Posts Tagged ‘Justice Department’
Trump 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…
Read MoreMore Thoughts on Whistleblower Awards
Today let’s revisit the Justice Department’s whistleblower awards program, first announced 10 days ago. Since then we’ve all had time to contemplate the program’s implications, several of which deserve compliance professionals’ attention. Let’s begin with the question most important to compliance professionals: Will the existence of this awards program drive would-be whistleblowers not to report…
Read MorePodcast: Do DPAs Really Work?
Today we have another Radical Compliance podcast, trying to unpack a question near to the hearts of compliance professionals everywhere: Do deferred-prosecution agreements really work to improve corporate behavior? This issue has been on my mind lately because federal prosecutors recently accused Boeing of breaching the DPA it struck in 2021 to settle criminal charges…
Read MoreJustice Department Eyes AI Risks
Last week the Justice Department announced that it will cast a more critical eye at abuses of artificial intelligence. Today let’s unpack what that news means for compliance officers in practice, and how you might need to adjust your compliance program to accommodate this brave new AI world. The pledge about increased scrutiny of AI…
Read MoreJustice Dept. Launches Whistleblower Program
The Justice Department is climbing aboard the whistleblower awards bandwagon, with a new program it plans to launch later this year offering monetary awards to whistleblowers akin to what numerous other federal agencies already do. Deputy attorney general Lisa Monaco made the announcement Thursday while speaking to the American Bar Association’s white-collar crime conference in…
Read MoreSwiss Trader Gunvor Pays $661M on FCPA Fails
Our latest FCPA enforcement action is a $661 million monster against Swiss trading firm Gunvor, which has pleaded guilty to bribing Ecuadorian government officials through the 2010s in exchange for intelligence about upcoming business contracts with the state-owned oil company of Ecuador. The Justice Department announced the settlement last Friday, along with a companion settlement…
Read MoreeBay Settles Crazy Harassment Case
eBay has agreed to a $3 million criminal penalty, a deferred-prosecution agreement, and compliance monitor, all to settle charges from a bizarre incident in 2019 of the company’s internal security team stalking and harassing an online critic of the company. The case was cuckoo crazy at the time, and remains so today. eBay’s then-head of…
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