Program on Corporate Compliance and Enforcement

CORPORATE LAW IN THE PUBLIC INTEREST

The NYU Program on Corporate Compliance and Enforcement (PCCE) is a law and policy program dedicated to developing a richer and deeper understanding of the causes of corporate misconduct and the nature of effective enforcement and compliance.

PCCE is directed by faculty co-directors Jennifer Arlen '86 and Geoffrey Miller and executive director Serina M. Vash. Through practical discourse and legal scholarship, PCCE seeks to help shape optimal enforcement policy, guide firms in developing more effective and robust compliance programs, and enhance education in the field of corporate compliance and enforcement. Each year, several students are accepted into the program, enabling them to gain unparalleled expertise in this area, both through courses and through access to leading practitioners. No other leading law school offers the same depth and breadth of courses by full-time faculty in this area.

Read Mission Statement

Upcoming Events

September 10, 2015
Deputy Attorney General Sally Quillian Yates Addresses Individual Liability for Corporate Wrongdoing in a Speech Hosted by PCCE
Greenberg Lounge  |  12:45 PM - 1:45 PM 

The NYU Program on Corporate Compliance and Enforcement will sponsor an address by Deputy Attorney General Sally Quillian Yates on the Justice Department’s commitment to ensuring individual accountability in matters of corporate wrongdoing.  By Invitation Only.

September 16, 2015 
Red Card for FIFA: Inside the Case Against Global Soccer
PCCE Co-Hosts the Milbank Tweed Forum    Greenberg Lounge  |  12:45 PM - 2:00 PM

This Forum, co-hosted by the Program on Corporate Compliance and Enforcement, will explore the federal investigation that led to the indictment of nine world soccer officials in an alleged $150 million bribery scheme. Join us for a discussion of how the investigation came about, what the racketeering, wire fraud, and money laundering charges mean for the individual defendants and FIFA, and why the US was able to—and chose to—exercise jurisdiction. Panelists include former prosecutors (two now defense lawyers) and one of the world’s leading soccer journalists.
Panel
Marc Agnifilo –  Senior Trial Counsel, Brafman & Associates
Antonia Apps – Partner, Milbank, Tweed, Hadley & McCloy
Marshall Miller – Senior Fellow, Program on Corporate Compliance and Enforcement, NYU School of Law
Serina Vash (Moderator)  – Executive Director, Program on Corporate Compliance and Enforcement
Grant Wahl  – Senior Writer, Sports Illustrated

September 29, 2015 
An Address by the President of Paraguay His Excellency Horacio Cartes  |  Lipton Hall  | 10:00 AM – 11:00 AM 

Together with NYU President John Sexton and the Center for Latin American and Caribbean Studies, the Program on Corporate Compliance and Enforcement  is pleased to welcome His Excellency Horacio Cartes to New York University for an address entitled, "Introducing Paraguay: A Land of Opportunity." President Cartes will discuss crucial reforms promoted by his Administration on : (i) poverty reduction and social inclusion, (ii) anti-corruption, public sector transparency and accountability; and (iii) Paraguay’s openness to the global economy.  President Cartes will also discuss Paraguay’s potential to become a business and industrial hub in Latin America and President Cartes’ groundbreaking educational initiative.    

April 8-9, 2016
Conference on Corporate Criminal Enforcement Policy

This conference will bring together enforcement officials, academics, white collar defense lawyers, judges, and other prominent members of the bar for an invitation-only event to discuss the evolution, efficacy and future of corporate criminal enforcement policy for individuals and firms, both in the United States and abroad.  Chatham House Rule will apply.  By Invitation Only.

Keynote Speaker:  Director David Green of the Serious Fraud Office (UK)
Conference OrganizerJennifer Arlen

Recent Headlines

July 28, 2015

Marshall L. Miller, Former Principal Deputy Attorney General and Chief of Staff of the USDOJ Criminal Division, to Join NYU Program on Corporate Compliance and Enforcement

The NYU Program on Corporate Compliance and Enforcement (PCCE) is pleased to announce that Marshall L. Miller, former Principal Deputy Attorney General and Chief of Staff of the USDOJ Criminal Division, will join PCCE in September as a Senior Fellow.  Miller is the third former government official to join the Program in less than a year.  He joins Senior Fellow Danny Alter, former General Counsel of the New York Department of Financial Services, and Executive Director Serina M. Vash, former Deputy Chief of the Criminal Division at the USAO in the District of New Jersey, at NYU School of Law's Washington Square Campus.  Read more about Marshall L. Miller's career at the DOJ and NY Times links below.

