31 Days to a More Effective Compliance Program

One Month to a More Effective Compliance Program Through Data-Driven Compliance: Day 1-Introduction to Data-Driven Compliance

01 Dec 2023

Contributed by Lukas

In the world of compliance, data analytics and monitoring have become increasingly important. The Department of Justice (DOJ) has emphasized the signi...

One Month to a More Effective Compliance Program Through Culture - Improve Corporate Culture Through an Internal Podcast

30 Nov 2023

Contributed by Lukas

One of the biggest benefits of podcasting is that it allows businesses to connect with their audience more personally. Unlike traditional forms of adv...

One Month to a More Effective Compliance Program Through Culture: Day 16 - How a Culture of Speak Up Improves Corporate Culture

29 Nov 2023

Contributed by Lukas

What is a speak-up culture, and how does it improve the overall corporate culture? A speak-up culture is a work environment where open communication i...

One Month to a More Effective Compliance Program Through Culture-Day 15-The ROI of a Culture of Speak Up

28 Nov 2023

Contributed by Lukas

We are now at a place where there is sufficient data, academic research, and actual use cases from corporations and businesses that demonstrate good e...

One Month to a More Effective Compliance Program Through Culture: Day 14 - How Investigative Triage Can Drive Culture

27 Nov 2023

Contributed by Lukas

One area that organizations rarely consider impacting culture is the assessment and triage process in a hotline or speak up process. A proactive appro...

One Month to a More Effective Compliance Program Through Culture - Day 13 - Preventing Retaliation to Improve Culture

17 Nov 2023

Contributed by Lukas

Retaliation against a person who speaks up is a pervasive issue that not only creates a toxic work environment but also discourages victims from repor...

One Month to More Effective Compliance Through Culture: Day 12 - Fixing an Unsafe Workplace

16 Nov 2023

Contributed by Lukas

We continue to look at fostering an ethical culture through psychological safety, using as a starting point the “Fostering Ethical Conduct Through P...

One Month to a More Effective Compliance Program Through Culture: Day 11 - Psychological Safety in the Middle

15 Nov 2023

Contributed by Lukas

Advancing ethical culture through psychological safety can be a powerful tool. But how can you determine the state of psychological safety in your org...

One Month to a More Effective Compliance Program Through Culture: Day 10 - Improving Culture Through Investigations

14 Nov 2023

Contributed by Lukas

Meric Bloch strongly emphasizes the importance of workplace investigations and fostering a culture of employee compliance. He believes that merely set...

One Month to a More Effective Compliance Program Through Culture: Day 9-Fostering Culture with Psychological Safety

13 Nov 2023

Contributed by Lukas

How can you improve corporate culture through speaking up? In an MIT Sloan Management Review, Summer edition, entitled “Fostering Ethical Conduct Th...

One Month to a More Effective Compliance Program Through Culture: Day 8 - A Listening Tour to Improve Culture

10 Nov 2023

Contributed by Lukas

Any top CEO must first listen. But it is more than simply listening to rebuild trust, it is rebuilding employee engagement by making them and their id...

One Month to a More Effective Compliance Program Through Culture: Day 7 - To Improve Culture, Engage More

09 Nov 2023

Contributed by Lukas

One thing I have learned in working with Carsten Tams is that one of the very top keys to a successful compliance program is employee engagement. Tams...

One Month to a More Effective Compliance Program Through Culture: Day 6 - Attributes of a Toxic Culture

08 Nov 2023

Contributed by Lukas

Corporate culture is finally being acknowledged as a key ingredient in a successful business, particularly one that operates ethically and in complian...

One Month to a More Effective Compliance Program Through Culture: Day 5 - Redesigning Culture

07 Nov 2023

Contributed by Lukas

How can you think through a different way to redesign your culture and compliance program based on an article in MIT Sloan Management, entitled The F...

One Month to a More Effective Compliance Program Through Culture: Day 4 - Assessing and Aligning your Corporate Values

06 Nov 2023

Contributed by Lukas

One of concepts enshrined in the Monaco Memo is that the Department of Justice (DOJ) will assess corporate culture for any company that may find its...

