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White Collar Crimes Compliance Department of Justice (DOJ)

Thomas Fox - Compliance Evangelist

10 Compliance Lessons Learned from the Telefónica Venezolana FCPA Enforcement Action

Last week, the Department of Justice (DOJ) announced a resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefónica Venezolana, the Venezuelan subsidiary of Telefónica S.A. (Telefónica)...more

Thomas Fox - Compliance Evangelist

Why Data-Driven Culture is the Future of Compliance

The DOJ’s message from the 2024 ECCP is clear: if companies want to maintain credibility, mitigate risks, and avoid scrutiny, they must embrace data analytics to support and document their compliance efforts. This evolution...more

Thomas Fox - Compliance Evangelist

Why the 2024 ECCP Update is a Game-Changer for Compliance

In the DOJ’s 2024 update to the Evaluation of Corporate Compliance Programs (2024 ECCP), compliance professionals face new expectations that could reshape how we approach compliance programs. In this latest update, the DOJ...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments – Q3 2024

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On August 1, 2024, the Department of Justice (DOJ) launched its Corporate Whistleblower Awards Pilot Program, first announced earlier this year. Through the pilot program, the DOJ may issue awards to whistleblowers who...more

Thomas Fox - Compliance Evangelist

Navigating Compliance in Interesting Times

I once had a boss whose catchphrase was ‘May you live in interesting times’. That applied back in the first decade of this century and I think it is even more appropriate now. In a world that often feels as if it is...more

Fenwick & West LLP

Don’t Wait for the DOJ to Come Knocking: Important Whistleblower Protection and AI Risk Management Updates

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In September 2024, the DOJ’s Criminal Division released an updated Evaluation of Corporate Compliance Programs (ECCP) guidance document to address emerging risks. The ECCP serves as a roadmap for how DOJ evaluates a company’s...more

The Volkov Law Group

SEC Settles FCPA Case with Moog, Inc. for Nearly $1.7 Million

The Volkov Law Group on

The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases. In the meantime, the Justice Department has been silent in the FCPA enforcement arena. In its latest settlement, Moog,...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 5- The Reckoning

Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more

The Volkov Law Group

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

The Volkov Law Group on

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger

Fox Rothschild LLP on

Recorded at our 2024 White-Collar Symposium held in Philadelphia last month, this special episode dives into the landscape of white-collar criminal prosecution from the perspectives of Bill Baroni and Jesse Eisinger. Both...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 1-Money Laundering and the China Syndrome

Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

The Volkov Law Group

Episode 340: DOJ Updates Evaluation of Corporate Compliance Programs

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How prepared is your company to handle the evolving risks of artificial intelligence and other emerging technologies in its compliance program? In this episode of Corruption, Crime and Compliance, Michael Volkov delves into...more

Wiley Rein LLP

Navigating Compliance in Government Contracts: Insights from SEC and DOJ Perspectives

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In this episode of Wiley's Government Contracts Podcast, Kevin Muhlendorf, a partner in Wiley’s White Collar and Defense & Government Investigations practice, discusses the critical intersection of compliance in government...more

Thomas Fox - Compliance Evangelist

Deere’s FCPA Case: Lessons on Gifts, Travel and Entertainment

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

The Volkov Law Group

Episode 339: Four Sanctions Cases Everyone Should Know

The Volkov Law Group on

How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more

The Volkov Law Group

DOJ Updates Evaluation of Corporate Compliance Programs

The Volkov Law Group on

The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs.  As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more

DLA Piper

DOJ's Revised ECCP Signals Expectations of a Data-driven Compliance Program

DLA Piper on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced much-anticipated revisions to the US Department of Justice (DOJ)’s Evaluation of Corporate Compliance Programs (Revised ECCP)...more

Wilson Sonsini Goodrich & Rosati

DOJ Raises Expectations on AI, Data Analytics, and More in New Guidance on Corporate Compliance

On September 23, 2024, the Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs policy (ECCP), which outlines the key factors prosecutors consider when evaluating the effectiveness of a...more

Baker Botts L.L.P.

DOJ Releases AI-Related Compliance Guidance

Baker Botts L.L.P. on

On September 23, 2024, the Department of Justice updated its guidance on the Evaluation of Corporation Compliance Programs to include questions specifically focused on companies’ use and implementation of artificial...more

Epstein Becker & Green

DOJ Updates Its Evaluation of Corporate Compliance Programs to Address New Technologies, Reinforce Promoting a “Speak Up” Culture,...

Epstein Becker & Green on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced updates to the U.S. Department of Justice’s (“DOJ”) guidance relative to its Principles of Federal Prosecution of Business...more

Alston & Bird

Getting on the Bandwagon: Eight Additional U.S. Attorneys’ Offices Announce Corporate Whistleblower Pilot Programs

Alston & Bird on

Our White Collar, Government & Internal Investigations Team examines a plethora of new whistleblower pilot programs from federal prosecutors across the country....more

Thomas Fox - Compliance Evangelist

The 2024 ECCP: Complying with the 2024 ECCP on Whistleblowers

The Department of Justice (DOJ), in its 2024 Update, has explicitly directed companies to ensure they have robust processes in place to identify, manage, and mitigate emerging risks related to new technologies, including AI....more

Thomas Fox - Compliance Evangelist

Argentieri on the DOJ’s Corporate Whistleblower Awards Pilot Program

The Department of Justice (DOJ) recently unveiled the Corporate Whistleblower Awards Pilot Program (CWA) to bolster corporate enforcement efforts. Although the program has only been operational for a few weeks, it has already...more

Alston & Bird

Compliance in the Age of AI: The DOJ Issues Updated ECCP Guidance

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The Department of Justice has revised its Evaluation of Corporate Compliance Programs guidance, adding new content related to technology, whistleblowers, and data analytics. Our White Collar, Government & Internal...more

Thomas Fox - Compliance Evangelist

The Argentieri Speech: Mid-Point Reflections on the DOJ’s Compensation Clawback Pilot Program

Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. She reiterated the long-stated policy that compliance...more

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