2024 • 2023 • 2022 • 2021 • 2020 • 2019 • 2018 • 2017 • 2016 • 2015 • 2014 • 2013 • 2012 • 20112024 Telefónica’s Bribery Scheme — The Usual Suspects and Tools (Part II of III) Telefónica Pays $85.2 Million to Settle FCPA Charges involving Venezuela Bribery (Part I of III) Webinar: DOJ’s Recent Compliance Program Guidance Episode 345 — Raytheon Settles for $950 Million for Fraud, FCPA, ITAR and False Claims Act Violations The Trump Administration’s Focus on the Department of Justice and Priorities (Part III of III) Forecasting the 2nd Trump Administration: Foreign Policy Changes and Increased Trade and Tariff Enforcement (Part II of III) Forecasting the 2nd Trump Administration: Translating Initiatives to Enforcement and Compliance Priorities (Part I of III) Episode 344 — SEC Settles FCPA Case with Moog, Inc. for $1.7 Million OFAC Imposes $860,000 Penalty on Vietnamese Beverage Company for Violations of North Korean Sanctions BIS Imposes $500,000 Penalty on Semiconductor Manufacturer for Entity List Violations LRN’s Code of Conduct Report: Tracking Innovation and Usage Episode 343 — TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations Raytheon’s False Claims Act Settlement (Part IV of IV) Raytheon’s FCPA and ITAR Case (Part III of IV) Raytheon’s Defective Pricing Fraud and Resolution (Part II of IV) Raytheon Reaches Comprehensive Settlement with Justice Department and Pays $950 Million to Resolve False Claims Act, FCPA and ITAR Violations (Part I of IV) Episode 342 — How to Conduct an Internal Compliance Visit and Review DDTC Fines Precision Castparts Corp. $3 Million for AECA and ITAR Violations Teva Pharmaceuticals Pays $450 Million to Resolve Anti-Kickback and False Claims Act Violations BIS Issues Guidance for Financial Institutions Concerning EAR Compliance SEC Settles FCPA Case with Moog, Inc. for Nearly $1.7 Million Certa-Volkov Law Webinar: Leveraging Technology to Mitigate Third-Party Risks Episode 341 — DOJ Charges Visa with Monopolization and Exclusionary Conduct in the Debit Card Market TD Bank’s Rotten Corporate Culture — From its Store-Level Operations to its Board’s Audit Committee (Part IV of IV) TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements (Part III of IV) TD Banks’ Pervasive and Systemic Criminal Misconduct (Part II of IV) TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV) Episode 340 — DOJ Updates Evaluation of Corporate Compliance Programs UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations BIS Reaches $151,875 Settlement with Quantum Corporation Over Violations of the EAR’s Antiboycott Provisions DOJ Charges Visa with Monopolization and Exclusionary Conduct in the Debit Card Market Episode 339 — The Four Sanctions Cases that Everyone Should Know Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations DOJ Updates Evaluation of Corporate Compliance Programs G7 Announces Joint Initiative to Combat Russian Sanctions and Export Control Evasion Episode 338 — Deep Dive into Deere SEC FCPA Settlement OFAC’s Stated Concern About Foreign Companies and Domestic Sanctions Compliance and Post-Acquisition Compliance (Party IV of IV) Supply Chain Sanctions Liability — The Importance of Supply Chain Audits (Part III of IV) “The New FCPA”: The Future Landscape of Sanctions Enforcement (Part II of IV) The Four Sanctions Compliance Cases that Everyone Should Know (Part I of IV) Episode 335 — Nicolas Garcia, GC at Orica, on Compliance Trends and Challenges in Latin America Welcome to New Sponsor — Certa, the AI-First Third Party Operating System Deere’s Bribery Schemes — Circumventing Expense Controls (Part II of II) The Deere SEC FCPA Settlement: A Textbook Case of Expense Abuse (Part I of II) Oak Street Health Pays $60 Million to Resolve False Claims Act Violations Supply Chain “Audits” and Risk Mitigation Episode 336 — Review of Recent DOJ Declinations John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations The Board’s Perspective: Wrapping Your Arms Around Risks The Importance of Compliance Independence Episode 335 — Review of the DOJ Whistleblower Program RTX Corporation Reaches Record $200 Million Settlement with DDTC for Serial Violations of the AECA and ITAR DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement SEC Outlines “Effective Cooperation” Standard DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million The Compliance “Curse” — Learning to Compromise Principles Antitrust Division Indicts Company, Executive and Employee for $100 Million Price-Fixing Conspiracy BIS Reaches Settlement of $5.8 Million Enforcement Action with TE Connectivity Corporation over Export of EAR99 Commodities Tracking FCPA Individual Enforcement DOJ’s New Whistleblower Program: Filling in the Gaps and Encouraging Tips (Part II of II) DOJ Implements New Corporate Whistleblower Plan to Accelerate Corporate Criminal Enforcement (Part I of II) Episode 334 — SEC Suffers Dismissal of Claims in Fraud Case Against Solarwinds Quarterly Trade Compliance Update – July 2024 BIS Publishes Proposed Revisions to EAR Addressing U.S. Person Support for “Foreign Security” and Military End Users Episode 333 — Boeing Plea Agreement in 737 MAX Safety Case EU Revises Restrictive Measure “Best Practices” to Account for Adoption of OFAC 50% Rule Equivalent FinCEN Issues Proposed Rule to Strengthen and Modernize Financial Institutions’ AML/CFT Programs State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence Episode 332 — Deep Dive into SEC’s Internal Controls and Cybersecurity Settlement with R&R Donnelly Gentiva Pays $19.4 Million for False Claims Act Violations Involving Hospice Care Boeing’s Failure to Integrate Compliance Anti-Fraud Controls with Quality and Safety Functions (Part III of III) Deep Dive into Proposed Boeing Plea Agreement (Part II of III) DOJ and Boeing Propose Criminal Plea Agreement — Boeing to Plead Guilty to Felony and Pay $243 Million Penalty (Part I of III) Episode 331 — NAVEX State of Risk and Compliance OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes DaVita Pays $34 Million to Settle Kickback Violations The Continuing Plague of Healthcare Fraud SEC Suffers Major Blow in Securities Fraud Case Against SolarWinds Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine NAVEX’s Report on the State of Compliance: Positive News with Serious Gaps Noted District Court Rejects Challenges to ITAR Criminal Charges SEC Expands Internal Controls Provision to Cover Cybersecurity Incidents and Reaches $2.1 Million Settlement with R.R. Donnelley & Sons Co. OFAC Amends SDN and SSI List Entries to Incorporate Secondary Sanctions Warnings Webinar: Building an Effective Cybersecurity Governance and Risk Mitigation Program Episode 329 — Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unitary Visibility Supreme Court Continues to Pare Back Criminal Laws BIS Announces Settlement Agreement with Indiana University Over Export Control Violations Supreme Court Strikes Down Chevron Deference Rule Episode 328 — Sanctions Enforcement and Red Lines Supreme Court Rules SEC’s In-House Adjudication Is Unconstitutional Episode 327 — Another Look at Corporate Culture OFAC Settles with Mondo TV for $538k for Violation of North Korean Sanctions BIS Issues Denial Order for Domestic Freight Forwarder Alleging Multiple Violations of Settlement Agreement Terms Deadline for CA Employers to Adopt New Workplace Violence Prevention Plans Approaches Episode 326 — Dottie Schindlinger on Diligent’s Report on Board Oversight of Cybersecurity CFTC Fines Trafigura $55MM for Market Abuses, Interfering with Whistleblower Communications European Council Officially Adopts New AML/CFT Package Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz Episode 325 — AI Risk and Compliance Frameworks Sanctions Enforcement on the Outer Edges of Trade Activity (Part II of II) Sanctions Compliance: Understanding the Red Lines of Enforcement (Part I of II) BIS Announces Settlement of Antiboycott Violations with Airbus Space and Defense Subsidiary LRN’s Call to Action: 5 Steps Every Company Should Take to Promote an Ethical Culture (Part II of II) Episode 324 — Third-Party Risks and Sanctions Compliance LRN Report Highlights (Again) the Importance of Ethical Culture (Part I of II) AI Compliance Programs: Filling in the Gaps and Mitigating Risks (Part II of II) Emerging AI Risk and Compliance Frameworks (Part I of II) Episode 323 — Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis DXC Technology Company Settles Sanctions and Export Control Violations Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues Aravo Webinar: Where Your Nth Party Liabilities Start and End Life Sciences Company Escapes Criminal Charges for Employee’s Illegal Export Scheme DOJ Antitrust Division Launches New Task Force on Health Care Monopolies and Collusion Episode 322 — Checking in on the Caremark Cases The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV) Supply Chain and Sanctions Compliance (Part III of IV) Distribution Chains and Sanctions Compliance (Part II of IV) The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV) Episode 321 — Review of the EU Whistleblowing Directive wih Alex Cotoia and Daniela Melendez Commerce Department Promulgates New Rule Adopting Medical Device License Exception for EAR99 Exports to Russia, Belarus and Ukraine EU Enacts New Directive Establishing Criminal Offenses for the Violation of Restrictive Measures DOJ and OFAC Sanctions and Export Control Detection Strategies Dancing on the Head of a Pin: Corporate Boards, Committees and Cybersecurity Risk Management Episode 320 — NAVEX 2024 Whistleblower Report Checking In on Caremark Cases in Delaware The Power and Reward of Cooperation: Binance Founder CZ Sentenced to 4 Months Imprisonment BIS Releases Updated Guidance for Freight Forwarders Quarterly Trade Compliance Update – April 2024 Episode 319 — Deep Dive into SCG Plastics $20 Million Settlement with OFAC to Resolve Violations of Iran Sanctions Program DOJ Charges Ten Individuals for Violating Venezuelan Sanctions NIST Adopts New 2.0 Cybersecurity Framework New BIS Rule Implementing AUKUS Effectuates Sweeping Changes to Dual Use Export Controls DOJ Heralds New Voluntary Self-Disclosure Program for Individuals La Oficina de Control de Activos (OFAC) no renovó la licencia 44 y en consecuencia se revoca el alivio de Sanciones a Venezuela Episode 318 — LRN’s Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership OFAC Rolls Back Venezuelan Sanctions Relief, Again Prohibiting Oil and Gas Transactions Webinar: Effective Strategies to Handle Whistleblower Complaints NAVEX 2024 Whistleblower Report Highlights Important Trend — More Reports are Being Made and More Are Being Substantiated BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program DOJ Takes Aim At Apple’s Dominance Over Smartphones DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations Episode 317 — Deep Dive into Trafigura’s FCPA Settlement Lessons-Learned from the Trafigura FCPA Settlement (Part III of III) Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III) Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of III) Episode 316 — DOJ Announces New Whistleblower Program and Encourages Self-Disclosures SEC Finally Issues Climate Change Disclosure Rules Carrots and Sticks: DOJ’s Push to Incentivize Voluntary Disclosure of Corporate Misconduct (Part II of II) DOJ Enters Whistleblower Sweepstakes — Plans to Implement Bounty Program (Part I of II) JP Morgan Fined $348 Million for Deficient Record-Keeping Episode 315 — Boeing Pays $51 Million for ITAR Violations DOJ and CFTC Bring Charges Against Crypto Exchange KuCoin for AML and KYC Failures General Data Protection Regulation (GDPR) and Whistleblowing Laws (Part II of II) Implementation of EU Directive on Whistleblowing 2019/1931 (Part I of II) OFAC Settles First Case in 2024: EFG, a Private Bank, Pays $3.7 Million for Sanctions Violations LRN 2024 Program Effectiveness Report Underscores Importance of Values, Adaptation and Accountability Episode 314 — A Deep Dive into DOJ’s Gunvor FCPA Enforcement Action The SEC’s Recent Action Against Crypto Exchange ShapeShift Lacks Guidance and Draws Internal Criticism Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III) Gunvor’s Bribery Schemes — Third-Parties, Shell Companies and Evasion of Controls (Part II of III) Gunvor Falls Under FCPA Axe and Agrees to Pay Criminal Penalty of $661 Million (Part I of III) Episode 313 — The Coming Sanctions Criminal Corporate Enforcement Storm Former Stericyle Official Charged in Foreign Bribery Scheme Ex-Vitol Oil & Gas Trader Convicted of Bribing Foreign Officials Justice Department Focuses on Artificial Intelligence Assisted Crime The UK Modern Slavery Act: Easy Wins and Practical Compliance (Part II of II) Compliance With the UK Modern Slavery Act: What It Means for Companies (Part I of II) Episode 312 — Eddie Green, CEO of SnippetSentry, on Communications Preservation Risks A Deeper Dive into Supply Chain Transparency & Accountability President Biden Issues Executive Order Concerning Bulk Data, With Parallels to Current Sanctions Regulations Diligent and Volkov Law Partner to Host Virtual Roundtable Highlighting Current Compliance Priorities Boeing Reaches $51 Million Settlement with State Department for ITAR Violations Webinar — Export Controls Compliance: Nuts and Bolts Episode 311: Tom Fox on FCPA Enforcement — DOJ’s Approach to Recidivism and Self-Disclosure DOJ’s FCPA Enforcement Focus on Central and Latin America TradeStation Settles Securities Violations Stemming From its Crypto Yield Product Biden Administration Responds to Death of Alexey Navalny with Additional Sanctions Against Russia Federation Episode 310 — Christian Focacci, CEO and Founder, Threat.Digital, on AI and Compliance Sterling Bank’s ex-General Counsel hit with OCC Cease-and-Desist over Longstanding BSA/AML Shortcomings On the Horizon: EU Puts Final Touches on Risk-Based Artificial Intelligence Regulatory Overhaul Supreme Court’s Unanimous Decision Provides Important Protections for Sarbanes-Oxley Whistleblowers UFLPA in Focus: Lessons to Be Learned from Volkswagen’s Recent Experience Episode 309 — Alex Cotoia on Compliance with Uyghur Forced Labor Prevention Act Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II) The Coming Corporate Sanctions Enforcement Storm (Part I of II) New Executive Order Prohibitions Targets Violence in West Bank Episode 308 — Gabrielle Griffith, Director BPE Global, on Trade Compliance Trends and Expectations Licencia 43a: reimposición de sanciones en Venezuela OFAC Begins to Roll Back Venezuelan Sanctions Relief, Again Prohibiting Transactions with CVG Minerven BIS Imposes $153,175 Penalty Against Wabtec Corporation to Resolve Multiple Violations of Antiboycott Regulations DOJ’s New Mantra — Data and Detection Data Privacy Update — Keeping Up with Developments Episode 307 — Sanctions Enforcement Review and Predictions for 2024 Quarterly Trade Compliance Update – January 2024 SEC Settlement with BarnBridge DAO and its Founders for Securities Violations Highlights Legal Risks for DAOs and DeFi NYDFS Sues Citigroup Over Lax Antifraud Defenses, Seeking Major Expansion in Antifraud Liability for Banking Institutions Top Five Risks Facing Corporate Boards Episode 306 — 2023 FCPA Year in Review BIS Announces Further Enhancements to Voluntary Self-Disclosure Process A Practical Guide to Compliance with the Uyghur Forced Labor Prevention Act (“UFLPA”) “Person” of the Year: Technology and the Challenges for Ethics and Compliance 2023 Sanctions Year in Review and Predictions Webinar — 2024 Ethics and Compliance Program Priorities and Trends Episode 305 — Deep Dive into the SAP FCPA Settlement A Recap of Significant Export Control Enforcement Efforts from 2023 Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls (Part III of III) SAP’s Bribery Schemes — Systemic Corruption Around the Globe (Part II of III) SAP Returns to U.S. Enforcement Scene: Pays DOJ and SEC Over $220 Million to Resolve FCPA Violations (Part I of III) Episode 304 — Natalie Druckmann, VP from Certa, on Cutting Edge Third-Party Risk Management Freepoint FCPA Settlement: Incendiary Mix of Commodities Trading and Third-Party Risks (Part II of II) DOJ and CFTC Close Out Slow FCPA Enforcement Year with $98 Million Resolution with Freepoint Commodities LLC (Part I of II) Top Compliance Reminders from 2023 FCPA Enforcement 2023 FCPA Year in Review — Questioning the Tea Leaves and Trends Congress Passes Foreign Extortion Prevention Act in Effort to Address “Demand-Side” of Foreign Bribery Equation New Executive Order Expands Treasury’s Authority to Impose ‘Secondary Sanctions’ on Foreign Financial Institutions Involved in Russian Federation Activities Episode 303 — Deep Dive into HHS-OIG Compliance Guidance OFAC Bolsters Russian Oil Price Cap Record-Keeping Requirements in New Round of Sanctions Diligent Webinar 01/16—Elevating Ethics: A Deep Dive into Modern Slavery Regulations for Compliance Leaders HHS-OIG Guidance — Practical Steps to Achieve Effective Compliance (Part III of III)2023 Happy Holidays And Happy New Year!! HHS-OIG Guidance — Chock Full of Compliance Best Practices and Strategies (Part II of III) HHS-OIG Issues Comprehensive Compliance Guidance that Underscores the Need for a Robust and Independent Compliance Function (Part I of III) OFAC Reaches Settlement with Cryptocurrency Company CoinList for Violations of Ukraine/Russia Sanctions Biden Administration Issues New Guidance for Freight Forwarders Episode 302 — Matt Stankiewicz on DOJ’s Massive Criminal Settlement with Cryptocurrency Exchange Binance and its CEO Changpeng Zhao Nasdaq Settles Iran Sanctions Violations for Pennies on the Dollar, Thanks to Voluntary Disclosure Lessons Learned from Binance’s Criminal Settlement (III of III) Binance Intentionally Avoided Compliance with U.S. Laws Under CEO Changpeng Zhao (II of III) DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III) Start the New Year with Two Free Webinars: 2023 FCPA and Sanctions Enforcement and Compliance Reviews Episode 301 — Steve Naughton on Compliance and Compliance Education Program at Loyola Law School U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws Combatting Corruption: Marking the Anniversary of the Anniversary of the UN Corruption Convention’s Ratification BIS Ramps Up Antiboycott Enforcement Efforts DOJ Repeats Warnings on Aggressive Criminal Enforcement of Sanctions and Export Controls Episode 300 — Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador DOJ Declines Prosecution Applying Corporate Enforcement Program in Healthcare Fraud Case Lessons Learned from the Tysers Insurance Brokers and H.W. Wood Limited FCPA Settlements (Part III of III) U.K. Reinsurance Bribery Scheme — the Critical Role Played by the Third-Party Intermediary (Part II of III) Two UK Reinsurance Brokers Settle with DOJ for FCPA Violations in Ecuador (Part I of III) Episode 299 — Bobby Butler on the Compliance Profession and the Future of Compliance BIS and FinCEN Release Joint Notice Concerning Global Export Control Evasion Justice Department Declines FCPA Prosecution Against Lifecore Biomedical Under Corporate Enforcement Policy Episode 298 — Electronics Communications Risks in the Era of Ephemeral Messaging SEC and DOJ Charge SafeMoon Cryptocurrency and its Executives For Multi-Million Dollar Fraud The EU Corporate Sustainability Reporting Directive is (Almost) Here. Is Your Company Ready? DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose Gan Integrity and Control Risks Webinar: From Compliance to Sustainability Episode 297 — Susan Divers on LRN’s 2023 Program Effectiveness Report Avoiding the Misclassification Mess—Practical Solutions for Managing Your Trade Compliance Program A pesar del alivio en materia de sanciones comerciales por parte del gobierno de EE.UU al sector del petróleo y gas en Venezuela todavía hay retos por superar OFAC Settlement with DaVinci Payments Is Wake-Up Call for Prepaid Access Industry Despite OFAC Sanctions Relief, the Venezuelan Oil and Gas Industry Still Presents Risks Biden Administration Issues Sweeping Executive Order on Artificial Intelligence UK Parliament Enacts Sweeping New Fraud Legislation Aimed at AML/TF Activities SEC Sues SolarWinds and its CISO for Fraud Over Botched Data Breach Response, Marking New Era in Cyber Enforcement Webinar: DOJ’s New M&A Enforcement Policy — Due Diligence and Integration The Volkov Law Group and Diligent Unveil New AI Certification for Board Members Quarterly Trade Compliance Update – October 2023 Profiles in Effective CEO Leadership La Oficina de Control de Activos Extranjeros (OFAC) otorgó alivios a las sanciones comerciales en Venezuela y autorizó ciertas transacciones en la industria de petroleo y gas. Episode 296 — Deep Dive into Clear Channel’s SEC FCPA Settlement Simplicity – the Key to Compliance Persuasion BioTek and Chaitanya Gadde, its CEO, Agreed to Pay $20 Million, and Dr. David Tabby, Agreed to Pay $480K to Resolve Anti-Kickback Violations The Evolution of the Compliance Profession Webinar: Electronic Communications Risks in the Era of Ephemeral Messaging Cigna Group Falls Under the False Claims Axe and Pays Over $172 Million for Abuse of Medicare Advantage Program OFAC Provides Venezuela with Sanctions Relief, Authorizes Certain Transactions in the Oil and Gas Industry Episode 295 — Deep Dive into the Albemarle DOJ and SEC FCPA Settlement DOJ Revises Standard Ethics and Compliance Requirements Used in Settlements Practical Steps to Mitigate Electronics Communications Risks: “This is the Way” (Part III of III) Electronic Communications Risks — DOJ Enters the Fray in March 2023 (Part II of III) Electronic Communications Risks — Asking the Critical Questions? (Part I of III) Mike Volkov and Julie DiMauro Discuss the FCPA and its Evolution Episode 294 — Catch Up on OFAC Enforcement Actions: 3M and Emigrant Bank OFAC Ramps Up Price Cap Enforcement as Coalition Publishes Compliance Advisory for Maritime Oil Industry Google’s Failure to Preserve Electronic Communications — A Warning to Every Company of a New Reality Surrounding Electronic Data Pain in the App: Messaging Apps Lead to Large SEC Enforcement Actions DOJ Extends Voluntary Disclosure Benefits to Merger and Acquisitions Episode 293 — Catching Up with California and State Data Privacy Laws Compliance Week Sessions with Volkov Law – November 6th and 7th Clear Channel Settles SEC FCPA Case Against Former Chinese Subsidiary for $26.1 Million Alex Cotoia Discusses Recent Anti-Boycott Enforcement Action on Passages: The International Trade Blog Lessons Learned from the Albemarle FCPA Enforcement Action: Mind Your Third Parties (Part III of III) Albemarle’s Reliance on Third-Parties to Execute Bribery Schemes (Part II of III) Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III) Episode 292 — A Deep Dive into 3M’s SEC FCPA Settlement OFAC Imposes Modest $31,867 Penalty on Emigrant Bank for Iran Sanctions Violations, Highlighting Value of Voluntary Disclosure Reminder to file your 2023 Annual Report of Blocked Property: Due date September 30, 2023 3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations LRN’s 2023 PEI Report: Values and Corporate Culture OFAC & State Department Announce New Russia Sanctions, Targeting Military-Industrial Complex Episode 291 — Interview of Mary Shirley on Her New Compliance Book Diligent Podcast: Alex Cotoia and Tom Fox Discuss Corporate Culture Issues Webinar: Elevating Your Sanctions and Export Controls Compliance Program Do We Really Need an ISO Standard for Internal Investigations? A Compliance Reminder: Focus on Your Culture Catching Up with California and State Data Privacy Laws Episode 290 — Deep Dive into DOJ’s and SEC’s Corficocolombiana FCPA Settlement Michael Volkov Discusses 3M’s FCPA Settlement with David Noah from Passages: International Trade Blog DOJ’s National Security Division Places Corporate Crime in the Crosshairs BIS Signals New Enforcement Initiative for Antiboycott Compliance — Pratt and Whitney Settles Antiboycott Violations DOJ Resolves First Corporate Sanctions Case Involving Iran Sanctions Program Episode 289: Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure ECI’s New Survey – The State of Ethics & Compliance in the Workplace Episode 288 — SEC Adopts Robust New Cybersecurity Disclosure Rules Mary Shirley Releases New Book on Compliance FCPA Opinion Release Provides Guidance on Payment of Travel and Other Expenses for Foreign Government Officials DOJ Settles Criminal Antitrust Charges with Teva and Glenmark for $305 Million 3M Corp Pays SEC $6.5 Million to Resolve FCPA Charges Episode 287 — Board Oversight and Monitoring of AI Risks OFAC Settles with Construction Specialties, Inc. for $660,594 for Violations of Iran Sanctions Board Oversight and Monitoring of Artificial Intelligence Risks Daniela Melendez Joins The Volkov Law Group Episode 286 — Matt Stankiewicz on Ripple Decision and Indictment of Celsius Network CEO SEC Charges Richard Heart and His Three Cryptocurrency projects – Hex, PulseChain, and PulseX The Corficocolombiana FCPA Settlement: the Bribery Scheme (Part II of II) Corficocolombiana and Grupo Aval Pay $80 Million to Settle DOJ and SEC FCPA Violations in Colombia (Part I of II) Episode 285 — The Importance of a Consequence Management System Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export Control Violations SEC Adopts Robust New Cybersecurity Disclosure Rules Do You Have an Effective Internal Investigation Program? (Part III of III) Episode 284 — How to Implement a Compliance Compensation System The Key Elements of an Employee Reporting System (Part II of III) A Robust Consequence Management System (Part I of III) Quarterly Trade Compliance Update – July 2023 U.S. Department of Justice Unseals Indictment against Celsius Network’s Alexander Mashinsky Episode 283 — Bank of America Hit with $250 Million Penalty for Consumer Account Abuse Ripple and the SEC Both Claim Wins in Split Court Decision Enforceability of Clawback and Compensation Penalty Provisions (Part II of II) How to Build a Compliance Compensation System (Part I of II) Episode 282 — The Evolving Partnership: Compliance and Cybersecurity Navigating Recent BIS Changes to the EAR: A Practical Primer for the Medical Device and Product Industry Third-Party Risk Management: A Critical Task for Cybersecurity and Breach Prevention Bank of America Hit with $250 Million in Penalties for Account Abuse Practices Episode 281 — NAVEX’s 2023 State of Risk and Compliance Report Technical Elements of a Cybersecurity Compliance Program (IV of IV) The Cyber Compliance Imperative: Bringing Employees Together with Technology (Part III of IV) Maintaining Focus on Cyber Risks (Part II of IV) The Evolving Partnership: Compliance and Cybersecurity (Part I of IV) Webinar: Cybersecurity and Compliance — A New Path Forward Episode 280 — Healthcare Compliance and Fraud NAVEX’s 2023 State of Risk & Compliance Report: Compliance Steps Up Telehealth: A New Opportunity for Fraudsters Happy 4th of July DOJ Arrests 78 Defendants in Nationwide Crackdown on Healthcare Fraud The Unique Elements of Healthcare Compliance Programs (Part II of II) The Challenge of Healthcare Compliance Programs (Part I of II) Volkov Law TV Offers New You Tube Compliance Channel Episode 279 — Matt Stankiewicz and Mike Volkov Review SEC Enforcement Actions Against Binance and Coinbase The Inextricable Link Between Ethical Culture and Profitability Jessica Sanderson Presenting at Compliance Week’s Third-Party Risk Management Oversight Summit Swedbank Latvia Settles with OFAC for $3.43 Million for Crimea Sanctions Violations Artificial Intelligence: The New Exponential Threat The Growing ESG Backlash: Navigating Turbulent Waters Commerce, Justice, State and Treasury Issue Unprecedented Joint Advisory Concerning Iranian UAV Procurement Activities The SEC Targets Cryptocurrency Exchange Coinbase With Suit in Southern District of New York The SEC Sues Cryptocurrency Exchange Binance Alleging Sweeping Securities Violations Episode 278 — “The New FCPA”: Sanctions and Export Control Enforcement and Compliance The Supreme Court Rejects Challenge to False Claims Act Intent Standard Justice Department Announces First Criminal Cases from Multi-Agency Disruptive Technology Strike Force Episode 277 — The Murad OFAC Settlement and Sanctions Compliance Lessons Ransomware Criminal Prosecution of Russian National Underscores Pervasive Ransomware Risks Murad Pays OFAC $3.3 Million for Iran Sanctions Violations; Former Senior Executive Pays $175k Gartner Settles FCPA Case with SEC for $2.5 Million Episode 276 — Review of Philips and Franks Int’l SEC FCPA Enforcement Actions Memorial Day: A Day for Honor TD Bank Eats $225 Million Termination Fee After AML Failures Doom Merger DOJ’s Enforcement and Compliance Changes: Weighing the Pros and Cons of Voluntary Disclosures Koninklijke Philips Pays SEC $62 Million to Resolve FCPA Violations in China Episode 275 — Five Steps to Enhance Your Sanctions Compliance Program Supreme Court Cuts Back Wire Fraud Prosecutions Five Practical Steps to Elevate Your Sanctions Compliance Program (Part III of III) Refreshing and Elevating Your Sanctions Compliance Program (Part II of III) Corporate Crime and National Security – The Confluence of Prosecution and Foreign Policy (Part I of III) Episode 274 — Cryptocurrency and Sanctions Risks Featuring Matt Stankiewicz Fasten Your Seatbelt: An Important Message on Proactive Compliance Frank’s International Pays SEC $8 Million to Resolve FCPA Violations In Angola A Five Step Program for Every Company to Address the New Enforcement Threats Corporate Governance Challenges in an Evolving Risk Era Episode 273 — British American Tobacco’s $629 Settlement for Evasion of North Korean Sanctions Cryptocurrency Firm, Poloniex, Reaches Settlement with OFAC and