One Month to a More Effective Compliance Program Through Culture: Day 3 - Compliance and Corporate Principles in Today’s World

03 Nov 2023

Contributed by Lukas

For corporations, navigating the political landscape has become an increasingly difficult task. While being admonished to ‘stay in their lane’ by ...

One Month to a More Effective Compliance Program Through Culture: Day 2 – Getting Culture Right

02 Nov 2023

Contributed by Lukas

Vin DiCianni, founder of Affiliated Monitors, Inc. (AMI), talked about the Monaco speech and culture. He said, “The announcement by Deputy Attorney ...

One Month to a More Effective Compliance Program Through Culture: Day 1 - Introduction

01 Nov 2023

Contributed by Lukas

In her October 2021 speech, presaging the Monaco Memo, Deputy Attorney General Lisa Monaco talked at length about the importance of corporate culture....

One Month to a More Effective Compliance Program Through Innovation: Day 15 – Leveraging AI in Compliance Investigations

20 Oct 2023

Contributed by Lukas

The 2023 ECCP provided clear-cut criteria regarding effective compliance investigations. Unfortunately, many compliance teams fail to promptly substan...

One Month to A More Effective Compliance Program Through Innovation: Day 14 – Creating an Inventory of Metrics

19 Oct 2023

Contributed by Lukas

The 2023 ECCP not only continued to emphasize the importance of monitoring and testing the effectiveness of a compliance program, but it spoke more ab...

One Month to a More Effective Compliance Program Through Innovation: Day 13 – Consistency as a Compliance Best Practice

18 Oct 2023

Contributed by Lukas

The 2023 ECCP emphasized the need for the corporate compliance function to ensure consistency and fairness in monitoring investigations and the result...

One Month to a More Effective Compliance Program: Day 12 – A Seat at the Table

17 Oct 2023

Contributed by Lukas

Going into the 2020s and beyond, a corporate compliance function must be integral to your business strategy. One of the key reasons is that the ever-i...

One Month to a More Effective Compliance Program Through Innovation: Day 11 – Compliance Innovation Through KPIs

16 Oct 2023

Contributed by Lukas

Measuring your compliance program’s effectiveness will be a critical criterion going forward. One of the mechanisms to do so is through Key Performa...

One Month to a More Effective Compliance Program Through Innovation: Day 10 – Connected Compliance

13 Oct 2023

Contributed by Lukas

Disconnectedness compliance comes from the fact that there is not one system that connects the disparate strands of the compliance discipline. Connect...

One Month to a More Effective Compliance Program Through Innovation: Day 9 - The Competitive Advantage of Data

12 Oct 2023

Contributed by Lukas

The DOJ and SEC have both made it clear that they expect companies to be more robust in their use of data analytics in compliance programs. This means...

One Month to a More Effective Compliance Program Through Innovation: Day 8 – The Compliance Function into the 2030s and Beyond

11 Oct 2023

Contributed by Lukas

Today, we look at the Compliance Function. The pandemic accelerated changes in compliance that have been percolating for the last few years. Indeed, I...

One Month to a More Effective Compliance Program Through Innovation: Day 7-Skills for the Compliance Professional in 2025 and Beyond

10 Oct 2023

Contributed by Lukas

What should compliance practitioners do to move themselves forward professionally in 2025 and beyond? To consider this question, I drew inspiration fr...

One Month to More Effective Compliance Through Innovation: Day 6 – Future of Compliance Training

09 Oct 2023

Contributed by Lukas

Where is compliance training headed? In the 2020 Update, the DOJ stated, “companies have invested in shorter, more targeted training sessions to ena...

One Month to a More Effective Compliance Program Through Innovation: Day 5 - Communication to see Around Corners

06 Oct 2023

Contributed by Lukas

The more you can operationalize compliance, the more it works to operationalize culture in your organization. It works for all levels of a company, li...

One Month to a More Effective Compliance Program Through Innovation: Day 4 - The ROI of Effective Compliance

05 Oct 2023

Contributed by Lukas

We are now at a place where there is sufficient data, academic research, and actual use cases from corporations and businesses that demonstrate good e...

