United Technologies recently settled an FCPA enforcement action with the SEC by paying $13.9 million for bribes paid by its elevator and aircraft businesses. UT disclosed the investigation to DOJ and the SEC in late 2013 or early 2014. DOJ declined to prosecute in March 2018. UT agreed to disgorge $9 million, plus interest of about $919,000 and to pay a penalty of $4 million. The SEC’s FCPA settlement contains...
Webinar: The State of Third-Party Risk Management in 2018 Date: Tuesday, October 16 Time: 1:00 PM/ET/10:00 AM PT Duration: 60 minutes Sign Up HERE Over half of organizations leave themselves open to risk with an ineffective or non-existent third-party risk management program. That’s shocking given the damage a third party can inflict! To improve or get started on your third-party risk management program, join this...
Believe it or not, but companies are still struggling with third-party risk management systems. I know this sounds hyper-critical but many companies continue to hang onto paper due diligence systems (sometimes with or without a SharePoint platform to store third-party due diligence documentation). An even smaller percentage of companies are automating their due diligence programs, a basic requirement for all companies with a minimum number...
Webinar: Advanced Ethics and Compliance Program November 6, 2018, 12 Noon EST Sign Up HERE As companies’ ethics and compliance programs mature, chief compliance officers face new challenges to evolve their compliance programs. CCOs have to make important decisions on how to address the company’s culture, commitment to organization justice, changing risk profiles and global performance. Join Michael Volkov, CEO of The Volkov Law Group,...
The United Technologies FCPA settlement underscored, once again, the harm to a company when lawyers fail to do their job. As outlined in the SEC settlement, an in-house attorney at Otis Elevator was required to review and approve a contract with a third-party, where a cursory due diligence review would have uncovered major red flags. The in-house attorney reviewed the contract without inquiring about the...
As we continue our efforts to improve and grow our podcast, we have recently connected the Corruption, Crime & Compliance podcast feed to Spotify! You’ll now be able to listen to all of the latest episodes right from the Spotify app. Please click here to access our Spotify page. Be sure to listen to our latest episode on how to implement an effective and reliable...
Assume you are under the influence of a truth serum; does you company have a contract management system? Some will say yes; I suspect most will say no. My question is why not? Lawyers love contracts. Most business people see the value of a contract and will comply with a requirement that a deal will require a contract in order to move forward. But there...
Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a mature ethics and compliance program is whether the company assesses and mitigates its C-Suite risks. Over and over again, companies fall under government scrutiny because of misconduct in...
To promote a culture of integrity and a commitment to organizational justice, companies have to implement an effective, efficient and reliable internal investigation program. Such a system has to respond to employee concerns promptly and investigate these concerns fairly and consistently. Companies have to devote adequate resources and attention to its internal investigation program. In this episode, Michael Volkov discusses how to design and implement...
Karin Sweigart, a Senior Associate at The Volkov Law Group, rejoins us for another posting on employment compliance and litigation risks. Karin can be contacted at [email protected]. There are many reasons to have an employee manual or handbook can be good for your business. Employee manuals help set expectations, provide guidance on how to handle conflicts, and, when drafted and implemented correctly, can protect your...
