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White Collar Crimes Corporate Misconduct Corporate Culture

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

Thomas Fox - Compliance Evangelist

Deere FCPA Enforcement Action: Lessons on Pre-Acquisition Due Diligence in M&A

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

DLA Piper

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

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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

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 1 - The Mandate

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

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 3-The Role of Internal Controls

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Lathrop GPM

DOJ Criminal Division Announces Corporate Whistleblower Awards Pilot Program

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In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more

Thomas Fox - Compliance Evangelist

Bridging The Speak-Up Gap: Insights from The 2024 Ethisphere Ethical Culture Report

In a recent episode of the FCPA Compliance Podcast, we discussed the 2024 Ethisphere Ethical Culture Report, “Closing the Speak Up Gap,” with Erica Salmon Byrne. As an expert in ethical culture and a familiar voice to our...more

Thomas Fox - Compliance Evangelist

Transforming Culture: Part 1-From Merger to Culture Toxicity

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other...more

Holland & Knight LLP

DOJ Announces New Whistleblower Financial Rewards Program in Effort to Combat Corporate Crime

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U.S. Deputy Attorney General Lisa Monaco announced the creation of a new U.S. Department of Justice (DOJ or Department) Whistleblower Rewards Program at the 39th Annual ABA White Collar National Institute in San Francisco...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

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At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Thomas Fox - Compliance Evangelist

Leadership’s Conduct at the Top

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

Axinn, Veltrop & Harkrider LLP

Warning - Corporate Compensation Clawbacks Are Coming!

On October 4, 2023, Deputy Attorney General Lisa O. Monaco announced a new "safe harbor" policy for voluntary self-disclosures in the context of mergers and acquisitions, whereby the Department of Justice will decline to...more

The Volkov Law Group

The Evolution of the Compliance Profession

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One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more

Thomas Fox - Compliance Evangelist

Global Business Ethics Survey: Part 2 – Addressing Workplace Misconduct

The Global Business Ethics Survey (GBES) conducted by the Ethics & Compliance Initiative (ECI) provides valuable insights into workplace ethics and compliance from the perspective of employees. I recently had the opportunity...more

Thomas Fox - Compliance Evangelist

2023 Global Business Ethics Survey: Part 1 – Overview

The Global Business Ethics Survey (GBES) conducted by the Ethics & Compliance Initiative (ECI) provides valuable insights into workplace ethics and compliance from the perspective of employees. I recently had the opportunity...more

Thomas Fox - Compliance Evangelist

How Triage and Investigations Can Drive a Culture of Speak Up

I recently concluded a podcast series with Case IQ. Over this series, I visited with Sharlyn Lauby, Jakub Ficner, Kenneth McCarthy, and Meric Bloch on the different facets of a great speak-up regime and how each of those...more

The Volkov Law Group

Corporate Culture: Monitor, Intervene and Remediate (Part III of III)

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Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone.  To the contrary, as the business adapts through growth, innovation or in response to outside market and...more

The Volkov Law Group

Promoting Your Corporate Culture – Accountability and Messaging (Part II of III)

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As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture.  In these...more

Robinson & Cole LLP

DOJ Announces Significant Corporate Compliance Initiatives

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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

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

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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

NAVEX

NAVEX R&C Benchmark Finding: Programs Still Have Opportunities to Better Utilize Data

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NAVEX publishes the Definitive Risk and Compliance Benchmark Report each year, surveying over 1,100 industry professionals. The purpose of this report is to provide insight into the effectiveness of R&C programs and enable...more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Policies on Corporate Ethics and Compliance

Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more

BakerHostetler

Deputy AG Lisa Monaco Announces Tough-on-Corporate-Crime Updates to DOJ Policies

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In prepared remarks delivered at New York University School of Law on Sept. 15, Deputy AG Monaco announced significant updates to the DOJ’s corporate criminal enforcement policies. Deputy AG Monaco’s announcement...more

WilmerHale

The Corporate Crime Advisory Group Has Spoken: DOJ Revises Corporate Criminal Enforcement Policies

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On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more

Holland & Knight LLP

DOJ Expands Framework for Cracking Down on Corporate Crime

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In a speech to prosecutors, policymakers and academics on Sept. 15, 2022, U.S. Deputy Attorney General Lisa O. Monaco announced that the U.S. Department of Justice (DOJ) would no longer "accept business as usual" when it...more

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