Events
Webinar: Anti-Corruption Enforcement and Compliance -- The Year in Review January 5, 2016, 12 noon EST Sign Up Here The past year -- 2015 -- was another eventful year in global anti-corruption enforcement. While the US Department of Justice enforcement activity slowed, the SEC and other governments increased enforcement activity. DOJ&
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Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting about self-reporting FCPA violations. Lauren's profile is here, and she can be reached at lconnell@volkovlaw.com. One of the critical questions when evaluating a potential FCPA violation is to decide whether
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The Justice Department’s hiring of Hui Chen as the new Compliance Counsel is an important development in DOJ’s prosecution of corporate defendants. It is not clear yet what impact Ms. Chen will have. At a recent event at NYU (video here), Andrew Weissmann, the head of the Fraud
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Individual commitment to a group effort - that is what makes a team work, a company work, a society work, a civilization work.~ Vince Lombardi Like so many areas in life, a successful ethics and compliance program depends on teamwork. My last two postings, Parts 4 and 5, will highlight these
Events
Free Webinar: DOJ Shifts Prosecution Strategy December 15, 2015, 12 Noon EST Sign Up Here I am pleased to announce that Tom Fox, Principal, Advanced Compliance Solutions, and I are conducting a joint webinar on Tuesday, December 15, 2015 at 12 pm EST, on the Justice Department's shifting
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Do the right thing. It will gratify some people and astonish the rest. – Mark Twain We all know the obvious – a CEO’s commitment to ethics and compliance is critical to the success of a compliance program. A CEo who stands up and speaks about the company’s culture of
Events
I am pleased to announce that Tom Fox, Principal, Advanced Compliance Solutions, and I are conducting a joint webinar on Tuesday, December 1, 2015 at 2 pm EST, on the Justice Department's shifting FCPA prosecution strategy and compliance program requirements. Please sign up HERE. The Justice Department’s
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Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us with this posting. Lauren can be reached at lconnell@volkovlaw.com. Her profile is here. FCPA practitioners are familiar with the term “public international organization” as included in the definition of “foreign official” for FCPA liability purposes but do
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The Justice Department’s reexamination of corporate incentives to disclose violations appears to be in reaction to the steady escalation of cooperation requirements. In response to these extra burdens, DOJ could be concerned that FCPA voluntary disclosures will dwindle. For years, voluntary disclosures have fueled DOJ's FCPA enforcement
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Recent press reports suggest that the Justice Department is reconsidering its FCPA criminal prosecution policies, particularly with respect to corporate defendants. As reported, DOJ is considering defining and increasing corporate benefits from voluntary disclosures and cooperation. This re-evaluation appears to have been triggered by changes in the Criminal Division
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I am a positive person (anyone who has to say that raises doubts). At least I like to think I am. I am not yet sold on the wisdom of DOJ’s hiring of a compliance counsel. Frankly, I have a lot more respect for the knowledge and experience of
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In the public relations battle following the issuance of the Yates Memo, the Justice Department can now cite one example for the new policy – the recent arrest and charging of Carl Reichel, former President of Warner Chilcott. The Justice Department’s new policy got off to a rocky start: in