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2021

• Episode 207 — Common Pitfalls in Conducting Internal Investigations
• 4 Requirements for a Healthy Relationship Between a CCO and the Corporate Board
• Former Ericsson Employee Indicted for Role in Foreign Bribery Scheme
• The Big “G” in ESG – CCOs Need to Embrace ESG as a Compliance Opportunity
• NewTek, Inc., a Software Provider, Settles OFAC Violations for $189,483
• A Compliance Crisis at NFT Marketplace OpenSea – Transparency on the Blockchain
• The Fraud Hammer: DOJ and SEC Prosecute CEO of Silicon Valley Start Up
• The Myth of Corporate Resources and Efficiency
• Cryptocurrency and the Unbanked: How the Blockchain Can Benefit the Impoverished
• Culture and a Company’s Most Valuable Intangible Asset – its Reputation
• The Absent CEO – Who’s Minding the Store?
• Kraft Foods Agrees to Pay $62 Million for Misstatements in Financial Report
• Event: Overall FCPA Status and Trends in the Biden Administration
• Episode 206 — Update on Sanctions Compliance and Enforcement
• First Bank of Romania Settles OFAC Violations for $862,318 (Part IV of IV)
• United States and Global Community Adopt Broad Sanctions Targeting Belarus (Part III of IV)
• OFAC Settles with Bank of China for $2.3 Million for Violation of Now-Repealed Sudan Sanctions Program (Part II of IV)
• Trade Compliance Dominates Enforcement Landscape (Part I of IV)
• Episode 205 — How to Audit a Compliance Program
• Joseph R. Biden, Jr. —The Anti-Corruption President?
• White Collar Enforcement: Here We Go Again
• A Kinship with Sisyphus: Challenging an OFAC SDN Designation
• The Critical Relationship — Compliance and Business
• Insights from Recent NAVEX Global and KPMG Surveys
• The Challenge of Technology and Data
• Pipeline Company Pays $35 Million to Settle Criminal and Civil Environmental Violations for Inland Spill of Oil Drilling Generated Water
• The Dangers of a Fractured C-Suite
• 5 Common Internal Investigation Pitfalls
• Episode 204 — “This is the Way” on Corporate Culture
• SEC Approves Nasdaq Board Diversity Proposal
• Remediating the Organization’s Culture (Part IV of IV)
• Measuring and Reporting on the Organization’s Culture (Part III of IV)
• Communicating and Embedding the Organization’s Culture (Part II of IV)
• Practical Approaches to Managing Culture: Defining the Organization’s Mission (Part I of IV)
• Episode 203 — Interview of David Greenberg on LRN’s Report on Corporate Boards and Compliance Program Engagement
• ITAR Brokering Activities Demystified
• DOJ Takes Stock of Criminal Cartel Prosecution Program
• Internal Investigation Trap – When Does “Oversight” Turn into Control
• Two-Part Webinar: A Deep Dive into the Foreign Corrupt Practices Act
• The CEO Sets, Defines and Manages a Company’s Performance and Culture
• Episode 202 — A Deep Dive into the Alfa Laval OFAC Enforcement Action
• DOJ’s Criminal Cartel Prosecution of Chicken Industry Expands Net — Koch Foods and Four Pilgrim’s Pride Executives Charged
• A Basic Question — Where is the CCO’s Office?
• Unraveling Trade Compliance Issues Involving China’s Human Rights Abuses in Xinjiang
• When a CCO Fails to Speak Up
• Alfa Laval pays over $432K for Violations of OFAC’s Iran Sanctions Program
• Company Kool-Aid, Misconduct and a Misfiring Corporate Culture
• Why Do Companies Resist Change?
• Fixating on the Inextricable Link: Culture and Misconduct
• Looking Under the Hood – When Employees Engage in Wrongdoing?
• Payoneer Pays $1.4 Million to Resolve OFAC Sanctions Violations
• Watching a Slow Train Wreck – Culture Breakdowns Step-by-Step
• The Danger of an Out-of-Touch C-Suite
• Avanos Medical Pays $22 Million to Settle Criminal Mislabeling Charges for Surgical Gowns
• DOJ’s Antitrust Division Charges Seris Security and Three Executives, and Announces Plea Agreement with G4S Secure Solutions in Bid-Rigging Conspiracy Involving Overseas Security Services
• DOJ Antitrust’s Ongoing Criminal Investigation of Labor Market Collusion in Health Care Industry Nets DaVita and Former CEO
• False Claims Investigations and Criminal Prosecutions: Recent Examples of Criminal Charges – a Lab Owner, A Physician and a Nurse Practitioner (Part V of V)
• Akron Ohio Health System Agrees to Pay Over $21 Million to Settle False Claims Act Violations for Improper Payments to Referring Physicians (Part IV of V)
• St. Jude Agrees to Pay $27 Million to Settle False Claims Act Charges for Selling Defective Heart Devices (Part III of V)
• Alere Agrees to Pay $38.75 Million to Settle False Claims Act Violations (Part II of V)
• Justice Department, HHS-OIG and Defense Investigators Bring Flurry of False Claims Act Cases (Part I of V)
• Episode 201 — DOJ Brings Flurry of False Claims Act Cases
• New Sponsor: Clausematch
• EU Whistleblower Directive: A Primer (Part IV of IV) – Protections, Prohibitions and Penalties
• EU Whistleblower Directive: A Primer (Part III of IV) – Data Privacy and Recordkeeping
• Episode 200 — The Foster Wheeler FCPA Enforcement Action
• Happy 4th of July
• EU Whistleblower Directive: A Primer (Part II of IV) – Internal and External Reporting
• EU Whistleblower Directive: A Primer (Part I of IV) – An Overview
• Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III)
• Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III)
• DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over $18 Million to Settle Bribery Charges in Brazil (Part I of III)
• Supreme Court Narrows Computer Fraud Law
• The Justice Department Strikes Back and Recovers Ransom Paid by Colonial Pipeline
• Compliance Opportunities in and after the Time of COVID-19: A Fascinating Article by Stephen Naughton
• Listen to the Replay of the Recent Clausematch Webinar: Policy Management, Governance and Leveraging Your Culture of Compliance
• Episode 199 — Jonathan Marks, Baker Tilly, and Michael Volkov Review the SEC’s Under Armour Case, Accounting Fraud, and Revenue Recognition Issues
• First American Financial Corporation Settles SEC Case for $487,616 for Cybersecurity Data Breach and Disclosure Failures
• Contech Engineered Pleads Guilty and Agrees to Pay $8.5 Million for Bid-Rigging and Fraud
• Corruption Crime & Compliance: Subscribe to Blog and Podcast
• 1 MDB Corruption Scandal Ripples with Superseding Indictment of Jho Low and Former Rapper “Pras’ Michael for Back-Channel Attempt to Close 1MDB Prosecution
• Should CCOs Take Responsibility for the “New” ESG Function?
• Episode 198 — The Biden Administration Announces Anti-Corruption Battle as a National Security Interest
• LRN’s 2021 Ethics and Compliance Report — the Impact of COVID-19
• NAVEX Global Incident Management Study Confirms Impact of COVID-19 on Employee Reporting
• Cyber Incidents Underscore Absence of Real Private Sector Cybersecurity Standards
• The SEC’s Push on ESG Disclosure Regulations
• DOJ Indicts Two Former Diplomats from Chad for Taking a $2 Million Bribe
• Episode 197 — Review of LRN and NAVEX Global Compliance Surveys and Reports
• Julius Baer Bank Resolves Money Laundering Charges in FIFA Scandal and Pays Nearly $80 Million
• DOJ Charges Two Austrian Bankers with Money Laundering as Part of Massive Odebrecht Bribery Scheme
• The EU Speaking Up Regime – Plenty of Process and Protection but no Bounties
• Episode 196 — Managing Cybersecurity Risks
• Memorial Day: A Day of Honor
• Finding the Right Balance: Sales Incentives and Internal Controls
• Justice Department’s Antitrust Division Indicts Claxton Poultry Farms in Expanding Criminal Prosecution of Chicken Producing Industry
• ECI Conducts Important Compliance Survey: E&C Leaders — Voice Your Views!
• Volkov Law Group Secures False Claims Act Settlement of $5.6 Million Against Tungsten Heavy Powder of San Diego to Settle False Claims Act Case
• Cybersecurity Oversight: A Board Challenge
• Episode 195 — Antitrust Compliance Programs
• Judge Lamberth Sanctions Paul Weiss and Former Partner Alex Oh
• Webinar: Policy Management, Governance and Leveraging Your Culture of Compliance
• Under Armour Agrees to Pay $9 Million to Settle SEC Charges it Mislead Investors About Revenue Growth
• Swiss Life and Three Subsidiaries Agree to Pay Justice Department More Than $77 Million for Conspiracy with U.S. Taxpayers to Hide Assets and Income
• Episode 194 — Anti-Corruption Enforcement and Compliance Trends in the Pharmaceutical and Medical Device Industries
• MoneyGram Payment Systems Agrees to Pay OFAC $34k for Sanctions Violations
• The Transformative Role of “National AML Priorities” for Compliance in the AML Act of 2020
• EU Mandatory ESG Due Diligence
• Episode 193: Proactive Compliance — Monitoring, Testing and Audits
• The Headline from the SAP Settlement: It’s a New Dawn for Export and Sanctions Compliance (Part IV of IV)
• SAP’s Comprehensive Export Control and Sanctions Settlement – A New Compliance Frontier for Cloud-Based Services (Part III of IV)
• SAP’s Export Control and Sanctions Failures Results in Numerous Violations of Iran Sanctions Program (Part II of IV)
• SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)
• Episode 192 — The DOJ-SAP Settlement: A New Compliance Frontier
• SEC Risk Alert on ESG Investing
• ESG Automation: Picking the Right Solution
• Compliance Understanding of Business Processes
• Alliance Steel Settles with OFAC for $435,003 for Violations of the Iran Sanctions Program
• Whistleblower Protections under the Anti-Money Laundering Act of 2020
• Episode 191 — Interview of Chad Main, Founder of Percipient, a Leading Legal and Compliance Technology Firm
• Auditors, Lawyers and the Lack of “Independence” — Bias and Financial Incentives
• Burma Sanctions and Export Licensing Prohibitions Implemented in Response to Military Coup
• Blue Umbrella Webinar: Anti-Corruption Risks and Compliance Trends in the Pharmaceutical, Medical Device and Life Science Industries
• Biden Administration Ratchets Up Russia Sanctions
• China’s Digital Yuan: What to Know About the First Major Central Bank Digital Currency
• Episode 190 — Catching Up on Russia and Burma Sanctions Programs
• Where There is No Will, There’s No Way: The Bottom Line for Chief Compliance Officers
• Before Moving on to ESG, Fix Your Speak Up Culture!!
• Gunvor Group Former Employee Pleads Guilty to FCPA Scheme to Pay Bribes to Ecuadoran Government Officials
• Volkov Law Announcements: Matt Stankiewicz is Promoted to Partner, and Ameer Gopalani, Senior Counsel, Joins the Firm
• Environmental Crime Enforcement: Button Up for an Increase in Criminal Investigations and Compliance Demands
• Episode 189 — A Review of the ESG Movement
• Spring Cleaning: Time to Review Your Internal Controls
• Biden Administration Ramping Up Anti-Corruption Effort
• Antitrust Division Charges Health Care Staffing Company with Criminal Wage-Fixing and No-Poaching Agreement
• Episode 188 — 2021 First Quarter Review of OFAC Sanctions Enforcement
• Integrating ESG into Your Business
• Meeting the ESG Challenge
• In-House Counsel and Risk Management
• Nordgas Settles with OFAC As Part of UniControls Violations of Iran Sanctions Program
• Episode 187 — Review of DOJ’s Settlement with Boeing for the 737 MAX Safety Scandal
• Danger! Danger!: Retaliation Against Employees is Increasing (Part II of II)
• ECI’s Global Business Ethics Survey: The Plusses and Minuses (Part I of II)
• The Demand for Sustainability and Risk Management
• Building the Bridge(s) Between Compliance and Business
• Episode 186 — Interview of Pat Harned, CEO of Ethics and Compliance Initiative, the 2021 Global Business Ethics Survey
• UniControl Agrees to Pay $216,464 to Settle Case for Violations of OFAC’s Iran Sanctions Program
• CCOs and Expertise in Risk Management
• CFTC Opens Inquiry into Binance, One of the World’s Largest Cryptocurrency Exchanges
• The New York Attorney General’s Office Reaches Settlement with Bitfinex and Tether
• Webcast: The Future of Compliance and Policy Management
• Episode 185 – Anti-Boycott Compliance: Interview of Alex Cotoia from the Volkov Law Group
• Webinar: Leverage Due Diligence to Improve Enterprise-Wide Risk Management
• Biden Administration Executive Order Mandates 100-Day Review of U.S. Supply Chains
• The Coming AML Enforcement Storm
• The SolarWinds Cyber-Attack – The Devastation and Wreckage
• The Recurring Business Question — Increase Profits Versus Compliance with the Law?
