Author: Jason Lunday

And the Beat Goes On (Part 1)

New DOJ Antitrust Guidelines on Corporate Compliance Programs   For many, “And the Beat Goes On” awakens memories of Sonny & Cher’s anthem to changing times.   Perhaps not surprisingly, the words are just as applicable to business ethics—change keeps on coming.   This month, the US Department of Justice continued its push for change […]

And the Beat Goes On (Part 2)

And the Beat Goes On (Part 2)

New DOJ Antitrust Guidelines on Corporate Compliance Programs On homage to Sonny & Cher’s anthem to continuing change, let’s look at some new and some updated expectations in the new DOJ Antitrust Division’s July release of its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations. The Antitrust compliance guidelines reinforce the DOJ’s updated guidelines […]

The Department of Justice’s Gift That Keeps on Giving – Part 3

Two prior blogs have addressed the recently updated 2019 Department of Justice Evaluation of Corporate Compliance Program criteria. Department prosecutors use these criteria to assess an organization’s commitment to implementing and operating a compliance program when an organization comes before the Department, principally facing prosecution.   Among the chief factors that these criteria focus on […]

2018: The Year in Bribery

As 2018 passes on, one of the extraordinary aspects of the past year was the seeming normalization of bribery and corruption in the media. Yet despite the year’s headlines dominated by stories regarding sexual harassment, cyber security and data privacy, bribery was nonetheless the clear winner in news stories. One-Third of all News Headlines Involve […]

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