Episode 335 -- The New DOJ Whistleblower Program
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The Justice Insiders Podcast: DOJ’s Cacophony of Whistles
Understanding the Whistleblower Pilot Program in the Southern District of New York
What's Going on with FCPA?
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Encouraging and Managing Employee Self-Reporting
Compliant Business Communications Through Messaging Apps
Corruption, Crime, and Compliance - DOJ’s Compliance Frontier: Incentives and Disincentives
Internal Investigations for Nonprofits: A Means of Identifying and Addressing Misconduct Before the Regulators Come Calling
FCPA Compliance Report - Matt Galvin and Dan Kahn, Part 2 - Reflections on the Monaco Speech
Digging Deeper Episode 10: Misguided or Misconduct? Understanding Bad Behavior in the Corporate World
Compliance Perspectives: The German Corporate Sanctions Act
KT Sound Bytes Episode 1 | The Effects of the Supreme Court Decision in Liu v. SEC
Fraud and Abuse Enforcement Priorities in the Wake of COVID-19 - Diagnosing Health Care Podcast
Compliance Perspectives: The Compliance Law Track at the 2020 Virtual Compliance and Ethics Institute
Compliance Perspectives: The Right Kind of Wrong
Compliance Perspectives: Compliance Lessons from Theranos
Days to a More Effective Compliance Program-Day 22 | Assessing compliance internal controls
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
Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws. Like most cases, I always...more
Ed. Note: This week, leading up to Halloween, I will examine lessons for compliance professionals through the lens of the great Universal Movie Monsters: Frankenstein, Wolfman, Dracula, and The Mummy. Today, we use Lon...more
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
On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced much-anticipated revisions to the US Department of Justice (DOJ)’s Evaluation of Corporate Compliance Programs (Revised ECCP)...more
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
To build a robust ethical culture, ethics and compliance professionals need effective culture assessments to pinpoint vulnerabilities and proactively address them. The U.S. Department of Justice’s (DOJ) update to the...more
Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more
In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more
In a recent episode of the FCPA Compliance Podcast, we discussed the 2024 Ethisphere Ethical Culture Report, “Closing the Speak Up Gap,” with Erica Salmon Byrne. As an expert in ethical culture and a familiar voice to our...more
Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other...more
U.S. Deputy Attorney General Lisa Monaco announced the creation of a new U.S. Department of Justice (DOJ or Department) Whistleblower Rewards Program at the 39th Annual ABA White Collar National Institute in San Francisco...more
At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more
In March 2023 there were two days of speeches from the DOJ which added to the compliance complexity. The speeches were made by Deputy Attorney General (DAG) Lisa Monaco (2023 Monaco Speech) and Assistant Attorney General...more
One of the benefits of old(er) age is perspective and experience. (As we age, we have to find the positive reasons to tout). If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more
The Global Business Ethics Survey (GBES) conducted by the Ethics & Compliance Initiative (ECI) provides valuable insights into workplace ethics and compliance from the perspective of employees. I recently had the opportunity...more
It has been a summer of revelations leaving the financial services sector facing uncertainty and increased scrutiny on how allegations of behavioral misconduct might be managed going forward. This came after multiple...more
I recently concluded a podcast series with Case IQ. Over this series, I visited with Sharlyn Lauby, Jakub Ficner, Kenneth McCarthy, and Meric Bloch on the different facets of a great speak-up regime and how each of those...more
Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone. To the contrary, as the business adapts through growth, innovation or in response to outside market and...more
As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture. In these...more
Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more
Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more
The U.S. Department of Justice (DOJ) recently announced several new policies and programs aimed at incentivizing corporate compliance. These programs underscore the need for companies to investigate, mitigate and resolve...more