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Episode 89 -- DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
It has now been over a year since the updated Enforcement Guidelines: Economic Substance (the “Guidelines”) were issued on 31 March 2023, outlining the enforcement powers and processes of the Cayman Islands Tax Information...more
The emerging risks in the financial services market and the inception of the Regulation of Payment Services and Payment Initiation Law prompted the Capital Market, Insurance and Savings Authority (CMISA) to amend a series of...more
The Guidelines build on current social, environmental, and technological issues facing businesses following the last update in 2011. The Organisation for Economic Co-operation and Development (OECD) released updated...more
All companies—big and small—are collecting a tsunami of data. The US Department of Justice (DOJ) has now challenged corporate America to harness and analyze that data to improve corporate compliance programs by going beyond...more
Our Virtual Regional Healthcare Compliance Conferences provide updates on the latest news in regulatory requirement, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask...more
Recently, the Department of Justice (DOJ) updated its “Evaluation of Corporate Compliance Programs” guidance — the third iteration of DOJ’s guidance on this topic. The update is intended to offer transparency as to how DOJ...more
I recently had the opportunity to visit with Stephen Martin, Partner at StoneTurn, to consider some of the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ)...more
In June, the Department of Justice (DOJ) published an Update to their Evaluation of Corporate Compliance Programs (2020 Update) which set out to provide additional clarity on how enforcement officials will evaluate an...more
CEP Magazine (August 2020) - In June, the Department of Justice made small changes to the Evaluation of Corporate Compliance Programs guidance document that reflect the department’s growing understanding of how compliance...more
In June, the U.S. Department of Justice updated its Evaluation of Corporate Compliance Programs Guidance (“Guidance”). While the Guidance is intended to assist prosecutors by providing factors to consider in evaluating the...more
Earlier this month, the Criminal Division of the United States Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. In considering enforcement actions against companies, prosecutors...more
The Department of Justice issued additional clarification and revised guidance on June 1, 2020, for corporate program compliance programs. The additional guidance doesn’t introduce substantive changes; however, it emphasizes...more
When the Department of Justice takes aim at a corporation, the effectiveness of the corporation’s compliance program at the time of corporate wrongdoing and afterwards can be key to federal prosecutors’ decision-making. ...more
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
Companies must now address three questions proactively. On April 30, 2019, the DOJ’s Criminal Division issued updated guidance on how it will evaluate corporate compliance programs in its charging decisions going forward....more
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas.[i] In issuing the new document...more
When the SEC adopted Rules 38a-1 under the Investment Company Act of 1940 (Investment Company Act) and 206(4)-7 under the Investment Advisers Act of 1940 (Advisers Act) in 2003 – which required registered funds and registered...more