Pays $7.5 Million for Sanctions Violations DOJ Suffers Rule 29 Dismissal of Criminal Antirust No-Poach Case in Aerospace Industry British American Tobacco’s Financial Scheme to Avoid Sanctions Detection (Part II of II) British American Tobacco Pays $629 Million to Settle Violations of North Korea Sanctions (Part I of II) Webinar: “The New FCPA”: Sanctions and Export Control Enforcement Episode 272 — Making Corporate Culture a Reality BIS Clarifies Approach to Export Enforcement Concerning Voluntary Self Disclosures and Reporting of Third Party Misconduct under Guise of “Policy Clarifications” A Compliance Imperative – Breaking Down Silos Bureau of Industry and Security Extracts $300 Million Fine Against Seagate Technology for Violation of Huawei Prohibition Supreme Court Authorizes Criminal Prosecution of Foreign State-Owned Entities Episode 271 — A Deep Dive into the Microsoft OFAC Settlement Corporate Culture: Monitor, Intervene and Remediate (Part III of III) Promoting Your Corporate Culture – Accountability and Messaging (Part II of III) Making Corporate Culture a Reality: Define and Embed (Part I of III) U.S. and International Partners Unveil New Code of Conduct Respecting Human Rights Concerns in Relation to Export Control Measures NAVEX Global’s 2023 Hotline and Incident Management Report Episode 270 — DOJ Mandates Greater Cooperation Between CCOs and HR Uphold HQ Settles OFAC Violations for $72,230 Microsoft’s OFAC Settlement Underscores Important Remedial Measures (Part II of II) Microsoft Pays OFAC and BIS Over $3.3 Million for Violations of Multiple Sanctions Programs (Part I of II) Episode 269 — Deep Dive into the Wells Fargo OFAC Sanctions Settlement Bringing HR and Compliance Together for Compliance and Consequence Management (Part II of II) DOJ’s New Compliance Requirements Mandate Increased Compliance and HR Cooperation (Part I of II) Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II) Wells Fargo Pays OFAC $30 Million to Settle Sanctions Violations (Part I of II) Episode 268: FCPA Catch Up: Corsa Coal Declination and Flutter and Rio Tinto SEC Settlements Michael Volkov and Susan Divers from LRN Featured on Podcast on How Corporate Boards Are Facing Today’s Global Issues Carrie Tolstedt, former Wells Fargo Community Banking Head, Agrees to Plead Guilty and Pay a $17 Million Fine for Obstruction of Regulator’s Investigation Rio Tinto Pays $15 Million to Resolve FCPA Violations in Guinea Flutter Entertainment Settles SEC FCPA Case for $4 Million for Improper Payments to Russian Consultants Episode 267 — DOJ Escalates Compliance Program Requirements Alex Cotoia Featured on Tom Fox’s Diligent Third-Party Risk Management Podcast Series Michael Volkov on SCCE Podcast: What We Learned in 2022 and What it Means for 2023 Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million DOJ Outlines Compliance Expectations Relating to Preservation of Data from Messaging Applications (Part III of III) DOJ’s Criminal Division Issues Three-Year Pilot Program for Corporate Compensation Systems and Clawbacks (Part II of III) Episode 266 — Joint Compliance Notice Issued on Sanctions and Export Controls Evasion DOJ Issues Revised Corporate Compliance Guidance: Consequence Management, Clawbacks and Human Resource Cooperation (Part I of III) Roger Ng, Former Goldman Sachs Banker, Sentenced to 10 Years’ Imprisonment For Role in 1MDB FCPA Scandal Webinar: DOJ Raises the Bar on Corporate Compliance Programs OFAC Settles First Case in 2023: Godfrey Phillips India Pays $332,500 for Violations of North Korea Sanctions Program DOJ, and Departments of Commerce and Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls Episode 265 — The Ericsson FCPA DPA Breach Settlement DOJ Announces New Requirements for Compliance Compensation Systems and Business Data Preservation (Part II of II) DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II) Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III) Ericsson’s DPA Breach Conduct – Failures to Disclose and Report (Part II of III) Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend Corporate Monitorship (Part I of III) Episode 264 — Contract/Purchase Order to Invoice to Payment Controls DOJ Rolls Out Voluntary Disclosure Program for US Attorneys’ Offices United States Announces Sweeping New Sanctions Against Russia DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia Sanctions A Window into Corporate Boards’ Views for 2023 Episode 263: LRN’s 2023 Ethics and Compliance Program Effectiveness Report Featuring Susan Divers The Volkov Law Group is Hiring: Mid-Level Associate SEC Activision Enforcement Action Underscores Breadth of Disclosure Control Liability Fifth Circuit Court of Appeals Reverses Trial Judge’s Dismissal of Criminal FCPA Charges Against Two Venezuelan Officials DOJ Charges Two Oil and Gas Traders with FCPA Bribery Scheme Involving Petrobras Episode 262: DOJ’s Compliance Frontier:Incentives and Disincentives Webinar: Breaking Down and Managing Your Third-Party Risks Food Company Pleads Guilty and Agrees to Pay $19.2 Million for Manufacturing Under Unsanitary Conditions DOJ Begins Implementation of Compliance Compensation Requirements LRN 2023 Compliance Program Report Underscores Importance of Compliance Program Vigilance Delaware Court Extends Caremark Duty of Oversight to Senior Officers Episode 261 — 2023 Ethics Compliance Predictions and Trends Contract to Invoice to Payment (“Tinkers to Evers to Chance”) (Part II of II) The Importance of Accounting and Internal Controls (Part I of II) DOJ Charges Russian and British Businessmen for Facilitating Sanctions Evasion of Russian Oligarch’s $90 Million Yacht The Volkov Law Group Celebrates Ten-Year Anniversary Episode 260 — The Person of the Year: The Trade Compliance Officer Featuring Alex Cotoia from The Volkov Law Group Department of State Updates ITAR U.S. Persons Abroad (“USPAB”) Guidance Department of Justice’s Antitrust Division Sues Google (Again) for Monopolization of the Digital Advertising Market Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating Russia Sanctions Justice Department Tweaks Corporate Enforcement Policy to Entice More Corporate Voluntary Disclosures Episode 259 — Deep Dive into the Honeywell FCPA Case Webinar: Lessons Learned from 2022: Improving Your Ethics and Compliance Program Next Steps for CCOs – Revising Compensation Systems and Enhancing Data Preservation Technology Bitzlato Cryptocurrency Exchange Founder Charged with Processing $700 Million in Illicit Funds DOJ & OFAC Sanctions Predictions for 2023 Episode 258 — Deep Dive in the ABB FCPA Case OFAC’s New Year’s Eve Settlement with Danfoss for $4.3 Million for Sanctions Violations Ethics and Compliance Trends and Predictions Person of the Year: The Trade Compliance Officer Episode 257: 2022 FCPA Year in Review Featuring Tom Fox Catching Up with FCPA News 2022: The FCPA Year in Review Episode 256 – The FTX Scandal and Cryptocurrency Risks: Featuring Matt Stankiewicz from The Volkov Law Group Danske Bank Pleads Guilty and Pays $2 Billion to Resolve Massive Fraud Case Lessons Learned from the Honeywell FCPA Settlement (Part III of III) Digging into Honeywell UOP’s Bribery Schemes in Brazil and Algeria (Part II of III) DOJ and SEC Close Year with FCPA Settlement with Honeywell UOP for $160 Million (Part I of III) A New Year’s Resolution for Companies involved in Defense Business2022 From All of Us — Have a Wonderful Holiday and a Happy New Year Bankruptcy Proceedings Reveal Shocking Lack of Controls at Disgraced Cryptocurrency Exchange FTX (IV of IV) The SEC and CFTC Bring Civil Charges against FTX, Alameda, and SBF (III of IV) The Department of Justice Charges FTX CEO Sam Bankman-Fried in the Southern District of New York (II of IV) Episode 255 — The Curious FCPA Case of Asante Berko The Fall of FTX: The Legal Ramifications of the Collapse of Sam Bankman-Fried’s Cryptocurrency Empire (I of IV) OFAC Due Diligence and Attestation Requirements (Part IV of IV) Finding Safe Harbors Under OFAC’s Price Cap Regulations (Part III of IV) Navigating Risky Waters: Compliance with OFAC’s New Price-Cap Policy (Part II of IV) United States and Allies Set Price Cap on Russian Oil — $60 Per Barrel (Part I of IV) Episode 254 — Update on Export Controls and Sanctions: Interview with Alex Cotoia DOJ Promoting Enforcement and Compliance Message Kraken Coughs Up $362,158 to OFAC to Settle Iran Sanctions Violations Lessons Learned and the Big Picture: ABB – the Three-Time Loser – Settles Yet Another FCPA Case (Part III of III) Digging into the ABB Bribery Details in South Africa (Part II of III) ABB – A Three-Time Loser – Settles FCPA Case for Bribery in South Africa for $315 Million (Part I of III) Join us for The Third-Party Risk Management & Oversight Virtual Summit December 7-8, 2022 Episode 253 — A Deep Dive into the Oracle SEC FCPA Settlement State Department Announces Plans to Heighten ITAR Enforcement Over Transfers of Controlled Data Sam Finkelstein Joins Volkov Law Group DOJ’s Perspective on Clawbacks and Deferred Compensation Systems (Part III of III) Teasing Out Clawbacks and Deferred Payment Schemes – Who Should be Held Accountable and for How Much? (Part II of III) Two-Part Webinar: 2022 FCPA Enforcement and Compliance Year in Review (Part I); 2022 Sanctions Enforcement and Compliance Year in Review (Part II) Incentives and Disincentives as the New Engine of Effective Compliance (Part I of III) Department of Justice Prevails and Blocks Penguin Random House Acquisition of Simon and Schuster – Parties Abandon Transaction Happy Thanksgiving from The Volkov Law Group The Ins and Outs of the Ghana Bribery Scheme (Part II of II) Goldman Sachs Official Indicted Over Ghana Bribery Scheme (Part I of II) FATF Blacklists Myanmar for “Strategic Deficiencies” in Money Laundering and Terrorist Financing Infrastructure Bureau of Industry Security Ramping Up Export Control Enforcement Modernizing Medicine Settles False Claims Act Violations for $45 Million SEC Implements Clawback Rules Antitrust Division Secures First Criminal Attempted Monopolization Guilty Plea in Decades Former MoviePass Executives Indicted for Securities Fraud Bribery in the Pharmaceutical Industry — Avanir Pharma The Importance of Independence to a CCO’s Role NAVEX 2022 Risk and Compliance Benchmark Report: Ethics and Compliance Program Shortfalls Continue Board Director Accountability Episode 252 — Matt Stankiewicz on the Bittrex OFAC and FinCEN Enforcement Action: Cryptocurrency and AML and Sanctions Compliance Navigating DOJ and OFAC Voluntary Disclosures for Sanctions Violations Voluntary Self-Disclosure — DOJ’s Enforcement Engine DOJ Charges Two Companies and A Dozen Individuals for Export Control and Sanctions Violations to Aid Russian Military Antitrust Division Keeps on Pushing and Announces Initial Settlements of Potentially Illegal Interlocking Directorates Lafarge and Syrian Subsidiary Pay $778 Million in Fines and Forfeiture for Supporting ISIS Terrorist Organization Episode 251 — Training and Corporate Culture: Interview of Maria D’Avanzo, Chief Evangelist Officer, Traliant OFAC Issues Notice of Violation Against Puerto Rico Bank But Imposes No Penalty for Sanctions Violations Bittrex’s Sanctions and AML Violations: The Importance of Compliance Controls for the Cryptocurrency Industry (Part II of II) OFAC and FinCEN Reach Settlement Agreement with Virtual Currency Exchange Bittrex (Part I of II) BIS Adopts New Export Controls Aimed at Impeding China’s Ability to Acquire Advanced Computing Capabilities New Podcast Episode 250 — Cybersecurity Risks for Financial Institutions Relying on the Cloud — An Interview of Carlo Massimo Lessons Learned from OFAC’s Settlement with Tango Card Pulling Back the Curtain on CFIUS DOJ Brings Largest Pandemic Fraud Case Charging 47 Individuals with Conspiracy to Commit Fraud For Theft of $250 Million from Children’s Food Program Antitrust Division Sets Sights on Global Enforcement Against Digital Economy Monopolies VMware pays SEC $8 Million for Misleading Financial Reporting New Refreshed and Rebranded Podcast — Corruption Crime and Compliance FinCEN Issues Final Rule for Beneficial Ownership Reporting OFAC Settles Two Cases with Credit Agricole Corporate Subsidiaries for $1.1 Million DOJ Charges Russian Oligarch Oleg Deripaska and Three Associates for Sanctions Evasion and Obstruction of Justice Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II) Oracle Joins Ranks of FCPA Recidivists: Settles SEC Case for $23 Million (Part I of II) Episode 249 — DOJ Issues New Corporate Enforcement Policy Criminal Division AAG Polite Reinforces New DOJ Corporate Enforcement Policy (Part IV of IV) DOJ’s Revised Corporate Enforcement Policy Expands on Previous Factors: History of Misconduct; Voluntary Self-Disclosure; and Compliance Monitors (Part III of IV) DOJ Imposes New Standards for Evaluation of Corporate Compliance Programs: Compensations Structures that Promote Compliance (Part II of IV) DOJ Issues Sweeping New Corporate Criminal Enforcement Policy — A New Era of Compliance Begins with Increased Focus on Compensation and Incentives (Part I of IV) Webinar: DOJ’s New Corporate Enforcement Policy — Taking Compliance to the Next Level Episode 248 — Deep Dive into the GOL Brazil FCPA Enforcement Action Michael Volkov and Matt Crome Speak on Third-Party Risk Management at the NAVEX Next Global Virtual Conference Focusing on an Effective Employee Reporting and Investigation System GOL’s Bribery Schemes Orchestrated by Board Director (Part II of II) DOJ and SEC Secure $41 Million Settlement from Brazilian Airline for FCPA Violations (Part I of II) OFAC Releases Preliminary Guidance on Price Caps for Russian Origin Crude Oil and Petroleum Products Episode 247 — Corporate Culture Round Up DOJ Announces Two Significant Indictments Charging Individuals with Healthcare Fraud False Claims Act Round-Up — DOJ Continues Aggressive Prosecution of Healthcare Fraud The Disconnect Between Human Resources and Compliance Civility and Corporate Culture Corporate Culture = Talk + Action Episode 246 — NAVEX’s Annual Global Hotline Benchmarking Report NAVEX Issues 2022 Ethics Hotline Benchmarking Report: Whistleblower Reporting Rates and Retaliation Increase U.S. Sentencing Commission Report: Corporate Prosecutions Decline and Ethics and Compliance Programs Increase Justice Department Announces FCPA Charges Against Two Individuals for Bribery of Marshall Islands Officials SEC Modifies Whistleblower Regulations SEC’s Climate and Cyber Regulations Increase Compliance and Enforcement Risks (Part II of II) SEC Poised to Implement Complex Disclosure Obligations (Part I of II) Episode 245 — Second Circuit Affirms Trial Judge Dismissal of FCPA Verdicts Against Alstom Executive Michael Volkov Featured on Diligent’s Corporate Director Podcast Regulatory Implications from 2019 Capital One Hack and Recent Conviction of Former AWS Engineer Tracking Ethics and Compliance Program Performance (Part II of II) Building a Compliance Dashboard (Part I of II) New York’s Department of Financial Services Proposes New Cyber Compliance Requirements Episode 244 — Building a Compliance Program Dashboard LRN and Tapestry Networks Issue Important Guidance for Corporate Boards and CEOs to Build and Manage Ethical Cultures Department of Commerce Bureau of Industry and Security Brings Enforcement Actions Reflecting New Policies Second Circuit Affirms District Judge Dismissal of Alstom Official’s FCPA Convictions DOJ Targeting Crypto Industry for Enforcement Episode 243 — Scott Greytak, Transparency USA, and Erica Hanichak, the FACT Coalition, on House Passage of The Enablers Act The Growing Tension Between Compliance and Financial Controls Wells Fargo’s Woes Continue — A Rotten Culture that Continues to Stink Ethics and Compliance not Compliance … Oh, and Ethics DOJ’s Antitrust Division Begins Trials to Block Two Large Mergers Episode 242 — LRN Report on Assessing Corporate Culture — Interview of Ty Francis, LRN Chief Advisory Officer Assessing Your Audit and Testing Program (Part IV of IV) Compliance Program Monitoring: Leveraging Data and Analytics (Part III of IV) How to Monitor a Compliance Program? (Part II of IV) Compliance Program Monitoring, Testing, Audits, Assessments and Continuous Improvement (Part I of IV) Russian Sanctions Update: Five Months into the War in Ukraine Episode 241 — Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program OFAC Enforcement Action: Double Check Your Screening Tools Commerce Department Tacks to New Aggressive Enforcement Program DC Circuit Court Rejects Federal Express Challenge to Civil Liability for Violations of Export Regulations OFAC Settles for $430,500 with American Express National Bank for Violation of Foreign Narcotics Kingpin Sanctions Episode 240 — The CCO’s Role in an Effective Compliance Program BioReference Laboratories and Parent Company Agree to Pay $9.85 Million to Resolve False Claims Act Violations for Illegal Payments to Referring Physicians Where Does Your Compliance Program and CCO Fall Under DOJ’s Independence, Authority and Resources Test? (Part IV of IV) The Effective CCO: Independence, Authority and Resources (Part III of IV) The Importance of Ethics and Compliance to the Overall Corporate Mission (Part II of IV) The Chief Compliance Officer: The Blueprint for Success in the Future (Part I of IV) What Happens When the CCO is Buried in the Organization? Compliance Titles and Responsibilities The Importance of Line-of-Sight to Ethics and Compliance The Supreme Court Restricts Access to Discovery in Foreign Arbitration Proceedings United States Pushes More Sanctions Against Russia and Prohibits Russian Gold Imports A Letter from Sicily: The Magical Island and the Gift of Language Happy Fourth of July!! CCOs and Execution of Compliance Certification: A Significant Risk? (Part III of III) DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III) DOJ Compliance Program Certification Requirements (Part I of III) Episode 239 — DOJ’s New CCO Certification Requirement Sanctions in the Twenty-First Century: UK Imposes Social Media Restrictions in Response to Continued Russian Aggression Department of Commerce’s Bureau of Industry and Security Charges Russian Oligarch Abramovich with Violating Russia Export Controls Human Rights and Supply Chain Risks: The Uyghur Forced Labor Prevention Act (Part II of II) Private Attorneys General: Enforcing Human Rights Through Corporate Supply Chain and Risk Management (Part I of II) Episode 238: 2022 FCPA Enforcement Trends . . . So Far DOJ Snares Two More Guilty Pleas in Ongoing Criminal Investigation of Commercial Flooring Business SEC Joins DOJ in Probe of Ericsson ISIS Bribery Payments NAVEX Annual Hotline and Incident Report: A Mixed Bag of Reporting Trends Episode 237 — The Tenaris SEC FCPA Settlement Avoiding Compliance Overkill — Properly Assess and Manage Tangible Risks Banco Popular de Puerto Rico Settles with OFAC for $255,937 for Violations of Venezuela Sanctions Program Deciphering FCPA Enforcement Trends Tenaris Pays SEC $78 Million to Resolve FCPA Violations The Glencore Settlement: Lessons Learned (Part V of V) Glencore’s Commodity Trading Fraud Scheme (Part IV of V) Glencore’s Bribery Schemes (Part III of V) DOJ Puts its New Stamp on FCPA Settlements: Unraveling the Glencore FCPA Settlement (Part II of V) Episode 236 — The Glencore FCPA and Fraud Settlement Glencore Pleads Guilty and Resolves Foreign Bribery and Market Manipulation Charges — Pays Over $1.1 Billion (Part I of V) Responding to Supply Chain Glitches and Increased Bribery Risks Allianz Global Hit With $6 Billion Fine And Portfolio Manager Indicted in Connection with Million-Dollar Fraud Scheme DOJ Criminal Division AAG Underscores Role of CCOs and Announces CCO Certification Requirements Episode 235 — Third-Party Risk Management Third-Party Risk Mitigation and Monitoring (Part V of V) Identify and Understand Your Third-Party Population (Part IV of V) The Upside of Managing Third-Party Risks: Advancing Your Culture (Part III of V) Adjusting Your Perspective — Identifying Your Real Third-Party Risks (Part II of V) Renewing Your Third-Party Risk Management Vows — A Real World Perspective (Part I of V) United States and EU Expand Russian Sanctions and Export Controls Sanctions Enforcement: “The New FCPA” Gleaning the Inside of the Human Mind and Criminal “Intent” What Can We Expect in Future FCPA Enforcement Actions? Episode 234 — A Deep Dive into the Stericycle FCPA Enforcement Action Administration Proposes Legislative Changes to Enhance Asset Forfeiture, Sanctions Enforcement Against Russian Government and Oligarchs Diligent Sponsors Corruption Crime and Compliance Global Logistics Company Settles OFAC Violations for $6.1 Million Episode 233 — Tom Fox and Mike Volkov Discuss DOJ Criminal Trial Wins, Losses and Stumbles Newmont Corporation and Chisu International Settle with OFAC to Resolve Violations of Cuban Sanctions Program Stericycle DOJ and SEC FCPA Settlement: Lessons Learned (Part III of III) Stericycle’s Misconduct: Pervasive and Systemic Bribery Schemes (Part II of III) DOJ Brings First Corporate FCPA Enforcement Action – Settles with Stericycle for $84 Million (Part I of III) Episode 232 — OFAC Settles with S&P Global for $78,750 for Violations of Ukraine-Russia Sanctions SEC Takes Big First Step in Requiring Climate Disclosures SEC Proposes Robust Cyber Incident Reporting for Public Companies Antitrust Division Stumbles in Recent Criminal Cases (Part III of III) DOJ’s Big Case Victories and Misguided Targets (Part II of III) You Win Some and You Lose Some: DOJ’s Stumbles and Mixed Bag of Criminal Trial Results (Part I of III) Episode 231 — SEC Update: Climate Change and Cyber Incident Reporting Rules Appellate Court Upholds OFAC Designation of Oleg Deripaska, a Major Oligarch Ethics and Compliance Initiative Impact 2022 — Sign Up Now! Antitrust Division Enforcement – As Promised and Being Delivered DOJ Raises Stakes on Corporate Compliance Programs – Accountability and Certifications OFAC Focuses on Cybercrime by Sanctioning the Hydra Darknet Market and GARANTEX Cryptocurrency Exchange United States and Europe Ramp Up Sanctions Against Russia and Target Sberbank, Alfa Bank and “New Investments” Episode 230 — Catching Up with DOJ’s Antitrust Division Enforcement Efforts Jessica Sanderson Participates in Women in Compliance Event DOJ’s Focus on Prosecution of White Collar Criminals OFAC Settles with S&P Global for $78,750 for Violations of Ukraine-Russia Sanctions Program DOJ’s Antitrust Chief Outlines Aggressive Approach to Enforcement Against Digital Market Companies US Coal Company VP Arrested and Charged with FCPA, Money Laundering and Wire Fraud Violations DOJ Issues Declination to Global Insurance Company Under FCPA Enforcement Policy Putin’s Puppets Pick on Peppa Pig: Intellectual property rights are collateral damage in the economic war between Russia and the nations supporting Ukraine Interpreting OFAC Sanctions: The Fine Line Between Compliance and Evasion Boeing Technical Pilot Acquitted on Criminal Charges from 737 Max Safety Scandal DOJ Charges Russian Officials for Two Historical Hacking Campaigns The Power of a Corporate Mission, Values-Based Leadership and the “S” of ESG FinCEN Settles with USAA Federal Savings Bank for $140 Million for Willful AML Violations FINRA Issues Guidance on CCO Liability Episode 229 — DOJ Charges TV Producer with Violating Crimea-Related Sanctions United States Slaps Additional Sanctions on Russia Against Luxury Goods DOJ Charges United States/Russian National with Acting as an Illegal Agent under FARA How to Avoid Sanctions Liability Following a Ransomware Attack Compliance by Fear: An “Old” Mindset Episode 228 — Update on Russia Sanctions and Export Controls DOJ Continues Pace of Healthcare Fraud False Claims Act Prosecutions The Force Multiplier: Ethics and Sustainability United States and United Kingdom Move to Prohibit Russian Oil and Gas Imports DOJ Charges Television Producer for Violating Crimea-Related Sanctions Program DOJ Enforcement and Compliance with the New Russian Sanctions NAVEX and Volkov Law Webinar — Russia Sanctions: Impact on Your Third Party Compliance Episode 227 — A Review of the Russia Sanctions and Export Controls United States Announces Additional Sanctions Against Russia and Belarus Global Update and Review: Russia Sanctions and Asset Capture Initiatives OFAC Issues New Sanctions Against Russia’s Central Bank and Sovereign Wealth Funds United States and Allies Announce Further Sanctions Against Russia Targeting Access to the SWIFT System President Biden Announces Broad Coordinated Set of Sanctions and Export Controls Against Russia Episode 226 — A Deep Dive into KT Corp’s SEC Settlement for FCPA Violations Lessons Learned from the KT Corp. SEC FCPA Settlement (Part III of III) KT Corp’s Bribery Schemes (Part II of III) President Biden Announces Additional Sanctions Against Russia: Even More to Come United States Announces Initial Sanctions in Response to Russia’s Invasion of Two Ukraine Regions KT Corp. Settles SEC FCPA Case for $6.3 Million (Part I of III) Episode 225 — Interview of Susan Divers, LRN Senior Advisor, on LRN’s 2022 Ethics and Compliance Program Effectiveness Report DOJ FCPA Opinion Letter Draws Lines Regarding “Corrupt Intent” and the “Business Purpose” Test Prosecutors Embrace Criminal AML Charges in Corruption Cases The Current Trade Sanctions Landscape Against China Michael Volkov’s New Book: Making Money is Not a Mission: 10 Essays on the Compliance Culture Revolution Episode 224 — 2022 Ethics and Compliance Predictions 2021 False Claims Act Year in Review: Judicial and Congressional Developments (II of II) 2021 False Claims Act Year in Review: Enforcement Statistics (Part I of II) LRN’s 2022 Ethics and Compliance Program Effectiveness Report Confirms Importance of Values-Driven and Ethics-Based Corporate Culture DOJ Loses Another Libor-Rigging Case on Appeal Episode 223 — DOJ Issues FCPA Opinion Letter Drawing Lines on “Corrupt Intent” and “Business Purpose” Test Antitrust Division Indicts Four Individuals for Wage Fixing in Labor Markets (Part III of III) CCOs and Criminal Cartel Compliance Programs (Part II of III) The New “Era” of Antitrust Enforcement (Part I of III) Episode 222 — Managing Third-Party Sanctions Risks Preparing for New Russia Sanctions Program: Are You Ready? CCOs 2022 To-Do List: Ethical Culture and ESG Practical Steps to Implement to Manage Third-Party Sanctions Risks (Part III of III) Assessing Third-Party Sanctions Risks (Part II of III) Managing Third-Party Sanctions Risks (Part I of III) Episode 221 — The “Person” of the Year: Environmental Social and Governance Programs OFAC Settles with Hong Kong Trading Company for $5.2 Million for Violations of Iran Sanctions Program “Person” of the Year: Environmental, Social and Governance The Coming Trade Sanctions Against Russia Airbnb Pays $91,172.29 for OFAC Violations of Cuba Sanctions Episode 220 — DOJ NatWest Markets Fraud Spoofing Enforcement Action Growth of Holistic Risk Management Webinar: Antitrust Criminal Enforcement in Labor Markets and Human Resource Compliance 2022 OFAC and Sanctions Enforcement Predictions 2022 Ethics and Compliance Predictions 2022 FCPA Predictions OFAC Closes Out Year with Two-Fisted Settlement with TD Bank Episode 219 — Antitrust Division Indicts Six Aerospace Executives for Criminal Conspiracy in Labor Markets U.S. Commerce and Treasury Departments Increase Sanctions Against Chinese Entities FinCEN Issues Proposed Beneficial Ownership Reporting Regulations NatWest’s Fraudulent “Spoofing” Schemes (Part II of II) NatWest Markets Pleads Guilty and Agrees to Pay $35 Million for Fraudulent “Spoofing” Scheme (Part I of II)2021 Happy Holidays OFAC Collects $133k from a US Individual for Violations of Iran Sanctions Program United States, European Union, United Kingdom and Canada Coordinate Further Sanctions Against Belarus Department of Justice Does the Two-Step and Announces Criminal Conspiracy Charges Against Aerospace Executives The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III) The Five Pillars of the New Anti-Corruption Initiative (Part II of III) Biden Administration Announces New Anti-Corruption Strategy (Part I of III) SEC Adopts Final Rule Implementing Holding Foreign Companies Accountable Act Two-Part Webinar: 2021 FCPA and Sanctions Enforcement and Compliance Reviews Episode 218 — The Biden Administration’s New Strategy on Countering Corruption ECI Best Practice Forum: The Impact of DOJ Guidance on Corporate Compliance Programs District Court Upholds Criminal Antitrust Charges for Labor Price-Fixing FCPA Potpourri: Catching Up with FCPA Enforcement FCPA Enforcement Actions: “O DOJ, SEC, Wherefore Art Thou, DOJ & SEC?” Episode 217: The Growing Risk of Corporate Board Member Liability OFAC Implements New Ethiopia Sanctions Program Export Control Reform Focuses on Chinese Trade and Security Issues (Part II of II) Emerging Developments in U.S.