Posts Tagged ‘Justice Department’

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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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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Compliance Jobs Report: July 6

Compliance jobs

Juicy stuff in the Compliance Jobs report this week! Michigan State has named an interim compliance officer; Oklahoma University sacked its chief auditor. We have promotions at Juniper Networks and PayPal; departures from the Justice Department, Amazon, and Kemira, and more news beyond that! Plus our compliance Meme of the Week goes out to Johnny…

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Weed Compromise Moves DOJ Nominees

cooperation

Compliance officers curious about Justice Department enforcement policy, take note: the Trump Administration and an influential senator have cleared the way for more than a dozen Justice Department nominees proceed through Senate confirmation after months of delays. Colorado Sen. Cory Gardner said Friday that he wrangled a promise from President Trump not to crack down…

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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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Corporate Plea Bargains Under Fire Again

cooperation

Any time a federal judge begins a ruling with the words, “Let’s see if I’ve got this straight,” you know you’re in for something special. Last week, district court judge William Young did not disappoint. With that opening sentence, Young, a veteran and respected judge in Boston, delivered a 24-page broadside against the Justice Department’s…

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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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Future of the ‘Effectiveness Questions’

The other day a compliance officer asked me an interesting question: What’s going to happen to the Justice Department’s guidelines for evaluating the effectiveness of compliance programs? After all, the Trump Administration talks all the time about streamlining regulation. Deputy attorney general Rod Rosenstein has given a series of speeches this fall promising reviews of…

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Another Vague FCPA Enforcement Action

fcpa

The good news for compliance officers, as you may have already heard, is that we have another FCPA enforcement action under the Trump Administration— and yet again it’s a decision not to prosecute, because the company in question met all the criteria of the FCPA Pilot Program. The company is CDM Smith, a privately held…

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