Deputy Attorney General Rod Rosenstein’s announcement of a permanent expansion of the Department of Justice Foreign Corrupt Practices Act “Pilot Program” is good news for companies that repeatedly faced the dilemma of whether or not to investigate and disclose FCPA issues discovered internally.… Continue Reading
FCPA practitioners welcomed Rod Rosenstein’s announcement that the Department of Justice has made the FCPA Pilot Program permanent, and incorporated it into the U.S. Attorneys’ Manual. In the words of one of my colleagues, the audience “noticeably lightened up” at the Deputy AG’s news. … Continue Reading
Covington & Burling has translated the February 2017 Fraud Section guidance on compliance programs into Chinese.
The DOJ’s released the “Evaluation of Corporate Compliance Programs” in February.
It covers 11 key compliance program evaluation topics.… Continue Reading
At a recent conference, I had the good fortune of asking a former high-ranking DOJ official, “how is it that pre-existing compliance is no part of the Pilot Program’s penalty reductions and declinations?”… Continue Reading
Is my anti-corruption program effective or not effective? In the United States, companies only receive the definitive answer to that question in worst case scenarios — at the back end of a governmental program evaluation, typically while under FCPA scrutiny by the DOJ.… Continue Reading
The acting chief of the DOJ’s Criminal Fraud Section announced a new partnership last month between the DOJ’s Healthcare Fraud Unit’s Corporate Strike Force and Foreign Corrupt Practices Act prosecutors.
Their mission is to “investigate and prosecute matters relating to health care bribery schemes, both domestic and abroad.” … Continue Reading
The award-winning films “Spotlight” and “All the President’s Men” both chronicled investigative journalism that uncovered huge scandals. But in re-watching those movies, I’ve noticed something else they have in common — journalists who kept following the bread crumbs.… Continue Reading
At the 2017 Global Ethics Summit, put on by the Ethisphere Institute, Caroline Rees of SHIFT spoke on a panel about business and human rights.
When asked about differences in stakeholder management approaches between European and U.S.… Continue Reading
The Justice Department’s “Evaluation of Corporate Compliance Programs” outlines 11 topics and 119 questions that the Fraud Section commonly considers when evaluating corporate compliance programs in the wake of criminal misconduct.… Continue Reading
What does the failure of the Kraft Heinz attempted hostile takeover of Unilever portend for the greater world of global anti-corruption enforcement specifically and compliance programs more generally?
As with most business issues during the new administration, things are in flux.… Continue Reading