2017 • 2016 • 2015 • 2014 • 2013 • 2012 • 20112017 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 Enhancing Anti-Corruption Compliance and Life Sciences Industry American Leaders Conference on FCPA and 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
