Change is the law of life, and those who look only to the past and present are certain to miss the future -John F. Kennedy The measure of intelligence is the ability to change -Albert Einstein We are pleased to announce the release of a new, rebranded and refreshed podcast — Corruption, Crime & Compliance. Under the old banner, we produced 249 episodes. Listen for...

The Justice Department and the FBI have quickly acted to focus on fraudsters and hoarders who are preying on the public panic in response to the pandemic. DOJ has focused on new fraud schemes promising miracle cures and other means to take advantage of the public on the Internet.  At the same time, DOJ and the FBI have targeted hoarders of critical medical supplies who...

OFAC’s new  Framework for Sanctions Compliance Programs is a game changer.   When it comes to sanctions compliance programs, most companies are well behind the curve.  OFAC’s new framework raises the bar by creating a well-crafted framework for companies to assess their current program and then re-design important elements to meet OFAC’s standards.    To the extent that a company’s sanctions compliance program operates as part of an overall...

The Department of Justice (DOJ) has announced a number of modifications to its policies governing prosecution of corporations for criminal and civil violations of law.  In 2017, DOJ announced its FCPA Corporate Enforcement Policy.  Over the last year, DOJ expanded this policy to apply to non-FCPA corporate violations, as well as mergers and acquisitions.  In addition, DOJ recently announced the adoption of an Anti-Piling On...

Corruption, Crime & Compliance offers both blog postings and fresh podcasts on important topics. To make your life a little easier, we provide subscription services so that you receive convenient notices of new blog postings and podcast episodes. Corruption, Crime & Compliance maintains an email subscription feature.  You can sign up on the left hand side of the blog landing page. Here is a link to...

FCPA enforcement continued in 2017 with an increased emphasis on individual enforcement. Despite early questions as to the new administration’s commitment to FCPA enforcement, the Justice Department and the SEC continued to push aggressive enforcement cases, building on well-established relationships with global law enforcement partners. In a significant development, the Justice Department issued a new FCPA Corporate Enforcement Policy, which created a declination presumption for...

Tom Fox, Matt Kelly, Jonathan Armstrong, Jay Rosen and myself recorded a new episode of Everything Compliance.  In the first part of a two-part episode, Tom, Matt and I discuss the new FCPA corporate enforcement policy. You can listen Here. Thanks Tom, Matt, Jonathan and Jay.

On November 26, 2017, the Justice Department announced adoption of its new FCPA Corporate Enforcement Policy.  Deputy Attorney General Rod Rosenstein announced the new policy at an FCPA Conference in Washington, D.C. Under the new policy, corporations that voluntarily disclose potential FCPA violations, fully cooperate with the investigation and implement timely and appropriate remediation will earn a presumptive declination, subject to the absence of aggravating...

Compliance officers have to be mindful of new and emerging threats.  In the past few years, cyber security and data privacy have been quickly rising as new and significant threats that corporations face in the global marketplace. The European Union has adopted a far-reaching new regulatory regime applicable to companies that conduct business in the European Union and collect any sensitive data relating to EU...