Our Blog

Insights

RESULTS FOR: Monitoring

DOJ Maintains Interest in Bribery in Mexico and Latin America

January 16, 2024 | Compliance Investigations Monitoring

Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there.  By following the roadmap, companies may escape prosecution (or at least the imposition of a monitor) by enhancing their compliance programs.  While there is no guarantee that either prosecution or a monitor can be avoided, compliance program improvements are well worth the effort. First let’s review key takeaways from DOJ enforcement activity and … Read More

Summer Doldrums? Not for Human Resources Teams and I-9s!

July 26, 2023 | Immigration + Border Services Monitoring Risk + Compliance

I don’t think the word “doldrums” is used very much anymore, but I do remember it vividly from when I was a child. It was predominantly used in connection to the lazy hazy days of summer when things were hotter than heck and humidity was always higher than anyone wanted. When schools always started back up after Labor Day, August was considered the summer doldrums, especially when you knew it was inevitable that vacation time was soon coming to an … Read More

Forget Spy Balloons – The Bigger Threat is TikTok

March 22, 2023 | Cyber Security Monitoring Privacy Risk + Compliance

After the downing of the Chinese spy balloon by U.S. Forces in early February 2023, several additional objects have been identified over U.S. and Canadian airspace. While officials have denied that these were additional spy balloons, many have questioned what information was collected by these aerial spy devices, and for what purposes. Even though this is significant to national security, most citizens aren’t personally worried about this breach of privacy.

We suggest that an even greater threat to the average … Read More

The Sky Will Not Fall with New Justice Department CEO / CCO Certifications; Instead, the Sun Will Shine

June 30, 2022 | Compliance Monitoring Risk + Compliance

Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs are effective.

Instead, a warm productive sunlight will shine upon CCOs and companies. That’s because these CEO / CCO certifications – if done well with independent validation – will empower the CCO while holding the CEO, C-suite, and their business executives more accountable for their conduct and compliance.… Read More

Is a Monitor on the Horizon?

February 10, 2020 | Compliance Monitoring

The Department of Justice has come knocking and is investigating your company for let’s say –serious money laundering or sanction violations or for manufacturing a defective product that has caused injuries or deaths.

The press is bad, raising grave questions about the company’s culture. Emails released to the public show that employees are afraid to speak up for fear of retaliation, or worse, employees are hiding misconduct from the regulators.

It’s just a matter of time before your company settles … Read More

What to Prepare For and Expect With a CFIUS Monitor?

November 14, 2019 | Monitoring National Security

Given the recent expansion of transactions subject to review by the Committee on Foreign Investment in the United States (CFIUS), more foreign investments and acquisitions of US-based critical technology and data companies will need to be concerned about the government review.  Through the CFIUS review process, the government is attempting to mitigate US national security risks by foreign acquisition or investment in US-based companies which develop critical technologies or have access to sensitive US person data. Additionally, specific
Read More

How The DOJ’s New Guidelines on Monitorships Is an Opportunity for Corporations

October 23, 2018 | Monitoring

Navigating new criminal division guidance and accelerating remediation

As published in Corporate Compliance Insights on October 23, 2018.

In his remarks at the Corporate Compliance and Enforcement Conference last Friday, Assistant Attorney General Brian A. Benczkowski expanded on the Department of Justice’s (DOJ) new guidelines for corporate compliance and monitorships, issued on October 11, 2018.

While it is yet to be seen how these new guidelines will impact the frequency of monitorships, it does seem clear that the DOJ … Read More

Avoiding Fraud and Abuse in Disaster Reconstruction Efforts

October 30, 2017 | Monitoring

The recent series of natural disasters has left a staggering toll of ruin and loss. The instinct of all involved, citizens, businesses and government, is to clear the debris, restore energy and communications, and rebuild and repair infrastructure and buildings as quickly as possible.

Indeed, the recovery work itself is a cathartic experience that expresses hope in a restored future and the determination to get there.

Unfortunately, massive recovery efforts contain the seeds of their own failures, presenting fertile opportunity Read More

The Coming of the Cyber Monitor

January 20, 2016 | Cyber Security Monitoring

Regulators, like prosecutors, are increasingly turning to independent monitors as a means of moving non-compliant entities into compliance. It appears certain that the appointment of independent monitors to enforce compliance with cybersecurity regulations will become common.  Several financial industry regulators are moving to establish cybersecurity standards with which financial institutions will have to comply just as they do with money laundering and other regulations.

This past November, the New York State Department of Financial Services issued a memorandum to numerous
Read More

  • 1