Episode 335 -- The New DOJ Whistleblower Program
Navigating the Labyrinth of Private Equity Investments in Health Care – Diagnosing Health Care
AGG Talks: Women in Tech Law Podcast - Episode 3: Cybersecurity and FCA Compliance: Essential Insights for Tech Leaders
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
#WorkforceWednesday®: New DOJ Whistleblower Program - What Employers Must Know - Employment Law This Week®
The Presumption of Innocence Podcast: Episode 43 - New Horizons: Impact of Recent Appellate Circuit Rulings on White-Collar Criminal Defense Law
Redlining Isn’t What it Used To Be
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
Episode 328 -- Sanctions Enforcement Risks and Redlines
Common Scenarios Triggering False Claims Act Violations, Part 1: Gov. Contracts and Cybersecurity
Cannabis Law Now Podcast: What’s Next for Schedule III Marijuana
Redlining Complications Caused by Implementation of 2020 Census Tracts
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
The Justice Insiders Podcast: DOJ’s Cacophony of Whistles
The Latest on Healthcare Enforcement
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. I decided to write a series...more
Last month, I wrote a blog post on the tone at the top, exemplified in the Star Trek, the Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a...more
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
Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable and to protect the organization from potential private and government claims or investigations that...more
There’s good and bad news out there for compliance departments, and it’s also the same news: Governments now very much appreciate strong compliance programs. On the one hand, that is very good (if not great!) news....more
With any new administration, the U.S. Department of Justice (DOJ) often shifts focus from one set of enforcement priorities to another. However, one area has remained a focus from administration to administration: guidance...more
Just as risk assessment is the bedrock for an effective compliance program, root cause analysis (“RCA”) similarly underpins successful remediation of compliance violations. The DOJ’s March 2023 Evaluation of Corporate...more
For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more
Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more
While the U.S. Department of Justice’s Criminal Division published its fourth version of its “Evaluation of Corporate Compliance Programs (ECCP)” guidance more than six months ago now, the insights that in-house counsel and...more
The Department of Justice has laid down a marker – companies would be smart to understand the significant change in ethics and compliance program expectation. Companies that ignore this new landscape are gambling with their...more
Achieve your ESG goals in 2023 - Environment, Social, and Governance (ESG) is a top priority for organizations of all types and sizes, and it the compliance team is a key factor in the ESG equation. Much like regulatory...more
On January 17, 2023, Assistant Attorney General (AAG) Kenneth Polite, Jr. announced updates to the Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. Since the inception of the FCPA Corporate Enforcement...more
Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more
Each year, NAVEX releases the Top 10 Trends in Risk and Compliance to provide leaders with guidance and insights on where to focus their initiatives and resources. Staying ahead of global trends in risk and compliance has...more
As 2022 comes to a close, now is an ideal time to reflect on the developments and challenges this year held for the risk and compliance profession – and there was no shortage of either. The complexity of maintaining...more
The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more
On September 28, 2022, the Assistant Attorney General for the Criminal Division of the United States Department of Justice (DOJ) joined the Inspector General for the United States Department of Health and Human Services...more
As it continues its focus not just on enforcement, but on compliance, members of the U.S. Department of Justice have foreshadowed a sea change for Chief Executive Officers and Chief Compliance Officers in corporate...more
As we enjoy the remainder of the summer and get ready to launch into a new fall season (no, not football) but a time for renewal and recommitment, this may be a good opportunity to examine and analyze your own compliance...more
As Supreme Court Justice Potter Stewart eloquently opined in Jacobellis v. Ohio (1964), on the legal definition of obscenity, “I know it when I see it.” This same test applies to other issues as well — when it comes to an...more
Ethikos newsletter (July – Sept 2022) - Effective compliance and ethics programs have become goals of companies and organizations worldwide. Reaching this objective is possible, but it cannot be achieved without a culture...more
Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more
CCOs, by definition, are careful and deliberate. It comes with the profession. As risk managers, CCOs are skilled in identifying, assessing and acting in a risk environment....more
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