General
Global companies need to actively work to prevent fraud and corruption. Fraud and corruption go hand-in-hand. To commit bribery, bad actors have to gain access to money for unauthorized (illegal) purposes. A failure to prevent fraud and corruption can have significant legal, financial and reputational consequences. Luckily, companies
General
Chief compliance officers are politicians and have to possess great interpersonal skills. They have to “get along” and persuade key constituencies -- most especially their business partners – to commit and devote time and resources to ethics and compliance. In order to operationalize their programs, CCOs have to build relationships with important
General
As we celebrate Ethics and Compliance Week in 2017, I wanted to offer my own assessment of where the compliance profession stands and the challenges facing the profession for the future. I am an eternal optimist – I will never fall to the dark side of cynicism and pessimism. Over the
General
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
General
Volkov Law TV continues to offer high-quality webinars on relevant ethics and compliance topics. Over the last several months we have added a number of new webinars. Subscribe and check them out. Monthly access to a webinar is $8; monthly access to the full library is $29; and yearly
General
Human resources and compliance professionals share many common objectives and interests. They need to coordinate and operationalize their joint interests in a variety of ways. One area that demands more focus is the hiring of ethical employees. The ISO 37001 Anti-Bribery Management System includes important requirements for the hiring
General
Over the last year, we have seen the Justice Department and SEC’s international coordination efforts bear fruit. DOJ has expended time and efforts to train prosecutors and law enforcement on anti-corruption investigations and prosecutions strategy. These programs inevitably foster cooperation and coordination through personal and professional relationships. In
General
I always enjoyed the assumption underlying economic models – assuming people are rational actors, then . . . Sometime people do not act rationally, and sometimes people react out of fear or make unrealistic assumptions. The compliance profession faces many challenges including unrealistic or unfounded assumptions. In many cases, compliance professionals have to reassure
General
A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other enforcement actions from the past; country (or regional) specific violations that involve a group of employees
General
The Justice Department has touted its efforts to bring greater transparency to FCPA enforcement. There is no question that in the last five years the Justice Department has moved the needle – the FCPA Guidance issued in 2012; the release of the April 5, 2016 Pilot Program; the Evaluation of Corporate
General
I was pleased to participate in a live webinar with Exiger on artificial intelligence and third party risk management. Watch the 60 minute webinar replay -- here. The growing complexity of third party relationships and the immediate regulatory and reputational risks of those third parties has procurement teams, compliance officers and
General
Corporate boards need to devote more energy to oversight and improvement of corporate culture and compliance. Over the last ten years, we have witnessed corporate scandals and misconduct that could have been prevented or, at least, mitigated by a corporate board’s proper oversight, and management of a company’s