Catching Up with DOJ Compliance Program Guidance Tuesday, July 14, 2020, 12 Noon EST Sign Up HERE The Justice Department has issued two sets of important revisions to its compliance program guidance. First, on July 1, 2020, DOJ announced revisions to its 2019 Evaluation of Corporate Compliance Program Guidance. Second, on July 3, 2020, DOJ and the SEC released a Second Edition of its FCPA...
The FCPA Guidance continues to inform compliance practitioners on compliance best practices. Issued in 2012, the FCPA Guidance provides important information concerning a number of compliance functions and risks. The FCPA Guidance includes important discussions about legal intent, due diligence, successor liability and other issues, which can be used to establish important safe harbors for an effective ethics and compliance program. In this episode, Michael...
The Justice Department has released two important documents that provide guidance to compliance practitioners as to compliance program best practices: (1) The FCPA Guidance; and (2) The Evaluation of Corporate Compliance Programs. In combination, these two documents provide important compliance program guidance. In this episode, Michael Volkov discusses various issues related to ethics and compliance program best practices.
Webinar: Compliance Best Practices — Combining the FCPA Guidance and DOJ’s Evaluation of Corporate Compliance Programs May 30, 2018 12 Noon EST Sign Up HERE The FCPA Guidance issued in 2012 continues to provide the most effective direction to FCPA and ethics and compliance program practitioners. Last year, this important document was supplemented by the Justice Department’s Evaluation of Corporate Compliance Programs. Both of these...
The Justice Department has touted its efforts to bring greater transparency to FCPA enforcement. There is no question that in the last five years the Justice Department has moved the needle – the FCPA Guidance issued in 2012; the release of the April 5, 2016 Pilot Program; the Evaluation of Corporate Compliance Programs issued in February 2017; the release of letters confirming declinations awarded to...
We all value transparency as a general concept, especially when it comes to the government. In a real macro perspective, we fund the government and we demand that our government operate efficiently, effectively and ethically. Transparency is a fundamental requirement for all citizens to monitor and regulate our government. When it comes to our criminal justice system, or the enforcement of our laws, we expect...
The FCPA Paparazzi have a thick head and a stubborn chin. They just do not understand the significance of Compliance 2.0 to corporate governance and they blindly adhere to simplistic, yet unexplained, solutions to complex problems – kind of sounds like a presidential candidate we all know. Without getting into politics, which I avoid here on this blog, DOJ’s recent FCPA guidance on voluntary, disclosure,...
