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The genesis of the Information Technology Department was fairly simple in its purpose: Find one of a few available applications to meet a need, get it installed, and support it. IT had never really been viewed as a profit center, only as necessary overhead. In the many years that IT has been fulfilling that role, we've seen an explosion of software and hardware choices to meet all of our daily needs. We're no longer looking at just the core apps as in the days of old, e.g., word processing, spreadsheets, human resources and sales databases. Now, you name the need and chances are good that there is an application out there to meet that need. With this comes a lot of investment: research, trial periods for testing, hardware, software, added personnel, training and consultants to name just a few.
Training and the IT Staff
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.