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Global companies are expending more time and resources to understanding their relationships with foreign officials. This is a key focus of every anti-corruption compliance program. Foreign government officials create different risks dep[ending on the relationship and the nature of the interactions. A helpful way to examine the issue
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In January 2019, the US Attorney for the Eastern District of Michigan returned an indictment against four executives from Audi, a Volkswagen subsidiary, for their participation and direction of Audi’s emissions-cheating scandal. In December 2018, Audi paid a fine of 800 million euros to settle charges with German
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The corporate scandal landscape is littered with important examples of governance failures surrounding corporate ethics and mishandling of harassment and sexual assault controversies. Major corporate governance failures surrounding the handling of these issues have occurred at Google, CBS (Les Moonves), U.S. Gymnastics team, and U.S Congress, just to
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Noah Smith, an Associate at The Volkov Law Group, joins us for an interesting post on OFAC's new Venezuela sanctions. Noah can be contacted at nsmith@volkovlaw.com. Venezuela is undergoing a political upheaval. Since his rise to power in 2013, the embattled Venezuelan President Nicolás Maduro has
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Chief compliance officers at hospitals face a crushing burden of risks. The HHS-OIG has vigorously scrutinized hospitals compensation of physicians, especially for potential anti-kickback and Stark law violations. Most of these suspect situations involve compensation for physician practice groups. Unlawful compensation and influence arrangements have involved favorable leasing
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Given the significant risks posed by transfers of money and other items of value to physicians, pharmaceutical and medical device companies have to implement appropriate controls governing such payments. The federal Anti-Kickback Statute (“AKS”) prohibits the offering, paying, soliciting or receiving anything of value to induce or reward referrals
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The United States healthcare industry poses an infinite number of risks when it comes to interactions with healthcare professionals. Given the aggressive regulation and enforcement of prohibitions against kickbacks and referrals, healthcare companies have to devote significant resources and strategies governing interactions with physicians. First, healthcare provides, pharmaceutical and medical
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Colleen Hurson, Of Counsel at The Volkov Law Group joins us for her first posting on the blog concerning export control reform measures applicable to the firearms industry. Colleen has substantial experience in handling export control and sanctions compliance for clients subject to the State Department's ITAR regulations
Events
Webinar: Anti-Corruption Compliance in Pharma and Medical Device Industries February 26, 2019, 12 Noon EST Sign up HERE FCPA enforcement against drug and device companies continues at a robust rate. Given the high-risk nature of pharmaceutical and medical device industries and significant interactions with foreign government officials, drug
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We are living in a rapidly changing world (trite, I know) where companies have to focus on data privacy and security for a variety of reasons. Consumers and constituents are concerned about the safety and privacy of personal and financial information. In this era of “sharing” and posting of private
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As compliance programs (and the profession) continue to mature, there is growing interest in the need for measurement, monitoring and auditing of compliance programs. This is a natural evolution in the lifecycle of a compliance program. Once a CCO has operationalized a company’s compliance program, the next challenge logically
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I was honored to be named as a Top Thought Leader for 2019 by Trust Across America. More importantly, I am privileged to share this honor with 91 global professionals from a broad spectrum of professionals involved in integrity and trust, leadership, culture, compliance and ethics, reputation and risk management,