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
Earlier this year the Treasury Department’s Office of Foreign Assets Control published A Framework for OFAC Compliance Commitments. It describes essential components of a sanctions compliance program (management commitment, risk assessment, internal controls, testing and auditing, and training).… Continue Reading
The Criminal Division of the DOJ published expanded guidance on April 30 discussing the factors prosecutors should use to determine whether a company under investigation for misconduct will be regarded as having an effective compliance program.… Continue Reading
The U.S. Department of Justice recently published new guidance on how it will assess corporate compliance programs. The DOJ Guidance streamlines previous U.S. guidance and expands on key subjects; providing a greater insight into how the the DOJ will approach its evaluation of compliance programs when considering whether a prosecution or other resolution is appropriate. … Continue Reading
Transparency International UK launched a new online tool this month to provide businesses with practical and in depth guidance on tackling bribery and corruption.
In producing this tool we’ve worked with over 120 leading compliance and legal experts, over the course of eight years and we’re proud to be able to offer it as a free-to-use resource for businesses.… Continue Reading
Transparency International UK rolled out a new tool Tuesday to help companies in the UK and overseas create anti-bribery compliance programs and evaluate their effectiveness.
The free online tool is called “Global Anti-Bribery Guidance: Best practice for companies in the UK and overseas.”… Continue Reading
CCOs know that accountability and discipline are difficult and perilous areas to embed in their programs for a number of reasons.
Decisions involving discipline and internal enforcement involve levers of power that may be viewed as challenges to existing sources of power and “the way things are done around here.”… Continue Reading
The Justice Department’s new guidance about how it will evaluate corporate compliance programs takes the form of questions its prosecutors would typically ask about a corporate compliance program during an investigation.… Continue Reading
In the Justice Department’s new guidance for compliance programs, which appeared online unannounced, undated and unsigned, one detects the experienced hand of the DOJ’s new Compliance Counsel, Hui Chen.
I am so impressed by the content of the Evaluation of Corporate Compliance Programs that I suggest the DOJ rename this document: Evaluation of Corporate Compliance Programs (This Is What True Compliance Subject Matter Expertise (SME) Looks Like). … Continue Reading
2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines.… Continue Reading