One Month to a More Effective Compliance Program Through Innovation: Day 3 – The Digital Transformation of Compliance

04 Oct 2023

Contributed by Lukas

Through restructuring, senior leadership can signal that digital transformation in compliance is critical for the future of the organization. From thi...

One Month to a More Effective Compliance Program Through Innovation: Day 2 – Taming Complexity in Compliance

03 Oct 2023

Contributed by Lukas

One of the lessons we have learned from various FCPA enforcement actions over the years is how complexity in business organizations can work to defeat...

One Month to a More Effective Compliance Program Through Innovation: Day 1 - Originating a Compliance Ecosystem

02 Oct 2023

Contributed by Lukas

The compliance profession seems to be an inflection point, moving away from the lawyer-driven written policies and procedures to a more operationalize...

One Month to More Effective Written Standards: Day 18: Polices on extortion payments

29 Sep 2023

Contributed by Lukas

The next area for policies is extortion payments, which not are made illegal under the FCPA. Extortion payments are made for any action which threaten...

One Month to More Effective Written Standards: Day 17: Policies for third-parties

27 Sep 2023

Contributed by Lukas

As every compliance practitioner is well aware, third-parties still present the highest risk under the FCPA. The DOJ 2023 ECCP devotes an entire prong...

One Month to More Effective Written Standards: Day 16: Policies on Facilitation Payments

26 Sep 2023

Contributed by Lukas

From the information provided by the DOJ in Opinion Releases and in enforcement actions, there are several different insights which may be drawn on re...

One Month to More Effective Written Standards: Day 15: Enforcement Actions Featuring Facilitation Payments

25 Sep 2023

Contributed by Lukas

One of the more confusing areas of the FCPA is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, ...

One Month to More Effective Written Standards: Day 14-the Problem with Facilitation Payments

22 Sep 2023

Contributed by Lukas

The original version of the Foreign Corrupt Practices Act (FCPA), enacted in 1977, contained an exception for payments made to non-US officials who pe...

One Month to More Effective Written Standards: Day 13-Policies on Political Contributions

21 Sep 2023

Contributed by Lukas

The FCPA states, “The FCPA’s anti-bribery provisions apply to corrupt payments made to (1) “any foreign official”; (2) “any foreign politica...

One Month to More Effective Written Standards: Day 12-Policies on Charitable Donations

20 Sep 2023

Contributed by Lukas

What should your compliance policy and procedures on charitable donations look like? What should you prohibit or even caution against? The starting po...

One Month to More Effective Written Standards: Day 11 - Charitable Donation Enforcement Actions

19 Sep 2023

Contributed by Lukas

When is a rose not a rose? When it is a charitable donation not made for philanthropic purposes and violates the FCPA. This was a feature of the Eli L...

One Month to More Written Standards: Day 10 - Policies and procedures on gifts and business entertainment

18 Sep 2023

Contributed by Lukas

If one were to reflect upon the providing of gifts and business entertainment to foreign governmental officials, one might reasonably conclude that af...

One Month to More Effective Written Standards: Day 9-Dynamic Compliance Policies

15 Sep 2023

Contributed by Lukas

One of the key changes coming out of the Covid-19 pandemic is the need for dynamism on corporate policies. This message was driven home in a  MIT Sl...

One Month to More Effective Written Standards: Day 8: Revising Your Policies and Procedures

14 Sep 2023

Contributed by Lukas

More than simply having a Code of Conduct, compliance policies and procedures are required. As former Assistant Attorney General Lanny Breuer articula...

One Month to More Effective Written Standards: Day 7 - Policies and Procedures

13 Sep 2023

Contributed by Lukas

There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the ...

One Month to More Effective Written Standards: Day 6 - Operationalization of your Code of Conduct

12 Sep 2023

Contributed by Lukas

How can you work to operationalize your Code of Conduct as articulated in the DOJ 2023 Evaluation of Corporate Compliance Programs (ECCP)? The 2023 ...

One Month to More Effective Written Standards: Day 5 - Training on your Code of Conduct

11 Sep 2023

Contributed by Lukas

What about the training on your finalized Code of Conduct? While there have been criticisms of code training, if you consider training as one source o...

One Month to More Effective Written Standards: Day 4-Code of Conduct: Structure and format

08 Sep 2023

Contributed by Lukas

Next comes the evolution of the structure and format of a best practices Code of Conduct. Initially, my experience with this is that they were written...

