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Problem solved, right? With a vendor partner now in place to help remove the headaches associated with managing a review database, you should have it made it the shade. Hold on! You're certainly on the right track, but the job doesn't end once the vendor is chosen. There are still a number of technical items that need to be considered about this review environment before you can turn your entire review team loose on the data. An engineering assessment of the review environment itself will go a long way in helping identify potential problems and risks early on as well as becoming the first step toward a successful overall review. Following is a short checklist that can aid in this assessment process:
1. Who is the ISP?
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
This article explores legal developments over the past year that may impact compliance officer personal liability.