Harry Cassin
Publisher and Editor
Andy Spalding
Senior Editor
Jessica Tillipman
Senior Editor
Bill Steinman
Senior Editor
Richard L. Cassin
Editor at Large
Elizabeth K. Spahn
Editor Emeritus
Cody Worthington
Contributing Editor
Julie DiMauro
Contributing Editor
Thomas Fox
Contributing Editor
Marc Alain Bohn
Contributing Editor
Bill Waite
Contributing Editor
Shruti J. Shah
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
We know a lot about what the feds expect from compliance training. For example, from the Evaluation of Corporate Compliance Programs and the FCPA Resource Guide, we know training is a hallmark of a well-designed compliance program. … Continue Reading
In a previous post on the FCPA Blog I briefly explored five ways to make the most of risk assessments. Since then, interest in risk assessment has continued to be very strong.… Continue Reading
They craft policies, train employees, oversee due diligence, perform risk assessments, and lead investigations. But there’s another compliance role that’s practically unknown: disciplinarian. … Continue Reading
One of the most powerful episodes in risk assessment history is the story of the Maginot Line, which the French military had deployed after WWI to prevail in any future trench warfare against the Germans.… Continue Reading
Certifications are not the sexiest feature of compliance programs. However, they can and should play an important role in every program. This post will briefly review some of the key aspects of compliance certifications, including the related topic of honesty pledges.… Continue Reading
Mexico City-based law firm Litigio Estratégico y Compliance has updated the Spanish translation of the DOJ’s June 2020 Guidance for the Evaluation of Corporate Compliance Programs.… Continue Reading
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.”… Continue Reading
When the first set of general corporate compliance program standards – the Federal Sentencing Guidelines for Organizations – was issued in 1991, there was no mention of risk assessment. More recent standards, however – including the “Evaluation of Corporate Compliance Programs” issued by the U.S.… Continue Reading
The DOJ’s new guidance for evaluating corporate compliance programs put the spotlight on organizational justice, or what we might simply call fairness.… Continue Reading
The Justice Department Monday published a new version of its guidance on how it evaluates compliance programs when making corporate charging decisions. … Continue Reading
One of the most significant developments in the ethics space in recent years is the recognition that “paper” programs don’t afford meaningful protection against misconduct or its consequences. Established companies such as Nissan and Pacific Gas & Electric and media companies reeling from #MeToo scandals generally have a compliance infrastructure of lawyers, Codes of Conduct, training and hotlines but nonetheless their CEOs and senior managers have behaved as if these safeguards didn’t apply to them.… Continue Reading
This month the UK Serious Fraud Office published new guidance about how it assesses the effectiveness of the companies it investigates. The SFO’s eight-page document “Evaluating Compliance Programs” arrived with very little fanfare late last week.… Continue Reading
