The 2023 ECCP made it clear that a company must have more than simply good ‘Tone-at-the-Top’; it must move down through the organization from senior
The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters, and
Continuous monitoring and continuous improvement are two of the most important phrases for any compliance program. These twin concepts were further enshrined in the 2023
One of the areas articulated in the 2023 ECCP was around payments and payroll. For both the compliance professional and the corporate payroll function, there
Matt Galvin, Counsel, Compliance & Data Analytics at the DOJ and one of the experts leading the DOJ’s data analytics initiative, highlighted in another talk
In October 2023, Deputy Attorney General Lisa Monaco announced a new policy regarding M&A. It is a Mergers & Acquisitions Safe Harbor policy that encourages
Assistant Attorney General Kenneth A. Polite, Jr. began his speech on clawback policy developed by the DOJ to promote “innovative approaches to compensation,” which would
In March, Deputy Attorney General (DAG) Lisa Monaco reviewed a number of initiatives by the DOJ that every compliance professional needs to study in some
Messaging Apps There was a significant addition to the language around messaging apps. The ECCP opened this section by noting, “Messaging applications have become ubiquitous
The 2023 ECCP had significant changes regarding compliance-based incentives, both financial and non-financial; consequence management; messaging apps; and ancillary matters. I. Incentives This section