• Episode 184 — The State of the Chief Compliance Officer
• Webinar: Proactive Compliance, Monitoring, and Testing Strategies
• Bioventus Agrees to Pay $3.6 Million to Settle False Claims Act Violations
• When Federal Prosecutors Break Bad – Federal Judge Orders Investigation of Prosecutors’ Misconduct in Criminal Sanctions Case
• Pilgrim’s Pride Pleads Guilty to Price-Fixing and Bid-Rigging Conspiracy and Agrees to Pay $107 Million Fine
• Corporate Board Liability Risks Increase as Delaware Courts’ Reject Caremark Dismissal Claims
• Episode 183 — Review of DOJ’s Settlement with Deutsche Bank for FCPA and Spoofing Fraud Violations
• BitPay Agrees to Pay $507,375 to Settle OFAC Sanctions Violations
• Export Regulation 101—A Primer on U.S. Antiboycott Laws
• Avnet Asia Settles Export Control Violations for Illegal Sales to China and Iran
• Episode 182 — Antitrust Division Brings First Criminal Indictments for No-Poach and Wage-Fixing Agreements
• Volkov Law Group Announces New Ethics and Compliance Small Group Working Sessions
• DOJ and OFAC Settle with Indonesian Company for $2.5 Million for Violations of the North Korea Sanctions Program
• Ripple and SEC Joint Letter Indicates Sides Far Apart in Settlement Talks
• OFAC Starts New Year with Enforcement Action against French Bank for Violations of Syrian Sanctions Program
• The Rise of ESG In Response to Investor Demand
• The Urgency of Ethics and Compliance – The Biden Administration and Enforcement
• Episode 181 — Cryptocurrency Review: Matt Stankiewicz Discusses the SEC’s Case against Ripple, Predictions under the Biden Administration, and Bitcoin’s Corporate Surge
• Tom Fox Releases The Compliance Handbook 2nd Edition
• Corruption and Coronavirus – A Toxic Combination
• CCOs Have a Target on Their Backs: The Coming Storm (Part III of III)
• Troubling Trends: The CCO’s Authority, Independence and Access to Resources (Part II of III)
• The State of the Chief Compliance Officer: Looking Back and to the Future (Part I of III)
• Webinar — The Anti-Money Laundering Act: Enforcement and Compliance Implications
• Episode 180 — 2020 False Claims Act Review with Jessica Sanderson, Partner, The Volkov Law Group
• Alexander Cotoia Joins The Volkov Law Group as a Regulatory Manager and Compliance Consultant
• Boeing’s 737 MAX Scandal: A Fair Resolution? (Part III of III)
• Boeing’s 737 MAX Scandal: A Review of Boeing’s Deception of the FAA (Part II of III)
• Ripple Responds to the SEC’s Enforcement Action
• DOJ and Boeing Settle 737 Max Fraud and Safety Charges for $2.5 Billion (Part I of III)
• False Claims Act 2020 Year in Review: The FCA “Has Never Been More Important Than it is Right Now”
• Episode 179: Tom Fox and Mike Volkov Discuss the Biden Justice Department and Enforcement Issues
• New Jersey Businessman Pleads Guilty to FCPA Violation
• FinCEN Settles with Capital One for $390 Million for AML Violations
• Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)
• Deutsche Bank Agrees to Pay $130 Million to Resolve FCPA and Fraud Cases (Part I of II)
• DOJ Files Civil Complaint Against Walmart for Illegal Opioid Distribution
• Episode 178 — The Corporate Transparency Act: Interview of Scott Greytak, Transparency International, and Erica Hanichak, The Fact Coalition
• Sabre Travel Services Settles Data Breach Charges with State Attorneys General for $2.4 Million
• OFAC 2020 Review: Enforcement Themes and Common Violations (Part II of II)
• 2020 OFAC Sanctions Enforcement Year in Review (Part I of II)
• 2020: What a Year! The Important Keys to Rebuilding a Positive Corporate Culture
• The Curious Absence of Corporate Monitors
• Episode 177 — 2020 OFAC Enforcement Year in Review
• Attention U.S. Exporters to Hong Kong: Have you Reviewed Your Export Licenses and Trade Compliance Program to Account for Recent Changes?
• New Criminal Antitrust Whistleblower Law Enacted
• SEC Launches Enforcement Action Against Cryptocurrency Company Ripple
• The “Person” of the Year: Goldman Sachs
• DOJ’s Antitrust Division Launches Two Criminal Prosecutions of Illegal No-Poach and Wage-Fixing Agreements
• 2020: A Year of Ethical Challenges
• Episode 176 — 2020 FCPA Enforcement and Compliance Trends
• OFAC Ends 2020 with Two Enforcement Actions
• 2021 FCPA Predictions (Part IV of IV)
• 2020 Year in Review: Interesting Enforcement Actions (Part III of IV)
• Rescheduled Webinar: 2020 FCPA Enforcement and Compliance Review
• 2020 Year in Review: DOJ and SEC Compliance Guidance (Part II of IV)
• 2020 FCPA Review: Another Record Year for Enforcement (Part I of IV)

2020

• Happy Holidays!
• Episode 175 — A Deep Dive into the Vitol FCPA Settlement
• Episode 174: Five Basic Steps to Implement a Sanctions Compliance Program
• BitMEX Trading Exchange Earns Criminal and Civil Prosecution for AML Violations
• New Year Webinars: 2020 FCPA and OFAC Enforcement and Compliance Reviews
• California Mandates Increased Diversity on Corporate Boards
• The Danger of Internal Controls Enforcement: The Andeavor SEC Settlement
• FTC and 48 States File Antitrust Case Against Facebook
• Episode 173 — Review of HHS-OIG Fraud Alert on Speaker Programs
• Maintaining Perspective: Enterprise and Compliance Risk Management
• Vitol FCPA Settlement: Lessons Learned (Part III of III)
• Vitol’s Bribery Schemes in Brazil, Ecuador and Mexico (Part II of III)
• Vitol Pays $163.7 Million to Settle FCPA Case (Part I of III)
• Episode 172 — Interview of Brian Whisler, Baker McKenzie Partner, on Department of Justice Changes under the Biden Administration
• OCC Fines JP Morgan Chase $250 Million for Deficient Internal Controls
• Gatekeeper Misfires and Corporate Governance Failures
• Five Basic Steps to Implement a Sanctions Compliance Program
• Webinar: Monitoring Your Third Parties — Digging into Distributor and Agent Risks
• HHS-OIG Warns Drug and Device Companies on Speaker Program Fraud
• Citigroup Fined $400 Million by Banking Regulators for Risk and Compliance Control Deficiencies
• Episode 171 — Promoting an Ethical Culture: Interview of Jeffrey Tilton
• Happy Thanksgiving!
• Too Big to be Accountable: The Big Case Dilemma
• OFAC Screening and Internal Controls
• Episode 170 — The Beam Suntory FCPA Settlement
• Analysis of DOJ’s Antitrust Case Against Google (Part III of III)
• Webinar: Antitrust Enforcement and Compliance Trends
• DOJ’s Monopolization Claims Against Google (Part II of III)
• Justice Department Files Antitrust Case Against Google Claiming Monopolization of the Search and Search Advertising Markets (Part I of III)
• FinCEN Issues Human Trafficking Advisory (Part II of II)
• The Scourge of Human Trafficking and Financial Red Flags (Part I of II)
• Episode 169 — DOJ Files Antitrust Case Against Google
• The Herbalife FCPA Settlement: Board Oversight and Internal Audit Failures
• Veterans Day: Service and Sacrifice
• Goldman Sachs and the Economic Impact of Corruption
• Beam Suntory Bribery Scheme: Another Controls Failure (Part II of II)
• Webinar: The Nuts and Bolts of OFAC Sanctions Compliance
• DOJ Hits Beam Suntory with FCPA Settlement for $19.5 Million (Part I of II)
• Episode 168 — Review of Merit Medical False Claims Act Settlement
• The Long Path to a Whistleblower Recovery: Former CCO Vindicated by Merit Medical Systems False Claims Act Settlement (Part II of II)
• Merit Medical Systems Settles False Claims Act Case for $18 Million (Part I of II)
• DOJ Cryptocurrency Guidance Outlines Enforcement Partnerships (Part II of II)
• DOJ Releases Cryptocurrency Guidance and Enforcement Framework (Part I of II)
• Webinar: The Importance of an Ethical Culture
• Commerce Department Restricts Licensing for Exports of National Security Items to China, Venezuela and Russia
• Episode 167 — A Review of the J&F Investimentos FCPA Settlement
• The Fundamental Gap in Data Privacy Enforcement
• Stephen Naughton Joins the Volkov Law Group as Senior Counsel
• Berkshire Hathaway Agrees to Pay $4.1 Million for Iran Sanctions Violations
• Lessons Learned from the Goldman Sachs FCPA Enforcement Settlement (Part III of III)
• Goldman Sachs’ Lucrative and Wide-Ranging Corrupt Scheme (Part II of III)
• Goldman Sachs Settles Massive 1MDB Bribery Case and Agrees to Pay Nearly $3 Billion (Part I of III)
• Episode 166 — The Goldman Sachs FCPA Settlement for Nearly $3 Billion
• Elizabeth Slim, Senior Consultant from The Volkov Law Group, Interviewed on Captivated Audience, a Financial Crime Podcast
• J&F Investimentos Subsidiary, Pilgrim’s Pride, Agrees to $110 its Million Penalty for Antitrust Cartel in Chicken Processing Industry (Part V of V)
• J&F Investimentos FCPA Settlement: Lessons Learned (Part IV of V)
• Commerce Department Offers Six-Month Extension for Export Licenses
• SEC FCPA Settlement: J&F Investimentos Bribery Scheme (Part III of V)
• DOJ FCPA Settlement: J&F Investimentos’ Bribery Schemes (Part II of V)
• J&F Investimentos Pleads Guilty to FCPA Bribery Conspiracy and Settles SEC Case for Total of $283 Million (Part I of V)
• Episode 165 — Boeing Continues to Struggle from 737 MAX Safety Scandal
• Corruption Crime & Compliance: Subscribe to Blog and Podcast
• DOJ Indicts Former CEO of Cancer Treatment Company for Conspiracy
• Letting Third Parties Do the Dirty Work
• DOJ Adds Six New Defendants to Price-Fixing Boiler Chicken Conspiracy
• RNC Deputy Finance Chair Elliott Broidy to Plead Guilty to Foreign Agent Registration Act Conspiracy
• Episode 164 — Catching Up on Recent OFAC Enforcement Actions
• Welcome to New Sponsor: Blue Umbrella
• SEC Amends Whistleblower Rules
• OFAC Settles with Generali Global Assistance, Inc. for $5.8 Million for Violations of Cuban Sanctions
• DOJ, CFTC and SEC Settle Spoofing Fraud Charges with JP Morgan for $920 Million
• Ask Your Board and Your C-Suite – “How Do You Know We Have an Ethical Culture?”