-China Trade Relations (Part I of II) Boeing Settles Shareholder Litigation and Agrees to Reforms (Part IV of IV) Episode 216 — Tom Fox Releases the Second Edition of The Compliance Handbook Boeing’s Board Governance Failures and the 737 MAX Safety Scandal (Part III of IV) The Delaware Court’s Decision Highlights Boeing’s Defective Corporate Culture and Board Governance Failures (Part II of IV) A Tale of Two Boeing Boards — The Disparate Conclusions of the Justice Department and the Delaware Chancery Court (Part I of IV) Dubai Bank Pays $100 Million to Resolve Sanctions Violations with DFS, OFAC and Federal Reserve Episode 215 — Tom Fox and Michael Volkov Discuss the Board Governance Implications of the Boeing 737 MAX Safety Scandal A Recent Report Card on Board Diversity DOJ Battles Ransomware Attacks Supply Chain Disruption and Onboarding Due Diligence Webinar: How to Conduct a Compliance Program Assessment Important Planning and Design Steps in Targeted Employee Survey Program (Part II of II) Monitoring and Measuring A Company’s Ethical Culture: Relevant Survey Strategies (Part I of II) Episode 214 — Review of the Credit Suisse Global Fraud and Bribery Enforcement Action What to Know About the DOJ’s National Cryptocurrency Enforcement Team US Defense Contractor CEO Charged with Bribery Rockwell Automation Executives Arrested for Fraudulent Scheme Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts Justice Department Files to Block Penguin Random House’s Acquisition of Simon and Schuster Episode 213 — How to Structure and Implement an ESG Program Ransomware and OFAC Sanctions Compliance Keeping Track of Third Party Risks – Bribery and Sanctions Here Comes DOJ – Corporate Crime Enforcement Basic Operational ESG Program Issues (Part III of III) Episode 212: DOJ Returns Indictment Against Former Boeing Chief Technical Pilot in 737 MAX Safety Scandal Building an ESG Structure and Program (Part II of III) Implementing ESG Programs: Structure and Responsibilities (Part I of III) Takeaways from OFAC’s Sanctions Compliance Guidance for Virtual Assets and Cryptocurrency Credit Suisse’s Global Bribery and Fraud Scheme (Part II of II) Credit Suisse Settles Multi-Jurisdiction Bribery and Fraud Case for $547 Million (Part I of II) Episode 211 — Update on Anti-Corruption Issues, Interview of Scott Greytak, Transparency International USA An Aggressive Export Control Enforcement Program: The Department of Commerce’s Bureau of Industry and Security Delaware Court Rejects Motion to Dismiss Lawsuit Against Boeing Board Members for Failure to Conduct Proper Compliance Oversight (Part III of III) The Forkner Indictment for the Tragic Boeing 737 MAX Fraud and Crashes (Part II of III) Boeing Technical Pilot Indicted for Fraud in 737 MAX Scandal (Part I of III) Episode 210 — HR and CCOs Watch Out!! DOJ’s Aggressive Antitrust Enforcement in Labor Markets FINRA Reminds Broker-Dealers on Importance of Compliance with New AML Rules CCOs: Expert Problem Solvers The Impact of the Pandemic on Corporate Work Culture The Evolution of Third-Party Risk Management The Elevation of Sanctions Compliance Episode 209 — Schlumberger Settles Two OFAC Enforcement Actions Taro, Sandoz and Apotex Pay $447.2 Million to Settle False Claims Act Liability for Price-Fixing of Generic Drugs Social Media, Employees and Reputational Risks ESG and Business Risks – Leveraging Compliance Resources HR and CCOs Watch Out!! — The Antitrust Division Doubles Down on Labor Market Criminal Cartel Activity Episode 208 — A Review of the WPP SEC FCPA Enforcement Action Former Schlumberger Company Settles OFAC Case for $160k for Violation of Sudan Sanctions (Part II of II) Cameron Settles OFAC Case for $1.4 Million for Violation of Ukraine-Russia Sanctions (Part I of II) DOJ Ends Standoff & Agrees to DPA with Huawei CFO Wanzhou Meng WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III) A Deep Dive into WPP’s Bribery Schemes in India, China, Brazil and Peru (Part II of III) WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III) Episode 207 — Common Pitfalls in Conducting Internal Investigations 4 Requirements for a Healthy Relationship Between a CCO and the Corporate Board Former Ericsson Employee Indicted for Role in Foreign Bribery Scheme The Big “G” in ESG – CCOs Need to Embrace ESG as a Compliance Opportunity NewTek, Inc., a Software Provider, Settles OFAC Violations for $189,483 A Compliance Crisis at NFT Marketplace OpenSea – Transparency on the Blockchain The Fraud Hammer: DOJ and SEC Prosecute CEO of Silicon Valley Start Up The Myth of Corporate Resources and Efficiency Cryptocurrency and the Unbanked: How the Blockchain Can Benefit the Impoverished Culture and a Company’s Most Valuable Intangible Asset – its Reputation The Absent CEO – Who’s Minding the Store? Kraft Foods Agrees to Pay $62 Million for Misstatements in Financial Report Event: Overall FCPA Status and Trends in the Biden Administration Episode 206 — Update on Sanctions Compliance and Enforcement First Bank of Romania Settles OFAC Violations for $862,318 (Part IV of IV) United States and Global Community Adopt Broad Sanctions Targeting Belarus (Part III of IV) OFAC Settles with Bank of China for $2.3 Million for Violation of Now-Repealed Sudan Sanctions Program (Part II of IV) Trade Compliance Dominates Enforcement Landscape (Part I of IV) Episode 205 — How to Audit a Compliance Program Joseph R. Biden, Jr. —The Anti-Corruption President? White Collar Enforcement: Here We Go Again A Kinship with Sisyphus: Challenging an OFAC SDN Designation The Critical Relationship — Compliance and Business Insights from Recent NAVEX Global and KPMG Surveys The Challenge of Technology and Data Pipeline Company Pays $35 Million to Settle Criminal and Civil Environmental Violations for Inland Spill of Oil Drilling Generated Water The Dangers of a Fractured C-Suite 5 Common Internal Investigation Pitfalls Episode 204 — “This is the Way” on Corporate Culture SEC Approves Nasdaq Board Diversity Proposal Remediating the Organization’s Culture (Part IV of IV) Measuring and Reporting on the Organization’s Culture (Part III of IV) Communicating and Embedding the Organization’s Culture (Part II of IV) Practical Approaches to Managing Culture: Defining the Organization’s Mission (Part I of IV) Episode 203 — Interview of David Greenberg on LRN’s Report on Corporate Boards and Compliance Program Engagement ITAR Brokering Activities Demystified DOJ Takes Stock of Criminal Cartel Prosecution Program Internal Investigation Trap – When Does “Oversight” Turn into Control Two-Part Webinar: A Deep Dive into the Foreign Corrupt Practices Act The CEO Sets, Defines and Manages a Company’s Performance and Culture Episode 202 — A Deep Dive into the Alfa Laval OFAC Enforcement Action DOJ’s Criminal Cartel Prosecution of Chicken Industry Expands Net — Koch Foods and Four Pilgrim’s Pride Executives Charged A Basic Question — Where is the CCO’s Office? Unraveling Trade Compliance Issues Involving China’s Human Rights Abuses in Xinjiang When a CCO Fails to Speak Up Alfa Laval pays over $432K for Violations of OFAC’s Iran Sanctions Program Company Kool-Aid, Misconduct and a Misfiring Corporate Culture Why Do Companies Resist Change? Fixating on the Inextricable Link: Culture and Misconduct Looking Under the Hood – When Employees Engage in Wrongdoing? Payoneer Pays $1.4 Million to Resolve OFAC Sanctions Violations Watching a Slow Train Wreck – Culture Breakdowns Step-by-Step The Danger of an Out-of-Touch C-Suite Avanos Medical Pays $22 Million to Settle Criminal Mislabeling Charges for Surgical Gowns DOJ’s Antitrust Division Charges Seris Security and Three Executives, and Announces Plea Agreement with G4S Secure Solutions in Bid-Rigging Conspiracy Involving Overseas Security Services DOJ Antitrust’s Ongoing Criminal Investigation of Labor Market Collusion in Health Care Industry Nets DaVita and Former CEO False Claims Investigations and Criminal Prosecutions: Recent Examples of Criminal Charges – a Lab Owner, A Physician and a Nurse Practitioner (Part V of V) Akron Ohio Health System Agrees to Pay Over $21 Million to Settle False Claims Act Violations for Improper Payments to Referring Physicians (Part IV of V) St. Jude Agrees to Pay $27 Million to Settle False Claims Act Charges for Selling Defective Heart Devices (Part III of V) Alere Agrees to Pay $38.75 Million to Settle False Claims Act Violations (Part II of V) Justice Department, HHS-OIG and Defense Investigators Bring Flurry of False Claims Act Cases (Part I of V) Episode 201 — DOJ Brings Flurry of False Claims Act Cases New Sponsor: Clausematch EU Whistleblower Directive: A Primer (Part IV of IV) – Protections, Prohibitions and Penalties EU Whistleblower Directive: A Primer (Part III of IV) – Data Privacy and Recordkeeping Episode 200 — The Foster Wheeler FCPA Enforcement Action Happy 4th of July EU Whistleblower Directive: A Primer (Part II of IV) – Internal and External Reporting EU Whistleblower Directive: A Primer (Part I of IV) – An Overview Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III) Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III) DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over $18 Million to Settle Bribery Charges in Brazil (Part I of III) Supreme Court Narrows Computer Fraud Law The Justice Department Strikes Back and Recovers Ransom Paid by Colonial Pipeline Compliance Opportunities in and after the Time of COVID-19: A Fascinating Article by Stephen Naughton Listen to the Replay of the Recent Clausematch Webinar: Policy Management, Governance and Leveraging Your Culture of Compliance Episode 199 — Jonathan Marks, Baker Tilly, and Michael Volkov Review the SEC’s Under Armour Case, Accounting Fraud, and Revenue Recognition Issues First American Financial Corporation Settles SEC Case for $487,616 for Cybersecurity Data Breach and Disclosure Failures Contech Engineered Pleads Guilty and Agrees to Pay $8.5 Million for Bid-Rigging and Fraud Corruption Crime & Compliance: Subscribe to Blog and Podcast 1 MDB Corruption Scandal Ripples with Superseding Indictment of Jho Low and Former Rapper “Pras’ Michael for Back-Channel Attempt to Close 1MDB Prosecution Should CCOs Take Responsibility for the “New” ESG Function? Episode 198 — The Biden Administration Announces Anti-Corruption Battle as a National Security Interest LRN’s 2021 Ethics and Compliance Report — the Impact of COVID-19 NAVEX Global Incident Management Study Confirms Impact of COVID-19 on Employee Reporting Cyber Incidents Underscore Absence of Real Private Sector Cybersecurity Standards The SEC’s Push on ESG Disclosure Regulations DOJ Indicts Two Former Diplomats from Chad for Taking a $2 Million Bribe Episode 197 — Review of LRN and NAVEX Global Compliance Surveys and Reports Julius Baer Bank Resolves Money Laundering Charges in FIFA Scandal and Pays Nearly $80 Million DOJ Charges Two Austrian Bankers with Money Laundering as Part of Massive Odebrecht Bribery Scheme The EU Speaking Up Regime – Plenty of Process and Protection but no Bounties Episode 196 — Managing Cybersecurity Risks Memorial Day: A Day of Honor Finding the Right Balance: Sales Incentives and Internal Controls Justice Department’s Antitrust Division Indicts Claxton Poultry Farms in Expanding Criminal Prosecution of Chicken Producing Industry ECI Conducts Important Compliance Survey: E&C Leaders — Voice Your Views! Volkov Law Group Secures False Claims Act Settlement of $5.6 Million Against Tungsten Heavy Powder of San Diego to Settle False Claims Act Case Cybersecurity Oversight: A Board Challenge Episode 195 — Antitrust Compliance Programs Judge Lamberth Sanctions Paul Weiss and Former Partner Alex Oh Webinar: Policy Management, Governance and Leveraging Your Culture of Compliance Under Armour Agrees to Pay $9 Million to Settle SEC Charges it Mislead Investors About Revenue Growth Swiss Life and Three Subsidiaries Agree to Pay Justice Department More Than $77 Million for Conspiracy with U.S. Taxpayers to Hide Assets and Income Episode 194 — Anti-Corruption Enforcement and Compliance Trends in the Pharmaceutical and Medical Device Industries MoneyGram Payment Systems Agrees to Pay OFAC $34k for Sanctions Violations The Transformative Role of “National AML Priorities” for Compliance in the AML Act of 2020 EU Mandatory ESG Due Diligence Episode 193: Proactive Compliance — Monitoring, Testing and Audits The Headline from the SAP Settlement: It’s a New Dawn for Export and Sanctions Compliance (Part IV of IV) SAP’s Comprehensive Export Control and Sanctions Settlement – A New Compliance Frontier for Cloud-Based Services (Part III of IV) SAP’s Export Control and Sanctions Failures Results in Numerous Violations of Iran Sanctions Program (Part II of IV) SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV) Episode 192 — The DOJ-SAP Settlement: A New Compliance Frontier SEC Risk Alert on ESG Investing ESG Automation: Picking the Right Solution Compliance Understanding of Business Processes Alliance Steel Settles with OFAC for $435,003 for Violations of the Iran Sanctions Program Whistleblower Protections under the Anti-Money Laundering Act of 2020 Episode 191 — Interview of Chad Main, Founder of Percipient, a Leading Legal and Compliance Technology Firm Auditors, Lawyers and the Lack of “Independence” — Bias and Financial Incentives Burma Sanctions and Export Licensing Prohibitions Implemented in Response to Military Coup Blue Umbrella Webinar: Anti-Corruption Risks and Compliance Trends in the Pharmaceutical, Medical Device and Life Science Industries Biden Administration Ratchets Up Russia Sanctions China’s Digital Yuan: What to Know About the First Major Central Bank Digital Currency Episode 190 — Catching Up on Russia and Burma Sanctions Programs Where There is No Will, There’s No Way: The Bottom Line for Chief Compliance Officers Before Moving on to ESG, Fix Your Speak Up Culture!! Gunvor Group Former Employee Pleads Guilty to FCPA Scheme to Pay Bribes to Ecuadoran Government Officials Volkov Law Announcements: Matt Stankiewicz is Promoted to Partner, and Ameer Gopalani, Senior Counsel, Joins the Firm Environmental Crime Enforcement: Button Up for an Increase in Criminal Investigations and Compliance Demands Episode 189 — A Review of the ESG Movement Spring Cleaning: Time to Review Your Internal Controls Biden Administration Ramping Up Anti-Corruption Effort Antitrust Division Charges Health Care Staffing Company with Criminal Wage-Fixing and No-Poaching Agreement Episode 188 — 2021 First Quarter Review of OFAC Sanctions Enforcement Integrating ESG into Your Business Meeting the ESG Challenge In-House Counsel and Risk Management Nordgas Settles with OFAC As Part of UniControls Violations of Iran Sanctions Program Episode 187 — Review of DOJ’s Settlement with Boeing for the 737 MAX Safety Scandal Danger! Danger!: Retaliation Against Employees is Increasing (Part II of II) ECI’s Global Business Ethics Survey: The Plusses and Minuses (Part I of II) The Demand for Sustainability and Risk Management Building the Bridge(s) Between Compliance and Business Episode 186 — Interview of Pat Harned, CEO of Ethics and Compliance Initiative, the 2021 Global Business Ethics Survey UniControl Agrees to Pay $216,464 to Settle Case for Violations of OFAC’s Iran Sanctions Program CCOs and Expertise in Risk Management CFTC Opens Inquiry into Binance, One of the World’s Largest Cryptocurrency Exchanges The New York Attorney General’s Office Reaches Settlement with Bitfinex and Tether Webcast: The Future of Compliance and Policy Management Episode 185 – Anti-Boycott Compliance: Interview of Alex Cotoia from the Volkov Law Group Webinar: Leverage Due Diligence to Improve Enterprise-Wide Risk Management Biden Administration Executive Order Mandates 100-Day Review of U.S. Supply Chains The Coming AML Enforcement Storm The SolarWinds Cyber-Attack – The Devastation and Wreckage The Recurring Business Question — Increase Profits Versus Compliance with the Law? Episode 184 — The State of the Chief Compliance Officer Webinar: Proactive Compliance, Monitoring, and Testing Strategies Bioventus Agrees to Pay $3.6 Million to Settle False Claims Act Violations When Federal Prosecutors Break Bad – Federal Judge Orders Investigation of Prosecutors’ Misconduct in Criminal Sanctions Case Pilgrim’s Pride Pleads Guilty to Price-Fixing and Bid-Rigging Conspiracy and Agrees to Pay $107 Million Fine Corporate Board Liability Risks Increase as Delaware Courts’ Reject Caremark Dismissal Claims Episode 183 — Review of DOJ’s Settlement with Deutsche Bank for FCPA and Spoofing Fraud Violations BitPay Agrees to Pay $507,375 to Settle OFAC Sanctions Violations Export Regulation 101—A Primer on U.S. Antiboycott Laws Avnet Asia Settles Export Control Violations for Illegal Sales to China and Iran Episode 182 — Antitrust Division Brings First Criminal Indictments for No-Poach and Wage-Fixing Agreements Volkov Law Group Announces New Ethics and Compliance Small Group Working Sessions DOJ and OFAC Settle with Indonesian Company for $2.5 Million for Violations of the North Korea Sanctions Program Ripple and SEC Joint Letter Indicates Sides Far Apart in Settlement Talks OFAC Starts New Year with Enforcement Action against French Bank for Violations of Syrian Sanctions Program The Rise of ESG In Response to Investor Demand The Urgency of Ethics and Compliance – The Biden Administration and Enforcement Episode 181 — Cryptocurrency Review: Matt Stankiewicz Discusses the SEC’s Case against Ripple, Predictions under the Biden Administration, and Bitcoin’s Corporate Surge Tom Fox Releases The Compliance Handbook 2nd Edition Corruption and Coronavirus – A Toxic Combination CCOs Have a Target on Their Backs: The Coming Storm (Part III of III) Troubling Trends: The CCO’s Authority, Independence and Access to Resources (Part II of III) The State of the Chief Compliance Officer: Looking Back and to the Future (Part I of III) Webinar — The Anti-Money Laundering Act: Enforcement and Compliance Implications Episode 180 — 2020 False Claims Act Review with Jessica Sanderson, Partner, The Volkov Law Group Alexander Cotoia Joins The Volkov Law Group as a Regulatory Manager and Compliance Consultant Boeing’s 737 MAX Scandal: A Fair Resolution? (Part III of III) Boeing’s 737 MAX Scandal: A Review of Boeing’s Deception of the FAA (Part II of III) Ripple Responds to the SEC’s Enforcement Action DOJ and Boeing Settle 737 Max Fraud and Safety Charges for $2.5 Billion (Part I of III) False Claims Act 2020 Year in Review: The FCA “Has Never Been More Important Than it is Right Now” Episode 179: Tom Fox and Mike Volkov Discuss the Biden Justice Department and Enforcement Issues New Jersey Businessman Pleads Guilty to FCPA Violation FinCEN Settles with Capital One for $390 Million for AML Violations Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II) Deutsche Bank Agrees to Pay $130 Million to Resolve FCPA and Fraud Cases (Part I of II) DOJ Files Civil Complaint Against Walmart for Illegal Opioid Distribution Episode 178 — The Corporate Transparency Act: Interview of Scott Greytak, Transparency International, and Erica Hanichak, The Fact Coalition Sabre Travel Services Settles Data Breach Charges with State Attorneys General for $2.4 Million OFAC 2020 Review: Enforcement Themes and Common Violations (Part II of II) 2020 OFAC Sanctions Enforcement Year in Review (Part I of II) 2020: What a Year! The Important Keys to Rebuilding a Positive Corporate Culture The Curious Absence of Corporate Monitors Episode 177 — 2020 OFAC Enforcement Year in Review Attention U.S. Exporters to Hong Kong: Have you Reviewed Your Export Licenses and Trade Compliance Program to Account for Recent Changes? New Criminal Antitrust Whistleblower Law Enacted SEC Launches Enforcement Action Against Cryptocurrency Company Ripple The “Person” of the Year: Goldman Sachs DOJ’s Antitrust Division Launches Two Criminal Prosecutions of Illegal No-Poach and Wage-Fixing Agreements 2020: A Year of Ethical Challenges Episode 176 — 2020 FCPA Enforcement and Compliance Trends OFAC Ends 2020 with Two Enforcement Actions 2021 FCPA Predictions (Part IV of IV) 2020 Year in Review: Interesting Enforcement Actions (Part III of IV) Rescheduled Webinar: 2020 FCPA Enforcement and Compliance Review 2020 Year in Review: DOJ and SEC Compliance Guidance (Part II of IV) 2020 FCPA Review: Another Record Year for Enforcement (Part I of IV)2020 Happy Holidays! Episode 175 — A Deep Dive into the Vitol FCPA Settlement Episode 174: Five Basic Steps to Implement a Sanctions Compliance Program BitMEX Trading Exchange Earns Criminal and Civil Prosecution for AML Violations New Year Webinars: 2020 FCPA and OFAC Enforcement and Compliance Reviews California Mandates Increased Diversity on Corporate Boards The Danger of Internal Controls Enforcement: The Andeavor SEC Settlement FTC and 48 States File Antitrust Case Against Facebook Episode 173 — Review of HHS-OIG Fraud Alert on Speaker Programs Maintaining Perspective: Enterprise and Compliance Risk Management Vitol FCPA Settlement: Lessons Learned (Part III of III) Vitol’s Bribery Schemes in Brazil, Ecuador and Mexico (Part II of III) Vitol Pays $163.7 Million to Settle FCPA Case (Part I of III) Episode 172 — Interview of Brian Whisler, Baker McKenzie Partner, on Department of Justice Changes under the Biden Administration OCC Fines JP Morgan Chase $250 Million for Deficient Internal Controls Gatekeeper Misfires and Corporate Governance Failures Five Basic Steps to Implement a Sanctions Compliance Program Webinar: Monitoring Your Third Parties — Digging into Distributor and Agent Risks HHS-OIG Warns Drug and Device Companies on Speaker Program Fraud Citigroup Fined $400 Million by Banking Regulators for Risk and Compliance Control Deficiencies Episode 171 — Promoting an Ethical Culture: Interview of Jeffrey Tilton Happy Thanksgiving! Too Big to be Accountable: The Big Case Dilemma OFAC Screening and Internal Controls Episode 170 — The Beam Suntory FCPA Settlement Analysis of DOJ’s Antitrust Case Against Google (Part III of III) Webinar: Antitrust Enforcement and Compliance Trends DOJ’s Monopolization Claims Against Google (Part II of III) Justice Department Files Antitrust Case Against Google Claiming Monopolization of the Search and Search Advertising Markets (Part I of III) FinCEN Issues Human Trafficking Advisory (Part II of II) The Scourge of Human Trafficking and Financial Red Flags (Part I of II) Episode 169 — DOJ Files Antitrust Case Against Google The Herbalife FCPA Settlement: Board Oversight and Internal Audit Failures Veterans Day: Service and Sacrifice Goldman Sachs and the Economic Impact of Corruption Beam Suntory Bribery Scheme: Another Controls Failure (Part II of II) Webinar: The Nuts and Bolts of OFAC Sanctions Compliance DOJ Hits Beam Suntory with FCPA Settlement for $19.5 Million (Part I of II) Episode 168 — Review of Merit Medical False Claims Act Settlement The Long Path to a Whistleblower Recovery: Former CCO Vindicated by Merit Medical Systems False Claims Act Settlement (Part II of II) Merit Medical Systems Settles False Claims Act Case for $18 Million (Part I of II) DOJ Cryptocurrency Guidance Outlines Enforcement Partnerships (Part II of II) DOJ Releases Cryptocurrency Guidance and Enforcement Framework (Part I of II) Webinar: The Importance of an Ethical Culture Commerce Department Restricts Licensing for Exports of National Security Items to China, Venezuela and Russia Episode 167 — A Review of the J&F Investimentos FCPA Settlement The Fundamental Gap in Data Privacy Enforcement Stephen Naughton Joins the Volkov Law Group as Senior Counsel Berkshire Hathaway Agrees to Pay $4.1 Million for Iran Sanctions Violations Lessons Learned from the Goldman Sachs FCPA Enforcement Settlement (Part III of III) Goldman Sachs’ Lucrative and Wide-Ranging Corrupt Scheme (Part II of III) Goldman Sachs Settles Massive 1MDB Bribery Case and Agrees to Pay Nearly $3 Billion (Part I of III) Episode 166 — The Goldman Sachs FCPA Settlement for Nearly $3 Billion Elizabeth Slim, Senior Consultant from The Volkov Law Group, Interviewed on Captivated Audience, a Financial Crime Podcast J&F Investimentos Subsidiary, Pilgrim’s Pride, Agrees to $110 its Million Penalty for Antitrust Cartel in Chicken Processing Industry (Part V of V) J&F Investimentos FCPA Settlement: Lessons Learned (Part IV of V) Commerce Department Offers Six-Month Extension for Export Licenses SEC FCPA Settlement: J&F Investimentos Bribery Scheme (Part III of V) DOJ FCPA Settlement: J&F Investimentos’ Bribery Schemes (Part II of V) J&F Investimentos Pleads Guilty to FCPA Bribery Conspiracy and Settles SEC Case for Total of $283 Million (Part I of V) Episode 165 — Boeing Continues to Struggle from 737 MAX Safety Scandal Corruption Crime & Compliance: Subscribe to Blog and Podcast DOJ Indicts Former CEO of Cancer Treatment Company for Conspiracy Letting Third Parties Do the Dirty Work DOJ Adds Six New Defendants to Price-Fixing Boiler Chicken Conspiracy RNC Deputy Finance Chair Elliott Broidy to Plead Guilty to Foreign Agent Registration Act Conspiracy Episode 164 — Catching Up on Recent OFAC Enforcement Actions Welcome to New Sponsor: Blue Umbrella SEC Amends Whistleblower Rules OFAC Settles with Generali Global Assistance, Inc. for $5.8 Million for Violations of Cuban Sanctions DOJ, CFTC and SEC Settle Spoofing Fraud Charges with JP Morgan for $920 Million Ask Your Board and Your C-Suite – “How Do You Know We Have an Ethical Culture?” Episode 163 — Review of Recent FCPA Cases Involving Petroecuador Register Today for NAVEX NEXT Virtual Conference October 22, 2020 Boeing’s Culture of Neglect and Disregard of Safety: The House Transportation Committee Report Findings (Part II of II) Boeing 737 MAX Accountability: Shareholder Litigation Against Boeing Board & House Transportation Committee Issues Scathing Report (Part I of II) Keysight Technologies Settles with OFAC for $473,157 for Violations of Iran Sanctions Program Sargeant Marine Pleads Guilty to FCPA Charges and Agrees to Pay $16.6 Million Webinar: 2020 FCPA Enforcement and Compliance Review Justice Department Indicts Vitol Oil Trader in International Bribery and Money Laundering Conspiracy for Corrupt Payments to Ecuadoran Officials Episode 162 — Jessica Sanderson on How to Conduct a Remote Third Party Audit The Importance of a Separate Board Compliance Committee Remote Compliance Learning on Volkov Law TV Tom Fox Podcast Featuring John Fons, Former Head of Compliance at Modine, on CCO Challenges Comtech Telecomm Settles OFAC Violations for $894,111 Daimler AG and Mercedes Benz Settle with US for $1.5 Billion for Emissions Cheating Episode 161 — The European Union Whistleblower Directive Michael Volkov’s Guest Appearance on Technically Legal Podcast DOJ and CFTC Settle Spoofing Case with Scotiabank for $127.4 Million Deutsche Bank Settles Two OFAC Cases Totaling $583K for Violations of Ukraine-Russia Sanctions The Importance of the Internal Audit and Compliance Partnership Episode 160 — A Deep Dive into the Herbalife FCPA Settlement Webinar: Speak Up – How to Foster a Culture of Compliance Herbalife FCPA Settlement is An Important Reminder: Global Companies Need to Focus on Foreign Government Touchpoints DOJ’s Antitrust Division Targets Commercial Flooring Industry for Criminal Cartel Activity DOJ’s Focus on Criminal Antitrust Enforcement and Government Procurement Happy Labor Day! Episode 159 — The Steve Bannon “We Build The Wall” Fraud Scheme OFAC Settles Enforcement Action with Individual for $5000 Herbalife’s FCPA Settlement: Lessons Learned (Part III of III) Herbalife’s China Bribery Scheme (Part II of III) Herbalife Settles FCPA Charges and Agrees to Pay $123 Million (Part I of III) Teva Pharma Charged with Antitrust Conspiracy in Generic Pharmaceuticals Industry Episode 158 — Improving Corporate Board Governance Tom Fox’s 500th Podcast Episode Celebration DOJ Secures Guilty Plea and Charges A Second Former PDVSA Official with Money Laundering Three Individuals Charged with Fraud and FCPA Violations in International Adoption Scheme FCPA Issues First Opinion Release in Six Years The IIA’s New Three Lines of Defense Model Misses The Mark Steve Bannon and Three Defendants Indicted for $25 Million “We Build The Wall” Fraud Scheme Webinar: FCPA Compliance — Acquisitions, Integration & FCPA Audits Episode 157 — A Review of World Acceptance Corp. Settlement with SEC for FCPA Violations Ten Essential Steps to Take Now to Advance Corporate Board Governance (IV of IV) Challenges for Board Decision-Making (Part III of IV) Corporate Board Diversity: A Slow Train Moving (Part II of IV) The State of Corporate Board Performance and Accountability (Part I of IV) Episode 156 — OFAC Sanctions Enforcement and Screening Errors Companies and Change: A CCO Challenge The EU Whistleblowing Protection Directive: Implementing Practical Solutions to Comply (Part II of II) Leveraging the EU Whistleblower Directive to Improve Employee Reporting (Part I of II) World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million The Demand for Organizational Justice Webinar Reminder: Effective Management of Employee Reporting Systems Episode 155 — Tom Fox and Mike Volkov Discuss Governance Lessons from Blue Bell Creameries Listeria Outbreak Valeant Pharmaceuticals (Now Bausch Health) and Three Former Executives Settle SEC Cases Apple and Amazon Fall to OFAC Enforcement for “Screening Errors” (Part III of III) OFAC Enforcement Cases Focused on “Screening Errors”: American Express and Cobham Metalics (Part II of III) OFAC Enforcement and “Screening Errors” (Part I of III) ComplianceLine & The Volkov Law Group Webinar: Effective Management of Employee Reporting Systems OFAC On A Roll: Whitford Worldwide Company Agrees to Pay $824k for Violations of Iran Sanctions Episode 154 — Artificial Intelligence, Data Risk Management: Interview of Christian Focacci from Steele Compliance Solutions Oklahoma City Hospital, Management Company, And Physician Group To Pay $72.3 Million To Settle Federal And State False Claims Act Indivior Solutions Pleads Guilty to False Statements and Agrees to Pay $600 Million to Resolve Criminal and Civil investigations for Marketing of Opioid Addiction Treatment Drug Suboxone DOJ Criminal Generic Pharma Price-Fixing Investigation Gathers Steam: Taro Pharmaceuticals Agrees to Pay DOJ Total of $419 Million DOJ and OFAC Settle with UAE Company for $665,112 for Violations of North Korea Sanctions Episode 153 — Mighty Amazon Falls to the OFAC Sword Universal Health Agrees to Pay $122 Million for False Claims Act Violations The Mighty Amazon Falls to the OFAC Sanctions Sword Steele Announces