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Compliance Gatekeepers

Harvard Corporate Governance

Compliance has become a critical corporate governance issue. In response, companies pour billions of dollars into compliance programs meant to prevent and detect wrongdoing by their employees. Yet there remains much skepticism regarding the effectiveness of these compliance programs. more…)

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Strategic Compliance

Harvard Corporate Governance

Corporate compliance is at an inflection point, putting pressure on companies to reinforce their compliance programs more than ever before. Corporate policies serve as a blueprint for company-wide compliance programs, implementing compliance efforts into companies’ daily operations.

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Key Updates to the DOJs Evaluation of Corporate Compliance Programs

Harvard Corporate Governance

Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP) guidance. First published in 2017, the ECCP sets out factors that DOJ Criminal Division prosecutors will consider when evaluating the compliance program of a company facing a criminal enforcement action. On September 23, 2024, the U.S.

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DOJ Announces Changes to Corporate Compliance Program Evaluation Criteria

Harvard Corporate Governance

and other US government officials announced significant changes to the US Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (ECCP) and continued to emphasize the importance of effective and robust compliance policies.

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SEC Press Release provides Compliance Checklist for Corporations

Harvard Corporate Governance

Increasingly, as part of settlements, the commission has insisted that companies retain an independent compliance consultant who will report back to the staff of the SEC’s Division of Enforcement on compliance-related undertakings.

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Determining Whether Your Corporate Compliance Program is “Good Enough”

Harvard Corporate Governance

Business leaders of companies operating outside of the financial services industry (“corporates”) are more frequently asking their legal and/or compliance departments a variation of the following question: “Is our company’s compliance program good enough?”. more…).

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Empowering Corporate Compliance Functions in a Post-Pandemic Environment

Harvard Corporate Governance

The US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC) have issued a number of policy updates and public pronouncements over the last several months, emphasizing the importance of empowered and accountable corporate compliance programs. Ensure compliance has the resources to do its job. more…).