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To continue a “tradition” on Corruption Crime and Compliance, I like to end the year with recognition of the “person of the year,” referring to the institution which has had the most impact in the enforcement and compliance arena. Two years ago, I wrote a column naming the Chief Compliance
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The United States spends over $2.81 trillion dollars on health care annually and generates billions of claims from millions of health care service and product providers. The vast majority of these providers of services and products bill multiple payers, both private and public. In 2012, the Medicare program covered
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With all the hoopla over hiring of relatives of foreign officials, it is important to keep in mind the risks and how the FCPA applies. The talismanic concept for tan FCPA violation is “corrupt intent.” It is always difficult to know what is going on in someone’s mind (unless
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In this era of aggressive FCPA enforcement, companies are designing and implementing robust due diligence systems to screen and monitor third party representatives. These policies and procedures are critical to an effective anti-corruption compliance program. Due diligence, however, does not mean scientific certainty. In the context of anti-corruption
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JP Morgan stands as the poster child for how not to interact and resolve issues with the federal government. After what appeared to be a difficult set of negotiations, the Justice Department and JP Morgan reached a record $13 billion financial settlement to resolve government claims against JP Morgan relating
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This is a very complicated case, Maude. You know, a lotta ins, lotta outs, lotta what-have-you's. And, uh, lotta strands to keep in my head, man. Lotta strands in old Duder's head. – The Big Lebowski (1998) Luckily, the Justice Department and SEC’s recent
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Please check out the Volkov Law You Tube Channel . Subscribe Today!!! Click Here You will find plenty of interesting information, including an extensive video library: Volkov Law Firm Videos 1. Introduction to Volkov Law -- Click Here 2. Internal Investigations -- Click Here 3. Anti-Corruption Compliance and Risks -- Click Here 4.
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As global enforcement becomes a reality, companies face a unique set of risks which can be mind-numbing in complications. With the long-arm reach of the FCPA, UK Bribery Act and other anti-corruption laws, more enforcement actions are focusing on extraterritorial conduct. Even more complicating is the fact
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The controversy around punishment and deterrence of corporate misconduct continues to swirl. As fines increase against companies, it is important to ask the question whether the current enforcement scheme adequately punishes and deters corporations. The issue was underscored by recent comments made by JP Morgan’s General Counsel three days
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When it comes to health insurance fraud, Carl Sagan’s obsession with the words – billions and billions -- are particularly accurate. As the government’s role in health care increases, it is inevitable that fraud against the government will increase as well. The False Claims Act is the primary weapon the
General
One of the many challenges in the compliance profession centers on coordination and integration. There are plenty of compliance experts who can describe a perfect world – how to design a specific program and procedures to implement the program. Vendors are ready to line up at a chief compliance officer’s
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Companies need to recognize the importance of responding effectively to a whistleblower complaint. The Enron case, and many others after that, started with a whistleblower complaint which the company either ignored or bungled in its response. I have repeatedly advised companies to develop a whistleblower triage strategy for assessing, responding