New “Risk Intelligence Data” Platform While Navigating Middle Ground, Supreme Court Upholds Congressional Subpoena for President Trump’s Financial Records (Part II of II) Episode 152 — Supreme Court Issues Two Important Decisions on Subpoenas for President Trump’s Financial Records In Decisive Ruling, Supreme Court Rejects Trump Administration Challenges to State Criminal Grand Jury Subpoena (Part I of II) Episode 151 — Tom Fox and Michael Volkov Discuss the Revised FCPA Guidance Webinar: 2020 Mid-Year OFAC Sanctions and Compliance Review DOJ Charges Two Sons of Former Panama President Martinelli with Participation in Odebrecht Bribery Scheme in Panama Revised FCPA Guidance: Effective Compliance Program and Internal Controls (Part V of V) The Volkov Law Group Announces Promotions of Jessica Sanderson, Matt Stankiewicz and Noah Smith Webinar: Jessica Sanderson and Jonathan Marks — Best Practices for Conducting Remote Internal Investigations Revised FCPA Guidance: Legal Issues and Clarifications (Part IV of V) Revised FCPA Guidance: Updated DOJ Policies (Part III of V) Revised FCPA Guidance: New Case Updates (Part II of V) DOJ and SEC Issue Revised FCPA Guidance (Part I of V) Episode 150: Review of Novartis False Claims Act and Anti-Kickback Settlements for $729 Million Alexion FCPA Violations: Lessons Learned (Part II of II) Alexion Pays SEC $21 Million for FCPA Violations (Part I of II) Webinar: Catching Up with DOJ Compliance Program Guidance Supreme Court Restricts Disgorgement Remedy Novartis Settles False Claims Act Cases and Pays $729 Million for Domestic Bribery Schemes Episode 149 — A Deep Dive into the Alexion’s SEC Settlement for $21 Million for FCPA Violations Happy 4th of July! Corporate Culture: Health and Safety (Part II of II) Corporate Culture: Leadership (Part I of II) Novartis and Alcon FCPA Enforcement Action: Lessons Learned (Part III of III) Novartis and Alcon: A Review of Bribery and Accounting Violations (Part II of III) Novartis and Alcon Settle FCPA Violations for $345 Million (Part I of III) Episode 148 — A Review of the Novartis & Alcon FCPA Enforcement Action Building a Robust Post-Acquisition Integration Process (Part II of II) DOJ’s Revised Compliance Guidance: The Refocus of Mergers and Acquisitions Risks and Mitigation (Part I of II) Bumble Bee CEO Sentenced to 40 Months in Prison for Price-Fixing Insider Trading by Members of Congress: An Enforcement Nightmare? Episode 147 — DOJ’s Revised Compliance Guidance and Refocus of Merger and Acquisitions Risks Antitrust Compliance Lessons Learned from Chicken Price-Fixing investigation and Indictment (Part III of III) The Criminal Chicken Price-Fixing Conspiracy (Part II of III) Justice Department’s Antitrust Division Charges Four Executives in Chicken Price-Fixing Investigation (Part I of III) Treasury, State Department and Coast Guard Issue Advisory and Guidance on Maritime Industry Deceptive Shipping Practices Episode 146 — A Deep Dive into DOJ’s Indictment of Four Executives for Chicken Industry Price-Fixing Conspiracy The Fish Rots from its Head Down – Review of Criminal Charges Against Blue Bell’s Former CEO Paul Kruse DOJ’s Compliance Message: Implement Technology Solutions DOJ Plays Catch Up in Revised Compliance Program Guidance The Five Most Important Issues in DOJ’s Revised Compliance Program Guidance Episode 145 — DOJ Revises its Corporate Compliance Program Guidance DOJ Revisions to Corporate Compliance Guidance: Training, Third-Party Risk Management, Mergers/Acquisitions and Data (Part II of II) DOJ Revises its Corporate Compliance Guidance (Part I of II) Drug and Medical Device Fraud Risks Increase in Pandemic Era Episode 144: A Review of Criminal Charges Against Paul Kruse, the Former CEO of Blue Bell Ice Cream A Window into Boeing’s Defective Culture (Part III of III) Boeing and the 737 Max Scandal (Part II of III) The Boeing Scandal and the Demise of a Corporate Culture (Part I of III) Insights from the 2020 NAVEX Global Hotline and Incident Management Report Episode 143 — The Boeing Safety Scandal and the Demise of Boeing’s Corporate Culture Beneficial Ownership: Identification and Mitigation (Part IV of IV) Practical Risk-Based Ranking Strategies to Beneficial Ownership Issues (Part III of IV) Unraveling Beneficial Ownership Risks (Part II of IV) Addressing Beneficial Ownership Requirements in Your Compliance Program (Part I of IV) Episode 142: Covid-19: The New Risk and Compliance Framework In a Unanimous Decision, the Supreme Court Reverses New Jersey Bridgegate Convictions Cancer Treatment Center Agrees to DPA and $100 Million Penalty for Criminal Antitrust Violations in Florida Market Despite Pandemic, OFAC Settles with Animal Nutrition Company for $257k for Violations of Cuban Sanctions Program Episode 141 — Practical Approaches to Managing Beneficial Ownership Risks (Part II of II) Episode 140 — Addressing Beneficial Ownership Interest Risks in Your Compliance Program (Part I of II) Privacy and Employee Issues During the New COVID-19 Pandemic Era Chipotle Mexican Grill Enters Three-Year DPA and Pays $25 Million Penalty for Food Safety Violations (Part II of II) DOJ Resolves Two Important Food Safety Criminal Cases: Blue Bell Creameries and Chipotle Mexican Grill (Part I of II) DOJ and FBI Fight Back Against Pandemic Fraud Episode 139 — DOJ Resolves Two Food Safety Criminal Cases: Blue Bell Creameries and Chipotle Mexican Grills Ensuring Employee Reporting in the New COVID-19 Pandemic Era The Importance of the Human Resources and Compliance Partnership in the New COVID-19 Pandemic Era The Risk of “Price Gouging” in the New COVID-19 Pandemic Marketplace Webinar: COVID-19 — The New Compliance and Risk Framework Health and Safety in the New COVID-19 Pandemic Era Episode 138: Employee Relations and Engagement in the New COVID-19 Pandemic Era OFAC Releases Guidance on Sanctions Compliance During the Pandemic ENI Pays SEC $24.5 for FCPA Violations SEC Charges Ex-Goldman Investment Banker for FCPA Bribes in Ghana Power Project The CARES Act and DOJ Prosecution of Fraud Why a Duck: Tom Fox and Michael Volkov Discuss COVID-19 and Compliance BVD Webinar –COVID-19 and compliance: is lockdown accelerating automation in onboarding and AML? Are Compliance Officers “Essential”? Episode 137 — FCPA Update: Eni Settles FCPA Case and SEC Files Case Against Ex-Goldman Sachs Executive COVID-19 and Force Majure Contractual Provisions The Fundamental Foundation – Board Oversight of Corporate Ethics and Compliance Programs Risk Lessons from the Pandemic Warfront Episode 136 — Justice Department Fraud Enforcement in the Pandemic Era Videoconferencing and Export Controls COVID-19: DOJ’s Aggressive Prosecution of Fraud and Pandemic-Related Crimes A Personal Tribute to Judge Stanley Sporkin: The Fern Street Crew Gang Prosecution (Part II of II) A Personal Tribute to Judge Stanley Sporkin (Part I of II) Virginia Suveiu and Janet Longo Join Volkov Law Group Episode 135 — A Personal Tribute to Judge Stanley Sporkin IRS’ Response to COVID-19: What Taxpayers Need to Know Steele Webinar: Top 6 Due Diligence Best Practices Third-Party Risk Management DOJ Hoarding and Price Gouging Task Force Seizes Critical Medical Supplies and Distributes to New York and New Jersey Hospitals COVID-19: Supply Chain Risks Lessons COVID-19: Important Changes to Employment Law Board Governance Challenges in COVID-19 Crisis Episode 134: COVID-19 (Part II) — Business Response to Pandemic Episode 133 — COVID-19 (Part I): Absence of Federal Leadership and Recent Congressional Actions Congress Enacts CARES Stimulus Act COVID-19: Employee Risks and Privacy Bank Secrecy Act Compliance During the COVID-19 Crisis COVID-19: Crisis Management Ethical Business Decisions in the COVID-19 Crisis The Coronavirus Pandemic: A Call for Leadership Episode 132 — Key Elements of an Effective Antitrust Compliance Program Antitrust Compliance Programs: Training and Speak Up and Reporting Systems (Part III of III) Antitrust Compliance Programs: Ethical Culture and Monitoring (Part II of III) Webinar: How to Implement an Effective OFAC Sanctions Compliance Program Five Key Elements of an Antitrust Compliance Program: Risk Assessments (Part I of III) Webinar: Maintaining a Reliable and Effective Internal Investigation Program “Paralysis” and a Culture of Wrongdoing The Pandemic Crisis – A Note of Support Episode 131 — Third-Party Risk Monitoring and Auditing Strategies Addressing the Coronavirus Crisis and Corporate Response United Bank Risk Officer Agrees to $450k Penalty for AML Compliance Failures The Danger of a Hyper-Focused Sales Culture DOJ Catches Big Fish in Generic Pharmaceutical Criminal Antitrust Investigation Episode 130 — Practical Strategies for OFAC Sanctions Risk Assessments Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations Cardinal Health Pays SEC $8.8 Million for FCPA Violations Admit It – Your Compliance Program is Not Really “Effective” Episode 129 — How to Create a Third-Party Risk Profile The Impact of a New CEO Incident Data and Intra-Company Cooperation Three Former Executives from Alstom and Marubeni Charged with Criminal FCPA Violations in Indonesia The Volkov Law Group is Hiring — Junior Associate and Paralegal Wells Fargo Settles With Justice Department for $3 Billion Episode 128 — Compliance Automation and Program Measurement and Evaluation Fourth Circuit Overturns Federal Prosecutors’ Use of Filter Team to Conduct Search of Law Firm Documents The Dangerous Mix of Incentives and “Misconduct” Rebalancing Third-Party Risk Strategies Episode 127 — Deep Dive into OCC Enforcement Action Against Wells Fargo Executives The “Old” Board Governance Model Needs to Change NAVEX Global Webinar: Third-Party Risk Management & Effective Controls Why a Duck – Episode 10, A Night at the Opera, Part 2 and 2019 FCPA Enforcement Year in Review Keeping Your Eye on the Risk Ball Episode 126 — The Airbus $4 Billion Settlement for Bribery and ITAR Violations Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV) Airbus ITAR Settlement: Review of Airbus ITAR Violations (Part III of IV) Airbus FCPA Settlement: Review of Airbus Bribery Scheme (Part II of IV) Airbus Agrees to Pay $4 Billion in Global Settlement of Foreign Bribery and ITAR Violations (Part I of IV) Episode 125 — Interview of Elizabeth Slim, Senior Consultant at the Volkov Law Group: AML and Financial Compliance Trends OFAC Issues First Two Enforcement Actions of 2020 DOJ Announces Voluntary Disclosure Program for Criminal Export and Sanctions Violations OCC Settles Penalty Action with Former Wells Fargo CEO for $17.5 Million and Issues Penalty Notices Against Five Former Wells Fargo Officials Why a Duck — Episode 9, A Night at the Opera, Part 1 and 2019 Compliance Year in Review False Claims Act 2019 Year in Review Episode 124 — False Claims Act 2019 Review Get Compliance Straight – The Need to Automate OFAC Loses Exxon Sanctions Enforcement Case OFAC Sanctions Compliance: 2019 a Game-Changing Year (Part II of II) 2019 OFAC Sanctions Enforcement Review (Part I of II) Episode 123 — 2019 OFAC Enforcement and Compliance Review The Future of Compliance – The New Proactive CCO (Part III of III) The Future of Compliance: Building Bridges (Part II of III) The Future of Compliance: Re-Branding Compliance from Reactive to Proactive (Part I of III) Ethics and Compliance Trends and Predictions for 2020 Episode 122 — 2020 Ethics and Compliance Predictions and Trends A Speak Up Culture Depends on Follow Through and Accountability FCPA Predictions for 2020 (Part III of III) 2019 FCPA Enforcement Highlights (Part II of III) FCPA 2019: A Record Year in Enforcement and Compliance (Part I of III) Episode 121: 2019 — FCPA Year in Review Elizabeth Slim, a Certified Anti-Money Laundering Specialist, Joins The Volkov Law Group Two Webinars: 2019 FCPA Year in Review & 2019 OFAC Enforcement Year in Review2019 Happy Holidays Travel Insurance Companies Hit with OFAC Enforcement Actions Compliance Messaging: Need a Reason? ‘Tis the Season! Bumble Bee CEO Convicted of Participating in Price-Fixing Conspiracy Episode 120 — Interview of NAVEX Global’s Chris Bailey and Stephen Gooding Webinar: 2019 — The FCPA Year in Review Boston Heart Diagnostics Pays $26.67 Million to Settle False Claims Act Case Turning a Turbulent Social and Political Environment into Positive Ethical Culture Strategies Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II) Ericsson Pays $1 Billion for Systemic FCPA Violations (Part I of II) Episode 119 — The Ericsson FCPA Settlement DOJ Indicts Former Braskem CEO on FCPA Criminal Charges Apollo Aviation Group Pays $210k to OFAC for Violations of Sudanese Sanctions Program DOJ Tweaks FCPA Corporate Enforcement Policy Webinar: Third-Party Risk Management — Practical Solutions to Due Diligence, Monitoring and Testing Apple Pays $467K to OFAC for Sanctions Violations Episode 118 — OFAC Enforcement Update and Lessons Learned Happy Thanksgiving! Volkov Law in the News: Representation of Lt. Col. Alexander Vindman in House Impeachment Inquiry DOJ Notches Another Trial Victory — President of Transport Logistics Convicted of FCPA and Wire Fraud Charges New BVD White Paper — What you need to know for sanctions compliance Review of Samsung’s Bribery Scheme in Brazil (Part II of II) Samsung Agrees to Pay $75 Million to Resolve FCPA Violations (Part I of II) Episode 117 — FCPA Update: Samsung pays $75 million to settle FCPA charges; Braskem’s former CEO indicted on FCPA charges; and Transport’s co-CEO is convicted on FCPA charges SEC Examiner Charged with Stealing Confidential Information and Obstruction of Justice DOJ Charges Two Herbalife Executives with Criminal FCPA Violations Alstom Executive Convicted on FCPA and Money Laundering Violations California AG Issues California Consumer Privacy Act Regulations Under Armour Under DOJ and SEC Investigation For Revenue Recognition Scheme Episode 116 — Alstom Executive Convicted of FCPA and Money Laundering Offenses FINRA Fines BNP Paribas $15 Million for Anti-money Laundering Violations Two Charitable Foundations Pay $6 Million for Anti-Kickback Violations Justice Department Unseals Unaoil Executives’ FCPA Guilty Pleas Episode 115 — Review of Recent Healthcare Fraud Enforcement Actions Five Steps to Improve Board Monitoring of Compliance Why A Duck — Episode 6, Coconuts and the OFAC Compliance Framework Episode 114 — Update on Board Member Liability for Compliance Oversight Failures Department of Justice Brings Criminal Charges Against 35 Individuals for Involvement in $2.1 Billion in Fraudulent Genetic Testing Results Avanir Pharmaceuticals Pays More than $108 Million to Settle Kickback Violations Delaware Court Increases Scrutiny of Corporate Board Oversight and Monitoring of Compliance Programs Episode 113 — Managing Conflict of Interests Risks Why a Duck — Episode 5, Horsefeathers and the Juniper Networks FCPA Enforcement Action House of Representatives Passes Bill Aimed at Marijuana Industry Financial Reforms Sign Up for NAVEX Global’s 2019 Ethics & Compliance Virtual Conference What Does “Business Ethics” Mean? The Importance of Whistleblowers to a Speak Up Culture Episode 112 — Implementing an Effective Training Program How to Implement an Effective Ethics and Compliance Committee Technology and Compliance: The Magic Bullet? Webinar: Conflicts of Interest — Effective Strategies to Mitigate Risks General Electric Pays OFAC $2.7 Million for Violations of Cuba Sanctions Program Episode 111 — How to Design and Implement an Antitrust Compliance Program Canadian Fuel Technology Company and Former CEO Settle SEC FCPA Case Quad/Graphics Settles SEC FCPA Case for Nearly $10 Million Barclays Agrees to Pay the SEC $6.3 Million to Settle FCPA Offenses for Hiring of Relatives of Foreign Officials in Asia Episode 110: SEC Settles Three FCPA Cases on One Day Cooperating Cognizant COO Pays $50K to Settle SEC FCPA Action UK Bank Agrees to Pay $4 Million to Settle OFAC Sudanese Sanctions Violations Fixing a Toxic Corporate Culture Episode 109 — The Business Roundtable Restatement of Corporate Purposes and the Importance of Ethical Leadership Corporate Board Strategies for Monitoring and Promoting a Company’s Ethical Culture (Part III of III) Assent’s Supply Chain Risk Conference Living in the Cloud: Practical Approaches to Cybersecurity Risks (Part III of III) Bringing the Board to the Ethical Culture Table (Part II of III) The Business Roundtable’s Restatement of Corporate Purpose: A Big Step or a Fig Leaf? (Part I of III) Episode 108 — The Capital One Data Breach and Cybersecurity Vendor Risks Why A Duck – Episode 4, Horsefeathers and the DOJ Antitrust Division Compliance Program Guidance Managing Third-Party Vendor Cybersecurity Risks (Part II of III) Lessons Learned from the Capital One Data Breach (Part I of III) Episode 107 –FCPA Update — The Juniper Networks and Deutsche Bank SEC Settlements and the Ng Lap Seng Appellate Court Decision Juniper Networks Settles FCPA Violations with SEC for $11.7 Million Deutsche Bank Settles FCPA Case with SEC for $16 Million for Hiring Relatives of Public Officials Second Circuit Affirms FCPA Conviction of Ng Lap Seng and Rejects Application of Supreme Court’s McDonnell Decision to FCPA Volkov Law Group — In the News Episode 106 — Understanding the California Consumer Privacy Act US Board Diversity: Slow-Moving Change When Company Supervisors and Managers Engage in Misconduct The Current State of Compliance and Internal Audit Partnership Attend Converge19: October 1 – 3, 2019 Episode 105 — Third-Party Risk Management: Interview of Bill Hauserman and Ted Datta, Bureau van Dijk Putting Data Security Risks in Perspective: The Proper Role of a Chief Privacy Officer Key Actions to Ensure Compliance with the California Consumer Privacy Act (Part II of II) California Sunshine — The California Consumer Privacy Act (Part I of II) Episode 104 — Deep Dive into Microsoft FCPA Settlement OFAC Implements Broad Sanctions Against Venezuela Cybersecurity Threats, Data Privacy and the Important Role of Compliance OFAC Announces $1.7 Million Settlement with Truck Manufacturer for Violations of Iran Sanctions Program New Podcast: Tom Fox and Michael Volkov — Why a Duck? Into the Compliance Soup with Tom Fox and Michael Volkov Episode 103 — Managing Supply Chain Risks Antitrust Division Launches Broad Investigation of High-Tech Industry Board Members Should Take Note — Delaware Supreme Court Issues Important Decision on Caremark Compliance Standard OFAC’s New §501.604 Reporting Requirement: A Small Change with a Big Impact Episode 102 — The Future of Compliance Digging into High-Risk Distributors (Part II of II) Managing High-Risk Distributor Risks (Part I of II) Five Common Weaknesses in OFAC Sanctions Compliance Programs Corrupt Intent and Bribery Five Lessons for Third-Party Distributor Risk Management from Microsoft FCPA Settlement (Part III of III) Episode 101 — The Antitrust Division Announces New Credit for Compliance Programs Microsoft FCPA Settlement Underscores Third-Party Risks (Part II of III) Microsoft Pays DOJ and SEC $25 Million to Resolve FCPA Violations (Part I of III) Data, Data and Data – How to Collect and Measure Data for Your Compliance Program? The Overwhelmed CCO Episode 100 — Interview of Tom Fox, the Compliance Evangelist Five Important Mandates from OFAC Compliance Framework Ethical Culture Begins with Senior Management DOJ’s Antitrust Division Issues New Guidance for Evaluation of Corporate Compliance Programs (Part II of II) NAVEX Global and Volkov Law Issue Vendor Risk Management Toolkit DOJ’s Antitrust Division Announces New Policy for Crediting Corporate Compliance Programs (Part I of II) Webinar: Antitrust Division Announces New Policy to Credit Compliance Programs Episode 99 — When to Conduct Enhanced Anti-Corruption Due Diligence The Critical Dataset: HR, Hotlines and Incident Management Catching Up with OFAC Sanctions Enforcement Actions NAVEX Global’s 2019 Definitive Corporate Compliance Benchmarking Report An Introduction to Libra – Facebook’s Foray into Cryptocurrency and its Regulatory Hurdles Episode 98 — Quick Dive into Recent OFAC Enforcement Actions Episode 97 — Matt Stankiewicz Discusses Blockchain Domains and Trademarks with Brad Kam, Co-Founder of Unstoppable Domains A Classic Criminal Investigation: Unraveling PDVSA Corruption TechnipFMC Settles FCPA Violations for $296 Million Episode 96 — The End of the Line: The Walmart FCPA Settlement Applying OFAC’s Sanctions Enforcement Guidelines to Determine A Civil Monetary Penalty (Part II of II) Understanding the OFAC Sanctions Enforcement Guidelines (Part I of II) Lessons Learned from the Walmart FCPA Enforcement Action (Part III of III) Rescheduled Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices, and Industry Trends Walmart’s Recipe for Corruption Disaster: Rapid International Growth without a Compliance Program Foundation (Part II of III) Thank You, Thank You: DOJ and SEC Resolve Walmart FCPA Enforcement Action (Part I of III) Episode 95 — Interview of Teresa Troester-Falk, Chief Global Privacy Strategist at Nymity, on the California Consumer Privacy Act Compliance Program Evolution and Proactive Strategies (Part III of III) The New Compliance Test: Do CCOs Have Senior Management Support and Resources to Innovate? (Part II of III) Watching the River Flow: The Evolution and Future of Compliance (Part I of III) Ethics and Culture Lessons from the NBA Finals U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions Episode 94 — How to Conduct a Risk Assessment for Sanctions Compliance Operationalizing Your Compliance Program: Local Compliance Officers and Businesses OFAC Fines US Company for Iran Sanctions Violations Commerce Department Blocks Export Licenses to Huawei Technologies Co., Ltd. Michael Volkov Releases New E-Book: The Road Ahead — The Justice Department’s Path to a Balanced White-Collar Enforcement Policy Telefônica Brasil Pays $4.125 Million for Hospitality-Related FCPA Violations Episode 93 — Matt Stankiewicz Discusses Data Privacy on Blockchain with ImagineBC CEO Erik Rind Free Webinar Recording: ITAR Compliance: Navigating Complex Risks Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices, and Industry Trends OFAC’s New Sanctions Compliance Training and Testing Requirements (Part IV of IV) Making Sure Your Internal Controls Address Sanctions Risks (Part III of IV) Conducting a Sanctions Risk Assessment: A New Era for Analyzing Your Risks (Part II of IV) Putting Together Your Sanctions Compliance Program: Management Commitment (Part I of IV) Episode 92 — How to Implement a Sanctions Compliance Program Remediate and Enhance Your Internal Investigation Program (Part III of III) How to Audit Your Internal Investigation Program (Part II of III) Improving Your Internal Investigation Program (Part I of III) Episode 91 — How to Audit and Improve Your Internal Investigation Program Webinar: ITAR Compliance: Navigating Complex Risks Catching Up with Two Recent Compliance Studies: LRN and Ethisphere Third-Party Risk Management: Managing the Information Flow Corporate Culture and “Benign” Indifference What Happens When Managers Misbehave? Episode 90 — OFAC Issues New Framework for Sanctions Compliance Program Watch Bureau Van Dijk Webinar Replay — “Is Power and Control the New Beneficial Ownership?” The Positive and Negative Mix of Corporate Compliance Trends Report from SEC Conference: Compliance, Cooperation and Culture OFAC Framework for Sanctions Compliance Programs – Review of Lessons Learned from Enforcement Actions (Part IV of IV) Webinar: OFAC Issues New Framework for Sanctions Compliance Programs OFAC Framework for Sanctions Compliance Programs – Testing and Auditing and Training (Part III of IV) Episode 89 — DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV) OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV) DOJ’s New Corporate Compliance Guidance: Does Your Compliance Program Work? (Part V of V) RESCHEDULED WEBINAR: DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs DOJ’s New Corporate Compliance Guidance: Implementation, Operationalization and Effectiveness (Part IV of V) Episode 88 — Matt Stankiewicz Interview of Liquidity Digital CEO Syed Hussain DOJ’s New Corporate Compliance Guidance: Training and Communications, Reporting and Investigations, Third-Party Management and Mergers and Acquisitions (Part III of V) DOJ’s New Corporate Compliance Guidance: Risk Assessments and Policies and Procedures (Part II of V) Webinar: DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs DOJ Issues New and More Robust Guidance on Evaluation of Corporate Compliance Programs (Part I of V) OFAC Enforcement Action Underscores Russia Sectoral Sanctions The Important Link Between Anti-Corruption Compliance and Effective Training Programs Episode 87 — Review of Recent Compliance Benchmarking, Surveys and Studies Join Us for a May 16, 2019 BVD Webinar: “Is “Power and Control” the New Beneficial Ownership? DOJ and OFAC Announce Another Sanctions Settlement – UniCredit Group Banks Pay Over $1.3 Billion and Subsidiary Bank Agrees to Plead Guilty for Violating Iran Sanctions Acteon Pays $441,000 to Settle Two OFAC Enforcement Actions The Long Arm of OFAC: Secondary Sanctions, Facilitation, and Causing a Violation Episode 86 – Standard Chartered Bank Pays Over $1 Billion for Sanctions Violations NAVEX Global’s 2019 Hotline Benchmark Report OFAC Sanctions Compliance Insights from Standard Chartered Bank Enforcement Action (Part III of III) Standard Chartered Bank’s Continuing Culture Challenges and Sanctions Compliance (Part II of III) Stephen Cheng and Noah Smith Write on Senator Warren’s Corporate Executive Accountability Proposal Standard Chartered Pays Over $1 Billion for Continuing Sanctions Violations (Part I of III) Episode 85 — A Deep Dive into the Fresenius Medical FCPA Settlement Checking in on Criminal Healthcare Fraud Prosecutions Three Pharmaceutical Companies Pay a Total of $122 Million to Settle Kickback Allegations Involving Co-Pay Assistance Foundations DOJ Collects Millions in Two High-Profile False Claims Act Cases Five Signs Your Company Lacks Integrity Tom Fox and Mike Volkov Discuss the Fresenius Medical FCPA Enforcement Action Episode 84 — A Review of MTS Telesystems FCPA Enforcement Action Lessons Learned from Fresenius Medical FCPA Settlement (Part III of III) Fresenius Medical’s Bribery Conduct Precludes Declination (Part II of III) Fresenius Pays $231 Million to Resolve Long-Standing FCPA Enforcement Action (Part I of III) Episode 83 — Managing Hotlines and Reporting Systems Stanley Black and Decker Settles OFAC Enforcement Action for $1.9 Million DOJ “Tweaks” FCPA Corporate Enforcement Policy Former CFTC Chairman Calls to Strengthen Cryptocurrency Regulations Episode 82 — A Deep Dive into the Cognizant Technology FCPA Enforcement Action Ethics, Profits, Sustainability and Stakeholders: An Update on a Familiar Relationship Thomson Reuters Webinar: Top 3 Areas for Anti-Corruption Compliance Does Your Board Know How to Conduct Oversight and Monitor Your Compliance Program? National College Admissions Scandal Reveals Corrupt Underbelly of College Exams and Athletic Recruitment U.S. Domestic Bribery Enforcement and State and Local Corruption Episode 81 — Update on OFAC Enforcement and Compliance Lessons Learned 2019 Cryptocurrency Regulations – A Primer and What to Expect Throughout the Year Lessons Learned and Trends from MTS FCPA Enforcement Action and Criminal Indictment of Karimova and Akhmedov (Part III of III) Anatomy of MTS, Karimova and Akhmedov Bribery Scheme in Uzbekistan (Part II of III) Russian Mobile Carrier, Mobile Telesystems, Settles FCPA Case with DOJ and FCPA for $850 Million; MTS Executive and Notorious Uzbek Government Official Indicted (Part I of III) Episode 80 — Best Practices for Investigation of Allegations of Sexual Misconduct in the #MeToo Era DOJ Sweeps Up Two More Defendants in PDVSA Criminal Investigation Webinar: Best Practices for Internal Investigations of Sexual Misconduct Allegations in the #MeToo Era OFAC Announces Yet Another Enforcement Action – Cement Clinker Company Settles for Violations of Iran Sanctions Program DOJ Arrests Micronesian Official and Hawaii-Based Businessman Pleads Guilty to FCPA Violation The Criminal Pursuit of Huawei China: DOJ Brings Two Indictments Episode 79 — Update on GDPR Enforcement AppliChem Pays OFAC $5.5 Million for Cuba Sanctions Violations CCO and CLO “Authority”: A Fundamental Requirement U.S. Marijuana Laws Cause Uncertainty for Financial Institutions Episode 78 — Ethical Cultures and Proactive Measures to Mitigate Organizational #MeToo Risks Lessons Learned from the Cognizant FCPA Resolution (Part IV of IV) Reflections on the Cognizant FCPA Resolution: Does DOJ Mean What it Says? (Part III of IV) The Anatomy of a Bribery Scandal: Digging into the Cognizant Bribery Scheme (Part II of IV) Tom Fox and Michael Volkov Discuss Cognizant Technologies FCPA SEC Settlement, Declination and Criminal Indictment of Two Executives Cognizant Technology Pays $25 Million for FCPA Violations and Earns Declination — Two Executives are Indicted for Criminal FCPA Violations (Part I of IV) Episode 77 — Implementing an Effective Trade Compliance Program OFAC Announces Two Sanctions Enforcement Settlements Corruption Risks and the Issue of Foreign Government Officials Four Audi Executives Indicted for Emissions Cheating Scandal The Urgency of Now: Corporate Ethics and the #MeToo Movement New U.S. Sanctions Against Nicolás Maduro Place Venezuelan Oil Squarely in the Crosshairs Episode 76 — Review of 2018 AML Enforcement and Compliance Trends Hospitals and Physician Relationships – Navigating Stark, AKS and Fraud Risks (Part III of III) Pharmaceutical and Medical Device Company Payments to Healthcare Professionals (Part II of III) Focusing on “Payments” to