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Contrary to what parents always tell their kids, when it comes to the authority of a Chief Compliance Officer, appearance is everything. This may be another in the long line of profound grasps of the obvious, but if a Chief Compliance Officer is a member of the C-Suite, is
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Some areas of compliance are truly nascent. For a profession which is undergoing a radical change in terms of demand and new technologies, more research is needed and greater understanding of program measurements. The more subjective the measurements used, the more risk that companies can manipulate or even ignore significant
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Several years ago, the SEC sent shockwaves through the private equity and hedge fund industries. The SEC launched an industry investigation focused on the legal principle that foreign sovereign wealth funds were a part of foreign governments and led by foreign officials under the FCPA. The implications of such an
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William James used to preach the “will to believe”. For my part, I should wish to preach the “will to doubt”.... What is wanted is not the will to believe, but the will to find out, which is the exact opposite. * Bertrand Russell Skeptical Essays, 1928 “Man’s greatest asset
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An effective compliance program requires a culture of ethics and compliance, including "tone-at-the-top." A company's culture is not easy to measure. Nonetheless, there are practical steps which can be implemented to collect and assess information about a company's culture, including surveys,
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The Justice Department and the SEC have been busy. More enforcement actions are coming to a close -- Avon, Weatherford, and others are likely to be resolved before the end of the year. There is an inevitable fourth quarter push to close out enforcement actions and clear the plate. It is
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Compliance is becoming more and more specialized. Whatever is the soup du jour, or current high-risk operation, becomes the focus of compliance education, marketing, and surveys. After the passage of the PATRIOT Act in 2001, the focus was anti-money laundering compliance programs. In the last few years, the
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It is important to understand one’s limitations in life. In the world of compliance, CCOs need to be realistic when they start a new job with a new company. It also means that a CCO has to be honest with himself or herself. Every person knows deep down their
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View more videos like this on the Volkov Law Group YouTube Channel.
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Companies are always trying to do more with less. Senior executives will spend hours designing policies and programs to stretch dollars, resources and reduce costs. Committees are established for such research projects, consultants are brought in and solutions are reviewed and eventually implemented. Senior managers could reduce the time, the
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I am pleased to announce the launch of the new Volkov Law Group website (Here), Facebook Page (Here), Linked In Profile (Here) and You Tube Channel (Here).My practice has grown from largely a solo practice to a boutique practice, and currently includes three talented associates. Our firm focuses on
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In response to aggressive FCPA enforcement, the compliance industry has embraced innovative strategies and tools. Whether your company is large, medium or small, it is important to stay abreast of industry best practices. Some of these new strategies can be modified for application in different size companies. Join Michael Volkov,