One Month to More Effective Written Standards: Day 3-Code of Conduct

07 Sep 2023

Contributed by Lukas

What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to wave in the regul...

One Month to More Effective Written Standards: Day 2-Clearly Articulated Written Standards

06 Sep 2023

Contributed by Lukas

The written standard requirements have long been memorialized in the U.S. Sentencing Guidelines, which contain seven basic compliance elements that ca...

One Month to More Effective Written Standards: Day 1 - Introduction to Written Standards

05 Sep 2023

Contributed by Lukas

Welcome to the September edition of One Month to a More Effective Compliance Program. In this month, we will consider written standards. his month we'...

One Month to a More Effective Compliance Program: Day 21 - Ten Compliance Questions To Pose To HR

29 Aug 2023

Contributed by Lukas

As we end this month on the intersection of HR and compliance, I have developed a series of goals and objectives which you might want to use as a star...

One Month to a More Effective Compliance Program: Day 20-Gap Analysis for HR

28 Aug 2023

Contributed by Lukas

Join Tom Fox in this episode of the 31 Days to a More Effective Compliance Program podcast to delve deeper into the significant role of HR in implemen...

One Month to a More Effective Compliance Program: Day 19 - Compliance Culture At The Bottom

25 Aug 2023

Contributed by Lukas

One of the most important focuses of the DOJ’s 2023 ECCP was around culture. This means how far has the culture of compliance been driven down into ...

One Month to a More Effective Compliance Program: Day 18 - Operationalizing Compliance in the Middle

24 Aug 2023

Contributed by Lukas

The DOJ has clarified that middle management is critical to any compliance program’s success. While it does all start at the top, with the Board of ...

One Month to a More Effective Compliance Program: Day 17 – Promotions to Operationalize Compliance

23 Aug 2023

Contributed by Lukas

Welcome back as we dive into the role of HR in compliance and ethics. Today, we will explore the significant role of HR in operationalizing compliance...

One Month to a More Effective Compliance Program: Day 16 - The Exit Interview

22 Aug 2023

Contributed by Lukas

 Today, we're diving into the significance of exit interviews in fully operationalizing a best practices compliance program. Exit interviews provide ...

One Month to a More Effective Compliance Program: Day 15 - Employment Separation Issues and Compliance

21 Aug 2023

Contributed by Lukas

Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they wer...

One Month to a More Effective Compliance Program: Day 14 - Hiring A CCO: Developing The Job Profile

18 Aug 2023

Contributed by Lukas

What should a company do when it desires to hire a CCO? To do so, a company needs to fully understand and appreciate what it needs from such a positio...

One Month to a More Effective Compliance Program: Day 13 - Compliance Performance Appraisal Review

17 Aug 2023

Contributed by Lukas

One of the ways to operationalize compliance and to drive it into the DNA of an organization is through a performance review. Indeed, the 2023 ECCP st...

One Month to a More Effective Compliance Program: Day 12 - Succession Planning Around Compliance

16 Aug 2023

Contributed by Lukas

Another area where Human Resources can help to more fully operationalize compliance is in succession planning. Succession planning is just as importan...

One Month to a More Effective Compliance Program: Day 11 - Institutional Justice and Institutional Fairness

15 Aug 2023

Contributed by Lukas

Companies have finally come to realize that institutional justice and fairness are perhaps the most basic tenet of any successful workplace. If employ...

One Month to a More Effective Compliance Program: Day 10 - Sales Incentives and Compliance

14 Aug 2023

Contributed by Lukas

In the DOJ’s 2023 ECCP, Incentives and Disciplinary Measures it stated: Incentive System – Has the company considered the implications of its inc...

One Month to a More Effective Compliance Program: Day 9 - Clawbacks

11 Aug 2023

Contributed by Lukas

In this podcast series, host Tom Fox explores the growing emphasis on clawback provisions in compliance programs and employee compensation. The Depart...

One Month to a More Effective Compliance Program: Day 8-Executives and Compliance Compensation Incentives

10 Aug 2023

Contributed by Lukas

The lack of personal consequences for senior executives responsible for corporate malfeasance is explored in this podcast episode. Executives are ince...

