What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to
Mike Volkov, in a blog post entitled, Mood in the Middle Versus Tone at the Top, said, “Even when a company does all the right
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
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,
We continue our review of DOJ initiatives from 2023 and what they may portend for the compliance professional in 2024 and beyond. In October 2023,
Assistant Attorney General Kenneth A. Polite, Jr. began his speech with an interesting aside. It is about the clear tie between poverty and corruption. This
In March 2023 there were two days of speeches from the DOJ which added to the compliance complexity. The speeches were made by Deputy Attorney
January 2023 saw the release of the 2023 U.S. Department of Justice Criminal Division Evaluation of Corporate Compliance Programs (ECCP). It brought forward several new
2023 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate enforcement actions under the Foreign
The compliance community has long recognized the gaping hole in the Foreign Corrupt Practices Act (FCPA). As a supply side law, it criminalizes the payment