• Episode 163 — Review of Recent FCPA Cases Involving Petroecuador
• Register Today for NAVEX NEXT Virtual Conference October 22, 2020
• Boeing’s Culture of Neglect and Disregard of Safety: The House Transportation Committee Report Findings (Part II of II)
• Boeing 737 MAX Accountability: Shareholder Litigation Against Boeing Board & House Transportation Committee Issues Scathing Report (Part I of II)
• Keysight Technologies Settles with OFAC for $473,157 for Violations of Iran Sanctions Program
• Sargeant Marine Pleads Guilty to FCPA Charges and Agrees to Pay $16.6 Million
• Webinar: 2020 FCPA Enforcement and Compliance Review
• Justice Department Indicts Vitol Oil Trader in International Bribery and Money Laundering Conspiracy for Corrupt Payments to Ecuadoran Officials
• Episode 162 — Jessica Sanderson on How to Conduct a Remote Third Party Audit
• The Importance of a Separate Board Compliance Committee
• Remote Compliance Learning on Volkov Law TV
• Tom Fox Podcast Featuring John Fons, Former Head of Compliance at Modine, on CCO Challenges
• Comtech Telecomm Settles OFAC Violations for $894,111
• Daimler AG and Mercedes Benz Settle with US for $1.5 Billion for Emissions Cheating
• Episode 161 — The European Union Whistleblower Directive
• Michael Volkov’s Guest Appearance on Technically Legal Podcast
• DOJ and CFTC Settle Spoofing Case with Scotiabank for $127.4 Million
• Deutsche Bank Settles Two OFAC Cases Totaling $583K for Violations of Ukraine-Russia Sanctions
• The Importance of the Internal Audit and Compliance Partnership
• Episode 160 — A Deep Dive into the Herbalife FCPA Settlement
• Webinar: Speak Up – How to Foster a Culture of Compliance
• Herbalife FCPA Settlement is An Important Reminder: Global Companies Need to Focus on Foreign Government Touchpoints
• DOJ’s Antitrust Division Targets Commercial Flooring Industry for Criminal Cartel Activity
• DOJ’s Focus on Criminal Antitrust Enforcement and Government Procurement
• Happy Labor Day!
• Episode 159 — The Steve Bannon “We Build The Wall” Fraud Scheme
• OFAC Settles Enforcement Action with Individual for $5000
• Herbalife’s FCPA Settlement: Lessons Learned (Part III of III)
• Herbalife’s China Bribery Scheme (Part II of III)
• Herbalife Settles FCPA Charges and Agrees to Pay $123 Million (Part I of III)
• Teva Pharma Charged with Antitrust Conspiracy in Generic Pharmaceuticals Industry
• Episode 158 — Improving Corporate Board Governance
• Tom Fox’s 500th Podcast Episode Celebration
• DOJ Secures Guilty Plea and Charges A Second Former PDVSA Official with Money Laundering
• Three Individuals Charged with Fraud and FCPA Violations in International Adoption Scheme
• FCPA Issues First Opinion Release in Six Years
• The IIA’s New Three Lines of Defense Model Misses The Mark
• Steve Bannon and Three Defendants Indicted for $25 Million “We Build The Wall” Fraud Scheme
• Webinar: FCPA Compliance — Acquisitions, Integration & FCPA Audits
• Episode 157 — A Review of World Acceptance Corp. Settlement with SEC for FCPA Violations
• Ten Essential Steps to Take Now to Advance Corporate Board Governance (IV of IV)
• Challenges for Board Decision-Making (Part III of IV)
• Corporate Board Diversity: A Slow Train Moving (Part II of IV)
• The State of Corporate Board Performance and Accountability (Part I of IV)
• Episode 156 — OFAC Sanctions Enforcement and Screening Errors
• Companies and Change: A CCO Challenge
• The EU Whistleblowing Protection Directive: Implementing Practical Solutions to Comply (Part II of II)
• Leveraging the EU Whistleblower Directive to Improve Employee Reporting (Part I of II)
• World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million
• The Demand for Organizational Justice
• Webinar Reminder: Effective Management of Employee Reporting Systems
• Episode 155 — Tom Fox and Mike Volkov Discuss Governance Lessons from Blue Bell Creameries Listeria Outbreak
• Valeant Pharmaceuticals (Now Bausch Health) and Three Former Executives Settle SEC Cases
• Apple and Amazon Fall to OFAC Enforcement for “Screening Errors” (Part III of III)
• OFAC Enforcement Cases Focused on “Screening Errors”: American Express and Cobham Metalics (Part II of III)
• OFAC Enforcement and “Screening Errors” (Part I of III)
• ComplianceLine & The Volkov Law Group Webinar: Effective Management of Employee Reporting Systems
• OFAC On A Roll: Whitford Worldwide Company Agrees to Pay $824k for Violations of Iran Sanctions
• Episode 154 — Artificial Intelligence, Data Risk Management: Interview of Christian Focacci from Steele Compliance Solutions
• Oklahoma City Hospital, Management Company, And Physician Group To Pay $72.3 Million To Settle Federal And State False Claims Act
• Indivior Solutions Pleads Guilty to False Statements and Agrees to Pay $600 Million to Resolve Criminal and Civil investigations for Marketing of Opioid Addiction Treatment Drug Suboxone
• DOJ Criminal Generic Pharma Price-Fixing Investigation Gathers Steam: Taro Pharmaceuticals Agrees to Pay DOJ Total of $419 Million
• DOJ and OFAC Settle with UAE Company for $665,112 for Violations of North Korea Sanctions
• Episode 153 — Mighty Amazon Falls to the OFAC Sword
• Universal Health Agrees to Pay $122 Million for False Claims Act Violations
• The Mighty Amazon Falls to the OFAC Sanctions Sword
• Steele Announces New “Risk Intelligence Data” Platform
• While Navigating Middle Ground, Supreme Court Upholds Congressional Subpoena for President Trump’s Financial Records (Part II of II)
• Episode 152 — Supreme Court Issues Two Important Decisions on Subpoenas for President Trump’s Financial Records
• In Decisive Ruling, Supreme Court Rejects Trump Administration Challenges to State Criminal Grand Jury Subpoena (Part I of II)
• Episode 151 — Tom Fox and Michael Volkov Discuss the Revised FCPA Guidance
• Webinar: 2020 Mid-Year OFAC Sanctions and Compliance Review
• DOJ Charges Two Sons of Former Panama President Martinelli with Participation in Odebrecht Bribery Scheme in Panama
• Revised FCPA Guidance: Effective Compliance Program and Internal Controls (Part V of V)
• The Volkov Law Group Announces Promotions of Jessica Sanderson, Matt Stankiewicz and Noah Smith
• Webinar: Jessica Sanderson and Jonathan Marks — Best Practices for Conducting Remote Internal Investigations
• Revised FCPA Guidance: Legal Issues and Clarifications (Part IV of V)
• Revised FCPA Guidance: Updated DOJ Policies (Part III of V)
• Revised FCPA Guidance: New Case Updates (Part II of V)
• DOJ and SEC Issue Revised FCPA Guidance (Part I of V)
• Episode 150: Review of Novartis False Claims Act and Anti-Kickback Settlements for $729 Million
• Alexion FCPA Violations: Lessons Learned (Part II of II)
• Alexion Pays SEC $21 Million for FCPA Violations (Part I of II)
• Webinar: Catching Up with DOJ Compliance Program Guidance
• Supreme Court Restricts Disgorgement Remedy
• Novartis Settles False Claims Act Cases and Pays $729 Million for Domestic Bribery Schemes
• Episode 149 — A Deep Dive into the Alexion’s SEC Settlement for $21 Million for FCPA Violations
• Happy 4th of July!
• Corporate Culture: Health and Safety (Part II of II)
• Corporate Culture: Leadership (Part I of II)
• Novartis and Alcon FCPA Enforcement Action: Lessons Learned (Part III of III)
• Novartis and Alcon: A Review of Bribery and Accounting Violations (Part II of III)
• Novartis and Alcon Settle FCPA Violations for $345 Million (Part I of III)
• Episode 148 — A Review of the Novartis & Alcon FCPA Enforcement Action
• Building a Robust Post-Acquisition Integration Process (Part II of II)
• DOJ’s Revised Compliance Guidance: The Refocus of Mergers and Acquisitions Risks and Mitigation (Part I of II)
• Bumble Bee CEO Sentenced to 40 Months in Prison for Price-Fixing
• Insider Trading by Members of Congress: An Enforcement Nightmare?
• Episode 147 — DOJ’s Revised Compliance Guidance and Refocus of Merger and Acquisitions Risks
• Antitrust Compliance Lessons Learned from Chicken Price-Fixing investigation and Indictment (Part III of III)
• The Criminal Chicken Price-Fixing Conspiracy (Part II of III)
• Justice Department’s Antitrust Division Charges Four Executives in Chicken Price-Fixing Investigation (Part I of III)
• Treasury, State Department and Coast Guard Issue Advisory and Guidance on Maritime Industry Deceptive Shipping Practices
• Episode 146 — A Deep Dive into DOJ’s Indictment of Four Executives for Chicken Industry Price-Fixing Conspiracy
• The Fish Rots from its Head Down – Review of Criminal Charges Against Blue Bell’s Former CEO Paul Kruse
• DOJ’s Compliance Message: Implement Technology Solutions
• DOJ Plays Catch Up in Revised Compliance Program Guidance
• The Five Most Important Issues in DOJ’s Revised Compliance Program Guidance
• Episode 145 — DOJ Revises its Corporate Compliance Program Guidance
• DOJ Revisions to Corporate Compliance Guidance: Training, Third-Party Risk Management, Mergers/Acquisitions and Data (Part II of II)
• DOJ Revises its Corporate Compliance Guidance (Part I of II)
• Drug and Medical Device Fraud Risks Increase in Pandemic Era
• Episode 144: A Review of Criminal Charges Against Paul Kruse, the Former CEO of Blue Bell Ice Cream
• A Window into Boeing’s Defective Culture (Part III of III)
• Boeing and the 737 Max Scandal (Part II of III)
• The Boeing Scandal and the Demise of a Corporate Culture (Part I of III)
• Insights from the 2020 NAVEX Global Hotline and Incident Management Report
• Episode 143 — The Boeing Safety Scandal and the Demise of Boeing’s Corporate Culture
• Beneficial Ownership: Identification and Mitigation (Part IV of IV)
• Practical Risk-Based Ranking Strategies to Beneficial Ownership Issues (Part III of IV)
• Unraveling Beneficial Ownership Risks (Part II of IV)
• Addressing Beneficial Ownership Requirements in Your Compliance Program (Part I of IV)
• Episode 142: Covid-19: The New Risk and Compliance Framework
• In a Unanimous Decision, the Supreme Court Reverses New Jersey Bridgegate Convictions
• Cancer Treatment Center Agrees to DPA and $100 Million Penalty for Criminal Antitrust Violations in Florida Market
• Despite Pandemic, OFAC Settles with Animal Nutrition Company for $257k for Violations of Cuban Sanctions Program
• Episode 141 — Practical Approaches to Managing Beneficial Ownership Risks (Part II of II)
• Episode 140 — Addressing Beneficial Ownership Interest Risks in Your Compliance Program (Part I of II)
• Privacy and Employee Issues During the New COVID-19 Pandemic Era
• Chipotle Mexican Grill Enters Three-Year DPA and Pays $25 Million Penalty for Food Safety Violations (Part II of II)
• DOJ Resolves Two Important Food Safety Criminal Cases: Blue Bell Creameries and Chipotle Mexican Grill (Part I of II)
• DOJ and FBI Fight Back Against Pandemic Fraud
• Episode 139 — DOJ Resolves Two Food Safety Criminal Cases: Blue Bell Creameries and Chipotle Mexican Grills
• Ensuring Employee Reporting in the New COVID-19 Pandemic Era
• The Importance of the Human Resources and Compliance Partnership in the New COVID-19 Pandemic Era
• The Risk of “Price Gouging” in the New COVID-19 Pandemic Marketplace
• Webinar: COVID-19 — The New Compliance and Risk Framework
• Health and Safety in the New COVID-19 Pandemic Era
• Episode 138: Employee Relations and Engagement in the New COVID-19 Pandemic Era
• OFAC Releases Guidance on Sanctions Compliance During the Pandemic
• ENI Pays SEC $24.5 for FCPA Violations
• SEC Charges Ex-Goldman Investment Banker for FCPA Bribes in Ghana Power Project
• The CARES Act and DOJ Prosecution of Fraud
• Why a Duck: Tom Fox and Michael Volkov Discuss COVID-19 and Compliance
• BVD Webinar –COVID-19 and compliance: is lockdown accelerating automation in onboarding and AML?
