Sentencing Commission Confidential: Who Speaks To The Board?

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This time, in anticipation for a Sentencing Guideline presentation next month at the SCCE’s CEI in Washington DC, we have another belated edition of Sentencing Commission Confidential. Eric talks about a commonly overlooked or misunderstood part of Chapter Eight of the guidelines that sets out responsibilities for reporting to the Board (or governing authority) of…

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Three Key Components for Compliance Surveys

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These days it’s easy to find and use survey tools. While the tools have become more accessible and powerful, there are some steps you are going to want to carefully consider to produce the best results. Eric discusses three areas that he believes can help you design and deliver a more efficient and successful survey…

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Three Key Components for a Compliance Program Assessment

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This time Eric discusses compliance program assessments – or risk assessments – or program benchmarking – or whatever you want to call the periodic review of your program that the Sentencing Guidelines, USDOJ guidance and best practices call for. Eric discusses three key pieces of the puzzle you might want to consider whether you are…

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Do We Need Compliance Expertise on the Board?

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One of the questions raised by the recent updated USDOJ guidance is the question of “expertise” at or on the board of directors. Eric takes some time this week to discuss the guidance and the practical considerations about expertise in the boardroom. If you are interested in the intersection of compliance and the board of…

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3 Tips for an Excellent (Formal) Informal Communication Program

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One of the areas many compliance teams still struggle with is getting a consistent, effective informal communication plan off the ground. Eric has a few ideas that might help focus informal communication efforts at your organization. Eric talks about being realistic regarding time and resources and thinking strategically about what might reach your audience.

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New USDOJ Guidance -Conclusion

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After a dozen episodes detailing the new guidance, what are some parting thoughts? Eric talks a little about the memo’s impact and potential impact as well as highlighting some of the more important concepts the Department has chosen to highlight.

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New USDOJ Guidance – Part 10 – Does It Work?

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In Part 10 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric finishes discussing the memo! We will walk through Part III of the memo with a review of “Does the Corporation’s Program Work in Practice?” Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download

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New USDOJ Guidance – Part 9 – Incentives and Discipline

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In Part 9 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric finishes discussing Part II of the memo with a review of incentives and discipline expectations. Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download Also, check out Eric “live” in Houston on June 20, 2019 –…

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New USDOJ Guidance – Part 8 – Resources

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In Part 8 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric discusses the second topic in Part II of the memo: Autonomy and Resources. Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download Also, please take a look at Ryan McConnell’s comparison review of the new memo…

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New USDOJ Guidance – Part 7 – Management Commitment to Compliance

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In Part 7 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric discusses the first topic in Part II of the memo: Commitment by Management — or tone from the top, middle and everywhere else! Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download Also, please take a…

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