FCPA Compliance Report - Eric Young on the Evolution of the CCO
FCPA Compliance Report - Tom Fox and Mike Volkov with the 2022 Year in Review for the FCPA, Part 2
FCPA Compliance Report - Scott Garland and Zach Hafer - Practice After the DOJ
The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more
On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more
How do enforcement priorities impact your compliance program? Supply chains, tech tools, consumer data, the use of sanctions, the list is long — there are a vast number of organizational processes and procedures under...more
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
Earlier this month, at the American Bar Association’s (ABA) 38th National Institute on White Collar Crime, Deputy Attorney General Lisa O. Monaco and Assistant Attorney General Kenneth A. Polite, Jr. highlighted the...more
In back-to-back speeches to the American Bar Association's National Institute on White Collar Crime on March 2-3, 2023, U.S. Department of Justice (DOJ) Deputy Attorney General Lisa O. Monaco and Assistant Attorney General...more
As part of a recent series of announcements regarding updates to its corporate compliance policies, the Department of Justice (DOJ) announced significant revisions to its evaluation criteria for corporate compliance programs,...more
Monaco’s and Polite’s remarks, and the DOJ’s new policies and guidance, come amid the Department’s increasingly tough on corporate crime approach and emphasis on rewarding companies that have effective compliance programs...more
On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...more
On Wednesday, February 22, 2023, the Department of Justice (“DOJ”) released a new nationwide voluntary self-disclosure policy for corporate criminal enforcement. The policy codifies previous corporate enforcement guidance...more
On February 22, 2023, the US Department of Justice (DOJ) announced a Voluntary Self-Disclosure Policy (VSD Policy) to formalize DOJ’s efforts to incentivize companies to voluntarily self-report criminal misconduct to the...more
On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more
The U.S. Attorney's Offices (USAOs) Voluntary Self-Disclosure Policy, announced on Feb. 22, 2023, sets forth a nationwide standard for how USAOs will define and credit corporate self-disclosures of misconduct by employees or...more
On February 22, 2023, the Department of Justice (DOJ) issued a Voluntary Self-Disclosure Policy (VSDP) which, effective immediately, applies to all U.S. Attorneys’ Offices (USAOs) nationwide with respect to corporate criminal...more
The Monaco memo’s imposition of CCO certification in DOJ investigations has, reasonably, been a major anxiety-inducer for compliance professionals. And while DOJ officials have said the requirement is designed to “empower”...more
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this special episode, I am joined by Eric Young from Guidepost Solutions. Young has worked at prestigious institutions like...more
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this special episode, I am joined by Mike Volkov, founder of the Volkov Law Group, and conclude with Part 2, looking back on...more
Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more
Welcome to the award-winning FCPA Compliance Report, the most senior podcast in compliance. I have double trouble in this episode as I welcome Scott Garland and Zach Hafer, who worked together for many years at the US...more
On September 15, 2022, Deputy Attorney General Lisa Monaco released a memorandum titled “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group,” known...more
On September 9, 2015, then U.S. Deputy Attorney General Sally Quillian Yates issued a memo, “Individual Accountability for Corporate Wrongdoing,” that sent shivers down the spines of those in the workplace safety community....more
Welcome to a special five-part podcast series, entitled Corporate Case Management in the Era of the DoJ’s Monaco Memo, sponsored by i-Sight Software Solutions (i-Sight). Over this series, Jakub Ficner, Director of Partnership...more
The Department of Justice (DOJ) recently recently made revisions to its corporate criminal enforcement policies that provide useful insights to corporations and their executives regarding establishing policies and procedures...more
Last week, the United States Securities and Exchange Commission (SEC) fined 16 Wall Street firms a total of $1.1 billion for recordkeeping violations based on the failure to maintain employees’ electronic communications, such...more