporate Ethics and Compliance Programs

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We all know the importance of the sentencing guidelines and the impact the revisions, especially the 2010 amendments, have had on corporate governance and compliance. The history behind the sentencing guidelines tracks the...more

Thomas Fox - Compliance Evangelist

The All-Star Game and Tone at the Top

Quite simply, any compliance program starts at the top and flows down throughout the company. Before you arrive at tone in the middle and bottom, it must start with a commitment at the top. All regulatory schemes for...more

NAVEX

Real Guidance (Finally) On the Compliance Oversight Role of Boards

NAVEX on

New guidance for boards of directors on what it means to have “reasonable oversight” for the implementation and effectiveness of corporate compliance programs could signal the beginning of a global trend towards more—and more...more

The Volkov Law Group

Designing The Right Structure For Your Compliance And Ethics Program

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People love to make mountains out of mole hills. Or to put in another way (as my daughter might say), “She/he is a drama freak.”...more

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