• Are Compliance Officers “Essential”?
• Episode 137 — FCPA Update: Eni Settles FCPA Case and SEC Files Case Against Ex-Goldman Sachs Executive
• COVID-19 and Force Majure Contractual Provisions
• The Fundamental Foundation – Board Oversight of Corporate Ethics and Compliance Programs
• Risk Lessons from the Pandemic Warfront
• Episode 136 — Justice Department Fraud Enforcement in the Pandemic Era
• Videoconferencing and Export Controls
• COVID-19: DOJ’s Aggressive Prosecution of Fraud and Pandemic-Related Crimes
• A Personal Tribute to Judge Stanley Sporkin: The Fern Street Crew Gang Prosecution (Part II of II)
• A Personal Tribute to Judge Stanley Sporkin (Part I of II)
• Virginia Suveiu and Janet Longo Join Volkov Law Group
• Episode 135 — A Personal Tribute to Judge Stanley Sporkin
• IRS’ Response to COVID-19: What Taxpayers Need to Know
• Steele Webinar: Top 6 Due Diligence Best Practices Third-Party Risk Management
• DOJ Hoarding and Price Gouging Task Force Seizes Critical Medical Supplies and Distributes to New York and New Jersey Hospitals
• COVID-19: Supply Chain Risks Lessons
• COVID-19: Important Changes to Employment Law
• Board Governance Challenges in COVID-19 Crisis
• Episode 134: COVID-19 (Part II) — Business Response to Pandemic
• Episode 133 — COVID-19 (Part I): Absence of Federal Leadership and Recent Congressional Actions
• Congress Enacts CARES Stimulus Act
• COVID-19: Employee Risks and Privacy
• Bank Secrecy Act Compliance During the COVID-19 Crisis
• COVID-19: Crisis Management
• Ethical Business Decisions in the COVID-19 Crisis
• The Coronavirus Pandemic: A Call for Leadership
• Episode 132 — Key Elements of an Effective Antitrust Compliance Program
• Antitrust Compliance Programs: Training and Speak Up and Reporting Systems (Part III of III)
• Antitrust Compliance Programs: Ethical Culture and Monitoring (Part II of III)
• Webinar: How to Implement an Effective OFAC Sanctions Compliance Program
• Five Key Elements of an Antitrust Compliance Program: Risk Assessments (Part I of III)
• Webinar: Maintaining a Reliable and Effective Internal Investigation Program
• “Paralysis” and a Culture of Wrongdoing
• The Pandemic Crisis – A Note of Support
• Episode 131 — Third-Party Risk Monitoring and Auditing Strategies
• Addressing the Coronavirus Crisis and Corporate Response
• United Bank Risk Officer Agrees to $450k Penalty for AML Compliance Failures
• The Danger of a Hyper-Focused Sales Culture
• DOJ Catches Big Fish in Generic Pharmaceutical Criminal Antitrust Investigation
• Episode 130 — Practical Strategies for OFAC Sanctions Risk Assessments
• Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations
• Cardinal Health Pays SEC $8.8 Million for FCPA Violations
• Admit It – Your Compliance Program is Not Really “Effective”
• Episode 129 — How to Create a Third-Party Risk Profile
• The Impact of a New CEO
• Incident Data and Intra-Company Cooperation
• Three Former Executives from Alstom and Marubeni Charged with Criminal FCPA Violations in Indonesia
• The Volkov Law Group is Hiring — Junior Associate and Paralegal
• Wells Fargo Settles With Justice Department for $3 Billion
• Episode 128 — Compliance Automation and Program Measurement and Evaluation
• Fourth Circuit Overturns Federal Prosecutors’ Use of Filter Team to Conduct Search of Law Firm Documents
• The Dangerous Mix of Incentives and “Misconduct”
• Rebalancing Third-Party Risk Strategies
• Episode 127 — Deep Dive into OCC Enforcement Action Against Wells Fargo Executives
• The “Old” Board Governance Model Needs to Change
• NAVEX Global Webinar: Third-Party Risk Management & Effective Controls
• Why a Duck – Episode 10, A Night at the Opera, Part 2 and 2019 FCPA Enforcement Year in Review
• Keeping Your Eye on the Risk Ball
• Episode 126 — The Airbus $4 Billion Settlement for Bribery and ITAR Violations
• Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV)
• Airbus ITAR Settlement: Review of Airbus ITAR Violations (Part III of IV)
• Airbus FCPA Settlement: Review of Airbus Bribery Scheme (Part II of IV)
• Airbus Agrees to Pay $4 Billion in Global Settlement of Foreign Bribery and ITAR Violations (Part I of IV)
• Episode 125 — Interview of Elizabeth Slim, Senior Consultant at the Volkov Law Group: AML and Financial Compliance Trends
• OFAC Issues First Two Enforcement Actions of 2020
• DOJ Announces Voluntary Disclosure Program for Criminal Export and Sanctions Violations
• OCC Settles Penalty Action with Former Wells Fargo CEO for $17.5 Million and Issues Penalty Notices Against Five Former Wells Fargo Officials
• Why a Duck — Episode 9, A Night at the Opera, Part 1 and 2019 Compliance Year in Review
• False Claims Act 2019 Year in Review
• Episode 124 — False Claims Act 2019 Review
• Get Compliance Straight – The Need to Automate
• OFAC Loses Exxon Sanctions Enforcement Case
• OFAC Sanctions Compliance: 2019 a Game-Changing Year (Part II of II)
• 2019 OFAC Sanctions Enforcement Review (Part I of II)
• Episode 123 — 2019 OFAC Enforcement and Compliance Review
• The Future of Compliance – The New Proactive CCO (Part III of III)
• The Future of Compliance: Building Bridges (Part II of III)
• The Future of Compliance: Re-Branding Compliance from Reactive to Proactive (Part I of III)
• Ethics and Compliance Trends and Predictions for 2020
• Episode 122 — 2020 Ethics and Compliance Predictions and Trends
• A Speak Up Culture Depends on Follow Through and Accountability
• FCPA Predictions for 2020 (Part III of III)
• 2019 FCPA Enforcement Highlights (Part II of III)
• FCPA 2019: A Record Year in Enforcement and Compliance (Part I of III)
• Episode 121: 2019 — FCPA Year in Review
• Elizabeth Slim, a Certified Anti-Money Laundering Specialist, Joins The Volkov Law Group
• Two Webinars: 2019 FCPA Year in Review & 2019 OFAC Enforcement Year in Review

2019

• Happy Holidays
• Travel Insurance Companies Hit with OFAC Enforcement Actions
• Compliance Messaging: Need a Reason? ‘Tis the Season!
• Bumble Bee CEO Convicted of Participating in Price-Fixing Conspiracy
• Episode 120 — Interview of NAVEX Global’s Chris Bailey and Stephen Gooding
• Webinar: 2019 — The FCPA Year in Review
• Boston Heart Diagnostics Pays $26.67 Million to Settle False Claims Act Case
• Turning a Turbulent Social and Political Environment into Positive Ethical Culture Strategies
• Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)
• Ericsson Pays $1 Billion for Systemic FCPA Violations (Part I of II)
• Episode 119 — The Ericsson FCPA Settlement
• DOJ Indicts Former Braskem CEO on FCPA Criminal Charges
• Apollo Aviation Group Pays $210k to OFAC for Violations of Sudanese Sanctions Program
• DOJ Tweaks FCPA Corporate Enforcement Policy
• Webinar: Third-Party Risk Management — Practical Solutions to Due Diligence, Monitoring and Testing
• Apple Pays $467K to OFAC for Sanctions Violations
• Episode 118 — OFAC Enforcement Update and Lessons Learned
• Happy Thanksgiving!
• Volkov Law in the News: Representation of Lt. Col. Alexander Vindman in House Impeachment Inquiry
• DOJ Notches Another Trial Victory — President of Transport Logistics Convicted of FCPA and Wire Fraud Charges
• New BVD White Paper — What you need to know for sanctions compliance
• Review of Samsung’s Bribery Scheme in Brazil (Part II of II)
• Samsung Agrees to Pay $75 Million to Resolve FCPA Violations (Part I of II)
• Episode 117 — FCPA Update: Samsung pays $75 million to settle FCPA charges; Braskem’s former CEO indicted on FCPA charges; and Transport’s co-CEO is convicted on FCPA charges
• SEC Examiner Charged with Stealing Confidential Information and Obstruction of Justice
• DOJ Charges Two Herbalife Executives with Criminal FCPA Violations
• Alstom Executive Convicted on FCPA and Money Laundering Violations
• California AG Issues California Consumer Privacy Act Regulations
• Under Armour Under DOJ and SEC Investigation For Revenue Recognition Scheme
• Episode 116 — Alstom Executive Convicted of FCPA and Money Laundering Offenses
• FINRA Fines BNP Paribas $15 Million for Anti-money Laundering Violations
• Two Charitable Foundations Pay $6 Million for Anti-Kickback Violations
• Justice Department Unseals Unaoil Executives’ FCPA Guilty Pleas
• Episode 115 — Review of Recent Healthcare Fraud Enforcement Actions
• Five Steps to Improve Board Monitoring of Compliance
• Why A Duck — Episode 6, Coconuts and the OFAC Compliance Framework
• Episode 114 — Update on Board Member Liability for Compliance Oversight Failures
• Department of Justice Brings Criminal Charges Against 35 Individuals for Involvement in $2.1 Billion in Fraudulent Genetic Testing Results
• Avanir Pharmaceuticals Pays More than $108 Million to Settle Kickback Violations
• Delaware Court Increases Scrutiny of Corporate Board Oversight and Monitoring of Compliance Programs
• Episode 113 — Managing Conflict of Interests Risks
• Why a Duck — Episode 5, Horsefeathers and the Juniper Networks FCPA Enforcement Action
• House of Representatives Passes Bill Aimed at Marijuana Industry Financial Reforms
• Sign Up for NAVEX Global’s 2019 Ethics & Compliance Virtual Conference
• What Does “Business Ethics” Mean?
• The Importance of Whistleblowers to a Speak Up Culture
• Episode 112 — Implementing an Effective Training Program
• How to Implement an Effective Ethics and Compliance Committee
• Technology and Compliance: The Magic Bullet?
