Just to add to the cacophony of voices campaigning during this primary season, DOJ, SEC, FINRA, and CFTC officials launched their own campaign promoting recent initiatives to increase corporate self-reporting of potential violations. After months of announcements, which were preceded by internal wrangling and bureaucratic leaks, DOJ has put in place its new initiative – the Yates memorandum to focus on individual culpability and a...

I am excited to announce a new sponsor of Corruption Crime and Compliance, Bureau van Dijk (BvD). I have been impressed with BvD’s product offering – key tools in your third party screening process that offer difficult to find information. BvD specializes in information on private companies, detailing company hierarchies and standardized financial reports so you can compare companies across international borders. BvD’s product range...

Job: Compliance Manager (Columbus, Ohio, metro area) A leading industrial growth company that delivers a comprehensive set of products for use in the construction and infrastructure sectors is seeking a Compliance Manager to oversee the day-to-day operation of its compliance program and internal controls procedures.  This position is suited for a self-motivated individual seeking to help structure and manage a program from the ground up. ...

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on DOJ’s recent FCPA guidance announcement.  Lauren can be reached at [email protected].  Her bio is here.   Lots of people are talking about the DOJ’s new self-disclosure pilot program, but it was only the last of three steps announced in the DOJ’s Fraud Section FCPA Enforcement Plan and Guidance. One...

We all have heard the scenario involving a compliance professional. A new CCO joins a company with promises from the board, the CEO and senior executives of cooperation, compensation and support for a robust independent compliance function. The new CCO arrives with an idealistic spirit only to discover that he or she has been misled. Sure, the CCO has a title, and a nice salary,...

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,...

Compliance programs are required to create and manage case investigation systems to handle potential misconduct, investigate allegations of wrongdoing and then dispense discipline. Lessons learned from these investigations are valuable sources of information to improve compliance programs. Chief compliance officers play a critical role – either supervising the internal investigation system or coordinating with other functions in the organization to monitor internal investigations. Along the...

The D.C. Circuit dealt a blow last week to judicial attempts to exercise supervision over Justice Department negotiated Deferred Prosecution Agreements. In United States v. Fokker (Here), the Court answered the question in a resounding affirmation  of the authority of prosecutors to resolve criminal cases and exercise discretion in charging decisions. In the end, the court’s decision was not a great surprise but the strength...