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
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.… Continue Reading
CCOs know that accountability and discipline are difficult and perilous areas to embed in their programs for a number of reasons.… 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.… 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
Dear FCPA Blog,
I am writing today because I recently learned about the DOJ’s new “Evaluation of Corporate Compliance Programs,” which they released on February 8, 2017 without apparent fanfare.
I didn’t see this covered on the FCPA Blog (or anywhere else for that matter) and thought I would bring it to your attention (in case you, like me, had missed it).
While it doesn’t exactly break new ground, I think it does give us an insight into Hui Chen’s views on compliance programs, and thus the DOJ’s position on the same.… Continue Reading