Friday, July 3, 2020

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At Large: Is This the Most Important Change in the DOJ’s New Guidance?

DOJ’s new guidance for evaluating corporate compliance programs puts the spotlight on organizational justice, or what Richard L. Cassin simply calls “fairness.” The update adds this question: Does the compliance function monitor its investigations and resulting discipline to ensure consistency? “Why is the added emphasis on monitoring to ‘ensure consistency’ so important?” Cassin asks. “Because […]
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DOJ Updates Guidance on Evaluating Corporate Compliance Programs

The update of the DOJ’s Evaluation of Corporate Compliance Program guidance is another reminder of its heightened focus and increasing sophistication regarding evaluating compliance programs during investigations. While the overall structure of the guidance generally remains consistent with the last version, the revisions provide additional insight into the DOJ’s expectations for corporate compliance programs. More […]
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DOJ Updates Corporate Compliance Guidance, Continues Focus on Risk, Reporting, and Training

The Department of Justice has published updated guidance on how it evaluates corporate compliance programs when conducting investigations, making charging decisions, and negotiating pleas...

Here’s Every Change the DOJ Made Monday to its Corporate Compliance Program Evaluation Guidance

The Justice Department has published a new version of its guidance on how it evaluates compliance programs when making corporate charging decisions, with a focus on ensuring that compliance programs are updated to fit new circumstances, and adequately resourced, with its effectiveness being the central principle. The revised guidance also includes more focus on third-party […]
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Justice Dept. Updates Compliance Guidance Again

The Justice Department has updated its guidance for evaluating effective compliance programs, adding new material about how often a company reviews the structure of its program, a compliance officer’s access to data, and how companies integrate acquisitions into their existing programs. The differences are fairly minor, mostly consisting of additions. For example, they put an […]
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DOJ Freezes Collection Of Civil Penalties to Blunt Economic Impact of COVID-19

The Department of Justice has paused its collection of civil penalty payments until at least May 31, in an effort to blunt the coronavirus...

DOJ Lets Companies Skip Paying Penalties During Pandemic

Because of the current health crisis, the Department of Justice is giving a temporary pass to any companies that are required to pay civil penalties in settlements with the federal government, until at least June 1. Enforcement attorneys who have spent years going after the companies say they were shocked by the blanket policy. Critics […]
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Federal Jury Convicts Founder and Chairman of a Multinational Investment Company and a Company...

Greg E. Lindberg, the founder and chairman of Eli Global LLC and the owner of Global Bankers Insurance Group, and Lindberg’s consultant John D. Gray, have been convicted of orchestrating a bribery scheme involving independent expenditure accounts and improper campaign contributions. The defendants promised millions of dollars in campaign contributions to North Carolina’s elected Commissioner […]
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A Coalition Grows: What WMATA’s Partnership with the Procurement Collusion Strike Force Means for...

On February 18, 2020, Washington Metropolitan Area Transit Authority (“WMATA”) Inspector General Geoffrey Cherrington announced that special agents from WMATA would be partnering with the Department of Justice’s Procurement Collusion Strike Force (“PCSF”) to prevent and detect fraud affecting WMATA.  The announcement portends a growing partnership amongst federal, state, and local entities in the procurement […]
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Senior DOJ Attorneys Speak About FCA Enforcement Priorities, Dismissal, and Cooperation

On February 27 and 28, 2020, Joseph H. (Jody) Hunt, Assistant Attorney General for DOJ’s Civil Division, and Michael Granston, Deputy Assistant Attorney General,...