Posts Tagged ‘FCPA’

More DOJ! New Cooperation Policy

cooperation

More news from the Justice Department on corporations cooperating with criminal investigations: from now on, prosecutors will only insist that companies identify individuals “substantially” involved with the misconduct in question, rather than everyone involved. So says deputy attorney general Rod Rosenstein, who announced the new policy on Thursday at the annual FCPA Conference happening in…

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DOJ Plugs Cooperation, Compliance

compliance

All eyes in the compliance community might be the annual FCPA Conference happening in Washington right now, but compliance professionals might also want to note a different speech given across town Wednesday by John Cronan, deputy assistant attorney general. Cronan popped up at a Practising Law Institute event to talk about companies cooperating with law…

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SEC Dings Vantage $5M on FCPA Issues

fcpa

Texas-based Vantage Drilling International has agreed to pay $5 million in disgorgement to the Securities and Exchange Commission for sloppy FCPA accounting controls that let the company’s largest outside director and various third parties pay bribes to Brazilian government officials in the 2000s. The SEC’s settlement order recounting the failures reads like a long, torturous…

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New DOJ Policy on Compliance Monitors

compliance monitors

The Justice Department dropped a bundle of new policies last Friday about evaluating compliance programs and corporate monitors, with potentially significant implications for corporate compliance officers and the programs you run. Brian Benczkowski, assistant attorney general for the Criminal Division, announced the news during a speech he delivered in New York on Friday. Always be…

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FCPA Enforcement & Inherited Liability

fcpa

The Justice Department made another plug for voluntary disclosure of FCPA trouble on Wednesday, this time stressing that prosecutors will apply the department’s new FCPA Corporate Enforcement Policy even to misconduct companies inherit through mergers and acquisitions. Matthew Miner, deputy assistant attorney general, delivered that message while giving a speech to compliance professionals in Washington.…

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Review: Complete Compliance Handbook

Tom Fox, the self-proclaimed “FCPA Evangelist” and my friend for years in compliance news and commentary, just published a new book: The Complete Compliance Handbook: A Guide to Operationalizing Your Compliance Program. Fox was generous enough to supply me with an advance copy, so today we have a review of his book in case you’re…

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Eight Compliance Events to Watch in 2018

compliance

Welcome to 2018, everyone! Now that we’re done returning Christmas presents, watching college football, and prepaying this year’s property taxes, our thoughts turn to how the corporate compliance landscape might evolve in the coming year. Without further delay, then, my annual list of compliance issues that should be worth watching in 2018. In no particular…

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DOJ Expands FCPA Pilot Program

fcpa

The Justice Department is going to expand the benefits of the FCPA Pilot Program and make those benefits permanent policy, in a sweeping gesture to entice more corporations to confess possible FCPA violations and then cooperate in investigating them. Most important detail: from now on, if your company discloses an FCPA violation and meets the…

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DOJ Penalty Policy Under Review

The Justice Department is reconsidering how it imposes monetary penalties for corporate misconduct, so that parallel investigations happening with other regulators don’t pile on the pain unnecessarily, the deputy attorney general said Wednesday. Deputy AG Rod Rosenstein made those remarks during a wide-ranging speech in New York. He also said he hopes to avoid putting…

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Rosenstein Talks Yates Memo, Says Diddly

fcpa

Don’t look now, but the compliance Internet is all a-Twitter today because Deputy Attorney General Rod Rosenstein said in a public forum that maybe, sometime soon, the Justice Department might change its views of corporate cooperation under the Yates Memo— or then again, maybe not. Who knows, really. To remind everyone, the Yates Memo is…

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