Healthcare Professionals (Part I of III) Export Control Reform: Major Changes for ITAR Regulations for Firearms Industry Webinar: Anti-Corruption Compliance in Pharma and Medical Device Industries It is 2019 . . . Do You Know Where Your Data Is? Episode 75 — 2018 False Claims Act Review The Requirement for a Proactive Audit Program Michael Volkov Named to Trust Across America’s 2019 Top Thought Leaders in Trust Tying Mitigation to Third Party Risks US Brings First Criminal AML Case Against Broker-Dealer Touting Corporate Culture to Excuse a Commitment to Compliance Julie DiMauro and Michael Volkov Video Discussion of FCPA and Compliance Issues Episode 74 — ITAR Compliance Review ComplianceNext — Michael Volkov Videos Trade Secret Risks, Criminal Prosecutions and Protecting Trade Secrets The Dangerous Compliance Threat – Budget Cuts to Compliance Programs University of St. Thomas Open House on Organizational Ethics and Compliance Programs Complimentary NAVEX Global Webinar: Best Practices for Vendor Risk Profiling Ethics and Compliance Trends: Humans and Automation, Intelligence and Technology Merging Trade Compliance and Ethics and Compliance Silos False Claims Act 2018 Year in Review – Making Sense of the DOJ Fraud Statistics Episode 73 — Review of FCPA Settlements for Polycom, Eletrobras, and Two Former Panasonic Avionics Officers Eletrobras Settles SEC FCPA & Bid-Rigging Enforcement Action for $2.5 Million The Danger of Benchmarking Assessing Your Hotline System Jessica Sanderson Joins The Volkov Law Group Polycom Pays $36 Million, Settles with SEC, and Earns DOJ Declination for Bribery in China Episode 72 — 2018 Review of OFAC Sanctions Enforcement and Compliance Trends SEC Settles FCPA Charges Against Ex-Panasonic Avionics Officers OFAC Relaxes Russia Sanctions After Oligarch Ownership Changes 2019 Ethics and Compliance Predictions Webinar: 2018 OFAC Sanctions Enforcement and Compliance Trends Sanctions Enforcement and Compliance Year in Review Episode 71 — 2019 Ethics and Compliance Predictions and Trends FCPA Predictions for 2019 2018 FCPA Year in Review: The More Things Change, The More They Stay the Same Episode 70 — FCPA Year in Review and Predictions for 20192018 Webinar: Review of 2018 FCPA Enforcement and Compliance Trends Happy Holidays From The Volkov Law Group UBS Pays $15 Million for AML Compliance Deficiencies OFAC Announces Russia Sanctions Settlement with Software Company Episode 69 — Update on DOJ Corporate Enforcement Policies Convercent Webinar — FCPA Enforcement: What Happened in 2018? (Plus, What’s in Store For 2019) The Mindset of Employee Fraudsters (Part III of III) Fraud Detection: New Technologies and Analytics (Part II of III) The Growing Problem of Corporate Fraud (Part I of III) Episode 68 — FCPA Guidance and Safe Harbors Smart Compliance: Embracing Proactive Solutions The “60-60” Issue and Indoctrinating Middle Management into the Compliance Mission Enforcing Corporate Compliance Policies and Controls The Purpose of a Compliance Program: To Prevent and Detect Episode 67 — Conducting Compliance Audits Vantage Drilling Forks Over $5 Million for SEC FCPA Settlement Your CEO Agrees the Company’s Culture is Important – Now What? OFAC Completes Re-Imposition of Iran Sanctions Société Générale Pays $1.4 Billion for Systemic Sanctions Violations Episode 66 — Gifts, Meals, Entertainment and Travel Expense Compliance Effective Compliance is More than the Sum of a Program’s Parts Behavioral Studies and Compliance Episode 65 — Goldman Sachs and the 1MDB Corruption Scandal Michael Volkov on FCPA Compliance Report Podcast and Compliance Next Ethics and Compliance Initiative Report: The Importance of Ethics Communications and Accountability NAVEX Global Research Demonstrates Correlation Between Business Performance and Hotline System Where Has All the Money Gone? Longtime Passing, Oh Where Has it Gone? The Goldman Sachs 1MDB Scandal: The Doctrine of Respondeat Superior Episode 64: Stryker’s SEC FCPA Settlement Webinar: Measuring Your Compliance Program: Data and Analytics The Tangible Benefits of a Positive Ethical Culture Human Resources and Criminal Antitrust Prosecutions Justice Department Recalibrates Corporate Monitors and DOJ Compliance Position Goldman Sachs and the 1MDB Criminal Prosecutions Episode 63 — The Epsilon Case and Third-Party Sanctions Risks Japanese Electrolytic Capacitor Manufacturer Sentenced to Pay $60 Million for Criminal Price-Fixing Speak Up is Great – Is Anyone Listening? Ethics and Compliance as a “Marketing” Program University of St. Thomas Law Graduate Programs in Organizational Ethics Compliance Episode 62 — Update on the Cuba and Venezuela OFAC Sanctions Programs Health Management Associates Pays Over $260 Million in Criminal and Civil Penalties for Pervasive False Billing and Kickback Charges Doctor and Two Medical Equipment Officers Head to Jail for Illegal Kickback Scheme Managing Your Supply Chain: Turning “Do No Harm” Into “Doing Good” Episode 61 — How to Implement and Promote a Speak Up Culture NAVEX Global Releases 2018 Third-Party Risk Benchmark Report Sign Up for November 8, 2018 NAVEX Global Ethics and Compliance Virtual Conference JP Morgan Chase Bank Settles “Old” Sanctions Case for $5 Million Are Unpaid Interns Worth the Cost (and the Risk)? Successful Compliance Officers – A Balancing Act DaVita Medical Pays $270 million to Settle False Claims Act Case Employees and Political Activity Episode 60 — A Deep Dive into the SEC’s FCPA Settlement with United Technologies NAVEX Global Webinar: The State of Third-Party Risk Management in 2018 The Importance of a High-Risk Due Diligence Committee Webinar: Advanced Ethics and Compliance Program Design The Danger to a Compliance Program of Ineffective In-House Lawyers Corruption, Crime & Compliance Podcast – Now on Spotify! A Basic Compliance Requirement: A Contract Management System CEO Falls to SEC FCPA Settlement Episode 59 — Implementing an Internal Investigation Program Developing an Employee Handbook that Helps Protect Your Business from Lawsuits Wit and Wisdom from Michael Volkov: It’s the Culture Stupid: Ethics and the Definition of Successful Companies What Happens When a CFO Fails to Listen to the CCO? Petrobas Closes Out “Massive” Corruption Investigations and Litigation Stryker Suffers “Strike Two” and Settles SEC FCPA Case Episode 58 — Interview of Donna Boehme — The Future of the Independent, Empowered Chief Compliance Officer Maintaining Your Company’s Compliance Program in the Rapid Policy World of Change by Tweet Webinar: The False Claims Act — Enforcement Risks and Compliance Trends Compliance and Recruiting Women in the Workforce OFAC Enforcement: The Epsilon Case and Third Party Risks Cryptocurrency 101 for Lawyers – What is Mining? Episode 57 — A Review of the Russia Sanctions and Recent Changes A Compliance Priority — Watching Where Your Money Goes United Technologies SEC FCPA Enforcement Action: Gifts, Meals, Entertainment and Travel Abuse and Bribery (Part II of II) United Technologies Pays $13.9 Million to Settle FCPA Charges (Part I of II) Sanofi Coughs Up $25 Million to Settle SEC FCPA Charges Episode 56 — Catching Up with Special Counsel Mueller’s Russia Investigation The Real Focus for Compliance: Post-Acquisition Integration of an Acquired Company (Part III of III) The Importance of Pre-Acquisition FCPA Due Diligence (Part II of III) FCPA Risks and Merger and Acquisitions: The Evolving Policies (Part I of III) Webinar — FCPA 2018: Update on Enforcement and Compliance Trends Noah Smith Joins The Volkov Law Group State Department Announces Additional Sanctions Against Russia Episode 55 — Update on the Iran Sanctions Program Legg Mason Pays $34 Million to Resolve SEC’s Libyan FCPA Investigation The Ups and Downs of Cooperating Witnesses Court of Appeals Cuts Back Extraterritorial FCPA Jurisdiction Over Foreign Nationals Episode 54 — A Deep Dive into the SEC’s FCPA Settlement with Beam Suntory DOJ Issues Declination and Disgorgement Under FCPA Corporate Enforcement Policy OFAC Begins to Re-Impose Iran Sanctions and Expands Reach of Previous Sanctions Fighting Corruption and Obstacles to Criminal Prosecution — (Part II of II) Defining Corruption: From the Framers to the Supreme Court’s Decision in Citizens United (Part I of II) Episode 53 — How to Test and Evaluate Your Compliance Program CFIUS Reform: An Expanded Role (Part II of II) CFIUS Review: An Increasing Risk (Part I of II) DOJ Expands FCPA Corporate Enforcement Policy Episode 52 — The False Claims Act and Healthcare Fraud New Episode Everything Compliance: The Five-Year Retrospective Edition Federal Enforcement and the Opioid Epidemic (Part IV of IV) Webinar: FCPA Risks and Mergers and Acquisitions Rolling Along with False Claims Act Enforcement Actions (Part III of IV) Hospital Official and Three Dentists Convicted for Kickback and Bribery in RICO Criminal Case (Part II of IV) The Supreme Court’s Escobar Decision and the Impact on False Claims Act Cases (Part I of IV) Episode 51 — Interview of Dr. Pat Harned, CEO of the Ethics and Compliance Initiative Crime-Fraud Exception to Attorney-Client Privilege Real-World Applications of Blockchain to Compliance (Part II of II) The Revolution of Blockchain and Compliance (Part I of II) Episode 50 — Cryptocurrency and Blockchain: Matt Stankiewicz Interview of Jason Davis, CEO of Hoard Invest Defining Deterrence in White Collar Crime Cases (Part III of III) White Collar Criminals and Sending a Message to Deter Misconduct (Part II of III) Criminal Sentencing and Deterrence: White Collar Crime and Corporate Misconduct (Part I of III) Episode 49 — Data Breach Notification in the GDPR Era Corporate Doublespeak: A Bribe is a Bribe Artificial Intelligence, Hype and Financial Misconduct Corporate Character and Lack of Corporate Will Iran Sanctions and Third Party Risk Episode 48: Tom Fox and Michael Volkov Review FCPA Enforcement for First Half of 2018 The Risk of Employee Misconduct Antitrust Division Continues to Wrestle with Credit for Pre-Enforcement Compliance Programs Four Current FCPA Enforcement Trends Episode 47 — Cybersecurity Threats and Compliance Beam Settles FCPA Violations with SEC for $8 Million for Pervasive Third-Party Bribery Schemes Stephen Cheng and Marcel de Chermont Join The Volkov Law Group Lessons Learned from Credit Suisse Corrupt Hiring Scheme and FCPA Settlement (Part II of II) Credit Suisse Pays $76 Million for Sons and Daughters FCPA Violations in China (Part I of II) Episode 46 — Implementing a Policy Management Program Drawing Legal Lines in Cryptocurrency Regulation: The Importance of Decentralization Webinar: Cybersecurity Threats and Compliance Happy 4th of July! Cryptocurrency Compliance: The Importance of Internal Investigations Episode 45 — Sicily: An Inspiration — Interview of Rosetta Sciacca Karin Sweigart Joins The Volkov Law Group Leadership and Compassion Is Your Compliance Program Adrift? The Culture Bandwagon — SEC Chairman Joins the Club Episode 44 — Compliance Program Best Practices: The FCPA Guidance and DOJ’s Evaluation of Corporate Compliance Programs When Your CEO Just Does Not Get It Welcome! You Are the New Chief Compliance Officer: Five Basic Steps to Get Started The Pernicious Effect of Conflicts of Interest The Shoe Drops on Theranos’ Former CEO and COO – Criminal Indictment Filed Charging Fraud New Episode Everything Compliance — Four of a Kind Edition Episode 43 — Global Compliance Program Design and Challenges New NAVEX Global White Paper — How to Develop the Business Case for a Third-Party Risk Management System Hallelujah: OFAC Announces First Enforcement Action in 2018 Against Ericsson, Inc. Compliance Next Announces Official Partnership with Volkov Law Group Webinar: Update on OFAC’s Iran Sanctions Program Textbook Lessons Learned from the Société Générale and Legg Mason FCPA Enforcement Action (Part III of III) Société Générale and Legg Mason Pay the Price for Bribery in Libya (Part II of III) Justice Department Settles Gaddafi-Libya FCPA Cases with Société Générale and Legg Mason (Part I of III) Episode 42 — How to Manage Your CEO on Compliance Issues When Corporate Leaders Fail to Listen Compliance and Technology Leadership Support Provides Compliance Credibility Episode 41 — Compliance and Technology DOJ Charges Two Additional Individuals in FCPA Rolls Royce Case Webinar: A Deep Dive into the Russia-Ukraine Sanctions Program Compliance and the Reckoning The Vital Role of Internal Audit to Compliance Episode 40 — How to Conduct a Corporate Culture Assessment Sunshine, Disinfectant and SEC Guidance on Cybersecurity Disclosures CEOs Under the Criminal Spotlight – More C-Suite Misconduct Tom Fox’s Valuable Contribution to the Compliance Profession – The Complete Compliance Handbook Volkov Law — In the News and on the Web Episode 39 — Tom Fox’s New Book — The Complete Compliance Handbook Time for Companies to Establish an Independent Corporate Ombudsman Corporate Attitudes: When Speak Up Means Keep Quiet Justice Department Charges Former Volkswagen CEO in Diesel Vehicle Emissions Cheating Scheme Webinar: The FCPA Guidance and DOJ’s Evaluation of Corporate Compliance Programs Update on Russia Trade Sanctions Turning Back the Clock – OFAC Plans to Reimpose Iran Sanctions Program Episode 38 — Update on Special Counsel Mueller’s Russia Investigation and the Michael Cohen Investigation Dun and Bradstreet Pays $9 Million for FCPA Violations in China Compliance Lessons Learned from Panasonic Avionics $280 Million FCPA Enforcement Action (Part II of II) Complying with FinCEN’s CDD Rule: Beneficial Ownership Register Vendor Trulioo The Volkov Law Group is Hiring: Senior Associate and Associate Positions Panasonic Avionics Pays $280 Million to Resolve FCPA Offenses in Middle East and Asia (Part I of II) A Valuable Resource: The Fifth Edition of The Foreign Corrupt Practices Act Handbook Episode 37 — Ethics and Compliance Trends from Recent Surveys and Studies FLIR Systems ITAR Settlement Outlines Important Export Compliance Factors (Part II of II) FLIR Systems Pays $15 Million Civil Penalty for AECA and ITAR Violations and Earns First DTCC Monitor (Part I of II) Volkov Law Group Joins Forces with NAVEX Global’s Compliance Next The NYAG’s Virtual Markets Integrity Initiative and Transparency of Cryptocurrency Exchanges Lying and Accountability: ZTE Pays the Price Episode 36 – How to Respond to a Government Investigation FCPA Compliance: Navigating Joint Venture Risks (Part V of V) FCPA Compliance: Automate and Audit Third Parties (Part IV of V) FCPA Compliance: Automation and Mitigating Gifts, Meals, Entertainment and Travel Expenditures Risks (Part III of V) FCPA Compliance: When a Foreign Official is a Third-Party (Part II of V) FCPA Compliance: The Importance of Relativity to Risk Ranking (Part I of V) Episode 35 –Update on AML Compliance from Recent AML Enforcement Actions AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions Webinar: The New Era of AML Compliance — The Need to Refresh Your AML Compliance Program CCOs and Compromising Positions FinCEN Issues Guidance for Beneficial Ownership Regulations The Cohen Search Warrants – DOJ Procedures for Approval Episode 34 — The Cohen Criminal Investigation and Search Warrants Supreme Court Narrows Criminal Tax Obstruction of Justice Statute OFAC Hits Russia with New Sanctions The New Test for CCOs Bringing a Compliance Program to Life: Connecting the Dots Episode 33 — Bitcoin, Cryptocurrencies and Compliance — Interview of Matt Stankiewicz New Episode — Everything Compliance: Will the Astros Repeat Edition? Internal Testing and Monitoring of a Compliance Program Cryptocurrencies, Blockchain and Ponzi Schemes The State of Whistleblowing Kinross Gold Mining FCPA Settlement: SEC Continues Internal Controls Focus Episode 32 — Ten Steps to Prepare Your Company for Execution of a Search Warrant ECI’s New Business Ethics Survey Confirms Misconduct Rates Declining — But Retaliation Rates Increasing The State of Affairs: General Counsels and Chief Compliance Officers Webinar: Healthcare Providers — The Need to Enhance Your Ethics and Compliance Program Who’s on First, What’s on Second – Who is Regulating ICOs, Cryptocurrencies and Exchange Platforms? Culture and Leadership in Middle Management Episode 31 — Doing Business in Haiti: Interview of Angelo Viard Congress and the Blockchain: The 2018 Joint Economic Report’s Discussion on Cryptocurrency Webinar: A Review of FinCEN’s New Beneficial Ownership Regulations DOJ Settles Follow-On FCPA Case: Transport Logistics Pays $2 Million Penalty First FCPA Action of 2018: Elbit Imaging Episode 30 — Common Due Diligence Problems (Part III of III) Connecting with Your Employees – What is Your Company’s Purpose? Compliance and the Attorney-Client Privilege Compliance Needs to Understand Business Sapin II and French Anti-Corruption Enforcement The SEC Targets ICOs for Enforcement Episode 29 — Building Blocks for an Effective Due Diligence Program (Part II of III) Five Questions for Corporate Boards on Oversight of Compliance Governments Begin to Embrace Cryptocurrency A New Holistic Model for Internal Controls Management (Part II of II) Time to Review and Revise Your Internal Controls (Part I of II) Episode 28 — Due Diligence and Third Party Risk Management (Part I of III) Company Culture, #MeToo and Anti-Harassment Programs Three Critical Questions to Ask Your CEO About Your Ethical Culture Three Important Points to Remember About Third-Party Risks Episode 27 — Internal Controls and Enforcement Risks New Episode — Everything Compliance — The Year-End Wrap Up Financial Institutions and the Glaring Absence of an Ethical Culture The Obvious Partnership — Compliance and Cybersecurity US Bancorp Pays $613 Million and Joins the Ranks of AML Violators Rabobank Coughs Up $368 Million and Pleads Guilty to Conspiracy to Money Launder and Obstruct Investigation Episode 26 — Federal Reserve Blocks Wells Fargo Growth In Response to Governance and Risk Management Disaster Planning for the Perilous Consequences of a Data Breach The Long Road Back to Redemption: Wells Fargo’s Path to Remediation (Part II of II) Federal Reserve Hits Wells Fargo with Unprecedented Enforcement Action (Part I of II) Subscribe to Corruption, Crime & Compliance Podcasts and Blog Episode 25 — Unraveling the KPMG Audit Scandal Local Compliance Strategies to Embrace the Business (Part II of II) Challenges in Global Compliance Operations: Structure and Responsibilities (Part I of II) Webinar: Making Your Board of Directors a Partner in Compliance Resources, Resources, and More Resources – The True Test of an Effective Ethics and Compliance Program “Trust Better Be Your Most Important Value” – Marc Benioff, Salesforce CEO Episode 24 — Corporate Board Reform Criminal Enforcement Against Senior Executives: The Fish Rots from the Head Cybersecurity Compliance for Financial Institutions The KPMG Debacle – Five Former KPMG Employees and Former PCAOB Employees Indicted for Fraud and Conspiracy Episode 23 — Tom Fox and 2017 FCPA Year in Review Cybersecurity: The Law and Regulatory Framework Welcome to New Sponsor Trulioo: A Leading Global Identity and Business Verification Provider Cybersecurity and Third-Party Risks The Convergence of Cybersecurity, Compliance, and Enterprise Risk Management Cybersecurity Threats and Risks Renewing Corporate Vows to the Chief Compliance Officer Episode 22 — Testing and Evaluation of Your Compliance Program The Need for Anti-Money Laundering Regulatory Reform Financial Institutions Are Playing Catch-Up in AML and Sanctions Compliance Webinar: How to Implement an Effective Internal Investigation Program AML Regulation and Compliance Trends Regulators Slap Banks, MSBs and Card Club with AML Violation Penalties Episode 21 — Interview of Jean-Michel Ferat, FCPA Forensic Accounting Expert, Senior Managing Director, Ankura Consulting Three Simple Steps to Improve Your Corporate Culture Webinar: 2018 Ethics and Compliance Program Trends and Expectations Time to Test and Audit Your Compliance Program Five Major Compliance Predictions for 2018 Episode 20 — Data Security and Privacy Compliance Justice Department Closes Out 2017 with 2 FCPA Actions: Keppel Offshore and Marine and Embraer Individual 2018 FCPA Predictions (Part II of II) 2017 FCPA Year in Review (Part I of II) Webinar — 2017 FCPA Year in Review Episode 19 — 2017 FCPA Year in Review2017 Happy Holidays from The Volkov Law Group New Episode Everything Compliance — The New FCPA Corporate Enforcement Policy (Part I of II) Michael Volkov’s New E-Book: Pointing the Finger — How Corporate Boards Are Dodging Accountability and What CCOs Can Do About It Episode 18 — Michael Volkov’s Perspective on the Russian Investigation — Next Steps for Special Counsel Mueller’s Investigation (Parts III of III) Episode 17 — Michael Volkov’s Perspective on the Russian Investigation — The Michael Flynn Plea Agreement (Part II of III) Episode 16 — Michael Volkov’s Perspective on the Russian Investigation — Analysis and Review of Manafort/Gates Indictment and Papadopolous Plea (Part I of III) Ethics and Mitigating Reputation Risks Episode 15 — The Justice Department’s New FCPA Corporate Enforcement Policy May 2018: D-Day for FinCEN Customer Due Diligence and EU’s General Data Privacy Regulations Calculating the New Balance Between Disclosure and Non-Disclosure of Potential FCPA Violations Sponsored Product Update: NAVEX Global’s RiskRate 6.0 Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy Episode 14 — What Every Compliance Officer Needs to Know About Data Privacy and the EU’s GDPR Practical Ethics – The New Way to Advance an Ethical Culture Sanctions Updates: Cuba, North Korea, Russia, Sudan, Venezuela Foreign Agents Registration Act Enforcement Webinar: How to Implement An Effective Sanctions Compliance Program SBM Offshore Finally Reaches the Finish Line and Settles FCPA Case for $238 Million Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy Episode 13 — Top 10 Rules for Conducting Internal investigation Interviews New Episode — Everything Compliance: The Regulatory (Or Not) Edition Incorporating AML Compliance Into a Compliance Program (Part III of III) Addressing AML Risks in Your Third-Party and Vendor/Supplier Relationships (Part II of III) Anti-Money Laundering Risks for Global Companies (Part I of III) DOJ Continues Run on Individual FCPA Criminal Prosecutions Episode 12 — OFAC Screening and Sanctions Compliance Webinar Reminder — Global Antitrust Enforcement Risks and Compliance Third Party Risk Management: Require ISO 37001 Certification from Your Third Parties Internal Investigations: Protecting the Attorney- Client Privilege Making the Case for Requiring Beneficial Ownership Information Episode 11 — Seven Individuals Charged with FCPA Criminal Violations Global Antitrust Enforcement Risks and Compliance Programs Putting Ethics Back Into Compliance (Part IV of IV) Six Specific Areas to Embed and Promote Business Ethics (Part III of IV) Trust and Integrity – Bedrock of Corporate Sustainability (Part II of IV) Business Ethics, Values and Personal Ethics (Part I of IV) Episode 10 — How to Conduct a Risk and Compliance Program Assessment The FCPA Week That Was — Seven Individuals Charged for FCPA Violations MyCompliance Office Webinar: Taking a Fresh Look at Gifts, Entertainment, & Hospitality Programs COSO Framework: Breaking Down the Silos and Bringing Everyone Together (Part II of II) COSO Framework: Fraud, Corruption and Compliance (Part I of II) CCOs and CFOs: Bringing Everyone Together Ominous Signs for the Future of the Compliance Profession Update on The Volkov Law Group Episode 9 — The Need for a Robust Criminal Antitrust Compliance Program Volkov Law TV — New Webinars For Low Monthly or Annual Fees HR and Compliance: Working Together to Hire Ethical Employees Anti-Corruption Risks: Global Enforcement Means Global Detection Compliance and Technology – Rational Actors Need to Adopt Technology Webinar: How to Conduct Periodic Reviews and Assessments of Your Compliance Program Episode 8 — The Critical Importance of Beneficial Ownership to Compliance It Takes a Village . . . To Commit Bribery FCPA Enforcement and Credit for an Effective Compliance Program Watch Exiger Webinar Replay “How AI is Transforming Third Party Risk Management” Five Essential Steps to Improve Corporate Board Oversight and Support of Compliance Episode 7 — The Perils of Compliance with the Russia Sanctions Program ISO 37001: Training, Employee Concerns, and Internal Investigations (Part V of V) ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V) ISO 37001: Board, Top Management and Anti-Bribery Compliance Responsibilities (Part III of V) ISO 37001: The Good, The Bad and the Ugly (Part II of V) A Closer Look at ISO37001 – Something Old or Something New? (Part I of V) Podcast Episode 6 — ISO 37001 — Anti-Bribery Risk Management System: Something Old or Something New? Webinar: ISO 37001 — A Review of the Anti-Bribery Risk Management System Lawyers Can Be A Positive Force for Compliance In Defense of Compliance Checklists The Importance of A Robust Conflicts of Interest Program Podcast Episode 5 — Interview of Tom Fox Volkov Law Group Sponsors Tom Fox’s One Month to More Effective Compliance for Business Ventures ArthroCare CEO Reconvicted for Fraud The Delusion of a Barebones Compliance Program The FCPA Compliance Defense — Don’t Wish for It, You Just Might Get It Where O’ Where Did Our Monitors Go? — The Telia Bribery Case Podcast Episode 4 — Too Big To Fail, Too Big To Jail, DOJ’s Outsourcing of Criminal Investigations The Compliance Conundrum — Spending Money to Save Money The Five Most Important Issues for a CCO to Report to the Board Ethics and Compliance Controls – Different Means to the Same Objective Podcast 3 — The Latest FCPA Undercover Sting — John Baptiste Case Subscribe to New Podcast Service CEO Leadership – Honesty, Integrity, Listening and Empathy No More Excuses: CCOs Have to Embrace Technology 4 Signs of a Poor Relationship Between a CCO and the Board Podcast Episode 2 — Ethics and Profits Michael Volkov Interview with BvD’s Alistair King CCOs and the C-Suite Slippery Slopes: “Broken Windows” and Employee Misconduct The Emperor Has No [Compliance Program] New Podcast: Corruption, Crime and Compliance — Episode 1, A Review of Trump Administration Enforcement Priorities Live Webinar: How AI is Transforming Third Party Risk Management (via Live Stream) The Objective of Due Diligence: To Protect Your Culture Tales from the Corporate Scandal Crypt: GM, VimpelCom, VW and Wells Fargo Webinar: How to Conduct Effective and Efficient Due Diligence? Compliance Missed Opportunities: CCOs and HR Financial Controls and Contract Management Systems Challenges in Transitioning from the Law to Compliance Ethics, Temptation and Money Focusing Antitrust Compliance Programs on the Real Criminal Risks (Part II of II) Chief Compliance Officers Have to Address Criminal Antitrust Risks (Part I of II) Infusing Corporate Culture with Accountability German Auto Antitrust Cartel – A Record Enforcement Action Begins OFAC Pushes Iran Sanctions Enforcement Tom Fox and Mike Volkov Discuss Linde Gas and CDM Smith FCPA Declinations Anti-Corruption Risks and Drug and Device Companies Retaining a “Risky” Third-Party Wake Up and Mind Your Culture — Practical Approaches to Managing a Company’s Culture Every CCO Needs Authority + Autonomy + Resources Get Your Board On Board Maximizing Compliance Opportunities: Your Vendor Onboarding Process and Vendor Master File New Sanctions Law Complicates Trade Compliance What Happens When Employees Stop Speaking Up? LIBOR Criminal Convictions Reversed – The Perils of Global Enforcement How Do You Define a Compliance Program Failure? Double Whammy for United Healthcare: Two False Claims Act Cases in Two Weeks The Perfect Compliance Combo: Culture and Controls FCPA Risks and Acquisition Integration Challenges Webinar: Is Your Company “At-Risk” for a Government Enforcement Action? Anti-Corruption Compliance: The Need to Look Under the Cloak of Materiality The Strange Case of OFAC Against Exxon for Sanctions Violations Is Your Company At-Risk for a Government Enforcement Action? Should You Record Internal Investigation Interviews? United States v. Nixon – An Important Reminder Important Polling Results from BvD Webinar on Beneficial Ownership CCO’s and Delusions About a Company’s Ethical Culture New Episode — Everything Compliance Is Your Chief Compliance Officer Lonely? “Too Important to Jail,” the Yates Memorandum and FCPA Criminal Prosecutions DOJ’s “Filip” Factors and Corporate Prosecutions Criminal Prosecutions of Individuals Outside the FCPA Justice Department Resolves Two Cases Under FCPA Pilot Program La Bella Vita in Sicilia Webinar: The Importance of a Risk and Compliance Program Assessment Will the Justice Department Continue to Use DPAs and NPAs? The Importance of Compliance Program Audits Working in a “Happy Talk” Corporate Culture Top 5 Mistakes Chief Compliance Officers Make (And How to Avoid Them) Tom Fox and Michael Volkov Discussion on Blockchain and Compliance Poor Performing CEOs and Boards and Compliance Disasters CCOs and Resources: Put Your Money Where Your Mouth Is! Are Risk Assessments Just a Report on the Obvious? 