Tagged: root cause analysis

DOJ’s New Corporate Compliance Guidance: Does Your Compliance Program Work? (Part V of V)

DOJ’s New Corporate Compliance Guidance: Does Your Compliance Program Work? (Part V of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 14, 2019, at 12 noon EST. Sign up HERE. The final issue discussed in the new DOJ Corporate Compliance Guidance is the assessment of whether a company’s compliance program is working – at the time of the offense and at the time of the resolution of an enforcement...

Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy

Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy

In a significant FCPA enforcement development, DOJ’s Deputy Attorney General (“DAG”) Rod Rosenstein announced the implementation of a new FCPA Corporate Enforcement Policy last week. (Here).  The announcement was not a surprise based on earlier statements made by DAG Rosenstein. Before outlining the specific five takeaways, there are a few issues surrounding the release of the new policy that require some comment. DAG Rosenstein implemented...