CRA team members were selected to review the policies for a European-based online gaming company that was concerned its compliance program had not kept up with its explosive growth. The team’s detailed review and interviews with stakeholders uncovered substantial gaps requiring remediation to align with global business operations. The team designed a comprehensive Code of Conduct and Business Ethics plan and made a series of recommendations including the hiring of a Chief Compliance Officer, requiring annual training of executives and staff, and visibly promoting Compliance as a core value of the company.
Safe Harbor for M&A-Driven Voluntary Self-Disclosures of Criminal Misconduct
On October 4, 2023, Deputy Attorney General Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for criminal misconduct discovered...