• Webinar: Conflicts of Interest — Effective Strategies to Mitigate Risks
• General Electric Pays OFAC $2.7 Million for Violations of Cuba Sanctions Program
• Episode 111 — How to Design and Implement an Antitrust Compliance Program
• Canadian Fuel Technology Company and Former CEO Settle SEC FCPA Case
• Quad/Graphics Settles SEC FCPA Case for Nearly $10 Million
• Barclays Agrees to Pay the SEC $6.3 Million to Settle FCPA Offenses for Hiring of Relatives of Foreign Officials in Asia
• Episode 110: SEC Settles Three FCPA Cases on One Day
• Cooperating Cognizant COO Pays $50K to Settle SEC FCPA Action
• UK Bank Agrees to Pay $4 Million to Settle OFAC Sudanese Sanctions Violations
• Fixing a Toxic Corporate Culture
• Episode 109 — The Business Roundtable Restatement of Corporate Purposes and the Importance of Ethical Leadership
• Corporate Board Strategies for Monitoring and Promoting a Company’s Ethical Culture (Part III of III)
• Assent’s Supply Chain Risk Conference
• Living in the Cloud: Practical Approaches to Cybersecurity Risks (Part III of III)
• Bringing the Board to the Ethical Culture Table (Part II of III)
• The Business Roundtable’s Restatement of Corporate Purpose: A Big Step or a Fig Leaf? (Part I of III)
• Episode 108 — The Capital One Data Breach and Cybersecurity Vendor Risks
• Why A Duck – Episode 4, Horsefeathers and the DOJ Antitrust Division Compliance Program Guidance
• Managing Third-Party Vendor Cybersecurity Risks (Part II of III)
• Lessons Learned from the Capital One Data Breach (Part I of III)
• Episode 107 –FCPA Update — The Juniper Networks and Deutsche Bank SEC Settlements and the Ng Lap Seng Appellate Court Decision
• Juniper Networks Settles FCPA Violations with SEC for $11.7 Million
• Deutsche Bank Settles FCPA Case with SEC for $16 Million for Hiring Relatives of Public Officials
• Second Circuit Affirms FCPA Conviction of Ng Lap Seng and Rejects Application of Supreme Court’s McDonnell Decision to FCPA
• Volkov Law Group — In the News
• Episode 106 — Understanding the California Consumer Privacy Act
• US Board Diversity: Slow-Moving Change
• When Company Supervisors and Managers Engage in Misconduct
• The Current State of Compliance and Internal Audit Partnership
• Attend Converge19: October 1 – 3, 2019
• Episode 105 — Third-Party Risk Management: Interview of Bill Hauserman and Ted Datta, Bureau van Dijk
• Putting Data Security Risks in Perspective: The Proper Role of a Chief Privacy Officer
• Key Actions to Ensure Compliance with the California Consumer Privacy Act (Part II of II)
• California Sunshine — The California Consumer Privacy Act (Part I of II)
• Episode 104 — Deep Dive into Microsoft FCPA Settlement
• OFAC Implements Broad Sanctions Against Venezuela
• Cybersecurity Threats, Data Privacy and the Important Role of Compliance
• OFAC Announces $1.7 Million Settlement with Truck Manufacturer for Violations of Iran Sanctions Program
• New Podcast: Tom Fox and Michael Volkov — Why a Duck? Into the Compliance Soup with Tom Fox and Michael Volkov
• Episode 103 — Managing Supply Chain Risks
• Antitrust Division Launches Broad Investigation of High-Tech Industry
• Board Members Should Take Note — Delaware Supreme Court Issues Important Decision on Caremark Compliance Standard
• OFAC’s New §501.604 Reporting Requirement: A Small Change with a Big Impact
• Episode 102 — The Future of Compliance
• Digging into High-Risk Distributors (Part II of II)
• Managing High-Risk Distributor Risks (Part I of II)
• Five Common Weaknesses in OFAC Sanctions Compliance Programs
• Corrupt Intent and Bribery
• Five Lessons for Third-Party Distributor Risk Management from Microsoft FCPA Settlement (Part III of III)
• Episode 101 — The Antitrust Division Announces New Credit for Compliance Programs
• Microsoft FCPA Settlement Underscores Third-Party Risks (Part II of III)
• Microsoft Pays DOJ and SEC $25 Million to Resolve FCPA Violations (Part I of III)
• Data, Data and Data – How to Collect and Measure Data for Your Compliance Program?
• The Overwhelmed CCO
• Episode 100 — Interview of Tom Fox, the Compliance Evangelist
• Five Important Mandates from OFAC Compliance Framework
• Ethical Culture Begins with Senior Management
• DOJ’s Antitrust Division Issues New Guidance for Evaluation of Corporate Compliance Programs (Part II of II)
• NAVEX Global and Volkov Law Issue Vendor Risk Management Toolkit
• DOJ’s Antitrust Division Announces New Policy for Crediting Corporate Compliance Programs (Part I of II)
• Webinar: Antitrust Division Announces New Policy to Credit Compliance Programs
• Episode 99 — When to Conduct Enhanced Anti-Corruption Due Diligence
• The Critical Dataset: HR, Hotlines and Incident Management
• Catching Up with OFAC Sanctions Enforcement Actions
• NAVEX Global’s 2019 Definitive Corporate Compliance Benchmarking Report
• An Introduction to Libra – Facebook’s Foray into Cryptocurrency and its Regulatory Hurdles
• Episode 98 — Quick Dive into Recent OFAC Enforcement Actions
• Episode 97 — Matt Stankiewicz Discusses Blockchain Domains and Trademarks with Brad Kam, Co-Founder of Unstoppable Domains
• A Classic Criminal Investigation: Unraveling PDVSA Corruption
• TechnipFMC Settles FCPA Violations for $296 Million
• Episode 96 — The End of the Line: The Walmart FCPA Settlement
• Applying OFAC’s Sanctions Enforcement Guidelines to Determine A Civil Monetary Penalty (Part II of II)
• Understanding the OFAC Sanctions Enforcement Guidelines (Part I of II)
• Lessons Learned from the Walmart FCPA Enforcement Action (Part III of III)
• Rescheduled Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices, and Industry Trends
• Walmart’s Recipe for Corruption Disaster: Rapid International Growth without a Compliance Program Foundation (Part II of III)
• Thank You, Thank You: DOJ and SEC Resolve Walmart FCPA Enforcement Action (Part I of III)
• Episode 95 — Interview of Teresa Troester-Falk, Chief Global Privacy Strategist at Nymity, on the California Consumer Privacy Act
• Compliance Program Evolution and Proactive Strategies (Part III of III)
• The New Compliance Test: Do CCOs Have Senior Management Support and Resources to Innovate? (Part II of III)
• Watching the River Flow: The Evolution and Future of Compliance (Part I of III)
• Ethics and Culture Lessons from the NBA Finals
• U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions
• Episode 94 — How to Conduct a Risk Assessment for Sanctions Compliance
• Operationalizing Your Compliance Program: Local Compliance Officers and Businesses
• OFAC Fines US Company for Iran Sanctions Violations
• Commerce Department Blocks Export Licenses to Huawei Technologies Co., Ltd.
• Michael Volkov Releases New E-Book: The Road Ahead — The Justice Department’s Path to a Balanced White-Collar Enforcement Policy
• Telefônica Brasil Pays $4.125 Million for Hospitality-Related FCPA Violations
• Episode 93 — Matt Stankiewicz Discusses Data Privacy on Blockchain with ImagineBC CEO Erik Rind
• Free Webinar Recording: ITAR Compliance: Navigating Complex Risks
• Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices, and Industry Trends
• OFAC’s New Sanctions Compliance Training and Testing Requirements (Part IV of IV)
• Making Sure Your Internal Controls Address Sanctions Risks (Part III of IV)
• Conducting a Sanctions Risk Assessment: A New Era for Analyzing Your Risks (Part II of IV)
• Putting Together Your Sanctions Compliance Program: Management Commitment (Part I of IV)
• Episode 92 — How to Implement a Sanctions Compliance Program
• Remediate and Enhance Your Internal Investigation Program (Part III of III)
• How to Audit Your Internal Investigation Program (Part II of III)
• Improving Your Internal Investigation Program (Part I of III)
• Episode 91 — How to Audit and Improve Your Internal Investigation Program
• Webinar: ITAR Compliance: Navigating Complex Risks
• Catching Up with Two Recent Compliance Studies: LRN and Ethisphere
• Third-Party Risk Management: Managing the Information Flow
• Corporate Culture and “Benign” Indifference
• What Happens When Managers Misbehave?
• Episode 90 — OFAC Issues New Framework for Sanctions Compliance Program
• Watch Bureau Van Dijk Webinar Replay — “Is Power and Control the New Beneficial Ownership?”
• The Positive and Negative Mix of Corporate Compliance Trends
• Report from SEC Conference: Compliance, Cooperation and Culture
• OFAC Framework for Sanctions Compliance Programs – Review of Lessons Learned from Enforcement Actions (Part IV of IV)
• Webinar: OFAC Issues New Framework for Sanctions Compliance Programs
• OFAC Framework for Sanctions Compliance Programs – Testing and Auditing and Training (Part III of IV)
• Episode 89 — DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
• OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV)
• OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)
• DOJ’s New Corporate Compliance Guidance: Does Your Compliance Program Work? (Part V of V)
• RESCHEDULED WEBINAR: DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
• DOJ’s New Corporate Compliance Guidance: Implementation, Operationalization and Effectiveness (Part IV of V)
• Episode 88 — Matt Stankiewicz Interview of Liquidity Digital CEO Syed Hussain
• DOJ’s New Corporate Compliance Guidance: Training and Communications, Reporting and Investigations, Third-Party Management and Mergers and Acquisitions (Part III of V)
• DOJ’s New Corporate Compliance Guidance: Risk Assessments and Policies and Procedures (Part II of V)
• Webinar: DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs
• DOJ Issues New and More Robust Guidance on Evaluation of Corporate Compliance Programs (Part I of V)
• OFAC Enforcement Action Underscores Russia Sectoral Sanctions
• The Important Link Between Anti-Corruption Compliance and Effective Training Programs
• Episode 87 — Review of Recent Compliance Benchmarking, Surveys and Studies
• Join Us for a May 16, 2019 BVD Webinar: “Is “Power and Control” the New Beneficial Ownership?
• DOJ and OFAC Announce Another Sanctions Settlement – UniCredit Group Banks Pay Over $1.3 Billion and Subsidiary Bank Agrees to Plead Guilty for Violating Iran Sanctions
• Acteon Pays $441,000 to Settle Two OFAC Enforcement Actions
• The Long Arm of OFAC: Secondary Sanctions, Facilitation, and Causing a Violation
• Episode 86 – Standard Chartered Bank Pays Over $1 Billion for Sanctions Violations
• NAVEX Global’s 2019 Hotline Benchmark Report
• OFAC Sanctions Compliance Insights from Standard Chartered Bank Enforcement Action (Part III of III)
• Standard Chartered Bank’s Continuing Culture Challenges and Sanctions Compliance (Part II of III)
• Stephen Cheng and Noah Smith Write on Senator Warren’s Corporate Executive Accountability Proposal
• Standard Chartered Pays Over $1 Billion for Continuing Sanctions Violations (Part I of III)
• Episode 85 — A Deep Dive into the Fresenius Medical FCPA Settlement
• Checking in on Criminal Healthcare Fraud Prosecutions
• Three Pharmaceutical Companies Pay a Total of $122 Million to Settle Kickback Allegations Involving Co-Pay Assistance Foundations
• DOJ Collects Millions in Two High-Profile False Claims Act Cases
• Five Signs Your Company Lacks Integrity
• Tom Fox and Mike Volkov Discuss the Fresenius Medical FCPA Enforcement Action
• Episode 84 — A Review of MTS Telesystems FCPA Enforcement Action
• Lessons Learned from Fresenius Medical FCPA Settlement (Part III of III)
• Fresenius Medical’s Bribery Conduct Precludes Declination (Part II of III)
• Fresenius Pays $231 Million to Resolve Long-Standing FCPA Enforcement Action (Part I of III)
• Episode 83 — Managing Hotlines and Reporting Systems
• Stanley Black and Decker Settles OFAC Enforcement Action for $1.9 Million
• DOJ “Tweaks” FCPA Corporate Enforcement Policy
• Former CFTC Chairman Calls to Strengthen Cryptocurrency Regulations
• Episode 82 — A Deep Dive into the Cognizant Technology FCPA Enforcement Action
• Ethics, Profits, Sustainability and Stakeholders: An Update on a Familiar Relationship
• Thomson Reuters Webinar: Top 3 Areas for Anti-Corruption Compliance
• Does Your Board Know How to Conduct Oversight and Monitor Your Compliance Program?
