Public-Private Partnerships to Stem Corruption
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
INTERPOL Red Notices - do they expire?
The Legal Tightrope: Surviving Parallel Investigations
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Should you try to remove an INTERPOL Red Notice yourself?
Episode 335 -- The New DOJ Whistleblower Program
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
INTERPOL Red Notices and Immigration. Can You Obtain Immigration Relief in the U.S. Even with a Red Notice?
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
The Presumption of Innocence Podcast: Episode 43 - New Horizons: Impact of Recent Appellate Circuit Rulings on White-Collar Criminal Defense Law
INTERPOL and Politically Motivated Red Notices - What We Can Learn from INTERPOL’s Annual Reports.
Episode 333 -- The Boeing Proposed Plea Agreement
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
What to do when finding that you are the subject of a RedNotice?
Episode 324 -- Third-Party Risks and Sanctions Compliance
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
The Justice Department is rapidly pushing corporations to a new level of compliance. We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs. It would be a...more
The U.S. Department of Justice (DOJ) recently announced several new policies and programs aimed at incentivizing corporate compliance. These programs underscore the need for companies to investigate, mitigate and resolve...more
The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers. In Part I of this series, I outlined the specific language and the Plea Agreement...more
To say it’s a challenge might be an understatement: Many managers are wondering to what extent their regulators will allow them to modify compliance standards during COVID-19....more
Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces. I am exaggerating a little bit to make...more
Let’s consider a list of 20 questions to reflect the oversight role of directors. These are questions the Board should ask of both senior management and the Board itself. The questions are not intended to be an exact...more
On April 30, the Criminal Division of the Department of Justice released an update to the Fraud Section’s February 2017 guidance document titled “Evaluation of Corporate Compliance Programs.” ...more
On April 30, 2019, the U.S. Department of Justice (DOJ) released updated guidance detailing how prosecutors will evaluate corporate compliance programs in charging and resolving criminal cases....more
On May 1, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) released updated guidance for prosecutors to utilize in assessing whether an organization had in place “an adequate and effective corporate...more
We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more
Yesterday I introduced, with the help of the Red Baron, the topic of a Compliance Center of Excellence (CCoE). Today I want to expand out into how a Chief Compliance Officer (CCO) or compliance practitioner would design a...more
Global companies face ever-increasing challenges when building and implementing global ethics and compliance programs. From my vantage point, the set of challenges can be different depending on the industry. Global...more
If you do not believe in the compliance regime that you are pushing, it will be nearly impossible for the rest of your far-flung corporate work force to believe in it. Talk about compliance and the positive aspects of your...more
Every Chief Compliance Officer (CCO) and compliance practitioner who thinks about their compliance program one, three or five years down the road is a budding futurist. The Compliance Week 2017 Annual Conference opened this...more
How agile is your compliance program? How does this fit into the operationalization requirement laid out in the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation)? While many have argued...more
When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more
I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more