Announcement of Policy Revisions Reflects a More Practical, Flexible Enforcement Approach The US Justice Department has adjusted its approach to holding individuals, and not only corporations, responsible for improper conduct. In remarks at the ACI’s FCPA conference on November 29, Deputy Attorney General Rod Rosenstein softened the DOJ’s formal policy…
Any company manufacturing or contracting to manufacture products using such conflict minerals had previously been required to conduct extensive due diligence on its supply chain. Following a series of partial losses in court, the SEC appears to be backing off the rule—for now.
Last month marked one year since Deputy Attorney General Sally Quillian Yates issued a much-discussed mandate directing federal prosecutors to focus on not just companies but also individual employees.
After several years of development, involving input from over 50 countries, the International Organisation for Standardisation (ISO) has finally published ISO 37001: Anti-Bribery Management Systems Standard – a new international standard designed to assist organisations worldwide in implementing and maintaining effective anti-bribery systems.
According to a recent U.S. DOJ Inspector General’s Office report, DOJ is not enforcing the Foreign Agents Registration Act, which governs foreign lobbying in the United States, aggressively enough. What does this mean for your business?
In some watershed cases companies have received significant benefits from self-reporting FCPA violations to the U.S. Government, including substantial reduction of fines and even declinations. But these benefits are not guaranteed.
Corporate compliance officers are used to facing pressure from within their companies to protect them from legal exposure, but increasingly, external pressure from regulators means that compliance officers themselves may face liability if something goes wrong.
Balancing corporate resolution of high-profile criminal and civil cases against companies for fraud and other misconduct with the prosecution of individuals has become a top policy priority for the U.S. Department of Justice (DOJ). On September 9, 2015, Deputy U.S. Attorney General Sally Yates issued a memo to all DOJ attorneys to provide guidance to prosecutors handling cases involving both companies and individuals. There are several significant developments directors should be aware of.
In recent years, U.S. prosecutors have continued apace in resolving substantial, high-profile criminal and civil cases against companies for fraud and other misconduct. Convicting individuals who perpetrated the wrongdoing, however, has proven more difficult.
In February, yet another high-profile negotiated settlement between a company and a government agency was thrown into doubt after a judge refused to approve the terms reached by the parties. On Feb. 5, U.S. District Court for the District of Columbia Judge Richard Leon refused to approve a motion filed…