• National College Admissions Scandal Reveals Corrupt Underbelly of College Exams and Athletic Recruitment
• U.S. Domestic Bribery Enforcement and State and Local Corruption
• Episode 81 — Update on OFAC Enforcement and Compliance Lessons Learned
• 2019 Cryptocurrency Regulations – A Primer and What to Expect Throughout the Year
• Lessons Learned and Trends from MTS FCPA Enforcement Action and Criminal Indictment of Karimova and Akhmedov (Part III of III)
• Anatomy of MTS, Karimova and Akhmedov Bribery Scheme in Uzbekistan (Part II of III)
• Russian Mobile Carrier, Mobile Telesystems, Settles FCPA Case with DOJ and FCPA for $850 Million; MTS Executive and Notorious Uzbek Government Official Indicted (Part I of III)
• Episode 80 — Best Practices for Investigation of Allegations of Sexual Misconduct in the #MeToo Era
• DOJ Sweeps Up Two More Defendants in PDVSA Criminal Investigation
• Webinar: Best Practices for Internal Investigations of Sexual Misconduct Allegations in the #MeToo Era
• OFAC Announces Yet Another Enforcement Action – Cement Clinker Company Settles for Violations of Iran Sanctions Program
• DOJ Arrests Micronesian Official and Hawaii-Based Businessman Pleads Guilty to FCPA Violation
• The Criminal Pursuit of Huawei China: DOJ Brings Two Indictments
• Episode 79 — Update on GDPR Enforcement
• AppliChem Pays OFAC $5.5 Million for Cuba Sanctions Violations
• CCO and CLO “Authority”: A Fundamental Requirement
• U.S. Marijuana Laws Cause Uncertainty for Financial Institutions
• Episode 78 — Ethical Cultures and Proactive Measures to Mitigate Organizational #MeToo Risks
• Lessons Learned from the Cognizant FCPA Resolution (Part IV of IV)
• Reflections on the Cognizant FCPA Resolution: Does DOJ Mean What it Says? (Part III of IV)
• The Anatomy of a Bribery Scandal: Digging into the Cognizant Bribery Scheme (Part II of IV)
• Tom Fox and Michael Volkov Discuss Cognizant Technologies FCPA SEC Settlement, Declination and Criminal Indictment of Two Executives
• Cognizant Technology Pays $25 Million for FCPA Violations and Earns Declination — Two Executives are Indicted for Criminal FCPA Violations (Part I of IV)
• Episode 77 — Implementing an Effective Trade Compliance Program
• OFAC Announces Two Sanctions Enforcement Settlements
• Corruption Risks and the Issue of Foreign Government Officials
• Four Audi Executives Indicted for Emissions Cheating Scandal
• The Urgency of Now: Corporate Ethics and the #MeToo Movement
• New U.S. Sanctions Against Nicolás Maduro Place Venezuelan Oil Squarely in the Crosshairs
• Episode 76 — Review of 2018 AML Enforcement and Compliance Trends
• Hospitals and Physician Relationships – Navigating Stark, AKS and Fraud Risks (Part III of III)
• Pharmaceutical and Medical Device Company Payments to Healthcare Professionals (Part II of III)
• Focusing on “Payments” to Healthcare Professionals (Part I of III)
• Export Control Reform: Major Changes for ITAR Regulations for Firearms Industry
• Webinar: Anti-Corruption Compliance in Pharma and Medical Device Industries
• It is 2019 . . . Do You Know Where Your Data Is?
• Episode 75 — 2018 False Claims Act Review
• The Requirement for a Proactive Audit Program
• Michael Volkov Named to Trust Across America’s 2019 Top Thought Leaders in Trust
• Tying Mitigation to Third Party Risks
• US Brings First Criminal AML Case Against Broker-Dealer
• Touting Corporate Culture to Excuse a Commitment to Compliance
• Julie DiMauro and Michael Volkov Video Discussion of FCPA and Compliance Issues
• Episode 74 — ITAR Compliance Review
• ComplianceNext — Michael Volkov Videos
• Trade Secret Risks, Criminal Prosecutions and Protecting Trade Secrets
• The Dangerous Compliance Threat – Budget Cuts to Compliance Programs
• University of St. Thomas Open House on Organizational Ethics and Compliance Programs
• Complimentary NAVEX Global Webinar: Best Practices for Vendor Risk Profiling
• Ethics and Compliance Trends: Humans and Automation, Intelligence and Technology
• Merging Trade Compliance and Ethics and Compliance Silos
• False Claims Act 2018 Year in Review – Making Sense of the DOJ Fraud Statistics
• Episode 73 — Review of FCPA Settlements for Polycom, Eletrobras, and Two Former Panasonic Avionics Officers
• Eletrobras Settles SEC FCPA & Bid-Rigging Enforcement Action for $2.5 Million
• The Danger of Benchmarking
• Assessing Your Hotline System
• Jessica Sanderson Joins The Volkov Law Group
• Polycom Pays $36 Million, Settles with SEC, and Earns DOJ Declination for Bribery in China
• Episode 72 — 2018 Review of OFAC Sanctions Enforcement and Compliance Trends
• SEC Settles FCPA Charges Against Ex-Panasonic Avionics Officers
• OFAC Relaxes Russia Sanctions After Oligarch Ownership Changes
• 2019 Ethics and Compliance Predictions
• Webinar: 2018 OFAC Sanctions Enforcement and Compliance Trends
• Sanctions Enforcement and Compliance Year in Review
• Episode 71 — 2019 Ethics and Compliance Predictions and Trends
• FCPA Predictions for 2019
• 2018 FCPA Year in Review: The More Things Change, The More They Stay the Same
• Episode 70 — FCPA Year in Review and Predictions for 2019

2018

• Webinar: Review of 2018 FCPA Enforcement and Compliance Trends
• Happy Holidays From The Volkov Law Group
• UBS Pays $15 Million for AML Compliance Deficiencies
• OFAC Announces Russia Sanctions Settlement with Software Company
• Episode 69 — Update on DOJ Corporate Enforcement Policies
• Convercent Webinar — FCPA Enforcement: What Happened in 2018? (Plus, What’s in Store For 2019)
• The Mindset of Employee Fraudsters (Part III of III)
• Fraud Detection: New Technologies and Analytics (Part II of III)
• The Growing Problem of Corporate Fraud (Part I of III)
• Episode 68 — FCPA Guidance and Safe Harbors
• Smart Compliance: Embracing Proactive Solutions
• The “60-60” Issue and Indoctrinating Middle Management into the Compliance Mission
• Enforcing Corporate Compliance Policies and Controls
• The Purpose of a Compliance Program: To Prevent and Detect
• Episode 67 — Conducting Compliance Audits
• Vantage Drilling Forks Over $5 Million for SEC FCPA Settlement
• Your CEO Agrees the Company’s Culture is Important – Now What?
• OFAC Completes Re-Imposition of Iran Sanctions
• Société Générale Pays $1.4 Billion for Systemic Sanctions Violations
• Episode 66 — Gifts, Meals, Entertainment and Travel Expense Compliance
• Effective Compliance is More than the Sum of a Program’s Parts
• Behavioral Studies and Compliance
• Episode 65 — Goldman Sachs and the 1MDB Corruption Scandal
• Michael Volkov on FCPA Compliance Report Podcast and Compliance Next
• Ethics and Compliance Initiative Report: The Importance of Ethics Communications and Accountability
• NAVEX Global Research Demonstrates Correlation Between Business Performance and Hotline System
• Where Has All the Money Gone? Longtime Passing, Oh Where Has it Gone?
• The Goldman Sachs 1MDB Scandal: The Doctrine of Respondeat Superior
• Episode 64: Stryker’s SEC FCPA Settlement
• Webinar: Measuring Your Compliance Program: Data and Analytics
• The Tangible Benefits of a Positive Ethical Culture
• Human Resources and Criminal Antitrust Prosecutions
• Justice Department Recalibrates Corporate Monitors and DOJ Compliance Position
• Goldman Sachs and the 1MDB Criminal Prosecutions
• Episode 63 — The Epsilon Case and Third-Party Sanctions Risks
• Japanese Electrolytic Capacitor Manufacturer Sentenced to Pay $60 Million for Criminal Price-Fixing
• Speak Up is Great – Is Anyone Listening?
• Ethics and Compliance as a “Marketing” Program
• University of St. Thomas Law Graduate Programs in Organizational Ethics Compliance
• Episode 62 — Update on the Cuba and Venezuela OFAC Sanctions Programs
• Health Management Associates Pays Over $260 Million in Criminal and Civil Penalties for Pervasive False Billing and Kickback Charges
• Doctor and Two Medical Equipment Officers Head to Jail for Illegal Kickback Scheme
• Managing Your Supply Chain: Turning “Do No Harm” Into “Doing Good”
• Episode 61 — How to Implement and Promote a Speak Up Culture
• NAVEX Global Releases 2018 Third-Party Risk Benchmark Report
• Sign Up for November 8, 2018 NAVEX Global Ethics and Compliance Virtual Conference
• JP Morgan Chase Bank Settles “Old” Sanctions Case for $5 Million
• Are Unpaid Interns Worth the Cost (and the Risk)?
• Successful Compliance Officers – A Balancing Act
• DaVita Medical Pays $270 million to Settle False Claims Act Case
• Employees and Political Activity
• Episode 60 — A Deep Dive into the SEC’s FCPA Settlement with United Technologies
• NAVEX Global Webinar: The State of Third-Party Risk Management in 2018
• The Importance of a High-Risk Due Diligence Committee
• Webinar: Advanced Ethics and Compliance Program Design
• The Danger to a Compliance Program of Ineffective In-House Lawyers
• Corruption, Crime & Compliance Podcast – Now on Spotify!
• A Basic Compliance Requirement: A Contract Management System
• CEO Falls to SEC FCPA Settlement
• Episode 59 — Implementing an Internal Investigation Program
• Developing an Employee Handbook that Helps Protect Your Business from Lawsuits
• Wit and Wisdom from Michael Volkov: It’s the Culture Stupid: Ethics and the Definition of Successful Companies
• What Happens When a CFO Fails to Listen to the CCO?
• Petrobas Closes Out “Massive” Corruption Investigations and Litigation
• Stryker Suffers “Strike Two” and Settles SEC FCPA Case
• Episode 58 — Interview of Donna Boehme — The Future of the Independent, Empowered Chief Compliance Officer
• Maintaining Your Company’s Compliance Program in the Rapid Policy World of Change by Tweet
• Webinar: The False Claims Act — Enforcement Risks and Compliance Trends
• Compliance and Recruiting Women in the Workforce
• OFAC Enforcement: The Epsilon Case and Third Party Risks
• Cryptocurrency 101 for Lawyers – What is Mining?
