It’s easy to get caught up in the dogma of how compliance programs have historically been managed.
Entries in FCPA Guidance (28)
Lanny Breuer, who stepped down this month after heading the DOJ's criminal divison for four years, has returned to Covington & Burling to be the law firm’s vice chair.
As companies struggle to deal with compliance issues in the expanding global markets, they can no longer rely solely on automated compliance. Today compliance should also be intelligent.
The Justice Department said today that Assistant Attorney General Lanny Breuer, head of the Criminal Division and the FCPA Unit, will leave on March 1.
Lanny Breuer, the head of the Justice Department's criminal division, is reported to be preparing his exit.
Before the Siemens case and the birth of the modern era of FCPA enforcement, there were the ten elements of an effective compliance program. They came from the U.S. federal sentencing guidelines applicable to corporate defendants.