News & Analysis as of

Department of Justice (DOJ) Cooperative Compliance Regime Compliance

Woods Rogers

Wax On, Wane Not: Corporate Investigations and Enforcement Actions are on the Rise at DOJ

Woods Rogers on

Every national election cycle, we are reminded that presidential administrations drive the trajectory of white-collar civil and criminal enforcement priorities. Halfway through President Biden’s first term, in 2022, Attorney...more

Thomas Fox - Compliance Evangelist

Using a Root Cause Analysis for Remediation

The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively...more

J.S. Held

Building a Strong Compliance Program That Meets the Revised DOJ Corporate Enforcement Policy

J.S. Held on

A corporate compliance program can be thought of as a magnet that brings a company’s compliance efforts together. It is an operational program, not simply a code of expected ethical behavior. An effective compliance...more

The Volkov Law Group

DOJ Issues Revised Corporate Compliance Guidance: Consequence Management, Clawbacks and Human Resource Cooperation (Part I of III)

The Volkov Law Group on

The Justice Department is rapidly pushing corporations to a new level of compliance.  We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs.  It would be a...more

Robinson & Cole LLP

DOJ Announces Significant Corporate Compliance Initiatives

Robinson & Cole LLP on

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

The Volkov Law Group

DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)

The Volkov Law Group on

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement...more

The Volkov Law Group

DOJ Compliance Program Certification Requirements (Part I of III)

The Volkov Law Group on

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action.  DOJ has adopted this new requirement to...more

Mitratech Holdings, Inc

COVID Risk Events and DOJ Compliance Expectations

To say it’s a challenge might be an understatement: Many managers are wondering to what extent their regulators will allow them to modify compliance standards during COVID-19....more

Thomas Fox - Compliance Evangelist

2020 Update Review: Part 1 – Key Themes

Late Monday, the Department of Justice (DOJ) without fanfare, released an update to its 2019 Evaluation of Corporate Compliance Programs, the 2019 Guidance. ...more

The Volkov Law Group

Ethics and Compliance Trends and Predictions for 2020

The Volkov Law Group on

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

Troutman Pepper

New DOJ Guidance Instructs Corporations on Hallmarks of an Effective Compliance Program

Troutman Pepper on

On April 30, the Criminal Division of the Department of Justice released an update to the Fraud Section’s February 2017 guidance document titled “Evaluation of Corporate Compliance Programs.” ...more

Bricker Graydon LLP

DOJ updates guidance on evaluating the effectiveness of corporate compliance programs

Bricker Graydon LLP on

On April 30, 2019, the U.S. Department of Justice (DOJ) released updated guidance detailing how prosecutors will evaluate corporate compliance programs in charging and resolving criminal cases....more

Littler

Department of Justice Releases Guidelines for Effective Corporate Compliance Programs

Littler on

On May 1, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) released updated guidance for prosecutors to utilize in assessing whether an organization had in place “an adequate and effective corporate...more

Alston & Bird

DOJ Updates Guidance on Evaluating Corporate Compliance Programs

Alston & Bird on

The Department of Justice Criminal Division revised and shuffled two-year-old guidance to help prosecutors evaluate corporate compliance policies when making charging decisions. Our White Collar, Government & Internal...more

K&L Gates LLP

The Benczkowski Memorandum: DOJ’s New Guidance on Corporate Monitors

K&L Gates LLP on

On October 12, 2018, Assistant Attorney General Brian A. Benczkowski announced the publication of a new U.S. Department of Justice (“DOJ”) memorandum regarding the selection of corporate monitors in Criminal Division matters...more

Alston & Bird

DOJ Releases Guidance on Compliance Programs

Alston & Bird on

In February 2017, the Fraud Section of the Department of Justice’s Criminal Division published guidance on how it assesses corporate compliance programs. This is the first formal guidance issued by the Fraud Section under the...more

The Volkov Law Group

Lessons Learned and Compliance Trends from the VW and Takata Scandals (Part III of III)

The Volkov Law Group on

When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more

Thomas Fox - Compliance Evangelist

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

Thomas Fox - Compliance Evangelist

When the Compliance Counsel Speaks, CCOs Should Listen

I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more

Thomas Fox - Compliance Evangelist

Tangled Up in Blue and Rethinking the Role of the Compliance Professional

Today, I conclude my tribute to Bob Dylan-Nobel Laureate, by discussing my personal favorite Bob Dylan song, Tangled up in Blue. The time shifts and jumps in the song have always resonated with me. Indeed, it is one of the...more

The Volkov Law Group

The Real Value of Lawyers to Compliance

The Volkov Law Group on

The legal profession is transforming itself, especially in the area of compliance. Lawyers are an invaluable part of a compliance program. They provide important perspective and understanding of risk, they help a company to...more

Thomas Fox - Compliance Evangelist

Innovation in Compliance Week- Part IV: Innovation Through Continuous Improvement

What is the intersection of innovation in your compliance program and the requirements of an effective compliance program? I find the answer to be found in Hallmark 10 of the Ten Hallmarks of an Effective Compliance Program...more

Thomas Fox - Compliance Evangelist

Compliance Training, Part I

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

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