There is much to be learned from reviewing the wreckage of a major Justice Department enforcement action.  It is helpful to identify these themes, analyze the conduct and reasons for the violation, and identify helpful insights that can be applied to your company or project.  Two significant enforcement actions in 2020 highlighted an important issue that lies at the heart of every company’s culture, especially...

As the headlines continue to point to major misconduct and scandals involving senior corporate executives, compliance officers need to refocus their efforts and address a critical need. All too often, CCOs have difficulty in requiring board members and senior executives to undergo annual training programs. Board members and senior executives often laugh off such requirements by arguing that they know the code, the policies and...