• Episode 57 — A Review of the Russia Sanctions and Recent Changes
• A Compliance Priority — Watching Where Your Money Goes
• United Technologies SEC FCPA Enforcement Action: Gifts, Meals, Entertainment and Travel Abuse and Bribery (Part II of II)
• United Technologies Pays $13.9 Million to Settle FCPA Charges (Part I of II)
• Sanofi Coughs Up $25 Million to Settle SEC FCPA Charges
• Episode 56 — Catching Up with Special Counsel Mueller’s Russia Investigation
• The Real Focus for Compliance: Post-Acquisition Integration of an Acquired Company (Part III of III)
• The Importance of Pre-Acquisition FCPA Due Diligence (Part II of III)
• FCPA Risks and Merger and Acquisitions: The Evolving Policies (Part I of III)
• Webinar — FCPA 2018: Update on Enforcement and Compliance Trends
• Noah Smith Joins The Volkov Law Group
• State Department Announces Additional Sanctions Against Russia
• Episode 55 — Update on the Iran Sanctions Program
• Legg Mason Pays $34 Million to Resolve SEC’s Libyan FCPA Investigation
• The Ups and Downs of Cooperating Witnesses
• Court of Appeals Cuts Back Extraterritorial FCPA Jurisdiction Over Foreign Nationals
• Episode 54 — A Deep Dive into the SEC’s FCPA Settlement with Beam Suntory
• DOJ Issues Declination and Disgorgement Under FCPA Corporate Enforcement Policy
• OFAC Begins to Re-Impose Iran Sanctions and Expands Reach of Previous Sanctions
• Fighting Corruption and Obstacles to Criminal Prosecution — (Part II of II)
• Defining Corruption: From the Framers to the Supreme Court’s Decision in Citizens United (Part I of II)
• Episode 53 — How to Test and Evaluate Your Compliance Program
• CFIUS Reform: An Expanded Role (Part II of II)
• CFIUS Review: An Increasing Risk (Part I of II)
• DOJ Expands FCPA Corporate Enforcement Policy
• Episode 52 — The False Claims Act and Healthcare Fraud
• New Episode Everything Compliance: The Five-Year Retrospective Edition
• Federal Enforcement and the Opioid Epidemic (Part IV of IV)
• Webinar: FCPA Risks and Mergers and Acquisitions
• Rolling Along with False Claims Act Enforcement Actions (Part III of IV)
• Hospital Official and Three Dentists Convicted for Kickback and Bribery in RICO Criminal Case (Part II of IV)
• The Supreme Court’s Escobar Decision and the Impact on False Claims Act Cases (Part I of IV)
• Episode 51 — Interview of Dr. Pat Harned, CEO of the Ethics and Compliance Initiative
• Crime-Fraud Exception to Attorney-Client Privilege
• Real-World Applications of Blockchain to Compliance (Part II of II)
• The Revolution of Blockchain and Compliance (Part I of II)
• Episode 50 — Cryptocurrency and Blockchain: Matt Stankiewicz Interview of Jason Davis, CEO of Hoard Invest
• Defining Deterrence in White Collar Crime Cases (Part III of III)
• White Collar Criminals and Sending a Message to Deter Misconduct (Part II of III)
• Criminal Sentencing and Deterrence: White Collar Crime and Corporate Misconduct (Part I of III)
• Episode 49 — Data Breach Notification in the GDPR Era
• Corporate Doublespeak: A Bribe is a Bribe
• Artificial Intelligence, Hype and Financial Misconduct
• Corporate Character and Lack of Corporate Will
• Iran Sanctions and Third Party Risk
• Episode 48: Tom Fox and Michael Volkov Review FCPA Enforcement for First Half of 2018
• The Risk of Employee Misconduct
• Antitrust Division Continues to Wrestle with Credit for Pre-Enforcement Compliance Programs
• Four Current FCPA Enforcement Trends
• Episode 47 — Cybersecurity Threats and Compliance
• Beam Settles FCPA Violations with SEC for $8 Million for Pervasive Third-Party Bribery Schemes
• Stephen Cheng and Marcel de Chermont Join The Volkov Law Group
• Lessons Learned from Credit Suisse Corrupt Hiring Scheme and FCPA Settlement (Part II of II)
• Credit Suisse Pays $76 Million for Sons and Daughters FCPA Violations in China (Part I of II)
• Episode 46 — Implementing a Policy Management Program
• Drawing Legal Lines in Cryptocurrency Regulation: The Importance of Decentralization
• Webinar: Cybersecurity Threats and Compliance
• Happy 4th of July!
• Cryptocurrency Compliance: The Importance of Internal Investigations
• Episode 45 — Sicily: An Inspiration — Interview of Rosetta Sciacca
• Karin Sweigart Joins The Volkov Law Group
• Leadership and Compassion
• Is Your Compliance Program Adrift?
• The Culture Bandwagon — SEC Chairman Joins the Club
• Episode 44 — Compliance Program Best Practices: The FCPA Guidance and DOJ’s Evaluation of Corporate Compliance Programs
• When Your CEO Just Does Not Get It
• Welcome! You Are the New Chief Compliance Officer: Five Basic Steps to Get Started
• The Pernicious Effect of Conflicts of Interest
• The Shoe Drops on Theranos’ Former CEO and COO – Criminal Indictment Filed Charging Fraud
• New Episode Everything Compliance — Four of a Kind Edition
• Episode 43 — Global Compliance Program Design and Challenges
• New NAVEX Global White Paper — How to Develop the Business Case for a Third-Party Risk Management System
• Hallelujah: OFAC Announces First Enforcement Action in 2018 Against Ericsson, Inc.
• Compliance Next Announces Official Partnership with Volkov Law Group
• Webinar: Update on OFAC’s Iran Sanctions Program
• Textbook Lessons Learned from the Société Générale and Legg Mason FCPA Enforcement Action (Part III of III)
• Société Générale and Legg Mason Pay the Price for Bribery in Libya (Part II of III)
• Justice Department Settles Gaddafi-Libya FCPA Cases with Société Générale and Legg Mason (Part I of III)
• Episode 42 — How to Manage Your CEO on Compliance Issues
• When Corporate Leaders Fail to Listen
• Compliance and Technology
• Leadership Support Provides Compliance Credibility
• Episode 41 — Compliance and Technology
• DOJ Charges Two Additional Individuals in FCPA Rolls Royce Case
• Webinar: A Deep Dive into the Russia-Ukraine Sanctions Program
• Compliance and the Reckoning
• The Vital Role of Internal Audit to Compliance
• Episode 40 — How to Conduct a Corporate Culture Assessment
• Sunshine, Disinfectant and SEC Guidance on Cybersecurity Disclosures
• CEOs Under the Criminal Spotlight – More C-Suite Misconduct
• Tom Fox’s Valuable Contribution to the Compliance Profession – The Complete Compliance Handbook
• Volkov Law — In the News and on the Web
• Episode 39 — Tom Fox’s New Book — The Complete Compliance Handbook
• Time for Companies to Establish an Independent Corporate Ombudsman
• Corporate Attitudes: When Speak Up Means Keep Quiet
• Justice Department Charges Former Volkswagen CEO in Diesel Vehicle Emissions Cheating Scheme
• Webinar: The FCPA Guidance and DOJ’s Evaluation of Corporate Compliance Programs
• Update on Russia Trade Sanctions
• Turning Back the Clock – OFAC Plans to Reimpose Iran Sanctions Program
• Episode 38 — Update on Special Counsel Mueller’s Russia Investigation and the Michael Cohen Investigation
• Dun and Bradstreet Pays $9 Million for FCPA Violations in China
• Compliance Lessons Learned from Panasonic Avionics $280 Million FCPA Enforcement Action (Part II of II)
• Complying with FinCEN’s CDD Rule: Beneficial Ownership Register Vendor Trulioo
• The Volkov Law Group is Hiring: Senior Associate and Associate Positions
• Panasonic Avionics Pays $280 Million to Resolve FCPA Offenses in Middle East and Asia (Part I of II)
• A Valuable Resource: The Fifth Edition of The Foreign Corrupt Practices Act Handbook
• Episode 37 — Ethics and Compliance Trends from Recent Surveys and Studies
• FLIR Systems ITAR Settlement Outlines Important Export Compliance Factors (Part II of II)
• FLIR Systems Pays $15 Million Civil Penalty for AECA and ITAR Violations and Earns First DTCC Monitor (Part I of II)
• Volkov Law Group Joins Forces with NAVEX Global’s Compliance Next
• The NYAG’s Virtual Markets Integrity Initiative and Transparency of Cryptocurrency Exchanges
• Lying and Accountability: ZTE Pays the Price
• Episode 36 – How to Respond to a Government Investigation
• FCPA Compliance: Navigating Joint Venture Risks (Part V of V)
• FCPA Compliance: Automate and Audit Third Parties (Part IV of V)
• FCPA Compliance: Automation and Mitigating Gifts, Meals, Entertainment and Travel Expenditures Risks (Part III of V)
• FCPA Compliance: When a Foreign Official is a Third-Party (Part II of V)
• FCPA Compliance: The Importance of Relativity to Risk Ranking (Part I of V)
• Episode 35 –Update on AML Compliance from Recent AML Enforcement Actions
• AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions
• Webinar: The New Era of AML Compliance — The Need to Refresh Your AML Compliance Program
• CCOs and Compromising Positions
• FinCEN Issues Guidance for Beneficial Ownership Regulations
• The Cohen Search Warrants – DOJ Procedures for Approval
• Episode 34 — The Cohen Criminal Investigation and Search Warrants
• Supreme Court Narrows Criminal Tax Obstruction of Justice Statute
• OFAC Hits Russia with New Sanctions
• The New Test for CCOs
• Bringing a Compliance Program to Life: Connecting the Dots
• Episode 33 — Bitcoin, Cryptocurrencies and Compliance — Interview of Matt Stankiewicz
• New Episode — Everything Compliance: Will the Astros Repeat Edition?
• Internal Testing and Monitoring of a Compliance Program
• Cryptocurrencies, Blockchain and Ponzi Schemes
• The State of Whistleblowing
• Kinross Gold Mining FCPA Settlement: SEC Continues Internal Controls Focus
• Episode 32 — Ten Steps to Prepare Your Company for Execution of a Search Warrant
• ECI’s New Business Ethics Survey Confirms Misconduct Rates Declining — But Retaliation Rates Increasing
• The State of Affairs: General Counsels and Chief Compliance Officers
• Webinar: Healthcare Providers — The Need to Enhance Your Ethics and Compliance Program
• Who’s on First, What’s on Second – Who is Regulating ICOs, Cryptocurrencies and Exchange Platforms?
• Culture and Leadership in Middle Management
• Episode 31 — Doing Business in Haiti: Interview of Angelo Viard
• Congress and the Blockchain: The 2018 Joint Economic Report’s Discussion on Cryptocurrency
• Webinar: A Review of FinCEN’s New Beneficial Ownership Regulations
• DOJ Settles Follow-On FCPA Case: Transport Logistics Pays $2 Million Penalty
• First FCPA Action of 2018: Elbit Imaging
• Episode 30 — Common Due Diligence Problems (Part III of III)
• Connecting with Your Employees – What is Your Company’s Purpose?
