In the second quarter the Department of Justice (DOJ) issued two declinations which demonstrated that the DOJ Pilot Program is alive and well. Linde Gas and CDM Smith, both received declinations to prosecute by meeting the four prongs of the Pilot Program; (1) self-disclosure, (2) extensive cooperation, (3) extensive remediation, and (4) profit disgorgement. These cases demonstrate the clear advantages of self-disclosure as both companies had engaged in conduct which was clearly violative of the Foreign Corrupt Practices Act (FCPA).
K1 Combines Actiance and Smarsh to Create Global Compliance and Enterprise Information Archiving Leader4:00 pm -- November 16, 2017
CGOC Survey of Top Corporate Data Protection Challenges Reveals Only 6 Percent of Companies Feel Ready for GDPR Compliance7:43 pm -- October 31, 20176:00 am -- October 26, 20178:15 pm -- October 24, 2017