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Department of Justice (DOJ) Penalties Compliance

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...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

Dunlap Bennett & Ludwig PLLC

Can You Prove It? Evidence Of Compliance Is Critical For Government Contractors

The Department of Justice has been clamping down on false certifications in the System for Award Management (“SAM”), in government contracts, and on invoice submissions. New laws are being created, new frameworks are being...more

Woods Rogers

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

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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

The Gunvor FCPA Enforcement Action: Part 2 – The Bribery Schemes

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

Adams and Reese LLP

Beyond Borders: Navigating Global Business Compliance with the FCPA

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On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more

Harris Beach PLLC

False Claims Act Enforcement Highlights Need for Robust Compliance Programs

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The U.S. Department of Justice (“DOJ”) announced its False Claims Act (“FCA”) enforcement statistics for FY 2023 and identified key priorities for FCA enforcement in 2024 and beyond. The DOJ continues to pursue FCA...more

Venable LLP

Executive Order to Prevent Access to Americans' Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern

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On February 28, 2024, the Biden Administration issued Executive Order (EO) 13873, focused on restricting certain transactions involving Americans' personal data, as well as sensitive government data, to specific countries....more

Mintz - Technology, Communications & Media...

Telephone and Texting Compliance News: Regulatory Update — Senate Holds Hearing on “Protecting Americans from Robocalls”; Senators...

The US Senate Commerce, Science, and Transportation Committee’s Subcommittee on Communications, Media, and Broadband (“Subcommittee”) held a hearing on “Protecting Americans from Robocalls.” Testifying before the Subcommittee...more

NAVEX

The Subtle but Significant Shift at U.S. Justice Department

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In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more

WilmerHale

Breaking With Precedent - New Guidance on Future CFTC Enforcement Resolutions

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The Commodity Futures Trading Commission (CFTC) Division of Enforcement recently released a new advisory to its staff related to penalties, corporate compliance monitors and consultants, and admissions in CFTC enforcement...more

Health Care Compliance Association (HCCA)

DOJ: Stanford FCA Case Involved Failures to Disclose Foreign Support From Seven Countries

Report on Research Compliance 20, no. 11 (November, 2023) It wasn't just China. China is among the countries whose support for Stanford University investigators wasn’t reported to five federal research funding agencies,...more

Bradley Arant Boult Cummings LLP

Cybersecurity Compliance Issues with Verizon FCA Settlement Provides Helpful Suggestions on How to Reduce Liabilities or Mitigate...

Unfortunately, but as predicted earlier this year, the Department of Justice (DOJ) has shown no signs of pausing use of the False Claims Act (FCA) as a tool to enforce cybersecurity compliance. On September 5, 2023, DOJ...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 1 – Background

Last week, Albemarle Corporation (Albemarle), a publicly traded specialty chemicals manufacturing company headquartered in North Carolina, agreed to pay more than $218 million to resolve investigations by the U.S. Department...more

The Volkov Law Group

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

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Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

ArentFox Schiff

Investigations Newsletter: Arkansas Men Convicted in $18 Million Global Investment Fraud Conspiracy

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Arkansas Men Convicted in $18 Million Global Investment Fraud Conspiracy - A federal jury in the Western District of Arkansas convicted four men of conspiracy to commit wire fraud, wire fraud, and conspiracy to commit money...more

Bradley Arant Boult Cummings LLP

Does the End Justify the Means? Privacy Advocates React to the Cooper Davis Act

This summer, a proposed amendment to the Controlled Substances Act known as the Cooper Davis Act (the “Act”) is making its way through congressional approvals and causing growing dissension between and among parents, consumer...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - August 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Davis Wright Tremaine LLP

California Proposes Website Accessibility Law with Significant Compliance Obligations and Liability Risks Nationwide

On June 12, 2023, the California Assembly's Judiciary Committee replaced the full contents of AB 1757 (a bill originally addressing court consolidation) with new legislative language featuring heightened standards for...more

Foley & Lardner LLP

Ensuring Child Labor Law Compliance Amid Growing Scrutiny

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In February, the New York Times published an investigative report regarding alleged employment of underage migrants, many from Central America, at U.S. companies. While employment of certain minors is permitted under federal...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

The Volkov Law Group

How to Build a Compliance Compensation System (Part I of II)

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The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management.  The theoretical...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Anti-Corruption

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The international trade and regulatory environment never has been more difficult for multinational corporations to navigate. For companies that operate, source from, or sell goods, software, or services across borders, legal...more

Guidepost Solutions LLC

Compliance Experts Discuss Off-Channel Communications and Mobile Surveillance Policies

Roundtable Discussion: Off-Channel Communications and Mobile Surveillance Policies - Surveillance, monitoring, escalation, and reporting are critical components to regulatory compliance and risk management. So is...more

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