[…] corporat ion, determining whether to bring charges , and negotiating plea or other agreements . JM 9 -28.300. These factors include “the adequacy and effectiveness of the corporation’s compliance program at the time of the offense, as well as at the time of a charging decision” and the corporation’s remedial efforts “ to implement […]
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[…] corporat ion, determining whether to bring charges , and negotiating plea or other agreements . JM 9 -28.300. These factors include “the adequacy and effectiveness of the corporation’s complia nce program at the time of the offense, as well as at the time of a charging decision ” and the corporation’s remedial efforts “to […]
The DOJ released the first version of its Evaluation of Corporate Compliance Programs in 2017. That document (with its 2019 and 2020 updates) completed the chief compliance officer’s amazing transformation from part-time generalist to today’s highly specialized “super executive.” How did it happen, and why?
The Ethics and Reputation Society of Turkey has translated the DOJ’s June 2020 Guidance for the Evaluation of Corporate Compliance Programs.
[…] ç® ä» The âPrinciples of Federal Prosecution of Business Organizationsâ in the Justice Manual describe specific factors that prosecutors should consider in conducting an investigation of a corporation, determining whether to bring charges, and negotiating plea or other agreements. JM 9-28.300. These factors include âthe adequacy and effectiveness of the corporationâs compliance program at […]
[…] “CGU”). THE INDICTED ENTITY 3. For the entire period of the alleged offending (between 1996 and 2014), FWEL was a UK- incorporated, wholly-owned subsidiary of Foster Wheeler Corporation until 2001, FW Ltd (as defined in paragraph 169 below) from 2001 until 2009, and Foster Wheeler AG (formerly Foster Wheeler Inc.) from 2009 onwards (“FW” […]
The Supreme Court today published an opinion that limits the SEC’s ability to use disgorgement without considering and deducting legitimate business expenses, making a significant change to how corporate FCPA settlements will be reached with the agency.
[…] refining, transportation, and trade of energy resources throu ghout the world in behalf of the Venezuelan government. PDVSA Services, Inc. (“PDVSA -S”) is a United States based corporation, is a wholly -owned affiliate of PDVSA, yet located in Houston, Texas. PDVSA -S and Bariven, another wholly -owned subsidiary of PDVS A, are alleged to […]
[…] 59) Defendants. This Indictment arises from allegations that the defendants engaged in a scheme to bribe officials of a foreign government on behalf of Cognizant Technology Solutions Corporation (ÒCognizantÓ). Defendant Gordon J. Coburn, formerly the President and CFO of Cognizant, and Steven Schwartz, formerly CognizantÕs Executive Vice President and Chief Legal and Corporate Affairs […]
Taylor Swift was offered a $100 million sponsorship deal from FTX but turned it down a few months before the crypto firm collapsed after asking the perfect due diligence question, according to a lawyer leading a class action suit against FTX founder Sam Bankman-Fried and nearly a dozen celebrities who signed on with FTX.