Featured Articles:

Tom Fox and Doing Compliance — New Releases

My colleague, Tom Fox, is a prolific writer.  His talents extend from his new consulting firm, to his always interesting blog, and to his formal written volumes of work.  Tom is a major contributor to the compliance profession.  Everyone can always learn something from Tom, no matter what you level of experience. Compliance Week just released Tom’s new hardbound book — Doing Compliance: How to Design, Create,...

Reminder: May 19, 2015 Webinar: How to Respond to a Potential FCPA Violation

Webinar: Tuesday, May 19, 2015, 12 Noon EST How to Respond to a Potential FCPA Violation Sign Up Here   A company should adopt specific protocols for handling potential FCPA violations. The company’s immediate reaction to an apparent violation can be critical to the eventual outcome. Corporate decision-making depends on collecting relevant information as quickly as possible and making an informed strategic decision on follow-up...

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Have the latest posts on Corruption Crime & Compliance delivered to your mailbox.  No need to travel on the Internet or click on a Tweet — each posting will be delivered to you immediately when posted.  The email sign up is on the left-hand side of the blog.  Just enter your email address and you will receive email notifications. Thanks for all your support!!!!

Automation and AML/BSA Compliance

The future of compliance includes technology solutions. Do not get me wrong – technology is not a panacea but it is an important strategy for leveraging resources.   In the anti-corruption and sanctions compliance arenas, technology is an important tool, especially for third-party risk management and knowing who your business partners and customers are for sanctions compliance. AML and Bank Secrecy Act compliance heavily depends on...

Happy Talk and CCO Reporting to the Board

Everyone likes to talk. For most people, it is hard to listen. Chief Compliance Officers have to be proficient at both, especially listening. I have often criticized CCOs who engage in Happy Talk when reporting their boards. It is a practice that reveals much about the CCO, the company’s ethics and compliance program, and the overall corporate culture. CCOs committed to honest board reporting reflect...

The Missing Link in Third Party Due Diligence

As the old saying goes, “don’t break your arm patting yourself on your back.” Everyone is pretty happy about their due diligence systems for screening third parties. I understand how they feel but there is still a long way to go. It is one thing to screen a third-party at the on boarding process; it is quite another to build out an entire due diligence...

Schlumberger OFAC Enforcement Action – A New Threat?

I have been writing lately about the rise of OFAC sanctions enforcement. OFAC and the Justice Department have started to build a close working relationship similar to that between the SEC and the Justice Department relating to FCPA enforcement. For years, the blockbuster OFAC sanctions enforcement cases have involved the financial industry. DOJ’s recent settlement with Schlumberger Oilfield for $232 million demonstrates DOJ’s commitment to...

Volkov Law Group and The Claro Group Team Up for Internal Controls Assessments

I am proud to announce that the Volkov Law Group and The Claro Group have teamed up to offer companies a new and important service — internal controls assessments. Our proven experience in corruption investigations and compliance initiatives can help you put together the pieces The Environment The Justice Department and the SEC have keyed anti‐corruption investigations to reviewing a company’s internal controls. In fact,...

Questioning Due Diligence Questionnaires — Keeping It Simple

Lauren Connell from The Volkov Law Group rejoins us with a posting on third-party questionnaires and due diligence. Lauren’s profile is here and she be reached at lconnell@volkovlaw.com. Third Party questionnaires are a standard part of any due diligence process.  They are emailed to the potential third-party business partner, filled out and sent back, or the third-party enters the information through an Internet portal.  Compliance...

Welcome to New Sponsor — Click 4 Compliance

I am happy to welcome a new sponsor to Corruption, Crime & Compliance — Click 4 Compliance.  Click 4 Compliance’s website is here. Click 4 Compliance is an online compliance training company founded by Farzad Barkhordari and Robin Campbell. Mr. Barkhordari is the former head of global anti-corruption at Sun Microsystems, Inc., and Ms. Campbell is a Privacy and Data Protection expert, having assisted European and...