One Month to a More Effective Compliance Program: Day 7-Designing compensation to operationalize compliance

09 Aug 2023

Contributed by Lukas

In this podcast episode, Tom Fox highlights the importance of incorporating compensation systems into a company's compliance program. He discusses how...

One Month to a More Effective Compliance Program: Day 6-Six Core Principles for Compliance Incentives

08 Aug 2023

Contributed by Lukas

In these podcast episodes, Tom discusses the importance of incorporating incentives and support systems into a company's compliance program. He presen...

One Month to More Effective HR in Compliance: Day 5 - Role of HR in Incentivizing Compliance

07 Aug 2023

Contributed by Lukas

Welcome to the August edition of One Month to a More Effective Compliance Program. In the month of August, 2023 we will consider the role of Human Res...

One Month to a More Effective Compliance Program: Day 4-The Reference Check

04 Aug 2023

Contributed by Lukas

As far back as 2004, in Opinion Release 04-02, the DOJ realized this was an important part of an overall compliance program when it approved a propos...

One Month to a More Effective Compliance Program: Day 3-the Hiring Process and Compliance

03 Aug 2023

Contributed by Lukas

One of the conventional wisdoms about compliance training is that you will never be able to reach 5% of your workforce with compliance training becaus...

One Month to More Effective HR in Compliance: Day 2-The Role of HR in Creating an Ethical Culture

02 Aug 2023

Contributed by Lukas

The 2023 Evaluation of Corporate Compliance Programs, (ECCP), made clear that operationalization of compliance into an organization should be done at ...

One Month to More Effective HR in Compliance: Day 1-The Role of HR in Compliance

01 Aug 2023

Contributed by Lukas

I have long advocated for a greater role of Human Resources (HR) in compliance. Indeed, one sign of a mature compliance and ethics program is the e...

One Month to More Effective Reporting and Investigations - the Parameters of Privilege

31 Jul 2023

Contributed by Lukas

The concept of privilege in an internal investigation is critical. Two important privileges are the attorney-client privilege and the work product pri...

One Month to More Effective Reporting and Investigations - Miranda Warnings for Employees?

28 Jul 2023

Contributed by Lukas

Must an investigator warn an employee that concealing information from company lawyers conducting an internal FCPA investigation could be a federal cr...

One Month to More Effective Reporting and Investigations - Board Investigations

27 Jul 2023

Contributed by Lukas

In their article, “Successful Board Investigations”, David Bayless and Tammy Albarrán, offered seven considerations to facilitate a successful B...

One Month to More Effective Reporting and Investigations - Board Investigation Protocols

26 Jul 2023

Contributed by Lukas

Many companies have an investigation protocol in place when a potential compliance violation or other legal issue arises. However, many Boards of Dire...

One Month to Better Reporting and Investigations - How an investigation informs remediation

25 Jul 2023

Contributed by Lukas

There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to...

One Month to More Effective Reporting and Investigations – Issues in Cross Border Investigations

24 Jul 2023

Contributed by Lukas

In an article, entitled “Internal Investigations, How to Conduct an Anti-Corruption Investigation: Developing and Implementing the Investigation Pla...

One Month to More Effective Reporting and Investigations – The Witness Interview

21 Jul 2023

Contributed by Lukas

What are the characteristics of a good interview in the context of an internal investigation? Is there one technique you can use which will provide yo...

One Month to More Effective Reporting and Investigations - Investigative Challenges

20 Jul 2023

Contributed by Lukas

What are some of the top challenges you may well face during an investigation? Beyond the basics, a company must consider the intake process as a star...

One Month to More Effective Reporting and Investigations - The Investigative Team

19 Jul 2023

Contributed by Lukas

Since 2015, DOJ has put even more pressure on every CCO, compliance practitioner, and indeed company, to get an investigation done quickly, efficientl...

One Month to Better Reporting and Investigations - Selection of Investigative Counsel

18 Jul 2023

Contributed by Lukas

Dan Dunne, in a Compliance and Ethics Professional article, entitled “Foxes and henhouses: The importance of independent counsel”, discussed what ...

