All DOJ articles – Page 30
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Blog
Halliburton, the FCPA, and effectiveness
Having a great compliance program means nothing if it exists only on paper. If you want to keep the DoJ and SEC happy, that program must also be demonstrably effective.
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Blog
Memo to Telia, Deutsche Bank: Do not negotiate with the DOJ in public
While Telia Co. and Deutsche Bank are looking to publicly war with the Justice Department over upcoming penalties, they should be learning by Avon Product’s example, says Tom Fox—the firm initially suggested a $12M fine and ended up paying a cool $135M.
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Blog
It is good to have friends at the top
It’s good to know someone at the top—that well-known maxim was demonstrated yet again recently when it was revealed that U.K. Chancellor of the Exchequer George Osborne intervened with the U.S. government during the investigation of money laundering violations by the U.K. bank HSBC. Tom Fox reports.
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Blog
DoJ to everybody on FCPA prosecutions: We can make this all go away, you know
Just how serious is the Justice Dept. about making life easier if you comply fully with its FCPA violation investigations? Johnson Controls Inc. was caught dead to rights on egregious fraud—but, by cooperating with the DoJ, it managed to secure a declination to prosecute. Tom Fox reports.
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Blog
Compliance front and center
The SEC and Justice Department have made it clear that it will no longer be adequate for companies merely to have a compliance program in place; it must actually be taken seriously from within and given the power and resources to do its job. Tom Fox explores.
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Blog
Want evidence about the FCPA Pilot Program?
Do you want to see evidence of the effectiveness of the Justice Department FCPA Pilot Program? Read on ...
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Blog
Are anti-bribery experts focusing on the wrong numbers?
To be sure, enforcement data is an important tool for companies to understand their anti-bribery regulatory risks. But relying solely on U.S. enforcement statistics reveals only part of the increasingly complex and multi-layered regulatory landscape that multinationals are facing today. Inside, a look at what can be accomplished when the ...
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Article
Internal Investigations Just Got a Lot More Complicated
Image: Compliance officers should brace themselves after Deputy Attorney General Sally Yates’ speech last week calling for more prosecution of individuals involved in corporate misconduct—the implications for internal investigations are huge. Inside we have the full analysis of how this policy shift, which sharply splits company and executive interests, will ...
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Article
FTC Speaks on Antitrust; Leaves Many Confused
Image: The Federal Trade Commission has finally spoken (for the first time in 100 years) about how it defines the scope of its enforcement authority for anti-competitive business practices. The bad news: Its guidance is short reading and slim on specifics. The lack of detail “may have opened the floodgates ...