DOJ Compliance Program Guidance

Earlier this year the Department of Justice (DoJ) issued two publications for prosecuting attorneys to provide guidance on assessing the effectiveness of corporate compliance programs. The two publications (April 2019 and July of 2019) further develop and update the “Evaluation of Corporate Compliance Programs,” issued by the Criminal Division’s Fraud Section released in February 2017 […]

Federal Energy Regulatory Commission v. Vitol Inc. and Federico Corteggiano – A case study

Overview The FERC v. Vitol/Corteggiano matter is interesting on several different levels and telling from a compliance expectations standpoint. The matter involves the arcane world of congestion revenue rights (CCRs). The allegation made by FERC is that the Vitol trader understood the mathematical models (and the workings of those models) to such an extent that […]