All you need in this life is ignorance and confidence, and then success is sure. Mark Twain People are good at convincing themselves that everything is okay, despite troubling indications. Sometimes it is easier to ignore warning signs than to face the harsh reality. It is really a part of the human condition – we fail to intervene or take action unless required to do...
Company managers are the lynchpin of a corporate compliance program. Without belaboring the Tinkers to Evers to Chance baseball analogy, a corporate culture of compliance requires an important information and accountability flow (or cascade) from leadership to senior managers to on-the-ground managers. It is at this level that the compliance message requires effective communications and conduct by managers directly to employees. This is where the...
On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”). Together with its aggressive enforcement of economic sanctions, OFAC has set a new standard for SCPs, and has “strongly encourage[d]” companies and individuals subject to OFAC jurisdiction to implement a...
On May 16, 2019, I participated in a live webinar sponsored by Bureau Van Dijk, “Is Power and Control the New Beneficial Ownership?” The panel discussion was interesting and insightful. Ted Datta, Director, Governance, Risk and Compliance Solutions, Bureau van Dijk, Bill Hauserman, Senior Director, Compliance Solutions, Bureau van Dijk, and myself. The replay is available HERE. (Replay begins at 14:00) The discussion covered a...
We all like to believe in straight-forward and consistent trends and developments. For example, compliance programs are improving, budgets are increasing, and CCOs are embracing new technologies. Everything is just rosy when it comes to compliance. But reality is far from consistent and far from simple trend lines and straight-forward explanations. Please do not get me wrong – over the last ten years, the rise...
All you need in this life is ignorance and confidence, and then success is sure. Mark Twain People are good at convincing themselves that everything is okay, despite troubling indications. Sometimes it is easier to ignore warning signs than to face the harsh reality. It is really a part of the human condition – we fail to intervene or take action unless required to do...
Company managers are the lynchpin of a corporate compliance program. Without belaboring the Tinkers to Evers to Chance baseball analogy, a corporate culture of compliance requires an important information and accountability flow (or cascade) from leadership to senior managers to on-the-ground managers. It is at this level that the compliance message requires effective communications and conduct by managers directly to employees. This is where the...
On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”). Together with its aggressive enforcement of economic sanctions, OFAC has set a new standard for SCPs, and has “strongly encourage[d]” companies and individuals subject to OFAC jurisdiction to implement a...
On May 16, 2019, I participated in a live webinar sponsored by Bureau Van Dijk, “Is Power and Control the New Beneficial Ownership?” The panel discussion was interesting and insightful. Ted Datta, Director, Governance, Risk and Compliance Solutions, Bureau van Dijk, Bill Hauserman, Senior Director, Compliance Solutions, Bureau van Dijk, and myself. The replay is available HERE. (Replay begins at 14:00) The discussion covered a...
We all like to believe in straight-forward and consistent trends and developments. For example, compliance programs are improving, budgets are increasing, and CCOs are embracing new technologies. Everything is just rosy when it comes to compliance. But reality is far from consistent and far from simple trend lines and straight-forward explanations. Please do not get me wrong – over the last ten years, the rise...
Jessica Sanderson, Senior Counsel at The Volkov Law Group, recently attended the Rocky Mountain Securities Conference in Denver, Colorado. Jessica’s posting summarizes the major compliance themes from the conference. Jessica can be reached at jsanderson@volkovlaw.com. On Friday May 3, 2019, I attended the Rocky Mountain Securities Conference in Denver and heard from a number of regulators and industry experts, including SEC Commissioner Hester Peirce. SEC...
The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s new compliance framework includes a valuable section on common root causes of OFAC violations. OFAC has included this discussion to assist companies in designing, updating and amending their respective Sanctions Compliance Programs (SCPs). The discussion...
Webinar: OFAC Issues New Framework for Sanctions Compliance Programs Sign Up HERE May 22, 2019, 12 Noon EST On May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”) (Here). OFAC “strongly encourage[d]” companies subject to OFAC jurisdiction to implement a “risk- based approach to sanctions compliance by developing, implementing and routinely updating a...
The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s new Framework for Sanctions Compliance Programs incorporates a number of important principles from Justice Department and US Sentencing Guideline requirements for effective compliance programs. Today, I am going to review the requirements relating to Testing...
In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs . The new Evaluation Guidance supersedes the prior document issued in February 2017, which contained a lengthy list of questions on key topic areas. Join Michael Volkov as he discusses the new guidance and outlines the impact for...
