Tagged: Department of Justice

6 Jan, 2016

2016 Year in Review: AML and Sanctions Enforcement

Webinar: 2016 Year in Review: AML and Sanctions Enforcement Tuesday, January 19, 2016, 12 Noon EST Sign Up Here The Justice Department and the Treasury Department’s Office of Foreign Asset Control had another strong year in AML and Sanctions enforcement. With ever-changing sanctions programs, and vigilant AML enforcement, businesses now face significant risks of civil and criminal enforcement. Sanctions enforcement has stretched beyond financial institutions...

General

6 Jan, 2016

The Person (Idea) of the Year – Corporate Ethics and Culture

Each year I have identified the so-called “person” of the year to capture the most significant enforcement and compliance trend. In the past, I have given the award to the Chief Compliance Officer, the Ethics Officer, the Prosecutors, and others. This year is not an easy choice. In my view, there have been three significant events or trends, each of which could easily be named...

General

4 Jan, 2016

Ethics and Compliance Predictions for 2016

The New Year brings new promise for compliance professionals. I always sympathize with compliance officers because of their inevitable conflict – their idealism often is confronted by corporate realities – a CEO who fails to live by his or her promise of support for compliance, or the slow assignment of personnel and resources needed to implement an effective compliance program. When you add to these...

General

4 Jan, 2016

Predictions for Anti-Corruption Enforcement for 2016

In all honesty, if I were betting on my predictions, I would be broke. If I were setting the line on the Super Bowl, I am sure I would go bankrupt in paying off bets. With such confidence, you may want to just click to the new blog post on my colleague Tom Fox’s excellent blog (here) or Matt Ellis’ excellent blog (here), or many...

General

23 Dec, 2015

The Dangers of Quick Fix Solutions – Certifications and Compliance Defenses

When the going gets tough, the tough do not necessarily get going. This is evident in the world of corporate governance, compliance, and defense against aggressive government enforcement. Corporate lobbying interests are pushing a new and dangerous agenda, one that is shortsighted and certain to create problems for chief compliance officers. Several years ago the Chamber of Commerce launched an attack on FCPA enforcement with...

General

22 Dec, 2015

Counterfeit Goods: Third Party Due Diligence Beyond the FCPA

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting about third-party due diligence. Lauren’s profile is here, and she can be reached at [email protected]. Most discussions of third party due diligence begin with an explanation of indirect liability and the “deliberate ignorance” standard of knowledge the FCPA imposes. With so much focus on anti-bribery it is easy to lose...

General

20 Dec, 2015

Four Compliance Trends and Challenges for 2016

As we close out the year, it is now time to begin the retrospective reviews and predictions for the New Year. I will try to keep them to a minimum but I find it important to reflect and look forward to new challenges. Compliance is a fast moving profession. More attention is being paid to the compliance function, and more companies are embracing the importance...

Events

19 Dec, 2015

Webinar: Anti-Corruption Enforcement and Compliance — The Year in Review

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’s enforcement program took some unusual twists with the hiring of a Compliance Counsel and...

General

16 Dec, 2015

Now the Only Path to an SEC DPA or NPA: Self-Reporting

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 [email protected]. One of the critical questions when evaluating a potential FCPA violation is to decide whether to disclose the matter to the Justice Department and the SEC. The SEC recently announced a requirement for companies to voluntarily disclose...

General

7 Dec, 2015

DOJ’s Compliance Counsel & Compliance Expectations

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 Section, and Ms. Chen spoke about the new compliance position. The video provides important information. Ms. Chen...