Podcasts
The Justice Department and the FBI have quickly acted to focus on fraudsters and hoarders who are preying on the public panic in response to the pandemic. DOJ has focused on new fraud schemes promising miracle cures and other means to take advantage of the public on the Internet. At
Podcasts
OFAC's new Framework for Sanctions Compliance Programs is a game changer. When it comes to sanctions compliance programs, most companies are well behind the curve. OFAC’s new framework raises the bar by creating a well-crafted framework for companies to assess their current program and then re-
Podcasts
The Department of Justice (DOJ) has announced a number of modifications to its policies governing prosecution of corporations for criminal and civil violations of law. In 2017, DOJ announced its FCPA Corporate Enforcement Policy. Over the last year, DOJ expanded this policy to apply to non-FCPA corporate violations, as
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Corruption, Crime & Compliance offers both blog postings and fresh podcasts on important topics. To make your life a little easier, we provide subscription services so that you receive convenient notices of new blog postings and podcast episodes. Corruption, Crime & Compliance maintains an email subscription feature. You can sign
Podcasts
FCPA enforcement continued in 2017 with an increased emphasis on individual enforcement. Despite early questions as to the new administration's commitment to FCPA enforcement, the Justice Department and the SEC continued to push aggressive enforcement cases, building on well-established relationships with global law enforcement partners. In a
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Tom Fox, Matt Kelly, Jonathan Armstrong, Jay Rosen and myself recorded a new episode of Everything Compliance. In the first part of a two-part episode, Tom, Matt and I discuss the new FCPA corporate enforcement policy. You can listen Here. Thanks Tom, Matt, Jonathan and Jay.
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On November 26, 2017, the Justice Department announced adoption of its new FCPA Corporate Enforcement Policy. Deputy Attorney General Rod Rosenstein announced the new policy at an FCPA Conference in Washington, D.C. Under the new policy, corporations that voluntarily disclose potential FCPA violations, fully cooperate with the investigation and
Podcasts
Compliance officers have to be mindful of new and emerging threats. In the past few years, cyber security and data privacy have been quickly rising as new and significant threats that corporations face in the global marketplace. The European Union has adopted a far-reaching new regulatory regime applicable to
Podcasts
To implement an effective ethics and compliance program, global companies have to establish an effective internal investigation program. Whether conducting a critical or routine investigation, investigators have to be able to conduct interviews in a fair and effective manner. The success of an internal investigation often depends on the interviews
Podcasts
Global companies face ever-increasing risks with sanctions screening and compliance. The US Treasury Department's Office of Foreign Asset Control ("OFAC") has aggressively enforced complex sanctions regulations against global companies, including banks, manufacturing, oil service and technology companies. In this aggressive enforcement era, companies have to
Podcasts
In a watershed week for FCPA enforcement, the US Department of Justice announced FCPA criminal charges against seven individuals. Specifically, the Justice Department announced four guilty pleas and one indictment as follow on prosecutions to the January 2017 Rolls Royce FCPA enforcement action, and two guilty pleas in a yet
Podcasts
An effective ethics and compliance program requires a careful assessment of risks and existing controls. In order to design and implement an effective program, a chief compliance officer has to identify and prioritize company risks. In addition, a CCO has to review and understand how existing compliance controls mitigate existing