Tagged: DOJ Corporate Enforcement Policy

How to Build a Compliance Compensation System (Part I of II)

The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management.  The theoretical underpinning of DOJ’s expanded focus is to increase the consequences to individuals who engage in misconduct or supervisors who turn a blind eye to misconduct.  Individuals already face potential criminal prosecution for engaging in misconduct but the...

Episode 258 — Deep Dive in the ABB FCPA Case

Episode 258 — Deep Dive in the ABB FCPA Case

The Justice Department’s new Corporate Enforcement Policy and the heightened enforcement and compliance expectations were put to the test in its announcement of a $315 million settlement of bribery charges with ABB, a three-time loser in foreign bribery enforcement.  However you interpret this case, the ABB enforcement action demonstrates yet again the vitality of DOJ’s commitment to FCPA enforcement, and that the industry can expect...

Episode 249 — DOJ Issues New Corporate Enforcement Policy

Episode 249 — DOJ Issues New Corporate Enforcement Policy

The Biden Administration promised a new, aggressive approach to corporate crime. Well, the Justice Department just delivered a new, comprehensive policy that raises a number of issues, some of which are likely to be controversial. The new policy incorporates reforms announced last October that largely centered on prior corporate criminal and civil records; appointment of independent compliance monitors and expanding review of responsible persons in an internal...

Webinar: DOJ’s New Corporate Enforcement Policy — Taking Compliance to the Next Level

Webinar: DOJ’s New Corporate Enforcement Policy — Taking Complaince to the Next Level October 25, 2022 12 Noon EST SIGN UP HERE The Biden Department of Justice promised a tough, new approach to white collar enforcement. In a series of steps, the Justice Department has set out a new and comprehensive approach to corporate criminal enforcement with a direct and immediate impact across the Justice...