Compliance, Enforcement, and Risk Management Posts
On April 30, 2019, the U.S. Department of Justice (“DOJ”), Criminal Division, released updated guidance to DOJ prosecutors on how to assess corporate compliance programs when conducting an investigation, in making charging decisions, and in negotiating resolutions. This guidance emphasizes DOJ’s laser focus on compliance programs, requiring companies under investigation to carefully evaluate, test, and likely upgrade their programs well before the investigation is over.
In this episode of Reasonably Speaking two compliance experts speak about the greatest challenges in creating a strong compliance program and establishing a corporate culture that supports it.
The U.S. Department of Justice issued a press release announcing the recent publication of a guidance document for white-collar prosecutors on the evaluation of corporate compliance programs.
The Role of the Board of Directors and Executive Management in Promoting an Organizational Culture of Compliance and Risk ManagementGeoffrey P. Miller, Jennifer H. Arlen, James A. Fanto, Claire A. Hill and Pauline Toboulidis
The following entry is excerpted from the Black Letter of Tentative Draft No. 1, § 3.07 The Role of the Board of Directors and Executive Management in Promoting an Organizational Culture of Compliance and Risk Management.
The following entry is excerpted from the Black Letter and Comments of Tentative Draft No. 1; Section 3.06 Qualifications of Primary Governance Actors for Compliance and Risk Management.
This chapter reviews the empirical literature on the factors related to the likelihood and detection of corporate wrongdoing, which increasingly focuses on internal governance, and examines calls to split the traditional tasks of the General Counsel (GC) between the GC and a Chief Compliance Officer (CCO) who reports directly to the Board.
At its meeting in Philadelphia on January 17 and 18, the ALI Council reviewed drafts for six projects. Drafts or portions of drafts for six projects received Council approval, subject to the meeting discussion and to the usual prerogative to make nonsubstantive editorial improvements.
During its meeting in New York City on October 18 and 19, the ALI Council reviewed drafts for seven Institute projects. Drafts or portions of drafts for six projects received Council approval, subject to the meeting discussion and to the usual prerogative to make nonsubstantive editorial improvements.
Reputation risk is a material peril of economic harm from angry disappointed stakeholders. It is the gap between those stakeholders’ expectations and the reality of their experience with any given entity.
Technology is rapidly disrupting every industry and institution around the globe. Yet, corporate compliance has remained relatively unaffected by technological change when compared to other industries.