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Department of Justice (DOJ) Corporate Governance Ethics

Thomas Fox - Compliance Evangelist

Internal Reporting and Investigative Lessons from Star Trek: The Conscience of the King

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

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

Thomas Fox - Compliance Evangelist

Culture Week: Part 1- Redesigning Culture

In the FCPA Compliance and Ethics Blog this week, I will explore corporate culture from various angles. Since at least October 2021, the Department of Justice (DOJ) has made corporate culture part of its review for any...more

Thomas Fox - Compliance Evangelist

Auditing Culture

Why should you audit your culture? In doing so, a compliance professional can utilize a comprehensive approach designed to evaluate various aspects of a company’s culture, including ethics, engagement, accountability, and...more

The Volkov Law Group

Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks

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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

Vinson & Elkins LLP

[Hybrid Event] Third Annual Navigating the Annual Meeting and Reporting Season Program - November 16th, Houston, TX

Vinson & Elkins LLP on

In this program, we will focus on SEC developments affecting, and practical aspects of preparing for, public companies’ annual meetings and annual reports, including compensation, shareholder proposals and corporate...more

The Volkov Law Group

A Five Step Program for Every Company to Address the New Enforcement Threats

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Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - June 28th, 8:25 am - 4:30 pm CT

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

The Volkov Law Group

Promoting Your Corporate Culture – Accountability and Messaging (Part II of III)

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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

The Volkov Law Group

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

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The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s...more

Skadden, Arps, Slate, Meagher & Flom LLP

Variable Remuneration and Ethical Behavior: A Toolkit for Companies

Governmental authorities in the U.K. and the U.S. want companies to align employment incentives with ethical conduct. In 2022, the U.K. government undertook a consultation on this topic and in May 2022 published a paper —...more

Sheppard Mullin Richter & Hampton LLP

Organizational Integrity Shorts: Ethics & Compliance Program Funding

Welcome back to the seventh edition of OIG Shorts, a publication of the Sheppard Mullin Organizational Integrity Group. Today’s discussion focuses on the thorny issue of Ethics & Compliance (E&C) program funding. Arguing...more

StoneTurn

5 Tips For Meeting DOJ’s New CCO Certification Requirements

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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

Sheppard Mullin Richter & Hampton LLP

Organizational Integrity Shorts: Everyone Benefits When An Ethics & Compliance Program Is Integrated Throughout An Organization -...

Welcome back to our second installment of OIG Shorts. In this post, we focus on the difference between Checking Boxes and Solving Problems from an Ethics & Compliance (E&C) perspective. We all know what attributes an E&C...more

The Volkov Law Group

DOJ Imposes New Standards for Evaluation of Corporate Compliance Programs: Compensations Structures that Promote Compliance (Part...

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The Monaco Memo is a watershed moment as part of DOJ’s evolution and advocacy for effective ethics and compliance programs.  We have seen prior moments of significant action — DOJ’s adoption of the FCPA Guidance, DOJ’s...more

The Volkov Law Group

Where Does Your Compliance Program and CCO Fall Under DOJ’s Independence, Authority and Resources Test? (Part IV of IV)

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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

The Volkov Law Group

The Effective CCO: Independence, Authority and Resources (Part III of IV)

The Volkov Law Group on

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

Health Care Compliance Association (HCCA)

Building better culture and compliance with trust

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

StoneTurn

Beyond Whistleblowing: Five Steps to Establish an Effective Speak-Up Program

StoneTurn on

"Whistleblowing," a fundamental component of any compliance program, refers to specific allegations of misconduct raised typically through an anonymous hotline or similar mechanism. "Speak-Up" is broader and refers to a...more

Torres Trade Law, PLLC

Department of Justice Monitorships: They’re Costly, They’re Disruptive, and They’re Making a Comeback

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On October 28, 2021, Deputy Attorney General Lisa Monaco addressed the ABA’s National Institute on White Collar Crime, in which she made clear that monitorships are back on the menu as a means of ensuring corporate...more

Thomas Fox - Compliance Evangelist

Not Your Father’s Monitor – Jesse Caplan on Antitrust and Healthcare Compliance

In October, Deputy Attorney General (DAG) Lisa O. Monaco gave a Keynote Address at ABA’s 36th National Institute on White Collar Crime (Monaco Speech). Her remarks reframed a discussion about the uses of, reasons for and...more

Thomas Fox - Compliance Evangelist

Not Your Father’s Monitor – Cristina Revelo, Using Assessments to Drive Compliance

In October, Deputy Attorney General (DAG) Lisa O. Monaco gave a Keynote Address at ABA’s 36th National Institute on White Collar Crime (Monaco Speech). Her remarks reframed a discussion about the uses of, reasons for and...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Philadelphia Regional Compliance & Ethics Conference - December 3rd, 8:25 am - 4:30 pm EST

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

Thomas Fox - Compliance Evangelist

Shaken Not Stirred – Compliance Training From the Movies

Bond, James Bond was the first line uttered by James Bond to Sylvia Trench in the first onscreen introduction of the greatest film spy in “Dr. No”. It was of course Sean Connery as Bond, who recently passed away at 90. They...more

Thomas Fox - Compliance Evangelist

From Risk Assessment to Continuous Improvement

How does your risk assessment lead directly to continuous improvement in a best practices compliance program? I recently visited with John Arendes, Vice President and GM of Global Compliance Solutions at Skillsoft and Stephen...more

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