Effective Compliance Programs Look Beyond DOJ Guidance

July 31, 2019

Much ado has been made about the recent guidance on corporate ethics & compliance (E&C) programs issued by the U.S. Department of Justice (DoJ).  The attention is justified.  Starting with the Criminal Division’s Evaluation of Corporate Compliance Programs and continuing with the release of the Antitrust Division’s Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations, we now know more about the DoJ’s definition of “effectiveness” when it comes to E&C than ever before. Not […]

When your job is to teach corporations to do the right thing – CNN Business

June 26, 2019

Americans are concerned about some of the corporate practices that put people at risk: Mining and selling data in ways that compromise privacy. Using facial recognition software that leads to biased decisions. Sourcing materials from countries with few environmental or labor protections. That’s one reason why companies are putting more explicit emphasis on their ethical standards both publicly and internally. But how they formalize their commitment to ethics varies widely. There’s no hard data, but […]

FCPA Compliance Report – Episode 431, Pat Harned on ECI’s Impact 2019 Wrap Up

June 3, 2019

In this episode I visit with Pat Harned, CEO at the Ethics and Compliance Initiative. We discuss the ECI’s recently concluded annual conference, Impact 2019 and some of the highlights for both Pat and myself. The theme of the event was ECI’s High Quality Program (HQP) Framework Assessment. Some of the highlights from the podcast include: The key theme was the HQP Framework Assessment tool. How did the genius bar facilitate discussions around the tool? […]

FCPA Compliance Report-Bonus Episode — HQP and Framework Assessment

May 14, 2019

In special bonus episode, I present a full hour’s presentation of a panel discussion I recently chaired at the ECI Impact 2019 conference. The panel consisted of Steve Scarpino, Director, Ethics and Compliance at BP; Suzanne Mitchell, CCO at US Foods; and Karen Clapsaddle, Ethics Director Lockheed Martin. They were all involved in the design and creation of the ECI High Quality Program and had experience with the Framework Assessment. It was a great review […]


May 6, 2019

It should be mandatory reading for every Chief Compliance Officer (CCO), compliance practitioner and professional or any other person interested in the latest thinking of the Department of Justice (DOJ) on what constitutes a best practices compliance program.

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 2 – A Well Designed Program

May 3, 2019

We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics and Compliance Initiative (ECI) Impact 2019 Conference. It is an update to the 2017 Evaluation of Corporate Compliance Programs, released in February 2017. This new document is available for download at no charge. It should be mandatory reading for every Chief Compliance […]

Department of Justice Announces Sweeping New Guidance at ECI’s Annual Impact Conference

May 1, 2019

WASHINGTON, May 1, 2019 /PRNewswire/ — Assistant Attorney General for the Criminal Division, Brian Benczkowski, announced new guidance before an audience of leading ethics and compliance practitioners at the Ethics & Compliance Initiative’s (ECI) annual Impact conference. The AAG focused his presentation on the importance of an effective corporate compliance program and how such programs can influence prosecutorial outcomes. “We hope this updated version provides additional insight to both prosecutors and companies with respect to […]

AAG Brian A. Benczkowski Gives Keynote at the ECI’s 2019 Annual Impact Conference

April 30, 2019

Good afternoon and thank you for that gracious introduction. Thank you to the Ethics and Compliance Initiative for inviting me to speak today.    

The Ethics and Compliance Initiative Announces 2019 Annual Impact Conference

April 29, 2019

DALLAS, April 29, 2019 /PRNewswire/ — The Ethics & Compliance Initiative (ECI), America’s oldest ethics research and membership association has announced its 2019 Annual Impact Conference, which is set to take place during April 29th – May 2nd, 2019 at the Hilton Anatole in Dallas, TX.  In order to support High Quality Programs (HQP) , the ECI’s 2019 Annual Conference showcases forward-thinking practitioners, vendors, and innovations that can raise the bar for Ethics & Compliance (E&C) […]

Cynthia M. Patton of Amgen Inc. Awarded 2019 Carol R. Marshall Award for Innovation in Corporate Ethics

April 23, 2019

VIENNA, VA., April 22, 2019 — The Ethics & Compliance Initiative (ECI), the nation’s oldest ethics research and best practice community, today announced that Cynthia M. Patton, Senior Vice President and Chief Compliance Officer for Amgen, Inc., has been named this year’s recipient of the Carol R. Marshall Award for Innovation in Corporate Ethics. Each year, the prestigious Marshall Award is given to an ethics and compliance practitioner whose achievements exemplify the leadership and innovative […]