Events
Webinar: Best Practices for Vendor Risk Profiling February 6, 2019, 10 AM PST/1 PM EST Sign Up HERE Third-party vendors expose your organization to risk. How you manage your vendors—from onboarding, to identifying and scoring risk, to ongoing monitoring—has a huge impact on your business. Multi-
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For me, the year-end retrospectives have become a rite of passage. While there has been modest changes and trends in the enforcement arena, I am amazed each year at the pace at which compliance as a discipline and a profession continues to move forward. While there is much that
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Business operations can be riddled with inefficiencies. It is easy to spot them inside a company. The same rule applies to ethics and compliance programs. Given a specific global business configuration, ethics and compliance programs have to be designed efficiently to support the business. For some reason, a number of
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Jessica Sanderson, Of Counsel, The Volkov Law Group, joins us for her initial posting on the False Claims Act. Jessica can be reached at jsanderson@volkovlaw.com. On December 21, 2018, the Department of Justice (“DOJ”) released its Fraud statistics showing $2.8 billion recovery under the False Claims Act
Podcasts
The SEC and the Justice Department closed their respective 2018 books with resolution of three separate enforcement actions: Polycom, Eletrobras and Two Former Officers of Panasonic Avionics. In this episode, Michael Volkov reviews and discusses important lessons learned from these three separate FCPA enforcement actions.
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In a December 2018 enforcement settlement, the SEC and Brazil’s Centrais Elétricas Brasileiras S.A. (“Eletrobras”) agreed to violating books and records and internal accounting controls requirements and paid a $2.5 million penalty. (Here). DOJ declined to prosecute Eletrobras. Eletrobas stock is traded on the New York Stock
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As the Bible reminds us, “Beware of false prophets,” or in the compliance context, “Beware of false [measurements].” Compliance professionals have an obsession with benchmarking their compliance programs. Why are compliance officers so obsessed with such comparisons? Compliance is a function that, by definition, involves objective and subjective measurements. In
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Employee hotlines are – sorry about this – a “hot” topic these days in compliance. NAVEX Global’s recent study (here) confirmed the importance of an effective hotline system. Companies that implement robust and widely-used internal reporting systems are more effective in identifying and responding to potential problems. Such an impact
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The Volkov Law Group is pleased to announce the addition of Jessica Sanderson to the firm. Jessica has a wealth of compliance and enforcement defense experience. We look forward to introducing her to new and existing clients. Jessica Sanderson, Of Counsel, has more than 20 years of experience in a
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Polycom, Inc., a U.S. communication technology company, which was recently acquired by Plantronics, earned a DOJ declination and entered into an SEC settlement for FCPA violations in China. DOJ released a declination letter (here); and the SEC issued an administrative order (here). Polycom earned the declination under the FCPA
Podcasts
The Treasury Department's Office of Foreign Asset Control ("OFAC") had a busy year -- the first half of 2018 was dedicated to re-imposing the Iran Sanctions Program and updating the Russia Sanctions Program. In the second half of the year, OFAC resumed its pace for enforcement
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On December 19, 2018, the SEC announced settlements with two former senior executives of Panasonic Avionics Corporation. In April 2018, Panasonic Avionics settled FCPA charges with the Justice Department and the SEC and agreed to pay $280 million. (Here) Paul Margis (Here), the former CEO, and Takeshi Uonaga (Here), the