One Month to Better Reporting and Investigations - Preparing for the Investigation

17 Jul 2023

Contributed by Lukas

Under Part 1, Section D. Confidential Reporting Structure and Investigation Process stated in part, Properly Scoped Investigation by Qualified Perso...

One Month to Better Reporting and Investigations - The Investigation Protocol

14 Jul 2023

Contributed by Lukas

After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it, promptly, thoroughly, and with ...

One Month to Better Reporting and Investigations - Triage of Internally Reported Allegations

13 Jul 2023

Contributed by Lukas

One of the things that I learned from the television series M*A*S*H was the need for triage. In the hospital setting, triage is the process of determi...

One Month to More Effective Reporting and Investigations - Internal Reporting and Whistleblowers During Layoffs

12 Jul 2023

Contributed by Lukas

In Houston, we have experienced energy companies laying off upwards of 30% of their workforce, both in the US and abroad. Employment separations can b...

One Month to More Effective Reporting and Investigations - Answering DOJ Questions on Confidential Reporting

11 Jul 2023

Contributed by Lukas

What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include...

One Month to Better Reporting and Investigations - Internal Reporting System Best Practices

10 Jul 2023

Contributed by Lukas

What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include ...

One Month to More Effective Reporting and Investigations - Specific Benefits of a Hotline: A Case Study

07 Jul 2023

Contributed by Lukas

Is your hotline working for you? In an article, entitled, Promoting Effective Use of the Company Compliance Hotline, José Tabuena provided an excell...

One Month to More Effective Reporting and Investigations-Advantages of Internal Reporting

06 Jul 2023

Contributed by Lukas

While it is clear that the government expects companies to have an internal reporting system, there are benefits far beyond putting you in the governm...

One Month to More Effective Reporting and Investigations-Introduction

05 Jul 2023

Contributed by Lukas

The call, email, or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into...

One Month to a More Effective Compliance Program with Boards- 20 Questions Directors Should Ask about the Board Compliance Committee

30 Jun 2023

Contributed by Lukas

In an area of inquiry entitled Oversight, the 2023 ECCP asks three basic questions which we have explored throughout this chapter: 1. What compliance...

One Month to a More Effective Board - Vin DiCianni on Board Inquiries into Compliance

29 Jun 2023

Contributed by Lukas

Where does “tone at the top” start? With any public and most private U.S. companies, it is at the Board of Directors. But what is the role of a co...

One Month to a More Effective Compliance Program with Boards - 3 Areas of Board Inquiry

28 Jun 2023

Contributed by Lukas

There are three core areas upon which directors should focus their attention regarding to help establish and maintain an effective compliance program:...

One Month to a More Effective Compliance Program with Boards- Incorporating Compliance into a Long-Term Corporate Strategy

27 Jun 2023

Contributed by Lukas

How can a Board work incorporate the compliance function into a long-term business strategy of the organization? The starting point for a Board of Dir...

One Month to a More Effective Compliance Program with Boards- The Board and Succession Planning

26 Jun 2023

Contributed by Lukas

The 2023 ECCP mandated a Board of Directors ensure “the sufficiency of the personnel and resources within the compliance function, in particular, wh...

One Month to a More Effective Compliance Program with Boards- the Board Role in Hiring

23 Jun 2023

Contributed by Lukas

What is the role of a Board of Directors in hiring senior executives, CCOs and even other board members? I explored this issue with Candice Tal, who b...

One Month to a More Effective Compliance Program with Boards- Boards and Doing Business in China

22 Jun 2023

Contributed by Lukas

The Administration’s trade war with China has highlighted the risks of both doing business in China and investing the Chinese companies which come t...

One Month to a More Effective Compliance Program with Boards- Board Failures

21 Jun 2023

Contributed by Lukas

Today, consider a couple of landmark failures at the Board level around bribery and corruption. VimpelCom Ltd. In 2015 (now Veon Ltd.), the DOJ alleg...

One Month to a More Effective Compliance Program with Boards-Key Board Metrics for Compliance

20 Jun 2023

Contributed by Lukas

What are metrics for a Board of Directors around compliance? Former Assistant Attorney General Leslie Caldwell laid out some that the Department of Ju...