News & Analysis as of

Remediation Compliance

Bradley Arant Boult Cummings LLP

TD Bank’s Historic $3.1B Money Laundering Settlement a Warning to All Financial Institutions

On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more

Thomas Fox - Compliance Evangelist

Deere’s FCPA Enforcement Action: Performing a Root Cause Analysis to Inform Remediation

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Thomas Fox - Compliance Evangelist

Argentieri Speech: 6 Key Takeaways for the Compliance Programs

On Monday, Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. ( A copy of her remarks can be found here.) She...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Fundamentals of Compliance Investigations - December 16th - 17th, 8:00 am - 5:00 pm CT

Handle investigations with confidence - Effective compliance programs rely on effective investigators to follow up on reports and identify potential gaps that need attention. If you are a new or future investigator or are...more

The Volkov Law Group

SEC Outlines “Effective Cooperation” Standard

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The Securities and Exchange Commission is catching up to DOJ.  Not in enforcement but in transparency. After years of criticism, the Justice Department has set the gold standard for transparency and providing guidance on...more

Nilan Johnson Lewis PA

PFAS Reporting Requirements at the Federal and State Level – How Will Manufacturers Respond? – Part 4 of 10

Part 4. PFAS Reporting Requirements at the Federal and State Level – How Will Manufacturers Respond? Per- and polyfluoroalkyl substances, known by the acronym PFAS and better known by the moniker “forever chemicals,” are...more

Royer Cooper Cohen Braunfeld LLC

Is Your Compliance Program Active or Passive? It Matters.

The SEC's Director of the Division of Enforcement, Gurbir S. Grewal, outlined five principles of effective cooperation with the SEC during his keynote address at the Securities Enforcement Forum West 2024 conference...more

Holland & Knight LLP

Collaboration Station: Director Grewal Touts Benefits and Efficiency of Cooperation

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In recent remarks at the Securities Enforcement Forum West 2024, U.S. Securities and Exchange Commission (SEC) Director of the Division of Enforcement Gurbir Grewal extolled the benefits of and expounded on the elements of...more

Health Care Compliance Association (HCCA)

Explore the how and the why

Anytime a compliance violation occurs—or even a breakdown in compliance controls that doesn’t ultimately result in noncompliance—the remediation process takes center stage. And this is where questions of how and why are...more

Ankura

When the Stakes Are High: Managing a Crisis-Led Investigation From Incident to Remediation

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1 75 An investigative journalist implicates the company. An auditor threatens to resign. Premises are raided by enforcement agencies. Not all investigations are created equal and in a recent talk given at the General Counsel...more

Farella Braun + Martel LLP

California’s Estrada Decision and Impact on Employers and PAGA Claims

Following Estrada v. Royalty Carpet Mills, Inc., the California Supreme Court’s employee-friendly Private Attorneys General Act (PAGA) ruling earlier this year, employers must remain more diligent than ever to prevent and...more

Guidepost Solutions LLC

3 Key Factors in Safeguarding National Security: Economic Sanctions, Voluntary Self-Disclosures, and Whistleblower Retaliation

Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more

Holland & Knight LLP

New York State Issues Updated Soil Vapor Intrusion Guidance

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The New York State Department of Health (NYSDOH) in late February 2024 announced an update to its Guidance for Evaluating Soil Vapor Intrusion in the State of New York. For the first time, the Soil Vapor/Indoor Air Decision...more

Bradley Arant Boult Cummings LLP

Fannie Mae Issues Fair Servicing Best Practices Guide

This week, in line with the CFPB’s ever-increasing focus on fair lending, Fannie Mae issued a Fair Servicing Best Practices Guide to promote “servicer awareness of fair servicing best practices.” Taking a big picture...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 3, Extensive Remediation

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

Society of Corporate Compliance and Ethics...

[Virtual Event] Fundamentals of Compliance Investigations - May 1st - 2nd, 10:00 am - 2:00 pm CT

Handle investigations with confidence - Effective compliance programs rely on effective investigators to follow up on reports and identify potential gaps that need attention. If you are a new or future investigator or are...more

Thomas Fox - Compliance Evangelist

Using a Root Cause Analysis for Remediation

The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively...more

Guidepost Solutions LLC

DOJ Maintains Interest in Bribery in Mexico and Latin America

Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there.  By following the roadmap, companies may escape...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

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This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Paul Hastings LLP

More Clarity on the Horizon for FCPA Resolutions? DOJ and SEC Officials Discuss Enforcement Trends

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On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more

White & Case LLP

A View from Abroad: Unpacking DOJ’s M&A Safe Harbor Policy, Part II

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On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more

Ankura

U.S. DOJ’s New Safe Harbor Policy: Conducting Enhanced M&A Due Diligence

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Last month, U.S. Deputy Attorney General Lisa O. Monaco announced a new Safe Harbor Policy for voluntary self-disclosure (the “Policy”) made in connection with merger and acquisition activity. The Policy is intended to bring...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance Risk Assessment and Management - December 12th - 13th, 9:00 am - 3:15 pm CT

Do you want to learn valuable strategies for identifying and mitigating risk in your organization? This virtual workshop will give you a comprehensive look at how to perform better compliance risk assessments — an...more

Holland & Knight LLP

Understanding the Department of Justice's New Safe Harbor Policy

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Continuing its focus on incentivizing prompt and voluntary self-disclosure of criminal misconduct, Deputy Attorney General Lisa Monaco announced earlier this month a new U.S. Department of Justice (DOJ) Safe Harbor Policy...more

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