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Jon Umarov, Associate at The Volkov Law Group, returns as a guest contributor. His profile is available here. Jon can be reached at jumarov@volkovlaw.com. The Russian government adopted significant reforms to the country’s pharmaceutical industry starting in 2008. According to a 2012 survey of the Russian pharmaceutical
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We all know the jokes about lawyers. We have heard them over and over, at parties, with friends, and among colleagues. Right now, they seem particularly on point. The Valukas Report lays out an ugly picture of in-house counsel at GM. If you have the stomach to read the
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The Department of Justice and the Treasury Department have stepped up AML/BSA and Sanctions Enforcement. With the ever-increasing expansion and modification of sanctions, risks for all businesses, not just financial institutions, have increased exponentially. DOJ and the Treasury Department have warned banks and financial institutions to increase AML/
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“What we’ve got here is a failure to communicate”—Captain in Cool Hand Luke Sometimes Chief Ethics and Compliance Officers need to zero in on an issue because it is critical to the operation of an ethics and compliance program. I am not suggesting that CECOs should never focus
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The Valukas Report to the General Motors Board of Directors Regarding Ignition Switch Recalls is a lengthy report that describes in excruciating detail how GM failed to uncover and remedy significant safety issues relating to an ignition switch used in various GM model cars. It is easy to lose perspective
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The Volkov Law Group is offering a great opportunity for experienced attorneys seeking a position with a nationally-recognized boutique law firm. A leader in anti-corruption compliance and defense, the Volkov Law Group offers an innovative work environment with virtual offices on both east and west coasts. The Firm
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Chief compliance officers are under intense pressure. They are being watched inside every company to make sure they deliver on their “compliance” program, and outside observers are ready to comment on any misstep or breakdown in corporate compliance. It is a wonder that CCOs can get their job done. They
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The bedrock of a compliance program is corporate culture. Let’s all agree to throw away the following often-repeated phrases: ”tone-at-the-top” and “buzz at the bottom.” I would argue that we replace those trite and meaningless phrases with the all-important one – “culture of ethics.” There
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Global companies have to design and implement an efficient process for conducting internal investigations. An effective ethics and compliance program requires companies to screen complaints, assign appropriate resources to each, and resolve investigations in a fair and even-handed way. The internal investigation process provides important insights that can be
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Corporate boards have been under siege. If you ask a Board member about the changes in corporate governance, risk and accountability, they roll their eyes and lament that the job of a board member has become more complicated and difficult. Let’s try and look at the experience from their
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I always enjoy listening to the legal “doomsayers” who love to propound hysterical claims in an effort to gain attention. It reminds me of little children screaming for attention. Unfortunately, in the case of lawyers, they tend to wear suits, earn lucrative salaries and are respected in their professional community.
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I am always wary of definitive “best practices” lists. By definition, “best practices” vary depending on the size and nature of an organization in any compliance context. This variability is applicable to the financial industry. AML/BSA compliance can have a dramatic impact on one business but little impact on