5 Telltale Signs of a Weak Corporate Culture Two Steps Forward, One Step Back – Mixed Bag of Compliance Progress The Challenge of Auditing and Monitoring Your Distributors Blockchain and the Future of Compliance The EU’s New General Data Privacy Regulation (GDPR) – Global Companies New Compliance Test CCOs: The Importance of Documenting a Compliance Program “The Future is Now” — Compliance and Technology A CCO’s Challenge: How to Convince a CEO to Embrace Compliance Ensuring Compliance with Controls Promoting an Ethical Culture — Actions Not Just Words HCCA-OIG Resource Guide on Measuring Compliance Program Effectiveness The Compliance Profession Needs to Adopt Professional Standards Transparency in FCPA Enforcement Understanding Special Counsel Mueller’s Authorization Take the FCPA Quiz and Test Your Knowledge of the FCPA — Sponsored by Workplace Answers Obstruction of Justice – A Primer Effective Compliance and the Importance of Accounts Payable Function The State of Mind of a White Collar Criminal Data Privacy and Security – What is the Difference? MoneyGram CCO Pays Civil Penalty The Compliance Profession and the Demand for “Results” The Danger of Corporate Scandals – When CEOs and Senior Executives Circle the Wagons to Impugn a CCO Webinar: Managing Supply Chain Risks Corporate Shell Games and KYC Requirements Wait a Minute – The FCPA Enforcement Sky Did Not Fall? Compliance and Financial Audits – Distinctions With Substance What is the Real Risk of an FCPA Enforcement Action? The Revolution in Compliance Training – It is Not Just About Your ABCs Knowing Your Employees and Incident Management Systems Compliance is Not “Rocket Science” Yates, AG Sessions and Individual Criminal Prosecutions What Compliance Needs to Know About Data Privacy and Security Congrats to the New International Association of Independent Corporate Monitors Beneficial Ownership Due Diligence Requirements Dutch Prosecutors Record Shell CEO and Ensnare Shell in Nigeria Bribery Scandal Corporate Culture and Whistleblowers: A Reliable Barometer of a Company’s Culture United’s Crisis Mismanagement and Corporate Culture TD Bank and Sanctions Violations Wells Fargo’s Desperate Need for a Compliance and Business Ethics Function (Part III of III) Mike Volkov’s New E-Book — Moving the Goalposts: The Justice Department Redefines Effective Compliance The Axe Falls on Wells Fargo – A Scathing Independent Report (Part II of III) Can Wells Fargo Fix its Defective Culture? (Part I of III) A Money Laundering Nightmare: Western Union Ponies Up $770 Million to Settle with DOJ, FTC and FinCEN New White Paper — Online Compliance Training: Making the Right Choice A Strategy for Non-Disclosure of FCPA Violations Webinar: Ten Essential Elements of a Third Party Risk Management System Human Trafficking and Smuggling – A Compliance Requirement AML Enforcement and Compliance Trends FCPA Remediation Focus on Supervisory Personnel The Three Lines of Compliance Offense Versus The Three Lines of Compliance Defense Compliance, Technology and Data Analytics Lawyers and Culture in the Financial Services Industry Legal and Compliance Coordination – An Essential Foundation to an Effective Compliance Program (Part IV of IV) Webinar: Antitrust Training: Avoiding Criminal Cartel Risks Getting to Know You, Getting to Know All About You — Business Buy-In to Compliance Functions (Part III of IV) Bridging the Gap: Uniting Compliance and Financial Controls (Part II of IV) Operationalizing Compliance – Natural Partners and Breaking Down Walls (Part I of IV) DOJ’s Compliance Program Evaluation Guidance Managing Your Ethical Culture: Measure, Intervene and Remediate Welcome to New Sponsor: Exiger, a Global Governance, Risk and Compliance Leader ZTE Pays the Price for Circumventing Sanctions and Export Controls FCPA Pilot Program Motors On Compliance and Private Equity: An Oxymoron? The Two Most important Words in a Compliance Dictionary: Trust and Integrity Review, Revise and Re-Organize Your Company’s Internal Controls (Part II of II) A New Approach to Internal Controls (Part I of II) Webinar: DOJ Issues New Compliance Evaluation Guidance DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits (Part IV of IV) DOJ’s Compliance Program Evaluation: Risk Assessment, Policies and Procedures and Third-Party Risk Management (Part III of IV) DOJ’s Compliance Program Evaluation: the Role of the CCO (Part II of IV) Under the Dark of Night, DOJ Moves the Compliance Ball (Part I of IV) Parallel Universes: Antitrust Leniency and the FCPA Pilot Program Unpacking the Justice Department’s Compliance Remediation Standards (Part I of II) The FCPA Pilot Program Disciplinary Standards (Part II of II) Yikes: The Perils of Remediation and Corporate Monitors Focus on the Issue of “Corrupt Intent” The Test for Bad Actors in a Bad Company Webinar: Update on Healthcare Enforcement and Compliance Strategies The Challenges Facing the Antitrust Leniency Program and the Yates Memorandum SEC Snares Two “Masterminds” Behind Och-Ziff Bribery Scheme Walking the Walk and Talking the Talk – A CEO’s Commitment to Ethics and Compliance The Win-Win Argument: Compliance as a Marketing Advantage Las Vegas Sands Suffers Double Whammy and Resolves FCPA Action with DOJ for $7 Million Serious Fraud Office Makes Big Splash with UK Bribery Act Resolution with Rolls Royce C-Suite Misconduct Results in Sociedad Quimica Y Minera FCPA Resolution with DOJ and SEC FCPA Recidivists: Orthofix (Part II of II) Webinar: Lessons Learned from 2016 — Strategies to Improve Your Compliance Program FCPA Recidivists: Zimmer Biomet (Part I of II) The “New” Face of Corporate Misconduct The FCPA Enforcement Run Continues into 2017 Lessons Learned and Compliance Trends from the VW and Takata Scandals (Part III of III) NAVEX Global Webinar: 2017 — An Evolving Landscape for Third Party Risk Management Takata – Criminal Airbag Scheme and Innocent Consumer Harm (Part II of III) Volkswagen: When Car Companies Veer Off Course (Part I of III) Multi-Jurisdictional Prosecutions and the SFO Show Teeth in Rolls Royce Settlement Mondelez FCPA Enforcement Action — An Abuse of Prosecutorial Discretion? The Real Explanation for the Record Year for FCPA Enforcement Tom Fox and Mike Volkov on FCPA Enforcement and Compliance Year in Review — 2016 Predicting the Future: What Would Truly Global Anti-Corruption Enforcement Look Like? Compliance Trends and Predictions for 2017 FCPA Predictions for 2017 (Part III of III) Trends from 2016 Record FCPA Enforcement Year (Part II of III) Badda Bing, Badda Boom!! — DOJ and SEC Make 2016 a Record Year for FCPA Enforcement (Part I of III) Webinar: 2016 FCPA Enforcement and Compliance Year in Review — January 10, 2017 12 Noon EST Tom Fox and Mike Volkov Podcast on the Odebrecht and Teva FCPA Settlements2016 T’Was the Week After Christmas: General Cable and Mexico Aviation FCPA Prosecutions Happy Holidays and New Year The Power of Honesty – A Candid Assessment of Your Compliance Program Hiding Behind the Privilege – A Cloak or a Dagger? E-Mail Communications: The Devil is on the Server Forget About a Risk Assessment – Conduct a Risk AND Compliance Program Assessment Shortchanging the Compliance Function Code of Conduct Training – Now What? CCOs Cannot Ignore C-Suite Risks The SEC’s Continuing Refinement of Internal Controls Enforcement New Episode — Everything Compliance Podcast Reminder: How to Embed a Speak Up Culture (Part III) Make Sure You Address Compliance with Export Controls Doing the Two-Step: Prioritizing Risks and Allocating Resources Trump and Compliance Reminder — Sign Up for Conducting Interviews Webinar, Tuesday, December 6, 2016 Sign Up and Subscribe to Corruption, Crime & Compliance New Volkov Law Website Coordinating Third Party Due Diligence and Procurement Aggressive Remediation: Embraer and JP Morgan Two Executives Charged in Valeant Pharmaceuticals Criminal Investigation Conflict of Interest Issues – A Significant Risk Three-Part Webinar Series: Speak Up Culture, Internal investigations Systems and Witness Interviews Lessons Learned from FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program The Myths Surrounding Ethics and Compliance Programs When Your Internal Investigator Fails to “Investigate” Webinar: Improving Your Internal Investigation Program Super Moon Coincides with Low Tide for Hatch-Waxman Patent Disputes Do You Know and Understand Your Compliance Policies? Infusing Your Compliance Program with Business Ethics When Tone at the Top Is Missing A New Administration: A New FCPA Enforcement Regime? Watch Recorded Webinar — How to Tailor Training to Your Company’s Risk Profile New Podcast — Everything Compliance Rescheduled Webinar: Rising Government Expectations for Compliance Programs Due Diligence Basics – Beneficial Ownership Making Sure Business Ethics Has a Seat at the Table AAG Caldwell Touts Success of FCPA Enforcement and Pilot Program ISO 37001: Why Your Anti-Corruption Policy Needs to Go Global When Lawyers Cross the Line – Breaking Bad Under the Law Lessons Learned from Embraer $205 Million FCPA Settlement (Part II of II) Embraer Finally Lands $205 Million FCPA Settlement (Part I of II) Changes in the Balance of Power: The Board Versus CEO Rescheduled Webinar: Rising Government Expectations for Compliance Programs Tenet Healthcare Settles Fraud Case for $514 Million When Business Supersedes Compliance – A Recipe for Disaster A New and Significant Anti-Corruption Voice in the Ukraine NAVEX Global Webinar: Benchmarking Your Third Party Risk Management Program in 2016 DOJ Criminal Prosecution of Wells Fargo: What to Expect? DOJ and SEC Raising the Stakes on Third Party Risk Management After Circling the Wagons: Wells Fargo’s CEO Finally Falls Watch Replay of Bureau Van Dijk Live Webinar on Unraveling Corporate Structures Och-Ziff: Accountability and Internal Controls (Part IV) FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III) Och-Ziff Failures in Due Diligence and Transaction Compliance (Part II) DOJ and SEC Deliver Body Blow to Private Equity and Hedge Funds: Och-Ziff Settles FCPA Violations for $412 Million (Part I) The Recalibration of Compliance: What is the Definition of Success? GSK Settles SEC FCPA Case for $20 Million Double Play, Double Declinations: DOJ Pushes FCPA Pilot Program Benefits 5 Key Takeaways from AB InBev SEC FCPA Settlement Dig a Little Deeper: The Importance of Beneficial Ownership Free webinar: Unravelling Corporate Structures: Understanding beneficial ownership and introducing new tools for due diligence Match Made in Heaven: Compliance and Human Resources Who is Responsible for a Company’s Mood in the Middle? – the Wells Fargo Fiasco Trust But Verify — Due Diligence with a Jaded Eye Three Key Takeaways from the Nu Skin FCPA Settlement for a Corrupt Charitable Donation Sampling as a Compliance Strategy President Obama Pledges to Lift Myanmar Sanctions Talking with Your Feet – The CCO’s Ethical Dilemmas Third-Party Risk Management – Part 2: Contract Termination Third-Party Risk Management – Part 1: Contract Extension When Diligence is Not Given its “Due” The Risk of a Cooperating Witness Left Out in the Cold For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives Webinar: Creating a Strategic Partnership Between Human Resources and Compliance The Costs of Corruption Customer Due Diligence in the Post-Panama Papers Era Lessons Learned from AstraZeneca’s $5.5 Million SEC FCPA Settlement Joanna Belbey, Forbes Magazine Interview: Crime and Social Media — Law Enforcement is Watching FCPA Enforcement Actions and Reputational Damage Healthcare Compliance: Juggling Risk Mitigation Strategies Creating a Valuable Training “Program” Thinking Like a Prosecutor – Yates and Internal Investigations Five Key Takeaways from Key Energy’s SEC FCPA Settlement FinCEN Expands Crackdown on Real Estate Buyers Anti-Corruption, Sanctions and Export and Import Risks Listen to Webinar Recording: Best Practices for Effective Ethics and Compliance Training Drug Companies and Charitable Patient Foundations Yates, Whistleblowers and FCPA Pilot Project: Re-Examining Your Internal investigation Protocols Mexico’s New Anti-Corruption Initiative Responsible Corporate Officers’ Jail Sentences Upheld in Selling Contaminated Eggs Third Party Risk Management Not Just Due Diligence FCPA Compliance: Does “Anything of Value” Really Mean “Anything of Value”? Train Your Board and C-Suite Now – The Under-Education of Corporate Leadership Headlines from Mid-Year FCPA Enforcement Review Webinar: Best Practices for Effective Ethics and Compliance Training Click 4 Compliance Joins Forces with Workplace Answers Defining the Compliance Mission – More Than Just Preventing Violations Getting Your Arms Around Antitrust Compliance (Part II of II) The Often Ignored Importance of Antitrust Compliance (Part I of II) DOJ and SEC Collect $22 Million from LAN Airlines for Conduct in Resolving Labor Dispute The Real Value of Lawyers to Compliance The Power of a Justice Department Declination Building a Company Culture of Trust The Importance of Risk Ranking to Compliance Check Up on Healthcare Fraud Prosecutions New York Department of Financial Services Issues New AML and Sanctions Regulations Johnson Controls Pays $14 Million for China FCPA Violations: DOJ Declines Prosecution White Collar Criminal Sentencing – What A Difference Cooperation Makes The FCPA Implications of the Supreme Court’s McDonnell Decision – A Mountain Out of a Molehill? The Debate Over Shareholder Democracy The SEC’s Love Affair with Internal Controls Podcast: Convergence of Audit and Compliance Functions The Importance of Diversity on Corporate Boards Sanctions Updates: Iran, Myanmar (Burma) and Cuba Conflicts Of Interest After the Yates Memorandum When Lawyers Get in the Way of Compliance Happy 4th of July!! The Adnan Syed Case — New Trial Granted Based on Challenge to Cell Tower Data Analogic FCPA Settlement – From Russia With(out) Love Convergence of Audit and Compliance Functions The Only Thing You Have to Fear . . . Is No Documentation Guest Post from Patrick Henz — Compliance Indicators Compliance Reminder — DOJ Announces Largest Healthcare Fraud Takedown Con Men, Criminals, and Compliance DOJ Folds Criminal Case Against Federal Express DOJ Suffers Criminal Trial Setbacks: Warner Chillcott President Acquitted Defining “Effective” Ethics and Compliance Programs A Rush to Compliance: Patience is a Virtue Akamai and Nortek – DOJ Touts Declinations Under FCPA Pilot Program The “Economic Costs” of Compliance Mandates The SEC’s Return to Accounting Fraud Enforcement Third Party Risk Management: Balancing Due Diligence Screening and Monitoring A Fair Assessment of the Impact of the Yates Memorandum DOJ’s Pilot Program – The Five Factors Designed to Nurture the Compliance Function RESCHEDULED Webinar: Conducting Internal Investigations in the Yates Memorandum Era Addressing AML Risks in the Era of Aggressive Enforcement Do Former Prosecutors Make Good CCOs? AML Risks and Foreign Correspondent Banking FinCEN Issues New Beneficial Ownership Regulations Global Standardization of Enforcement Global Construction and Corruption Corruption Risks and Corporate Social Responsibility Spending Watch Michael Volkov on Bureau van Dijk Webinar Addressing Third-Party Due Diligence The McDonnell Case: Supreme Court Weighs Limiting Bribery Statute The Evolving Due Diligence Standards and Beneficial Ownership Teaching the Board How to Oversee and Monitor the Compliance Function Trust and Integrity: The Value of a Company’s Reputation Webinar: CCOs and the Board of Directors: Establishing an Effective Relationship The Legacy of Michigan Senator Levin and Offshore Taxation Issues Getting Back to Basics: CCOs and Independence Fixing a Sour Corporate Culture: Valeant Pharmaceuticals Faces an Uphill Challenge Panama Papers: Prosecutors Launch Investigations New Job: Compliance Manager (Columbus, Ohio, metro area) Private Equity and the Och-Ziff Enforcement Action Revisiting FinCEN’s Proposed Regulations on Beneficial Ownership Creating a Real Incentive for Self-Reporting FCPA Violations (Part II of II) Campaigning for Self-Reporting and Calculation of Incentives (Part I of II) New Sponsor: Bureau van Dijk (BvD) Looking for Compliance Position? Here is One!! Who Can Fire a CCO? The DOJ’s Self-Disclosure Program Is Not Even Half the Story CCOs: Living in the Land of False Promises Compliance 2.0: DOJ Pushes the Compliance Agenda Webinar: How to Conduct FCPA Audits Incident Management – The New Frontier Fokker: No Judicial Oversight of Deferred Prosecution Agreements Finding “Compliance” Religion Panama Papers: Looking Below the Headlines Internal Controls Enforcement: Hoisting Yourself on Your Own Petard Las Vegas Sands $9 Million SEC Settlement: An Easy Mark New and Important Compliance Standards in DOJ’s Recent FCPA Guidance (Part II of II) DOJ’s New FCPA Enforcement Plan and Guidance (Part I of II) Doing Business in China Should Be “Scary” Checking In on “The Year of Third-Party Due Diligence” Parent Company and Subsidiary Liability for FCPA Violations: Fighting the Disinformation Campaign The Demise of Valeant Pharmaceuticals: A Case Study in Rotten Culture and Business Ethics Your Company’s Compliance Program is Finished – April Fools Honest Assessment of the CCO-CEO Relationship The Myth of the Rogue Employee Novartis Coughs Up $25 Million to SEC for China FCPA Violations A New “Wildy Effective” Book on Compliance from Kristy Grant-Hart New Free E-Book: A Return to Common Sense: The Justice Department’s Latest Attempts to Deter Corporate Criminals The Telltale Sign of Corporate Culture: Treatment of Whistleblowers Corporate Directors in the Enforcement Cross-Hairs The Banking Stepchild: Money Service Businesses The Importance of Understanding “Corrupt” Intent Volkov Law TV — Free Webinar: Compliance Pointers from Recent FCPA Enforcement Actions Practical Management of Your Company’s Culture Creating an Ethical Culture and “Outside” Influences Nordion: A Contrast in FCPA Enforcement Actions Webinar: Top 10 Challenges to Implementing an Effective Ethics and Compliance Program Volkov Law TV: New Webinars Added: FCPA, Due Diligence, Sanctions, Internal Investigations, and Sanctions Compliance Subscribe to Corruption Crime and Compliance Tom Fox’s New Book — Effective Leadership Skills in Compliance: CCO 3.0 and Beyond Anti-Kickback Enforcement – Steady and Aggressive Drug and Medical Device Corruption Risks in China Food Safety Criminal Prosecutions: When Compliance is a Matter of Life and Death Olympus: A Culture of Bribery and Kickbacks Derailing Internal Reviews, Audits, Assessments and Investigations A Teaching Moment Inside VimpelCom’s Boardroom Individual Criminal Prosecutions and Deterrence PTC Settlement: Compliance Reminders for Internal Controls, Travel and Gifts The Force Awakens: Vimpelcom’s FCPA Settlement and the Wreckage Left Behind (Part II of II) Webinar: Compliance Program Pointers from Recent FCPA Enforcement Actions Return of the Jedi (DOJ): The Vimpelcom Enforcement Action (Part I of II) Three Keys to Minimizing Employment Litigation Risks Never Underestimate – Your Company’s Hotline(s) Criminal Antitrust Enforcement for FY 2015 Misconduct in the C-Suite: SEC Settles FCPA Case with CEO Writing Effective and Clear Compliance Policies Embedding the Compliance Message in Middle Management SciClone Pharmaceuticals: A Textbook Case of FCPA Violations for Gifts, Meals, Entertainment and Travel Digging Into Your Internal Controls The Modern UK Slavery Act: Supply Chain Risk Management Broadcat: A New and Innovative Tool to Promote the Compliance Message Corruption and Foreign Government Institutions Focusing on Internal Investigations Learning from Schlumberger’s Mistakes: Doing Business Under Iran General License H Beneficial Ownership: Sanctions and FCPA Compliance Webinar: Review of Iran and Cuba Sanctions Programs — Compliance Challenges Prosecuting Individuals – The Coming Wave Fraud and Bribery: Segregation of Duties How to Keep Your Whistleblower(s) “Happy” (or Satisfied) Bribery Requires – Money The Changes to Iran Sanctions and Compliance Challenges Prosecuting CCOs v. Holding CCOs Accountable The Antitrust Leniency Model and FCPA Enforcement Is Your Anti-Corruption Compliance Program “Operational”? Cyber Security Compliance: The Role of the CCO Cuba and Iran Export Compliance Defining Business Ethics 2016 Year in Review: AML and Sanctions Enforcement The Person (Idea) of the Year – Corporate Ethics and Culture Ethics and Compliance Predictions for 2016 Predictions for Anti-Corruption Enforcement for 20162015 Happy Holidays — See You Next Year Preventing Terrorism with AML Accountability AND Budgeting The Dangers of Quick Fix Solutions – Certifications and Compliance Defenses Counterfeit Goods: Third Party Due Diligence Beyond the FCPA Four Compliance Trends and Challenges for 2016 Webinar: Anti-Corruption Enforcement and Compliance — The Year in Review Organizational Justice: The Importance of Transparency Now the Only Path to an SEC DPA or NPA: Self-Reporting Creating an Ombudsman’s Office NYDFS Proposes to Require CCOs to Certify to Effectiveness of AML and Sanctions Programs Applying Practical Strategies to Supply Chain Risk Due Diligence and Beyond — Balancing Competing Priorities DOJ’s Compliance Counsel & Compliance Expectations The UK Bribery Act Enters a New Enforcement Era Defining Compliance 2.0: Key Compliance Partners (Part 5 of 5) Defining Compliance 2.0: Senior Leadership (Part 4 of 5) Defining Compliance 2.0: The CCO (Part 3 of 5) Tom Fox and Mike Volkov Free Webinar — DOJ Shifts FCPA Prosecution Strategy Defining Compliance 2.0 — The CEO (Part 2 of 5) Defining Compliance 2.0: The Board (Part 1 of 5) Tom Fox and Michael Volkov Webinar — December 1, 2015, 2 PM EST: DOJ Shifts Prosecution Strategy for FCPA Enforcement and Corporate Compliance Programs Win-Wins: Looking for Business and Compliance Success Subscribe to Corruption, Crime & Compliance Should the Definition of “Foreign Official” Matter? Compliance 2.0 and Trends: Culture and Technology FCPA Enforcement — Corporate Crime and Punishment Resetting FCPA Prosecution Policies Turning the CEO Around: How to Make Sure the CEO Embraces Ethics and Compliance Deutsche Bank and Sanctions Violations: More to Come Does Training + Code of Ethics = Culture of Ethics? New “Guidance” from DOJ on Compliance Defining a Corporate Culture of Ethics and Compliance Justice Department Charges Pharma President with Kickback Conspiracy Culture Caution: Should You Accept a New Job as a CCO at a Company? Reinvigorating Corporate Board Governance to Embed a Culture of Ethics and Compliance Building a Due Diligence Infrastructure (Part IV of IV) Due Diligence and Risk Priorities (Part III of IV) Focusing on Due Diligence (Part II of IV) Webinar: Compliance 2.0 — A New Model for Ethics and Compliance Programs Getting Started on Due Diligence of Third Parties (Part I of IV) Asking the Right Questions: How to Measure Corporate Culture Business Ethics as an Effective Control Silicon Valley: Third Party Risk Management Seminar — November 5, 2015 Dissecting a Bribery Violation: Two Important Questions to Answer Yates and Outsourcing Government Investigations Five Requirements for Organizational Justice The SEC’s Year of FCPA Enforcement Four Clear Messages from Bristol-Myers Squibb FCPA Enforcement Action New E-Book: Question Everything — Effective Due Diligence and Third-Party Risk Management US and China Expand Law Enforcement Cooperation The 5 Key Ingredients to a Culture of Ethics Ethics and Simplicity SEC’s Hitachi Enforcement Action and Important Compliance Reminders Masters of Disaster Podcast — Michael Volkov — Ethics Makes Good Business Sense The Compliance Dangers of Cheerleaders and Nay-Sayers Five Ways to Ensure Board Support for Compliance The VW Scandal: Insular Senior Management and Ethical Breakdowns Compliance Fatigue — A Dangerous Concept Checking In on Sanctions Enforcement Cleaning Up a Compliance Program Mess SEC Seeks Increased Access to Email Ethical Business Decision-Making Ashley Seeleman — A Courageous Woman The GM Criminal Settlement — Disappointing Prosecuting Doctors for Medicare Fraud Webinar: Update to Internal Investigations Best Practices Antitrust Division Announces First Guilty Plea in Capacitor Cartel Investigation Misconduct in the C-Suite: The United Airlines Scandal The True Impact of DOJ’s Individual Prosecution Memo 5 Practical Trade Compliance Steps to Save Time and Money The Two Essential Requirements for Tone-At-The-Top Slowing Down the SEC Administrative Train FinCEN Proposes to Apply AML/BSA Requirements to Investment Advisers Hiring Practices: A New or Old FCPA Compliance Challenge? Taking Charge of a Company’s Reputation: Assign a Single Person to Manage Reputational Risks (Part III of III) Managing Threats to Corporate Reputations (Part II of III) Calculating the Incalculable: Reputational Damage (Part I of III) Reminders: Volkov Law TV, E-Mail Subscriptions, Books and Volkov Law for Ethics and Compliance Webinar: Anti-Corruption Compliance in the High-Tech Sector The Necessary Ingredient to Compliance Success: Interpersonal Skills Promoting Your Culture: Communications and Measurement DOJ’s Warning to High-Tech Companies: SAP Official Pleads Guilty To FCPA Violation SEC Unveils First FCPA Enforcement Action Focused On Hiring Practices: BNY Mellon SEC Promotes Value of Cooperating Witnesses The Danger of Compliance Overkill Meaningful Measurement of the Effectiveness of an Ethics and Compliance Program You Cannot Buy an Ethical Corporate Culture The 5 Most Common AML Compliance Program Deficiencies Webinar: August 18, 2015: Effective Training Strategies for Ethics and Compliance Programs Supreme Court Called Upon to Review the Newman Case and Address Insider Trading Liability Why is it So ($&#%*!) to Hard to Hire People in Compliance? The Time is Now to Amend the US Sentencing Guidelines on Corporate Ethics and Compliance Programs 5 Signs Your Anti-Corruption Compliance Program is Suffering from “Tunnel Vision” Reminder: Webinar Managing Private Equity Corruption Risks — Tuesday, August 11, 2015 Mead Johnson: Baby Formula and Bribes DOJ’s Disdain for “Paper” Compliance Programs Cecil the Lion and Due Diligence Failures Berger FCPA Settlement: Back to the Future Political Cynicism and DOJ’s Appointment of an Internal “Compliance Program” Expert Defrauding Medicare — A Little Help from the Private Sector? Private Equity’s Corruption Risk Underbelly — Portfolio Companies New E-Book: The Art of the Internal Investigation A Hands-On CEO and Support for Compliance Volkov Law TV — Announces New Subscription Options and Pricing for On-Demand Webinars Ten Key Elements of an AML Compliance Program The Purpose of Compliance: Promoting a Positive, Not Preventing a Negative 3 Ways to Improve Compliance Training Webinar: Managing Private Equity Corruption Risks Leveraging a Global Compliance Network LexisNexis CLE-Eligible Webinar: A Holistic Approach to Due Diligence and Third-Party Risk Management Refining a CCO’s Reporting Relationship to a Corporate Board 4 Signs of a Weak Culture of Compliance and Ethics Rolling the Dice: Casinos, FinCEN and AML Compliance Scrutinizing Third-Party Payments Private Equity FCPA Enforcement Know Your Customer (“KYC”) Due Diligence Best Practices AML Risk Assessments AML Risks and Compliance for Non-Financial Institutions The Sigelman Case and DOJ’s FCPA Trial Record Happy 4th of July (from Sicily) Shining a Light on Corporate Boardrooms and the Absence of Diversity The Important Distinction Between Legal and Business Ethics Compliance Trends and the Future of Compliance Update on Petrobas Scandal – Recent Arrests of Construction Company Executives Webinar: Antitrust Compliance Programs — July 15, 2015 12 Noon EST The Microeconomic Perspective on Bribery Incentives The FIFA Criminal Case – DOJ’s Extensive Criminal Toolbox IAP Worldwide FCPA Settlement: The Power of “Voluntary” Disclosure Employee Surveillance and Monitoring The Dangerous “Cult” of CEO Rock Stars 9 Ways Global Businesses Need to Step Up Their Sanctions Compliance Strategies Antitrust Update: The Aggressive Global Enforcement Network Good People Do Bad Things Webinar: Building a Due Diligence System From the Bottom Up Crossing a New Bridge: Compliance Officers and Financial Controls Warning: Keeping Compliance Simple Whistleblowers – Tracking Ups and Downs A New Era of Sanctions Enforcement Announcing Volkov Law TV — Webinars On-Demand Encouraging Employees to Break the “Rules” to Do the Right Thing Washington Politics and Compliance Parallel Prosecutions and U.S. Jurisdiction: Looking Beyond the Bribes in the FIFA Scandal Wall Street and Ethics The New Role of the CCO: Good News and Bad News 4 Steps Corporate Directors Need to Take Toward Compliance 2.0 Diggin’ Your Company’s Culture Healthcare Compliance Programs to Avoid a False Claims Act Case Gifts, Meals and Prosecution: BHP Billiton’s Settlement Webinar: June 9, 2015 — How to Improve Your Healthcare Compliance Program Tea Leaves from AAG Caldwell on An Effective Compliance Program 4 Questions to Ask When You Learn of Potential FCPA Violation The Future of Corporate Criminal Prosecutions (Part IV of IV) Can a Corporation Survive a Criminal Conviction? (Part III of IV) DOJ Criminal Investigations: “Boiling the Ocean” and Other Fish Tales (Part II of IV) The (Relatively) “New” Model for Corporate Criminal “Investigations” (Part I of IV) FinCEN Flexes Its Muscles Risk Assessment: A Natural Partnership for Internal Auditors and CCOs Front Lines of Compliance: First Line of Defense Third Party Risk Management If Only the New England Patriots Had a CCO: Lessons from “Deflategate” Tom Fox and Doing Compliance — New Releases Reminder: May 19, 2015 Webinar: How to Respond to a Potential FCPA Violation Subscribe to Corruption, Crime & Compliance — Receive an E-Mail with Each New Posting Automation and AML/BSA Compliance Happy Talk and CCO Reporting to the Board The Missing Link in Third Party Due Diligence Schlumberger OFAC Enforcement Action – A New Threat? Volkov Law Group and The Claro Group Team Up for Internal Controls Assessments Questioning Due Diligence Questionnaires — Keeping It Simple Welcome to New Sponsor — Click 4 Compliance Data Breach Legislation – Creating a Federal Standard Reinventing Compliance Program Metrics