Posts Tagged ‘Justice Department’
Justice Department Policy Changes, Part II
We now have more clarity on attorney general Pam Bondi’s plan to overhaul Justice Department enforcement priorities — and yes, it’s going to be a big retreat from holding corporations accountable for certain types of misconduct, while the department spends more time prosecuting drug cartels, illegal aliens, and organizations with DEI programs. Bondi first announced…
Read MoreNew AG Signals FCPA Retreat
Well that didn’t take long: on the same day that Pam Bondi was sworn in as the next U.S. attorney general, Bondi issued a flurry of policy memos that will have the practical effect of taking several big steps back from enforcement of corporate misconduct laws. Bondi arrived at the Justice Department on Wednesday afternoon…
Read MoreAAR Settles Intriguing FCPA Case
Here’s a Christmas present for compliance professionals! AAR Corp., an aviation services company, has agreed to pay $55.6 million to settle civil and criminal charges that the company bribed government officials in Nepal and South Africa in the 2010s — and is giving the rest of us some points to ponder on Justice Department credit…
Read MoreCompliance Program Priorities That Endure
’Tis the season for speeches from Justice Department officials, as they reflect on the year’s enforcement activity — and these days, try to establish some sense of continuity even as the incoming Trump Administration portends a very different approach to corporate compliance and regulatory enforcement. Which brings us to a Justice Department speech delivered late…
Read MoreFour Reasons to Watch the Adani Case
Sometimes a tale of corporate corruption comes along that perfectly captures all the issues that ethics and compliance professionals face in our line of work. Such is the case with the Adani Group, and compliance officers everywhere should watch it closely; it could be a hugely telling case for corruption enforcement in 2025. By now…
Read MoreCorporate Enforcement Policy Tweaked Again
The Justice Department is relaxing its approach to corporate criminal enforcement yet again, this time giving companies a bit more breathing room for what counts as “self-disclosure” and “significant profit” — all to further entice companies to step forward and admit legal violations, so that those violations can be resolved more quickly. Nicole Argentieri, deputy…
Read MoreTrump Justice Dept. Comes Into View
Compliance officers have a few more clues this week about what the incoming Trump Administration might mean for corporate compliance programs, although we still have many questions still outstanding too. Today let’s take a fresh look at what we do know, what we still don’t, and what we could deduce about the gap between those…
Read MoreJustice Dept. Talks AI Concerns
The Justice Department wants companies tinkering with artificial intelligence to be more open-minded about testing their AI systems and products for vulnerabilities, and specifically wants them to adopt a “vulnerability disclosure program” much the same way tech companies already disclose software bugs. So says Nicole Argentieri, head of the Criminal Division, who delivered a speech…
Read MoreConcerns Over Access to Data
Today let’s return to the Justice Department’s newly revised guidance for effective corporate compliance programs. Specifically, let’s give a close analysis of what those updates say about compliance officers’ access to data and IT systems. For starters we should appreciate why access to data is such an important issue for the Justice Department at all.…
Read MoreRevamped Compliance Program Guidance!
The Justice Department is rolling out fresh guidance for how it evaluates corporate compliance programs, with new sections addressing artificial intelligence, a company’s speakup culture, and whether compliance teams have sufficient access to the data they need to keep their programs on the right path. The head of the department’s Criminal Division, Nicole Argentieri, announced…
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