The Department of Justice has laid down a marker – companies would be smart to understand the significant change in ethics and compliance program expectations. Companies that ignore this new landscape are gambling with their financial security and their reputational value. Every company that has suffered through a DOJ investigation knows how damaging and draining such an experience can be. The purpose of an ethics...
The Justice Department is rapidly pushing corporations to a new level of compliance. We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs. It would be a mistake, however, to interpret DOJ’s recent changes as limited to compliance compensation and preservation of internal communications data. When considered together, the changes to the Corporate Enforcement Policy, the Evaluation...
The Justice Department finally released its new policy to improve corporate preservation of data generated by executives and employees. In this new technology era, companies have had significant gaps in collecting and reviewing data generated by messaging applications, texting systems and emails. While many employees have been using personal devices for business purposes, a large number of companies have failed to apply strict BYOD policies...
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...