Documenting Your Compliance Program Questioning Prosecutorial Discretion Webinar: How to Respond to a Potential FCPA Violation Check Out You Tube Channel for Compliance Webinars FCPA Enforcement – Watching the Enforcement River Flow Improving Board Performance: Scrap the Old Model Implementing an Effective Third Party “Audit” Program Brazil Bribery Scandal Reaches Advertising Agencies Code of Conduct Enforcement How to Ensure the Right Tone at Every Level? A Neglected Compliance Task: Program Assessments Lions and Tigers and Bears – Certifications, Checklists and Standards Beneficial Ownership and AML, Sanctions and Anti-Corruption Compliance The Two Ps of Compliance: Promote and Protect Dancing on a Wire: Audit Committee Oversight of a Company’s Compliance Program Mike Volkov and Tom Fox Podcast on Internal Controls What to Do When The CEO Vanishes? Webinar: Third Party Due Diligence — Proactive Strategies to Minimize Risk The Empowerment of the CCO: Old Ways Die Hard The Importance of Conflicts of Interest Compliance The Value of a Vigilant Internal Audit Program The Crystal Ball for Future FCPA Prosecutions for Internal Controls Violations (Part IV of IV) FCPA Books and Records and Internal Controls Enforcement – A Retrospective (Part III of IV) Internal Accounting Controls – The Framework for Enforcement (Part II of IV) Internal Controls Enforcement (Part I of IV) DPAs and “Reforming” Corporate Criminal Liability Corporate Branding and Ethics and Compliance Charters and Policies Compliance Program Effectiveness Requires Accountability The Importance of Organizational Justice Webinar: Internal Controls — A New FCPA Enforcement Risk Ethics and Compliance, Not Compliance and Ethics Commerzbank: Remediation Under the Government Hammer and Microscope (Part III of III) Commerzbank’s Compliance Catastrophe — Flouting Sanctions and BSA/AML Laws (Part II of III) Commerzbank’s Settlement — The Government’s Frustration Boils Over (Part I of III) Technology is Transforming Third Party Risk Management: Predicting the Future When Does a CCO Need to Walk the Dotted Line to the Board? Practical Advice on Risk and Compliance Program Assessments Tracy and Hepburn: CCOs and Internal Auditors Reminders from the Goodyear FCPA Settlement Webinar: How Smart, Connected Due Diligence Systems are Transforming Third Party Risk Management Financial Institutions and Ethics – Some Just Do Not Get It Corporate Board Responsibility for Compliance Webinar — Top Ten Internal Investigation Problems The Need for Robust OFAC Compliance Programs Boiling Down the Attorney-Client Privilege Issue Putting a Stop to Human Trafficking Doctor “No” Versus Doctor Practical The Time is Now for Every Company to Conduct Culture Audits March 6, 2015 SCCE Webinar: FCPA Enforcement Review 2014 and 2015 Trends Avoiding Silos: Bringing Together the Key Compliance Players An “Effective” Compliance Program is Not a Perfect One The Over-Criminalization of Regulatory Compliance Future of Corporate Monitors Third Party Audits: Biting the Bullet The Compliance Revolution and Improving Board Oversight Sanctions Enforcement – Facilitation Violations A Most Violent Year – Doing What is Most Right Is Your Board Engaged on Compliance or Not? Be Honest! Webinar: Taking Your Anti-Corruption Compliance Program to the Next Level Judicial Oversight of Deferred Prosecution Agreements Corruption in America Ethics Are Contagious: It Isn’t Just About the FCPA Value of (Non-) Cooperation in FCPA Cases The Aviation Industry and Corruption NYSE Governance Webinar February 19, 2015: A Review of FCPA Enforcement and Compliance Trends SEC Starts the FCPA Year Off with a Bang 2015: The Year of FCPA Liability for Financial Institutions? Improving the Message of Ethics and Compliance Anti-Kickback and Stark Law: Pitfalls and Problems Healthcare Compliance Programs: Stepping Up the Game March 23 and 24, 2015: Anti-Corruption in Oil and Gas Conference Catching Up on the False Claims Act Healthcare Fraud: Aggressive Enforcement Strategies Trade-Based Money Laundering: What You Don’t Know Can Hurt You Sunlight on Corruption: An Important Strategy in the Global Anti-Corruption Movement My New E-Book: The Revolution in Ethics and Compliance The Real Impact of Aggressive AML/BSA Enforcement Top 5 Ethics and Compliance Trends for 2015 The Perils of Check-The-Box Training RESCHEDULED Webinar: Understanding the Different Mandates for Legal and Compliance The New Enforcement Threat – Sanctions Violations Financial Institutions and a Lack of Ethics Choosing the Right Vendor Risk Management Software Solution The Alstom Case: Realities and Lessons Learned Promoting Internal Compliance Communications The Person of the Year — the Chief Ethics Officer FCPA Predictions for 2015 (Part II of II) The FCPA Year in Review: Twist and Shout (Part I of II) Pow! Whack! Slam! Bam! – DOJ Finishes the FCPA Year with a Bang2014 Happy Holidays — Returning January 5, 2015 The OECD Report: Shedding Light on Foreign Bribery The “New Reality” for Corporate Boards Avenues for Reporting Employee Concerns Gifts, Meals and Then . . . FCPA Enforcement Adding Cyber Security to Corporate Risk Management Two Webinars: Year in Review — FCPA Enforcement and AML/Sanctions Enforcement Seven Key Actions to Accelerate Your Ethics and Compliance Program Focusing on the Disconnect: Mid-Level Managers and Handling of Employee Concerns Kickbacks and Bribery Compliance Attitudes in High-Risk Markets Lawyers and CCOs on the Front Line: Who’s on First? What’s on Second Building Your Third Party Due Diligence Checklist: The Right Pieces, Processes and Presumptions Ethical Culture: Action Speaks Louder Than Words Happy Talk and the Compliance Gap – Paper v. Reality C-Suite Risks and Compliance Due Diligence and The Holy Grail — Red Flags Volkov Law Group Offers In-House Compliance Training Webinar: Anti-Corruption Compliance in High-Risk Markets Corporations Need to Say the Words – “Let’s Go to Trial” Welcome to the New Corruption, Crime and Compliance Criminal Global Cartel Focus on Generic Pharmaceuticals New Attorneys Join The Volkov Law Group Happy Birthday FCPA Guidance Two New and Important Legal Blogs — Randall Eliason and Robert Connolly Volkov Law Group Webinars on ITunes The Importance of a Code of Conduct A Holistic Look at Third Party Risks Recent FCPA Enforcement Actions: The Layne Christensen Case and SBM Offshore Significant Trends from Recent FCPA Enforcement Actions: The Bio-Rad Case Working in the Compliance Field – The Need for Practical Solutions The Curious World of the Antitrust Division and Credit for Compliance Programs Voluntary Disclosure: The Continuing Debate Politics and the FCPA Gratitude and — 1001 Beers on the Wall . . . . Webinar: FCPA Guidance — Practical Compliance Solutions The Jodi Arias Sentencing Hearing: Can it Get Any Worse? Culture of Compliance: A Low-Cost Compliance Strategy A CCO’s Vision Needs to Include “Line of Sight” Sharing the Spotlight: M&A Due Diligence The Important Distinction Between Ethics and Compliance Jodi Arias: Bordering on Death? Knowing When to Fold — Arguing the FCPA’s Definition of “Foreign Official” Prosecution of Chief Compliance Officers: Establishing Basic Professional Standards Internal investigations and the Importance of Witness Interviews China and Antitrust Enforcement Supply Chain Management: Avoiding Headaches Goodbye Mr. Millikin: GM’s Continuing Culture Challenges Higher Education Compliance and the Scourge of Campus Sexual Assaults Look What DOJ Found – A New Enforcement Tool: FIRREA Justice Department Opens Up False Claims Files for Criminal Investigation Creating a “Speak Up” Culture and Whistleblowers Webinar: Anti-Corruption Compliance for Small and Mid-Sized Companies Compliance Challenges: When the Almighty Dollar Rules The Justice Department and Individual Criminal Prosecutions FinCEN’s Culture of Compliance Advisory: A Strong Message Ten Requirements for an Effective Due Diligence System FCPA Enforcement: Where Have All the Enforcement Actions Gone? Complicating Sanctions Compliance: OFAC Redefines 50 Percent Rule Kreller Group Blog: “Instrumentality” Defined for FCPA Purposes Warning: Banks Need to Re-Examine KYC Risk Evaluation Procedures GSK China: Did Case Finish with a Bang or a Whimper? More Empty Words for an FCPA Compliance Defense Upcoming Webinars: Due Diligence and Internal Investigations New RAND Publication: Transforming Compliance: Emerging Paradigms for Boards, Management, Compliance Officers, and Government Accountability: Where is the Board of Directors? Important Employee Values: Integrity and Trust Governance, Compliance and Simplicity International Coordination and Cooperation in Corruption Cases More Than Due Diligence: Never-Ending Due Diligence Where the Action Is: The SCCE Annual Meeting Customer Due Diligence and Beneficial Ownership Corporate Wrongdoing and Deterrence Attend the FCPA Master Class for In-House Compliance Staff — October 21-22, 2014, Chicago, Illinois The Human Factor: Joint Venture Partner Compliance (Part III of III) Inside and Out: Anti-Corruption Compliance for Joint Ventures (Part II of III) Joint Ventures and Compliance: Defining the Issues (Part I of III) Fraud and Bribery – They Go Hand in Hand When to Walk Away from an Agent or Distributor (Part IV of IV) Creative Contracting to Reduce Third-Party Risks (Part III of IV) Free NAVEX Global Webinar — September 4, 2014 — Policy Management Practices Integrating and Training Your Agents and Distributors (Part II of IV) The New Focus on Agent and Distributor Monitoring (Part I of IV) Webinar: Taking Third Party Due Diligence to the Next Level Long and Winding Road of FCPA Investigations Brothers and Sisters in Arms: Defining Protocols for Legal and Compliance Five Important Traits for a Successful CECO Compliance Training Is Also About What You CAN Do The Double Whammy: Cubist’s Recent FCPA Disclosure The Value of Due Diligence Certifications The Absence of a CECO and the GM Fiasco Five Essential Improvements to Corporate Governance Four Ways to Improve Antitrust Compliance Programs Five Ways for CCOs to Enhance Their Professional Qualifications and Status Five Most Common Weaknesses in Anti-Corruption Compliance Programs Complaints to Investigations to a Speak Up Culture: Maintaining Important Connections FCPA Fugitives Compliance Fatigue: You’re Kidding, Right? Step-by-Step, Inch-by-Inch: Trouble for Wal-Mart in Delaware Four Important Steps to Promote A Speak Up Culture Stacking the Deck: SEC’s Use of Administrative Proceedings CCO Reporting to Board: Five Best Practices FCPA Mid-Year Assessments Corruption Risks in Pharma Manufacturing in Russia Employee Culture Surveys: Low-Cost Critical Information The CCO’s Challenge: Becoming a Strategic Business Partner Marubeni: FCPA Repeat Offender Ignoring the Compliance Message Risk Planning and Board Liability Prosecuting Compliance “Gatekeepers” Putting the Ethics Back into Healthcare Compliance CCOs Take Note: It’s the Culture Stupid Improving Corporate Board Performance: Self-Evaluations HIPAA Data Breaches CCOs Need a Seat at the Table Upcoming Webinars: Basic FCPA Training and Creating a Culture of Ethics Healthcare Ethics and Compliance Program Requirements BNP: A Window Into A Systemic Compliance Breakdown CCO Challenges in the Healthcare Industry The Danger of Retaliating Against Whistleblowers The Intractable Problem of Medicare Fraud CCOs Need To Adopt Their Own Code of Conduct Webinar: Monitoring and Auditing Your Anti-Corruption Compliance Program Someone Has to Deliver the Bad News: What to Learn From GM and Sophocles A Chilling Message: Prosecuting Chief Compliance Officers Defining Corporate Governance: Decisions, Direction, Culture and Risk The Credit Suisse Case: Did the Justice Department Lose its Nerve? Drawing the Line on Accountability Fixing a Company’s Ethics and Compliance Culture American Leaders Conference on FCPA and Anti-Corruption Compliance and Life Sciences Industry American Leaders Conference on Enhancing Anti-Corruption Compliance and Life Sciences Industry Questioning The Caremark Standard Risks of International Anti-Corruption Enforcement Challenges for Pharmaceutical Companies in Russia When the In-House Lawyers Run Amuck Focusing on the Critical Compliance Disconnect The GM Safety Debacle – Everyone is Responsible and No One is Responsible Senior Associate Needed: The Volkov Law Group Compliance with a Purpose Corporate Culture – The Foundation of Compliance “Sympathy” for the Board There Is No Bark to the Barko Case AML/BSA Compliance Program Best Practices AML Compliance: The Four Pillars Cisco and Russia — Perils of Corruption in Russia Essential Requirements For An “Effective” Ethics and Compliance Program Two-Part Webinar Series: AML/BSA and Sanctions Compliance Webinar: Managing Your Internal Investigation Program On the Chopping Block: Banks and Financial Institutions Nigeria: The Corruption Poster Child NAVEX Global White Paper: “A Holistic Approach to Global Anti-Corruption Compliance” Esquenazi: DOJ Wins Appeal on “Instrumentality” Defining an “Ethical” Leader (Part IV of IV) Making an Ethical Culture Work (Part III of IV) Are Ethical Companies More Profitable? (Part II of IV) Ethics and Compliance Messaging (Part I of IV) Reporting on an Internal Investigation (Part IV of IV) Let the Games Begin: Conducting Witness Interviews (Part III of IV) Adopting a Vision: Putting the Pieces Together (Part II of IV) Lift-Off: Step-by-Step Procedures to Start an Internal Investigation (Part I of IV) Business Management Focus and Compliance Webinar: Designing Cost-Effective Risk Assessment Programs China’s Aggressive Enforcement of Domestic Corruption Laws Criminal FCPA Cases – Targeting Individuals Undermining an Internal Investigation: Lack of Impartial Investigator CCOs On the Hook: FinCEN Seeking Fine Against Moneygram CCO Revisiting the Corporate Top-10 FCPA Enforcement Actions Get Your Tutsi Fruitsi: Calculating FCPA Fines Under the Sentencing Guidelines The Criminal Mind: Acceptance of Responsibility Navex Global Webinar: Practical Strategies for Implementing Effective Due Diligence Systems Increase the Number of Women on Corporate Boards Three Blind Mice and the HP FCPA Settlement The Apple Monitorship: Airing Dirty Laundry Webinar: Managing Your Anti-Corruption Policies and Procedures Sifting Through the Ukraine Economic Sanctions Mitigating Bribery Risks with Financial Controls AML Enforcement and Sanctions A Close Look at Internal Controls To Be a Criminal, You Have to Act Like a Criminal Paper Tigers and Paper Compliance AML Enforcement Jitters and Due Diligence Corruption Continues to Eat Away at India Do Compliance Professionals Have to Be Lawyers? Webinar: Tailoring Your Anti-Corruption Program to Your Risk Assessment Digging Down on Joint Ventures and FCPA Compliance The Economic Crime Triad: Companies Facing Major Risks CCO’s Be Careful What You Ask For — You Just May Have It Alstom: The Next Poster Child for Anti-Corruption Enforcement Encouraging Communication of Employee Concerns Keeping Compliance Focus on Risky Interactions Best Practices for Anti-Corruption Compliance Programs – A Moving Target Och-Ziff and Private Equity Corruption Risks White Collar Crime: Reading Minds Webinar: Keeping Your Due Diligence System Manageable Board Reform: The Unpredictable Factor of Personal Interactions The Cost of Compliance Just Say No: Refusing to Pay Bribes The Value of an Ethical Culture The General Motors Scandal: Risky Issues Webinar: The Role of A Chief Compliance Officer: Navigating the Compliance Landscape Board Reform: Real Leadership Requires Robust Information Sharing Compliance Program Success: “Doing Better with Less” Mood in the Middle Versus Tone at the Top CCOs Speak with Their Feet Chief Compliance Officers: Are They Superheroes? CEOs Who Walk the Walk Michael Volkov Testifies Before House Judiciary Committee on Federal Criminal Code Reform Board of Directors Reform: Adopting a New Model for Board Members “Credit” for An Effective Ethics and Compliance Program Compliance Training and Corporate Culture Bribery is Bribery The Importance of a Risk Assessment Where O’ Where is the Board of Directors? The SEC’s Financial Fraud and Accounting Task Force Webinar: Internal Investigations — Soup to Nuts JP Morgan’s Tone-Deaf Attitude Four Critical Questions for Assessing Compliance Communications with the Board of Directors Target Lessons – Another Reminder on Responding to Employee Concerns Avon is Calling – Some Lessons Learned Merger and Acquisition Due Diligence and Voluntary Disclosures The SEC’s Enforcement of an Elastic “Internal Controls” Requirement The Healthcare Industry and Chief Compliance Officers Diagnosing a Compliance “Failure” Code Violations, Enforcement and “Broken Windows” Webinar Update: Past and Future The Financial industry – Life is Getting Tough Chief Ethics and Compliance Officers – Reasonable Expectations Three Keys to an Effective Disciplinary Program What’s in a Title? – CCOs versus CECOs The CFIUS Review Process and Foreign investments The Importance of Corporate Value Statements to Compliance Programs Download Michael Volkov’s New E-Book: Technology and GRC The So-Called Re-Emergence of Gifts, Meals and Entertainment as a Compliance Problem Chief Compliance Officers: Under the Microscope The Government’s Unrelenting Reliance on Anti-Kickback Prosecutions Anti-Corruption Compliance: Enhanced Elements Become the New Norm DOJ and SEC Award Significant Credit for Remediation During Investigation Follow the Bouncing Ball – Tracking DOJ Investigations Network Webinar: Navigating the Waters of Anti-Corruption Compliance in China The Relationship Between Sarbanes-Oxley and FCPA Compliance Books and Records Flexes its Muscles Here We Come . . . Walking Down [Wall Street] – More “Aggressive” AML Enforcement on the Horizon We Mean What We Say – FCPA Enforcement Begins the Year with a Bang Five Essential Leadership Traits Focusing on Board Performance Sign Up for Webinar: Interviews and Internal Investigations A New Approach to Compliance: “Informed” Risk and Resource Allocation Five New Year’s Resolutions for the CCO Little Help from My Friends – Predictions for Ethics and Compliance in 2014 FCPA Predictions for the New Year – 20142013 Webinar: FCPA Enforcement: A Review of 2013 and Trends for 2014 The Real Purpose(s) of a Compliance Program The FCPA Person of the Year – The Prosecutor Private Health insurance Fraud – Rooting Out Bogus Providers Hiring of Foreign Officials’ Relatives – Negating Corrupt Intent It Makes You Wonder – JP Morgan’s Diminishing Compliance Credibility Weatherford, Bilfinger and Systemic Breakdowns Global Anti-Corruption Enforcement and Emerging Practical Issues The Sky is the Limit: Escalating Fines, DPA/NPAs and Deterrence Private Health Insurance Fraud — Billions and Billions Putting the Pieces Together: Integrated Due Diligence Programs Responding to a Whistleblower’s Complaint Webinar: Third-Party Due Diligence: When is Enough, Enough? A Critical Requirement of a Major Internal Investigation — Independence Compliance Professionals and Data Analysis Monitors and Remediation Government’s Efforts to Bolster CCOs SEC Whistleblower Program: Gathering Steam The Only Thing [In-House Counsel and CCOs] Have to Fear, Is Fear Itself Webinar: Building an Integrated Third-Party Due Diligence System — Screening to Audits Bringing Human Resources into the Compliance Tent The CCO – not the CEO – Creates an Ethical Culture The Importance of an Effective Internal Investigation Process Where is your CCO’s Office? An Important Question! Searching for Relevant Compliance Measurements Private Equity FCPA Risks: Growing Rapidly Pushing Corporate Boards to a New Style of Governance How to Analyze FCPA Enforcement Actions: Stryker and Diebold Avoiding Stovepipes: Integrating Compliance Functions CCOs’ Destiny of Success or Failure Risk Sampling: The Key to a Successful Audit and Monitoring Program The New Volkov Law Group Website Documentation as a Compliance Principle Human Trafficking Compliance Proactive Whistleblower Strategies Webinar: Anti-Kickback and Stark Law Update: Enforcement and Compliance Issues Webinar: Creating a Culture of Ethics and Compliance Ignoring the Obvious: Facilitation Payments Compliance Reminders, Notices and Certifications CCOs as Superheroes: Compliance SWAT Teams Bringing the Board and the C-Suite into the Fold: Promoting a Culture of Compliance Bitcoin and the Silk Road The Importance of Listening Culture, Compliance and the C-Suite: The RAND Symposium HIPAA Compliance and September 23, 2013 — The Day The World Did NOT End Webinar: Buying an FCPA Violation: Merger & Acquisition Risks Corporate Board Oversight Responsibilities and Liability FinCEN Joins the Enforcement Party Strategic Risk Management Twenty Compliance Questions for the Chief Executive Officer Data and Compliance The Future of Virtual Currencies: Competition and Regulation Webinar: Fine-Tuning Your Anti-Corruption Compliance Program Webinar: Healthcare Fraud Compliance SEC “Refocuses” on Accounting Fraud Five Important Lessons from the Antitrust Division’s Record Criminal Settlement The CCO’s Vision and Commitment Corporate Board Risks in Internal Investigations “Survey Says”: Surprises in Anti-Corruption Attitudes Webinar: Anti-Corruption Compliance Program Audits Antitrust Compliance and Credit for an Effective Compliance Program JP Morgan: Can it Get Any Worse? Focus on Hiring Relatives of Foreign Officials: A Serious Bribery Risk? Uneven Discipline Undermines Compliance Hospitals and Compliance SEC Pushes Compliance Programs and Protects Compliance Officers from Lying Employees Elevating Board Performance: The Importance of Compliance Expertise Ten Basic Compliance and Ethics Program Questions Every CCO Should Ask Federal Judges and Corporate Settlement Agreements Ensuring Compliance Success: Building a Relationship with the Board Questions on World Bank Sanctions Program Webinar: Antitrust Enforcement and Compliance Programs Privacy: The FTC Takes Action and Warns Private Industry Additional Costs of FCPA Investigations — Collateral Litigation Donna Boehme: The Chief Compliance Officer’s Best Friend Brazil and its Commitment to Anti-Corruption Enforcement Corporate Change: How Does it Happen? AML Enforcement and Virtual Currencies Webinar — September 10, 2013 — Building an “Effective” Anti-Corruption Compliance Program Criminal Antitrust Enforcement: The Success of the Leniency Program Corporate Excuses to Avoid Compliance and Ethics Programs The SEC’s New Aggressive Tack The Chief Compliance Officer as a Corporate Leader Vendor/Supplier Due Diligence: Tricky Issues and Twists and Turns Dancing Around the Edges: Renewed Focus on Gifts and Hospitality The Risks of a Defective Internal Investigation All in the Family: Enforcement Focus on Hiring of Relatives of Foreign Officials Reactive Compliance: An Oxymoron? The Rise of Compliance Professionals China and Compliance Solutions: Choking Off the Money Supply Making Your Training Program Effective Facing Reality in China Stretching Compliance Resources Criminal Liability for Deficient Background Checks: Snowden and the False Claims Act Corporate Governance Breakdowns How to Ensure Compliance When the CEO Will Not Listen The Real Implications of the Glaxo Enforcement Action in China Webinar: How to Avoid Corruption Risks in China Instilling Ethics in a Compliance Program Internal Investigations in a “Bet the Company” Case The Heart of AML Compliance: Sanctions Violations Corporate Risks: What Do Corporate Leaders Worry About? Drilling Down on Due Diligence: Raising the Bar Einstein’s Theory of Relativity and Compliance Ten Required Steps To Ensure Effective Compliance Programs by Pharmaceutical and Medical Device Companies (Part III of III) Pharmaceutical and Medical Device Companies: Taking it on the Chin (Part II of III) Bad News for the Drug and Device Industries: Glaxo’s Systemic Breakdown in China (Part I of III) Risk Management Systems: The New Frontier The Anti-Corruption Movement and Human Rights Hyper-Focus on Corporate Governance: Dangers and Risks to Corporate Boards The Marriage of the CEO and CCO: A Match Made In Heaven Let the Sunshine In – The Risks to Pharmaceutical and Medical Device Companies from Open Payment Transparency Sign Up Now for 4 New Webinars — FCPA Compliance, Internal Investigations and Congressional Investigations Congressional Investigations: Unique and Significant Risks How to Disclose a Possible FCPA Violation Canada Continues Its Aggressive Push in Anti-Corruption Enforcement Managing and Minimizing Your Third-Party Risks Broker-Dealers: Pay Attention to Government Audits and Examinations Reminder: Webinar — FCPA Compliance Programs: A Review of Best Practices Doctors, Enforcement Risks and Compliance Programs Designing the Right Structure for Your Compliance and Ethics Program Anti-Corruption Compliance Program Assessments Hiding Out: The Danger of a Disconnected CCO Stretching the FCPA: The Danger of the Oracle Case FCPA Enforcement Against Broker-Dealers: A New Headache for CCOs A Mid-Year Assessment of FCPA Enforcement (Part II of II) FCPA Criminal Enforcement: DOJ Returns with a Vengeance (Part I of II) Webinar — FCPA Compliance Programs: A Review of Best Practices Corruption and International Enforcement Healthcare Providers and Self-Disclosure of Violations Corruption in Italy Mr. Bourke Heads to Jail – If Only He Had a Compliance Officer At the Table AML Transaction Monitoring The Three Keys to Compliance Programs: Structure, Processes and Results Doctors Going to Jail: Criminal Prosecutions for Quality of Care and Fraud Clinical Trials and Corruption Risks FCPA Criminal Liability: Follow George Costanza’s Advice – Do the Opposite FCPA 2013 Mid-Year Review Welcome to a New Sponsor: The Network, Integrated GRC Solutions Kazakhstan: Corruption and Stability? Anti-Kickback Laws, False Claims and Recidivists AML Compliance: KYC and Due Diligence Corruption and Economic Development Pharmaceutical and Medical Device Compliance: Domestic and Foreign Bribery The Tiger Woods Controversy and Compliance Lessons 2013 RAND Corporation Symposium: Culture, Compliance and the C-Suite Broker-Dealers Cross Into FCPA Territory Russia and Corruption: Don Quixote or Elliot Ness? (Part II of II) Russia and Corruption: Moving Forward, Backwards or Side-Stepping (Part I of II) Webinar: How to Solve Difficult FCPA Compliance Issues The Jodi Arias Trial: Justice Run Amok Conducting Audits: Financial and Compliance Teams Abuse of Government Power — The IRS Targets Political Groups HIPAA Enforcement: Unleashing the Dogs Playing with Ralph Lauren: A Fair Settlement? Demonstrating the Effectiveness of Your Compliance Program The Importance of a Senior Executive Compliance Committee CFPB Targets Auto Financing for Enforcement The Compliance Stepchild: Antitrust Turning CCOs Into Business Partners Leveraging the Board and CEO Relationship to Improve Compliance Improving Your Anti-Corruption Training Program The Three Amigos/Amigas: Compliance, Audit and Legal Webinar — How to Monitor, Audit and Improve Your Anti-Corruption Compliance Program The Continuing Controversy Over DPAs and NPAs Practical Suggestions for Conducting Risk Assessments Jodi Arias Trial: Prediction Intermountain Healthcare Settlement – Dangers of Hospital Agreements with Physicians Anti-Corruption High-Risk Audits The Hatfields and the McCoys: CCOs and GCs? Hospital and Physician Compliance with Anti-Kickback and Stark Restrictions Antitrust Criminal Enforcement The Danger of FCPA “Proactive” Investigations Cross-Examinations in the Jodi Arias Trial The Harder They Fall Managing an AML Compliance Program The Jodi Arias Trial — Lessons Learned The Importance of a Board Compliance Committee Assessing Your BSA/AML Compliance Program Promoting Ethics in Your Company India: The Quixotic Balancing of Benefits and Risks AML Enforcement – A New Era of Compliance An Independent CCO Is A Compliance Program Requirement The BizJet Case: The Drama Unfolds Webinar: The 10 Essential Steps to an “Effective” Anti-Corruption Compliance Program Empowering the Chief Compliance Officer Measuring Tone at the Top Monitoring of Third-Party Agents and Distributors Hospitals: Audits and Compliance Criminal Sentencing of Corporations The Truth Behind Gifts, Meals and Entertainment Enforcement The Importance of Anti-Corruption Compliance Remediation Third Party Risks and Internal Auditors Facilitation Payments: An Intractable Problem? FCPA Enforcement Outlook for 2013 Webinar — FCPA Enforcement: How to Respond to a Government Investigation The Lifeblood of Compliance: “Vertical” Information Due Diligence When Renewing a Third Party Relationship Breaking Bad: When a Good Employee Goes Bad? The Benefits of a Corporate Ombudsman CMS Issues Rules on Physician Payments Sunshine Act The Case for Increasing Boardroom Diversity The Future of Compliance – What Will the New Tools Look Like? Healthcare Compliance and Chief Compliance Officers Anti-Corruption Compliance Check-Ups Webinar — Anti-Corruption Due Diligence: Practical Steps to Protect Your Company from Third Party Risks Internal Investigations: Preserving Independence FATCA and Voluntary Disclosure FCPA “Reform”: Another Shot in the Dark Chief Compliance Officers and Stress JP Morgan and Lessons Learned for Corporate Governance Limiting the FCPA’s Reach — Squaring Two Recent Decisions High Anxiety: Five Basic Worries for Every Corporate Board Best Practices for Internal Investigation Interviews The Storm Has Arrived: Cybersecurity, Risks and Response Webinar — How to Conduct “Routine” Internal Investigations Protecting Your Hospital from Over-Utilization Prosecutions The Healthcare Industry and the Voluntary Disclosure Process The Rising Threat of