Top Official at Justice Dept. to Leave Post
New York Times 

Justice Department Announces Departure of Criminal Division Leader Marshall L. Miller
DOJ Press Release

Recent Events

June 17, 2015 
Professor Jennifer Arlen Delivers Keynote Address at the Third Annual Thai National Anti-Corruption Commission Conference in Bangkok

Speaking on "Deterring Corruption Through Effective Corporate Criminal Enforcement," Jennifer Arlen, Norma Z. Paige Professor of Law at NYU School of Law, addressed a packed auditorium of international legal experts at Third Annual Thai National Anti-Corruption Conference in Bangkok.  The conference is sponsored by the Thai National Anti-Corruption Commission, the World Bank and Transparency International.

May 8, 2015
Achieving Safe and Responsible Enterprise: Principles of Effective Compliance and Emerging Government Enforcement Policy

This one-day invitation only conference will bring together leaders in the compliance and enforcement worlds— prominent academics, general counsels, government officials, defense lawyers, judges and compliance officials — to discuss the principles of effective corporate compliance and the attendant emerging enforcement policy. Three of our four sessions will focus on the principles of effective compliance; corporate structure and the interplay of corporate controls on achieving effective compliance; and the effects of a corporation’s compliance efforts on enforcement action and how to treat corporate compliance in terms of enforcement policy. The afternoon presentation, entitled ALI Principles of the Law, Compliance, Enforcement, and Risk Management for Corporations, Nonprofits and Other Organizations, will focus on the development of a comprehensive legal treatise on the laws of compliance, enforcement, risk management and governance. Conference Organizer: Geoffrey P. Miller
Conference Agenda: View Here
 

April 17-18, 2015
Conference on Corporate Crime and Financial Misdealing

An interdisciplinary conference involving scholars from law, business, sociology, economics, and psychology who will present original papers on corporate crime and securities fraud. The papers will be published in the Research Handbook on Corporate Crime and Financial Misdealing (Jennifer Arlen ed., Edward Elgar Press). Conference participants include: Jennifer Arlen, Cindy Alexander, Miriam Baer, Samuel Buell, Stephen Choi, Mark Cohen, Kevin Davis, David Engstrom, Brandon Garrett, Vic Khanna, Michael Klausner, Geoffrey Miller, Adam Pritchard, Sally Simpson, Matthew Stephenson, and Tom Tyler. 
Conference Organizer: Jennifer Arlen.
Conference Agenda: View Here  
Download CLE Materials and Academic Papers
(Password Protected for Conference Attendees Only)

February 25, 2015

PCCE and the Milbank Tweed Forum Co-Host
Banks Behind Bars: Convicting BNP Paribas and Credit Suisse

If 2013 was the year of "too big to jail," 2014 was the year for convicting financial institutions.  In May, federal prosecutors sent a signal that no bank is too big to escape criminal sanctions, when they pressured Credit Suisse's parent company to plead guilty to conspiracy to aid and assist U.S. taxpayers file false tax returns; the bank paid $2.6 billion, the highest amount ever in a criminal tax case. Later in the summer, BNP Paribas agreed to pay $8.9 billion for illegally processing financial transactions for countries subject to U.S. economic sanctions. The move came after BNP separately pleaded guilty to criminal charges of conspiracy and filing false business records in New York state court.  These convictions were made possible, in part, by coordinated enforcement between the U.S. Attorney's office, New York Attorney General and New York Department of Financial Services. Join us for an in-depth discussion of how these convictions came about and what they portend for the future. The panelists included four people who were on the front lines, both for the prosecution and the defense.  View full program here.

November 18, 2014

ALI Announces Principles of the Law, Compliance, Enforcement, and Risk Management for Corporations, Nonprofits, and Other Organizations with PCCE's Faculty Co-Directors Geoffrey P. Miller and Jennifer Arlen

The NYU Program on Corporate Compliance and Enforcement is excited to announce that faculty co-directors Geoffrey P. Miller and Jennifer Arlen have partnered with the American Law Institute to author a Restatement of the Law in the areas of corporate compliance and enforcement. The target audience for this project includes outside counsel specializing in the areas of compliance and risk management; in-house attorneys, compliance officers, and other personnel who carry out internal control responsibilities; government regulators and prosecutors; and commentators, scholars, and people involved in law reform initiatives. The project will be divided into four parts: compliance, enforcement, risk management, and governance. Geoffrey P. Miller, New York University School of Law and Faculty Co-Director of the Program on Corporate Compliance and Enforcement is the Reporter for the Project. Jennifer Arlen, Norma Z. Paige Professor of Law and Faculty Co-Director of the Program on Corporate Compliance and Enforcement is the Associate Reporter covering Enforcement.

September 17, 2014

US Attorney General Eric Holder on Corporate Crime and Compliance

The NYU Program on Corporate Compliance and Enforcement and the Milbank Tweed Forum co-sponsored an address by US Attorney General Eric Holder on "Corporate Crime and Compliance." View AG's speech here.

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