Compliance

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Why Are Your Policies Yelling at Me? It’s Time to Rethink Tone in Rules.

Based solely on tone, an employee could be forgiven for wondering if their organization considers setting fire to the office less serious than submitting a form after a deadline. Policy-writing expert and author Lewis Eisen examines this absurd reality: Many laws governing serious crimes use simple, respectful present-tense statements, yet many corporate policies are worded more harshly, complete with subtle...

woven threads

Common Threads: What Global Enforcers & Policy-Makers Are Saying About Compliance Programs

The compliance world loves its frameworks: DOJ's three fundamental questions, France's risk mapping requirements, the UK's "adequate procedures" standard. But strip away the bureaucratic packaging and something interesting emerges — these disparate approaches share much of the same DNA. Former DOJ prosecutor Andrew Gentin joined World Bank senior counsel Joseph Mauro, former OECD legal director Nicola Bonucci and Paul Hastings'...

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How the New Federal Student Loan Caps Could Affect the Next Generation of Compliance Leaders

Colleges and universities have faced major difficulties in recent years, ranging from decreasing enrollment to increasing negative public perception, but a new law that includes sweeping reforms to federal student loan programs may prove to be their toughest challenge yet, and CCI contributing writer Esther D’Amico explores how those challenges are likely to extend to the corporate integrity world.

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Rare Declinations by DOJ’s National Security Division Demonstrate Potential Benefits of Voluntary Disclosure — but Could Obscure the Risks

In a recent speech, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, discussed changes in how the DOJ intends to conduct corporate enforcement. The speech, which followed the recent announcements of declinations by the National Security Division, provides insight into how the DOJ is likely to conduct its investigations and make charging determinations as well as guidance to...

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