RESULTS FOR: DOJ
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
September 27, 2023 | Immigration + Border Services
In the realm of corporate risk, immigration-related concerns often take a back seat. But a closer look at the current Administration’s actions reveals where priorities lie and which industries, sectors, and companies may be in the crosshairs. Form I-9 audits and Immigration and Customs Enforcement (ICE) inspections have common associations with immigration risk. The Department of Justice (DOJ), particularly its Immigrant and Employee Rights (IER) component, is also aggressively scrutinizing U.S. companies’ hiring practices, which can lead to settlements, DOJ … Read More
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
As per an October 11, 2022 announcement, the U.S. Department of Homeland Security (DHS) and Immigration and Customs enforcement (ICE) has officially extended Form I-9 flexibilities, particularly for remote hire instances. Those relaxed procedures now expire on July 31, 2023. For employers, it is business as usual and no need to rush to get employees’ documents inspected in person at the beginning of November. The government does encourage employers to begin that process in good faith and with discretion.… Read More
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
October 7, 2019 | Compliance
The Fraud Division of the U.S. Justice Department unsealed an indictment recently that charged three traders associated with a global U.S.-based bank with a racketeering conspiracy that involved alleged manipulation of the precious metals markets through “spoofing.” The indictment alleges numerous specific instances of spoofing, over an approximately eight-year period, intended to improperly affect prices for precious metals and related options. The U.S. Commodity Futures Trading Commission filed a parallel civil action against the three traders as well, likewise charging … Read More
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