General
Perhaps it is fitting to end this unusual FCPA enforcement year with another in a series of compliance reminders -- the quickest way to experience a bribery scandal is to ignore third-party risks. This has been a continuing theme this year and Freepoint is yet another example of why managing
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The Justice Department's FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred. DOJ's record is hard to square against DOJ official speeches, statements and policy
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While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I hope they stimulate further reflection and analysis to inform FCPA compliance practitioners as
General
FCPA trends often are relatively easy to describe and often overblown as a marketing technique by the usual cast of paparazzi suspects. (Self-proclaimed prognosticators that often push incorrect themes to promote business, or those that restate profound grasps of the obvious). 2023 has been a strange year in a
Podcasts
In November 2023, HHS-OIG issued a comprehensive document, the General Compliance Program Guidance ("GCPG"), which outlines important compliance guidance for the healthcare industry. The GCPG provides specific guidance on compliance with the Federal anti-kickback statute ("AKS"), the Physician Self-Referral Law ("Stark Law&
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Within the specific element discussions in HHS-OIG's Guidance, are important operational details and strategies for an effective compliance program. GCPG provides important suggestions and innovations for consideration by all compliance professionals. Effective Lines of Communication The GCPG stresses the importance of an open line of communication between
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To all our clients, family, friends and colleagues, The Volkov Law Group wishes everyone Happy Holidays and Happy New Year! Our blog, webinar and podcast services will resume on January 3, 2024. In the meantime, we wish everyone peace, gratitude. joy and love!! Mike, Matt, Alex, Sam, Daniela and Ben!
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Board Oversight of the Compliance Program The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization's compliance program, and provides that the board shall "be knowledgeable about the contents and operation of the compliance and ethics programs and shall exercise reasonable oversight"
General
The health care industry has a rich history of commitment and innovation in developing effective compliance programs. Going back to the 1990s, HHS elevated compliance program requirements for healthcare companies. Many of these innovations translated into strategies that became essential to the compliance industry. For example, in the 1990s, HHS&
Podcasts
On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as “CZ” in the cryptocurrency industry), the exchange’s founder and Chief Executive Officer (“CEO”). Under these agreements, Binance and
Events
FCPA Enforcement and Compliance Review January 9, 2024, 12 Noon EST Sign Up Here Sanctions Enforcement and Compliance Review January 16, 2024, 12 Noon EST Sign Up Here Start the New Year off right -- review 2023 FCPA enforcement and compliance on January 9, 2024, and then one week later, on
Podcasts
Steve Naughton, a well-known and accomplished compliance professional, joins Michael Volkov to discuss his compliance career and his role as the Director of Regulatory Compliance Studies and Clinical Professor at the Loyola University Chicago Law School. Steve has served in a variety of important roles in corporate compliance, including