Trade Secrets Theft Hospitals and Fraud Enforcement Expanding the Reach of HIPAA Data Security and Privacy Requirements “Give Me a Break” — Keeping “Risk” Analysis Simple The Dangers of Social Media and Employee Discipline Ticking Time Bomb: Private LIBOR Litigation Failing to Act: Lessons from 2012 FCPA Enforcement Michael Volkov Starts New Law Firm Human Trafficking and Government Contractors The FCPA Guidance and Accounting Controls A Status Check on the UK Bribery Act Improving Corporate Governance: Board Self-Evaluations When Does a Corporate Officer or Employee Need Separate Counsel? How to Prevent Whistleblower Complaints Chief Compliance Officers and the Healthcare Industry Heads in the Clouds: Government Requests for Cloud Data CFPB Examinations and Enforcement Five Steps to Improve Corporate Governance Reality Check on Compliance The Danger of a “Paper” Compliance Program Compliance and the Criminal Mind Subscribe to the New Corruption, Crime & Compliance Hospitals Need to Focus on Data Privacy and Security The Cutting Edge of Anti-Corruption Compliance: Proactive Audits Insider Trading Enforcement and Deterrence Reminder: Webinar January 22, 12 Noon — The FCPA Guidance: How to Ensure an Effective Compliance Program The Attorney-Client Privilege and Compliance 2013 Enforcement Predictions Audits, Audits and More Audits: Life in the Healthcare Industry EPA’s 2012 Enforcement Results – What Do They Mean? The Person of the Year: The Whistleblower The Compliance Officer’s Crystal Ball Privatizing Health Insurance Companies for Anti-Fraud Enforcement Five Biggest FCPA Stories of 2012 Fraud: Skilled Nursing Facilities and Nursing Homes Banks Take It On the Chin Data Privacy and Security Risks Welcome to the New Corruption Crime & Compliance2012 Internal Investigations: Making a Decision (IV of IV) Routine Internal Investigations and Interviews (Part III of IV) “Routine” Internal Investigations: Initial Phase (Part II of IV) Internal Investigation Procedures (Part I of IV) The FCPA Guidance and Voluntary Disclosures A Call to Arms: Conduct a Risk Assessment Private Health Insurance Efforts to Fight Fraud Rising from the Dead: Anti-Corruption Enforcement in Canada Dancing Around the Edges: A Journey in the FCPA Guidance Plugging the Leak: Tackling the Problem of Healthcare Fraud False Claims Recoveries in 2012 Hit Nearly $5 Billion FINCEN and Bank Secrecy Act Enforcement Asian Companies Playing with FCPA Enforcement Fire No More Ifs, Ands, and Buts — Anti-Corruption Compliance Now Second Circuit Rules Off-Label Prosecution Violates First Amendment Three Important Lessons from the FCPA Guidance for Pharmaceutical and Medical Device Companies The FCPA Guidance: Refining a Corporate Compliance Program (Part II of II) The FCPA Guidance and Compliance Programs: Leading the Charge (Part I of II) Good News, Bad News and Missed Opportunities on “Successor Liability” Flailing at the Definition of a “Foreign Official” Confusing “Guidance” from DOJ and SEC on Third Party Liability Safe Harbors and Gifts, Meals, Travel, and Entertainment Expenses FCPA Guidance: Refined Compliance and Safe Harbors The Whistleblower Era Ten Headlines from the FCPA Guidance The FCPA Guidance: Bob Dylan, Change and Political Reality Why Can’t A Company Go To Trial? Moving Corporate Governance “Forward” Creating a Framework for Reviewing Gifts, Meals, Travel and Entertainment Expenses Internal Investigations & Independence Four More Years – The Enforcement Outlook Join Us for Webinar: Update on Anti-Money Laundering Enforcement Trends: Nov. 13, at 12 Noon EST FCPA Compliance: A Seat at Every Merger & Acquisition Table Compliance Assessments Five Steps to Take When an EPA Inspector Knocks My Interview in SCCE’s Compliance and Ethics Professional Magazine November/December Issue You Receive a Subpoena: Now What? Ten Steps to Effective Due Diligence Catelas Webinar Series: Sign Up for Part 2, November 7 at 12 Noon Subscribe to Corruption Crime & Compliance — E-Mail Delivery to Your Mailbox Are Compliance Officers Being Asked to Accomplish the Impossible? Data Privacy and Security Compliance Programs Keeping Compliance Simple Yes, Virginia, Compliance and Ethics is a Profession Five Critical Questions to Weigh When You Find an FCPA Violation Who is Committing Healthcare Fraud? Individualized Compliance and Benchmarks: Focus on Your Company Free Webinar, November 1, 2012, 12 Noon EDT — Anti-Corruption Enforcement and Compliance Update The Financial Industry: Ignoring Corruption Enforcement Risks Compliance Officers: The Yin and the Yang Five Important Compliance Principles to Prevent FCPA Liability Sicily: Cuisine, Culture & Tradition The Changing Role of Internal Auditors CFPB Targets Fair Lending Turning the Screws: Justice Department and Regulators Ramp up AML Enforcement Welcome to Catelas — A New Sponsor Targeting Healthcare Fraud by Data Mining Entering High-Risk Corruption Markets Targeting Hospitals for Civil and Criminal Prosecutions World Compliance Event in Miami, FL on November 1, 2012 Civil and Criminal Environmental Enforcement Webinar — October 24, 2012 — Noon EST How to Keep Your United States Subsidiary Out of Legal Trouble Risky Interactions: Building a Compliance Record Healthcare Prosecutions for Failures to Return Overpayments Corporate Integrity Agreements and Anti-Corruption Compliance Schedules A Comprehensive Approach to Data Security Embedding Compliance Personnel in Business Operations Fixing the Justice Department’s FCPA Voluntary Disclosure Program Whither the UK Bribery Act? Join Us In Houston, Texas — FCPA Developments and Compliance FCPA Compliance for Start-Ups When to Launch an Internal Investigation Avoiding "Lotto-Sized" Anti-Fraud Fines How to Define “Tone-at-the-Top” Mandatory Compliance Programs for Healthcare Companies Preparing for Data Collection in Internal Investigations The CFPB, Part 2: The New Regulator on the Block Strikes (Again) The Undeniable Truth About Corporate Misconduct and Whistleblowers The Importance of HR Compliance When In Doubt – Remediate Your Compliance Program Healthcare Companies Need to Update Compliance Corruption in Mexico The Top 5 Corruption Risks for Pharmaceutical and Medical Device Companies Internal Investigations: How to Write a Report and Who Should Receive It? Predictions on Justice Department's Upcoming FCPA Guidance The CFPB: The New Regulator on the Block Video — The Importance of Whistleblower Procedures Antitrust Compliance: A Fresh Look Update on Corruption in Brazil Sanctions Violations Following the Money: The Importance of Financial Controls The Implications of Private LIBOR Litigation The Dangers of Ignorance: Avoiding an Internal Investigation Latest Tea Leaves from the Justice Department’s FCPA Settlements Twenty Questions for Reviewing Gifts, Meals, Entertainment and Travel Expenses Re-examining Corporate Criminal Prosecutions The Wisdom of Yogi Berra and Compliance Planning Do You Have an Insider Trading Compliance Policy? Join Me and Tom Fox in San Diego and Receive Free Copies of Our Books Subscribe to Corruption Crime & Compliance — E-Mail Delivery to Your Mailbox Update on Data Privacy Colombia: The Land of Opportunity Crisis Management Plans 2012 Antitrust Enforcement – A Big Year FTC and Data Privacy Compliance The LIBOR Scandal Unraveled Social Media Risks and Compliance The SEC Acts – New Rules for Extractive Industries and Conflict Minerals Due Diligence Workshop — Join Me and Tom Fox in San Diego The Key to Compliance: The Trenches Should the Justice Department Prosecute More Individuals? How to Define Compliance Success Catching Up on Compliance Corporate Governance Failures And FCPA Violations Off-Label Marketing: Fines and Industry Exclusion Banks and Operational Risks Tom Fox and I Hit the Road — First Stop San Diego Is Prosecutorial Misconduct On The Rise? World Compliance Tour — Bogota and Mexico City Welcome New Sponsors Compliance Risks: Rational or Stupid Decisions Current Trends in Corporate Governance Sign Up For Webinar: Health Care Fraud Enforcement Trends and Compliance FCPA Violations and Corporate Management Sweeps Export Controls and Sanctions: Stealing the Enforcement Limelight? The Reality of Compliance: The Individual Employee SEC Flexes Its Own Muscle FCPA Enforcement’s Dirty Little Secret Internal Investigations: What Should You Tell Witnesses About Government Contacts? Reforming the Respondeat Superior Doctrine Navigating Corruption Risks in China Giving Gifts Without Fear Global Retailers: The Next Industry Sweep Responding to a Potential False Claims Act Claim Measuring Deterrence: How Big a Fine Will Deter Corporate Crime? Should the Sentencing Guidelines Be Revised to Increase Corporate Compliance? False Claims Act Compliance and Health Care Lessons Learned for the SEC from the False Claims Act and Whistleblowers The Six Most Significant Recent Amendments to the False Claims Act Facilitation Payments: Are They Legal Bribery? Gathering Storm Against “Corporate Corruption” In-House Counsel: The Top 6 Risks (Part II of II) In-House Counsel: A Juggling Act (Part I of II) A “Slow Down” in FCPA Enforcement EthiXbase — A Valuable Resource Compliance Lessons from Cartel Enforcement Building a Positive Relationship with Legal and Compliance Staff Social Media Policies and Enforcement Risks Keeping Anti-Corruption Compliance Simple Best Practices in Developing an Internal Investigation Plan (Part II of II) Best Practices When Launching an Internal Investigation (Part I of II) Free Webinar on Wednesday July 11 — Mid-Year FCPA Update Have The Latest Posts Delivered to Your Mailbox — Subscribe by E-Mail A New Government Criminal Initiative – The Economic Espionage Act Challenges in Ensuring Anti-Corruption Compliance by Distributors Health Care Fraud Enforcement: Current Trends Five Basic Pillars of an Effective Compliance Program AML and FCPA “Due Diligence”: Apples and Oranges? A Test on Transaction Testing OFAC’s Long Arm of the Law Reforming the Maze of Export Control Regulation Money Laundering and Regulatory Enforcement Risks for Non-Banks Imagine a “Mandatory” Disclosure Requirement: It’s Easy if You Try Every Company Needs a Compliance Committee Red Flags Are Not Violations When Should the SEC or the DOJ Investigate an Allegation of Bribery? Sign Up Today for Webinar Tomorrow, June 20, 2012, on Anti-Corruption Compliance for Private Equity and Hedge Funds A Tale of Two Justice Departments: The Buck Stops at the Top GCs and CCOs: A Match Made in Heaven or in Hell? The Lifeblood of Every AML Compliance Program: Suspicious Activity Reports Congress and Corporate Governance Mandates: The Role of Chief Compliance Officers State-Owned Enterprises: What’s All the Hullabaloo? Creating a Culture of Compliance Corporate Culture of Compliance: Internal Communication and Reporting Act 1, Scene 1: FCPA Hits Hollywood Antitrust Enforcement and Compliance Keeps Chugging Along Do Not Forget AML Compliance “Sunshine” on Physician Payments The “Greatest” Risk of All – The False Claims Act Farewell John Edwards — We Know You All Too Well Environmental Crime Risks Global Retailers and Compliance Watch Out for Data Privacy — A Primer on Risks Putting Together a Due Diligence Package The 50th Anniversary of the Viet Nam War Just Say “Nyet (No)”: Corruption Compliance in Russia Should You Hire an Accounting Firm or a Lawyer? (or Both?) Corruption Risks in the Middle East Sanctions Enforcement — An Increasing Risk Nightmare Scenarios for an Internal Investigation Empowering Compliance Officers: The Key to an Effective Compliance Program The Implications of the Laura Stevens Criminal Prosecution A Practical Look at the Compliance Defense Proposals Advice of Counsel: An Effective Shield Carrots and Sticks — DOJ's Self-Reporting Policies Sign Up for Audioconference: Off-Label Marketing Enforcement and Risks for Medical Device Companies and Service Providers Red Flags And Compliance Corporate Boards: Time to Step Up Fortune 100 Companies Need to Double-Check on Compliance Morgan Stanley: Did the Justice Department Rollover? FCPA Reform: Dead is Dead Going Green: Corruption and the Environment Monitoring Your Anti-Corruption Compliance Program Russia and Bribery A Compliance Must Have: A Whistleblower Triage Program “Follow the Money” — Protecting Against Corrupt Payments Yawning in the Face of the UK Bribery Act DOJ Sets Its Criminal FCPA Sights on Officers and Managers FCPA Enforcement: Picking Up Steam The Spring Trial Season: Clemens and Edwards Africa and Anti-Corruption Risks Justice Department Guidance — Some Suggestions Bigger is Not Necessarily Better — A Compliance Truism Increased Focus on Audit Committees Bribery Risks and Charitable Giving Lessons Learned from the Africa Sting Case Navigating the Corruption Risks of Foreign Customs Clearance The Debate Over A Corporate Compliance Defense World Compliance Spring Tour: Join Tom Fox and Mike Volkov in Dallas and San Francisco Corruption Crime & Compliance: The Book Make Life Easier: Subscribe by E-Mail UK Points the Finger at Investment Bank ABC Compliance SEC: The Urban Case and Supervisor Liability Assessing an Initial Corruption Complaint Anti-Corruption and the Auto Industry FCPA Compliance in China: An Oxymoron? Take a Deep Breath: FCPA Criminal Prosecutions Will Continue DOJ and SEC Continue to Target Gatekeepers Watch Out Private Equity Managers – Here Comes the SEC Washington D.C.: An Era of Unprecedented Enforcement FCPA Reform: The Latest Developments New Firm: LeClair Ryan Ten-Step Risk Reduction Program How to Encourage Internal Reporting? FCPA Liability and the Bourke Decision Five Important Steps in Putting Together a Whistleblower Compliance Program The Stevens Case – A Fair Report? Buying an FCPA Violation: Successor Liability is Alive and Well High Tech and Corruption Risks FCPA Guidance: Asking DOJ for the Impossible? The Key to Compliance: Effective Corporate Governance Three Steps to Stay Clean and Avoid False Claim Act Liability FCPA Acquisition Risks Wiretaps — A New Tool for FCPA Enforcement? SEC Whistleblowers and Voluntary Disclosures Empowering Compliance Officers "Ongoing Assessments" and Compliance Due Diligence Nuts and Bolts FCPA Reform and Corporate Leniency Controlling Your Internal Controls Training — A Critical Component of an Anti-Corruption Compliance Program Common Sense and Internal Investigations Anti-Corruption Compliance: One Brick At A Time Third-Party Due Diligence: A Critical Part of Compliance Writing on a Blank Slate — Creating an Anti-Corruption Program The Cost of Non-Compliance Compliance Rules for Compliance Sakes? Corporate Governance Issues in Response to Potential FCPA Violations Focusing on Criminal Intent The Justice Department's Slippery Slope — Enforcement Versus Regulation Mergers & Acquisitions and Anti-Corruption Compliance Medium and Small Company Compliance The Real Risks of FCPA Criminal Prosecutions Tom Fox's Book is Out!! Buy it Now!! Compliance: The Final Frontier? Tips on Interviewing Witnesses The Danger of Congressional Oversight Mark Twain, Dr. No and Problem Solving The Book: Corruption Crime & Compliance: Buy It Now!! To Disclose or Not To Disclose: That is the Question ACC Article: Top Ten Action Steps When the Government Shows Up at Your Door Third Party Agents: What Kind of Due Diligence The Art of Internal Investigations The Relevancy and Reach of the U.S. Sentencing Commission On Vacation — "I'll Be Back" Ensuring Compliance Success Anti-Corruption Compliance Webinar for Private Equity & Hedge Funds on February 7, 2012 Fraud and Bribery: Kissin’ Cousins Prosecution of Foreign Companies and Foreign Individuals Off to the Races in 2012: DOJ’s Fast Start in FCPA Enforcement China: The Corruption Problem Child Too Many Cooks in the Compliance Kitchen Corporate Governance Focus on Risk DOJ’s FCPA Trial Record Are Prosecutors Pushing the Envelope Too Far? Anti-Corruption Risks for Private Equity — Portfolio Companies Drilling Down on Documentation Questioning Corporate Criminal Liability The Justice Department Walks the Tightrope Insider Trading Compliance FCPA Internal Investigations (Part IV of IV): How Far Can the Justice Department Reach? FCPA Internal Investigations: Parent Company Responsibility (Part III of IV) FCPA Internal Investigations — Board Supervision (Part II of IV) FCPA Internal Investigations: Planning and Vision (Part I of IV) Reminder: Subscribe by E-Mail Health Care Fraud and Compliance Politics and Prosecutions FCPA Jurisidiction Over Foreign Entities FCPA Violations and Collateral Litigation Thanks to Rob Levey at Catelas — My Interview on FCPA Predictions for 2012 The FCPA and Wiretaps FCPA Predictions for 20122011 Internal Controls and Foreign Subsidiaries — How to Protect Your Company Focused Risk Assessments Avoiding Stovepipes and Embracing Efficiencies Global Retailers and Corruption Risks "Materiality" and FCPA Disclosures The Top 10 FCPA Events In 2011 The SEC's Important Enforcement Role Sovereign Wealth Funds and the FCPA – Are They Really “Foreign Officials?” The World Bank’s Anti-Corruption Initiatives The Justice Department and FCPA Enforcement — Ending the Year with a Bang The First Step in Any Due Diligence Inquiry Corporate Governance and Compliance — The Disconnect Lawyers, Bribes and Money Asking Too Much from the Justice Department? Simplifying the US Criminal Code The Responsible Corporate Officer Phasing-In Your Company's New Anti-Corruption Compliance Program Punishing the Wrongdoer: Environmental Crimes and the Lack of Criminal Intent Lindsey and the FCPA Jon May Argues for FCPA Reform Losing Patience with Corruption Lindsey Manufacturing, Senator Stevens and Prosecutorial Misconduct The Bribery Act and FCPA Summit in Houston — December 7, 2011 Off-Label Marketing Enforcement: The Government's Focus on Medical Device Manufacturers and the Implications for Healthcare Providers Corruption Risks for Drug and Medical Device Companies Getting Third-Party Agents Under "Control" Corporate Governance: Getting It Right How to Leverage Transparency and Documentation SEC's Enforcement Division Activity Increases DOJ Guidance — What to Expect How to Comply In High-Risk Corruption Countries The End of the Facilitation Payment Exception? Anti-Corruption Compliance — Private Equity Portfolio Companies Failing to Conduct Third-Party Due Diligence Sovereign Wealth Funds and the FCPA Sentencing Disparities on the Rise (Again!) Corruption, Crime & Compliance: The Book is Out! Preparing a Witness for Deposition How to Handle Upjohn Warnings Reporting on FCPA Trade Shows — What is "News"? Compliance Committee Best Practices Private Sector Spurs Compliance The Courts and the FCPA The Perfect Storm for FCPA Enforcement in 2012 Corruption in India The Bribe Payer's Index and Risk Assessments DOJ Cries Uncle: Guidance Coming Corporate Governance for the Future The SEC and Accounting Fraud How to Interview a Witness Three Essential Steps for Compliance Operation Fast and Furious: Let's Focus on the Real Issue Dr. No Versus Problem Solving What Should the Justice Department Do? Enterprise Risk Management and the "KISS" Rule Subscribe by E-Mail China and Russia: Hotbeds of Corruption Is it Ever "Rational" to Ignore Compliance? The Stevens Case and Lessons Learned A Practical Solution to Gifts, Meals, and Entertainment Expenses Subscribe by E-Mail: Corruption, Crime and Compliance November 8, 2011 Webinar: Anti-Corruption Compliance for Private Equity and Hedge Funds Internal Auditors: Detecting Bribery Canada and Foreign Bribery Enforcement Congressional Oversight: The Risks to Businesses Improving Corporate Boards Headaches for Private Equity Funds The Emperor Has No Clothes: Copycat Compliance DOJ's Enforcement of Off-Label Marketing Prohibition Internal Investigations: Best Practices Does it Pay to Bribe? The (Grand)father of the FCPA Will the Haiti Telco Sentences Deter Bribery? Whistleblower Complaint Protocols How to Read Enforcement Tea Leaves Health Care Fraud v. The FCPA Back to Nature's Sunshine Join Us at World Compliance – FCPA Chicago Event 2011 The Key to Avoiding Criminal Liability Under the FCPA The US Model for Deferred and Non-Prosecution Agreements Welcome to Corruption, Crime and Compliance Compliance and the Global Economy Private Equity and Hedge Fund Compliance Webinar November 8, 2011 at 1230 pm Article on FCPA Blog: Where the Ombudsman and the Whistleblower Meet The Gathering Storm: Anti-Corruption Compliance for Private Equity and Hedge Funds On Vacation The Twists and Turns of DOJ's Corporate Charging Policies Leveraging AML Programs Into Anti-Corruption Compliance The Symbiotic Relationship: Criminal Antitrust and FCPA Enforcement Do You Have Internal Whistleblower Procedures and Policies? FCPA 2011 — The Year of the Trial A High Priority: Insider Trading Compliance Coordinating Anti-Corruption Enforcement in China The Link Between Corruption and Human Rights What To Do When the Government Shows Up at Your Company? FCPA Risks and the Middle East Howard Sklar's Convergence: Export Controls and the FCPA The Critical Compliance Gatekeeper — The Internal Auditor Congress and Corruption: Practicing What They Preach? When Does the SEC Act and the Justice Department Decline to Act? Corporate Boards and Risk Management How Far Should AML Laws Go? Do DPAs and NPAs Promote Balanced Justice? DOJ's Expansive View of "Obtain or Retain Business" Russia: The Anti-Bribery Frontier Criminal Antitrust: The Continuing Risk Has the Justice Department Lost Credibility? The News Corp Scandal Predictions News Corp and the FCPA: Focus on the Justice Department The SEC's New Target: Independent Directors Reaping What You Sow Internal Investigations and Special Committees Let's Get Real: Assessing Enforcement Risks AML Compliance and Convergence What Exactly are Accounting Controls? The Tenaris Settlement: No Big Deal Squaring Compliance with the UK Bribery Act and the FCPA Navigating the Minefield of the SEC Whistleblower Program Contracts and Anti-Corruption Compliance False Claims Act Feeding Frenzy Brazil and Corruption Defining Compliance: What is Onoing Assessment? What Are "Adequate Procedures" for Anti-Corruption Compliance? Director’s and Officers Insurance: Does it Cover the UK Bribery Act? Trip(pin) to and from China The FCPA and Joint Venture Liability Caremark, FCPA and Corporate Governance High Tech Means High Risk for Anti-Bribery Enforcement Detecting Corruption: Follow the Money Is the Justice Department Going Soft on White Collar Crime? Curb Your Enthusiasm and Compliance Officers The New Reality of Global Enforcement and Coordination The UK Bribery Act and Private Equity Firms Acquisition Risks in Emerging Economies Fastballs Coming: Clemens Trial to Start This Week Stretching the Limits of the FCPA EU and US Anti-Corruption Enforcement: A Bridge Across the Divide FCPA Enforcement 2011: Fireworks or a Dud? Coming Soon — More Wiretaps for More White Collar Crimes The Need for Corporate Compliance Committees Is the SFO Getting Ready to Flex its Muscles? T-Minus 32 hours and Counting — The UK Bribery Act Becomes Effective A Cold Wind Blows in from Canada: Niko Pleads Guilty to Bribery Managing Risk in These Heady Days of Enforcement A Letter from Sicily The State of Compliance: A Fresh Look Is an "Effective" Compliance Program Enough? Lessons from Foreign Corrupt Practices Act Enforcement Actions and Settlements The Voluntary Disclosure Process and the Lack of Transparency FCPA Trial Tactics — Part 2 An "Adequate Procedures" Defense: Just How Adequate a Defense? SEC Warning: The Danger of Lying and Obstruction of Justice SEC Warning: The Danger of Lying and Obstruction of Justice FCPA Trial Tactics — Part 1 Due Diligence Nuts and Bolts Due Diligence Nuts and Bolts Calming Down Over Due Diligence Congress and the FCPA: Here We Go Again FCPA Enforcement in the Health Care Industry: We Told You So! Do Physician Owned Distribution Companies Violate Federal Law? Kickbacks and Physician Owned Device Companies: Congress Turns Up the Heat Kickbacks and Physician Owned Device Companies: Congress Turns Up the Heat FCPA Compliance in Russia: Watch Out A Shot Across the FCPA Bow: SEC Provides Targeting Clues Anti-Money Laundering Compliance: A Continuing Risk Under the FCPA Microscope in Indonesia Under the FCPA Microscope in Indonesia Under the FCPA Microscope in Indonesia Empowering Compliance Officers Getting Your Internal Controls Under Control Getting Your Internal Controls Under Control Getting Your Internal Controls Under Control Getting Your Internal Controls Under Control China’s New Anti-Corruption Law: Window Dressing or New Era of Enforcement? Why is No One Talking About the UK Bribery Act? Insider Trading Law: What Kind of Compliance Program Do You Need? FCPA Corporate Leniency: A Good Try But the Wrong Idea Voluntary Disclosures and Whistleblowers: A New Dynamic Immunizing Your Third-Party Agent Due Diligence Process from Prosecution HHS’ Power of Exclusion: Guilt by Association The Next Step in FCPA Enforcement – Wiretaps in the Boardroom The Next Step in FCPA Enforcement – Wiretaps in the Boardroom The Next Step in FCPA Enforcement – Wiretaps in the Boardroom The Real Impact of the SEC’s New Whistleblower Program Health Care Reform and Competition Health Care Reform and Competition Giving With One Hand and Taking Away with the Other: The Government and Health Care Reform Giving With One Hand and Taking Away with the Other: The Government and Health Care Reform Three Simple Steps to Keep Clean and Avoid False Claim Act Liability Health Care Fraud and the False Claims Act Healthcare Compliance Programs: The Basics Health Care Fraud and Compliance Health Care Fraud and Compliance The Compliance Gap — A Reality Check The Compliance Gap — A Reality Check Anti-Corruption Training: A Critical Component of a Compliance Program Let the Headaches Begin: SEC Adopts Whistleblower Rules Building Your Anti-Corruption Compliance Program: One Brick At A Time Empowering Compliance Officers Empowering Compliance Officers Starting from Scratch on an Anti-Corruption Compliance Program Defendant Folds Hand in Online Poker Case Defendant Folds Hand in Online Poker Case Uneven Justice: A Critical Look at FCPA Enforcement Uneven Justice: A Critical Look at FCPA Enforcement Uneven Justice: A Critical Look at FCPA Enforcement Federal Judge Rebukes Prosecutors for Criminal Case Against In-House Counsel The Bribery Act: An alternative perspective The Bribery Act: An alternative perspective Corporate Governance in the Aggressive FCPA Enforcement Environment Corporate Governance in the Aggressive FCPA Enforcement Environment The Key to the UK Bribery Act – Prosecutorial Discretion The Key to the UK Bribery Act – Prosecutorial Discretion The Key to the UK Bribery Act – Prosecutorial Discretion The Key to the UK Bribery Act – Prosecutorial Discretion The Key to the UK Bribery Act – Prosecutorial Discretion The Critical Compliance Question: What is the Employee’s Intent? World Compliance FCPA Tour In Washington, D.C. May 12, 2011 World Compliance FCPA Tour In Washington, D.C. May 12, 2011 Targeting The Gate Keepers: Criminal Prosecution of In-House Counsel Targeting The Gate Keepers: Criminal Prosecution of In-House Counsel Compliance Rules for Rules Sakes? Practical Business Solutions for Companies Operating in India Chinese Companies and Accounting Fraud: Lawsuits on the Rise Chinese Companies and Accounting Fraud: Lawsuits on the Rise Cha-Ching: DOJ Goes After Online Poker Looking for Scalps: DOJ Seeks to Punish Bank Executives for Financial Crisis “You Cannot Be Serious!!!!” — John McEnroe China Enacts New Law to Criminalize Bribery of Foreign Officials DOJ Sends a Message to Chief Compliance Officers Compliance: The Final Frontier . . . Or Just the Beginning? Compliance: The Final Frontier . . . Or Just the Beginning? Reality Bites: The New Risky Enforcement Environment More On Online Poker Crackdown Chief Compliance Officers: The Evolving Picture The Cost of Compliance versus the Cost of Non-Compliance The Cost of Compliance versus the Cost of Non-Compliance The Cost of Compliance versus the Cost of Non-Compliance Another Significant Risk — Criminal Antitrust Enforcement Happy Tax Day: Foreign Bank Accounts and Continuing Enforcement Efforts Watch Out Justice Department: Lessons Learned from the Past Watch Out Justice Department: Lessons Learned from the Past Watch Out Justice Department: Lessons Learned from the Past Watch Out Justice Department: Lessons Learned from the Past Taking a Risk: Anti-Corruption Compliance in the Merger and Acquisition World Taking a Risk: Anti-Corruption Compliance in the Merger and Acquisition World Anti-Corruption Compliance for Medium and Small Companies Anti-Corruption Compliance for Medium and Small Companies Anti-Corruption Compliance for Medium and Small Companies Conflict Minerals Reporting Requirement What Are the Risks of Criminal Prosecution for an FCPA Violation? Federal Government Indicts Owners of Major Online Poker Companies and Shuts Down Three Sites Internal Investigations: A Practical Guide For Using Common Sense Environmental Crimes: Criminal Enforcement on the Increase Environmental Crimes: Criminal Enforcement on the Increase U.S. v. GOYAL: STRETCHING THE CRIMINAL LAW BEYOND ITS PROPER BOUNDS U.S. v. GOYAL: STRETCHING THE CRIMINAL LAW BEYOND ITS PROPER BOUNDS Mark Twain, Dr. No and Problem Solving World Bank Blacklists 45 Contractors UK Bribery Act Guidance: No Guidance At All UK Bribery Act Guidance: No Guidance At All World Compliance FCPA Tour — April 20 in Palo Alto Welcome to Day 1 Reading The Tea Leaves: DOJ’s Recent FCPA Enforcement Actions Justice Department Provides More Guidance on FCPA Compliance Justice Department Provides More Guidance on FCPA Compliance The Person of the Year — The Chief Compliance Officer
