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Goldman Sachs has a new leadership role – unfortunately, it is for corruption. It would be a serious mistake to characterize or describe the Goldman corruption scheme as the result of a few, bad actors. Instead, Goldman suffered this scandal because of a culture and a weak set of controls crafted
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Goldman Sachs now sits atop all charts with the largest US FCPA bribery penalty, totaling approximately $2.9 billion. The second largest is Ericsson’s 2019 FCPA settlement for $1 billion. There is a reason that Goldman “earned” this distinction. The bribery scheme and controls and compliance failures are repugnant
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We are proud to announce the addition of a new sponsor -- Blue Umbrella, a leading provider of due diligence research and innovative third-party compliance technologies. Combining global research excellence with disruptive RegTech SaaS solutions, Blue Umbrella serves multinational corporations working in technology, manufacturing, life sciences, defense/aerospace, agriculture, energy,
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Steele Webinar: Top 6 Due Diligence Best Practices Third-Party Risk Management April 16, 2020, 11 AM EST Sign Up HERE Faced with complex, global third-party networks, it's more critical than ever for companies to have an effective strategy for evaluating and monitoring third-party risk. Without
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The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies. Here are five important lessons learned: Discount Controls and Customer/End User Pricing: Microsoft agreed to provide significant discounts based on false
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NAVEX Global has issued its Third-PartyBenchmark Report. (HERE). The NAVEX Global Report contains important insights and data concerning ethics and compliance programs and third-party risk management strategies. I was pleased to assist NAVEX Global in preparing the 2018 Benchmark Report. Knowing how to appropriately define, screen and monitor
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The SEC continues to exercise its powerful enforcement tool – internal controls violations – in FCPA enforcement actions against public companies. Kinross Gold Corporation is the latest company to enter into an FCPA settlement. Kinross agreed to pay $950,000 for inadequate internal controls and books and records violations centered on the
Podcasts
Companies continue to face significant risks from their third parties. In response, companies are implementing sophisticated due diligence and third party risk management systems. FCPA enforcement risks are only one of several risks created by a company's third parties. Companies have to screen and review their third parties
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The Volkov Law Group continues to offer innovative legal services focused on ethics and compliance programs, enforcement defense, and internal investigations. See Firm website here. The Volkov Law Group team includes talented professionals: Lauren Connell, Managing Associate; Jacqui Martin (formerly Merrill), Senior Associate; Susan Simpson, Associate; Matt Stankiewicz, Associate; and
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In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk assessments. ISO 37001 requires companies to conduct regular risk assessments in order to identify the bribery
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In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting issues that are addressed and some missed opportunities to advance ethics
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There has been so much attention paid to due diligence. We have reams and reams of articles highlighting the importance of due diligence. In addition, numerous vendors of due diligence services and technologies fill the marketplace with whitepapers, articles and information underscoring the importance of due diligence and advising on