• Compliance and the Attorney-Client Privilege
• Compliance Needs to Understand Business
• Sapin II and French Anti-Corruption Enforcement
• The SEC Targets ICOs for Enforcement
• Episode 29 — Building Blocks for an Effective Due Diligence Program (Part II of III)
• Five Questions for Corporate Boards on Oversight of Compliance
• Governments Begin to Embrace Cryptocurrency
• A New Holistic Model for Internal Controls Management (Part II of II)
• Time to Review and Revise Your Internal Controls (Part I of II)
• Episode 28 — Due Diligence and Third Party Risk Management (Part I of III)
• Company Culture, #MeToo and Anti-Harassment Programs
• Three Critical Questions to Ask Your CEO About Your Ethical Culture
• Three Important Points to Remember About Third-Party Risks
• Episode 27 — Internal Controls and Enforcement Risks
• New Episode — Everything Compliance — The Year-End Wrap Up
• Financial Institutions and the Glaring Absence of an Ethical Culture
• The Obvious Partnership — Compliance and Cybersecurity
• US Bancorp Pays $613 Million and Joins the Ranks of AML Violators
• Rabobank Coughs Up $368 Million and Pleads Guilty to Conspiracy to Money Launder and Obstruct Investigation
• Episode 26 — Federal Reserve Blocks Wells Fargo Growth In Response to Governance and Risk Management Disaster
• Planning for the Perilous Consequences of a Data Breach
• The Long Road Back to Redemption: Wells Fargo’s Path to Remediation (Part II of II)
• Federal Reserve Hits Wells Fargo with Unprecedented Enforcement Action (Part I of II)
• Subscribe to Corruption, Crime & Compliance Podcasts and Blog
• Episode 25 — Unraveling the KPMG Audit Scandal
• Local Compliance Strategies to Embrace the Business (Part II of II)
• Challenges in Global Compliance Operations: Structure and Responsibilities (Part I of II)
• Webinar: Making Your Board of Directors a Partner in Compliance
• Resources, Resources, and More Resources – The True Test of an Effective Ethics and Compliance Program
• “Trust Better Be Your Most Important Value” – Marc Benioff, Salesforce CEO
• Episode 24 — Corporate Board Reform
• Criminal Enforcement Against Senior Executives: The Fish Rots from the Head
• Cybersecurity Compliance for Financial Institutions
• The KPMG Debacle – Five Former KPMG Employees and Former PCAOB Employees Indicted for Fraud and Conspiracy
• Episode 23 — Tom Fox and 2017 FCPA Year in Review
• Cybersecurity: The Law and Regulatory Framework
• Welcome to New Sponsor Trulioo: A Leading Global Identity and Business Verification Provider
• Cybersecurity and Third-Party Risks
• The Convergence of Cybersecurity, Compliance, and Enterprise Risk Management
• Cybersecurity Threats and Risks
• Renewing Corporate Vows to the Chief Compliance Officer
• Episode 22 — Testing and Evaluation of Your Compliance Program
• The Need for Anti-Money Laundering Regulatory Reform
• Financial Institutions Are Playing Catch-Up in AML and Sanctions Compliance
• Webinar: How to Implement an Effective Internal Investigation Program
• AML Regulation and Compliance Trends
• Regulators Slap Banks, MSBs and Card Club with AML Violation Penalties
• Episode 21 — Interview of Jean-Michel Ferat, FCPA Forensic Accounting Expert, Senior Managing Director, Ankura Consulting
• Three Simple Steps to Improve Your Corporate Culture
• Webinar: 2018 Ethics and Compliance Program Trends and Expectations
• Time to Test and Audit Your Compliance Program
• Five Major Compliance Predictions for 2018
• Episode 20 — Data Security and Privacy Compliance
• Justice Department Closes Out 2017 with 2 FCPA Actions: Keppel Offshore and Marine and Embraer Individual
• 2018 FCPA Predictions (Part II of II)
• 2017 FCPA Year in Review (Part I of II)
• Webinar — 2017 FCPA Year in Review
• Episode 19 — 2017 FCPA Year in Review

2017

• Happy Holidays from The Volkov Law Group
• New Episode Everything Compliance — The New FCPA Corporate Enforcement Policy (Part I of II)
• Michael Volkov’s New E-Book: Pointing the Finger — How Corporate Boards Are Dodging Accountability and What CCOs Can Do About It
• Episode 18 — Michael Volkov’s Perspective on the Russian Investigation — Next Steps for Special Counsel Mueller’s Investigation (Parts III of III)
• Episode 17 — Michael Volkov’s Perspective on the Russian Investigation — The Michael Flynn Plea Agreement (Part II of III)
• Episode 16 — Michael Volkov’s Perspective on the Russian Investigation — Analysis and Review of Manafort/Gates Indictment and Papadopolous Plea (Part I of III)
• Ethics and Mitigating Reputation Risks
• Episode 15 — The Justice Department’s New FCPA Corporate Enforcement Policy
• May 2018: D-Day for FinCEN Customer Due Diligence and EU’s General Data Privacy Regulations
• Calculating the New Balance Between Disclosure and Non-Disclosure of Potential FCPA Violations
• Sponsored Product Update: NAVEX Global’s RiskRate 6.0
• Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy
• Episode 14 — What Every Compliance Officer Needs to Know About Data Privacy and the EU’s GDPR
• Practical Ethics – The New Way to Advance an Ethical Culture
• Sanctions Updates: Cuba, North Korea, Russia, Sudan, Venezuela
• Foreign Agents Registration Act Enforcement
• Webinar: How to Implement An Effective Sanctions Compliance Program
• SBM Offshore Finally Reaches the Finish Line and Settles FCPA Case for $238 Million
• Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy
• Episode 13 — Top 10 Rules for Conducting Internal investigation Interviews
• New Episode — Everything Compliance: The Regulatory (Or Not) Edition
• Incorporating AML Compliance Into a Compliance Program (Part III of III)
• Addressing AML Risks in Your Third-Party and Vendor/Supplier Relationships (Part II of III)
• Anti-Money Laundering Risks for Global Companies (Part I of III)
• DOJ Continues Run on Individual FCPA Criminal Prosecutions
• Episode 12 — OFAC Screening and Sanctions Compliance
• Webinar Reminder — Global Antitrust Enforcement Risks and Compliance
• Third Party Risk Management: Require ISO 37001 Certification from Your Third Parties
• Internal Investigations: Protecting the Attorney- Client Privilege
• Making the Case for Requiring Beneficial Ownership Information
• Episode 11 — Seven Individuals Charged with FCPA Criminal Violations
• Global Antitrust Enforcement Risks and Compliance Programs
• Putting Ethics Back Into Compliance (Part IV of IV)
• Six Specific Areas to Embed and Promote Business Ethics (Part III of IV)
• Trust and Integrity – Bedrock of Corporate Sustainability (Part II of IV)
• Business Ethics, Values and Personal Ethics (Part I of IV)
• Episode 10 — How to Conduct a Risk and Compliance Program Assessment
• The FCPA Week That Was — Seven Individuals Charged for FCPA Violations
• MyCompliance Office Webinar: Taking a Fresh Look at Gifts, Entertainment, & Hospitality Programs
• COSO Framework: Breaking Down the Silos and Bringing Everyone Together (Part II of II)
• COSO Framework: Fraud, Corruption and Compliance (Part I of II)
• CCOs and CFOs: Bringing Everyone Together
• Ominous Signs for the Future of the Compliance Profession
• Update on The Volkov Law Group
• Episode 9 — The Need for a Robust Criminal Antitrust Compliance Program
• Volkov Law TV — New Webinars For Low Monthly or Annual Fees
• HR and Compliance: Working Together to Hire Ethical Employees
• Anti-Corruption Risks: Global Enforcement Means Global Detection
• Compliance and Technology – Rational Actors Need to Adopt Technology
• Webinar: How to Conduct Periodic Reviews and Assessments of Your Compliance Program
• Episode 8 — The Critical Importance of Beneficial Ownership to Compliance
• It Takes a Village . . . To Commit Bribery
• FCPA Enforcement and Credit for an Effective Compliance Program
• Watch Exiger Webinar Replay “How AI is Transforming Third Party Risk Management”
• Five Essential Steps to Improve Corporate Board Oversight and Support of Compliance
• Episode 7 — The Perils of Compliance with the Russia Sanctions Program
• ISO 37001: Training, Employee Concerns, and Internal Investigations (Part V of V)
• ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V)
• ISO 37001: Board, Top Management and Anti-Bribery Compliance Responsibilities (Part III of V)
• ISO 37001: The Good, The Bad and the Ugly (Part II of V)
• A Closer Look at ISO37001 – Something Old or Something New? (Part I of V)
• Podcast Episode 6 — ISO 37001 — Anti-Bribery Risk Management System: Something Old or Something New?
• Webinar: ISO 37001 — A Review of the Anti-Bribery Risk Management System
• Lawyers Can Be A Positive Force for Compliance
• In Defense of Compliance Checklists
• The Importance of A Robust Conflicts of Interest Program
• Podcast Episode 5 — Interview of Tom Fox
• Volkov Law Group Sponsors Tom Fox’s One Month to More Effective Compliance for Business Ventures
• ArthroCare CEO Reconvicted for Fraud
• The Delusion of a Barebones Compliance Program
• The FCPA Compliance Defense — Don’t Wish for It, You Just Might Get It
• Where O’ Where Did Our Monitors Go? — The Telia Bribery Case
• Podcast Episode 4 — Too Big To Fail, Too Big To Jail, DOJ’s Outsourcing of Criminal Investigations
• The Compliance Conundrum — Spending Money to Save Money
• The Five Most Important Issues for a CCO to Report to the Board
• Ethics and Compliance Controls – Different Means to the Same Objective
• Podcast 3 — The Latest FCPA Undercover Sting — John Baptiste Case
• Subscribe to New Podcast Service
• CEO Leadership – Honesty, Integrity, Listening and Empathy
• No More Excuses: CCOs Have to Embrace Technology
• 4 Signs of a Poor Relationship Between a CCO and the Board
• Podcast Episode 2 — Ethics and Profits
• Michael Volkov Interview with BvD’s Alistair King
• CCOs and the C-Suite
• Slippery Slopes: “Broken Windows” and Employee Misconduct
• The Emperor Has No [Compliance Program]
• New Podcast: Corruption, Crime and Compliance — Episode 1, A Review of Trump Administration Enforcement Priorities
• Live Webinar: How AI is Transforming Third Party Risk Management (via Live Stream)
• The Objective of Due Diligence: To Protect Your Culture
• Tales from the Corporate Scandal Crypt: GM, VimpelCom, VW and Wells Fargo
• Webinar: How to Conduct Effective and Efficient Due Diligence?
• Compliance Missed Opportunities: CCOs and HR
• Financial Controls and Contract Management Systems
• Challenges in Transitioning from the Law to Compliance
• Ethics, Temptation and Money
• Focusing Antitrust Compliance Programs on the Real Criminal Risks (Part II of II)
• Chief Compliance Officers Have to Address Criminal Antitrust Risks (Part I of II)
• Infusing Corporate Culture with Accountability
• German Auto Antitrust Cartel – A Record Enforcement Action Begins
• OFAC Pushes Iran Sanctions Enforcement
• Tom Fox and Mike Volkov Discuss Linde Gas and CDM Smith FCPA Declinations
• Anti-Corruption Risks and Drug and Device Companies
• Retaining a “Risky” Third-Party
• Wake Up and Mind Your Culture — Practical Approaches to Managing a Company’s Culture
• Every CCO Needs Authority + Autonomy + Resources
• Get Your Board On Board
• Maximizing Compliance Opportunities: Your Vendor Onboarding Process and Vendor Master File
• New Sanctions Law Complicates Trade Compliance
• What Happens When Employees Stop Speaking Up?
• LIBOR Criminal Convictions Reversed – The Perils of Global Enforcement
• How Do You Define a Compliance Program Failure?
• Double Whammy for United Healthcare: Two False Claims Act Cases in Two Weeks
• The Perfect Compliance Combo: Culture and Controls
• FCPA Risks and Acquisition Integration Challenges
• Webinar: Is Your Company “At-Risk” for a Government Enforcement Action?
• Anti-Corruption Compliance: The Need to Look Under the Cloak of Materiality
• The Strange Case of OFAC Against Exxon for Sanctions Violations
• Is Your Company At-Risk for a Government Enforcement Action?
• Should You Record Internal Investigation Interviews?
• United States v. Nixon – An Important Reminder
• Important Polling Results from BvD Webinar on Beneficial Ownership
• CCO’s and Delusions About a Company’s Ethical Culture
• New Episode — Everything Compliance
• Is Your Chief Compliance Officer Lonely?
• “Too Important to Jail,” the Yates Memorandum and FCPA Criminal Prosecutions
• DOJ’s “Filip” Factors and Corporate Prosecutions
• Criminal Prosecutions of Individuals Outside the FCPA
• Justice Department Resolves Two Cases Under FCPA Pilot Program
• La Bella Vita in Sicilia
• Webinar: The Importance of a Risk and Compliance Program Assessment
• Will the Justice Department Continue to Use DPAs and NPAs?
• The Importance of Compliance Program Audits
• Working in a “Happy Talk” Corporate Culture
• Top 5 Mistakes Chief Compliance Officers Make (And How to Avoid Them)
• Tom Fox and Michael Volkov Discussion on Blockchain and Compliance
• Poor Performing CEOs and Boards and Compliance Disasters
• CCOs and Resources: Put Your Money Where Your Mouth Is!
• Are Risk Assessments Just a Report on the Obvious?
• 5 Telltale Signs of a Weak Corporate Culture
• Two Steps Forward, One Step Back – Mixed Bag of Compliance Progress
• The Challenge of Auditing and Monitoring Your Distributors
• Blockchain and the Future of Compliance
• The EU’s New General Data Privacy Regulation (GDPR) – Global Companies New Compliance Test
• CCOs: The Importance of Documenting a Compliance Program
• “The Future is Now” — Compliance and Technology
• A CCO’s Challenge: How to Convince a CEO to Embrace Compliance
• Ensuring Compliance with Controls
• Promoting an Ethical Culture — Actions Not Just Words
• HCCA-OIG Resource Guide on Measuring Compliance Program Effectiveness
• The Compliance Profession Needs to Adopt Professional Standards
• Transparency in FCPA Enforcement
• Understanding Special Counsel Mueller’s Authorization
• Take the FCPA Quiz and Test Your Knowledge of the FCPA — Sponsored by Workplace Answers
• Obstruction of Justice – A Primer
• Effective Compliance and the Importance of Accounts Payable Function
• The State of Mind of a White Collar Criminal
• Data Privacy and Security – What is the Difference?
• MoneyGram CCO Pays Civil Penalty
• The Compliance Profession and the Demand for “Results”
• The Danger of Corporate Scandals – When CEOs and Senior Executives Circle the Wagons to Impugn a CCO
• Webinar: Managing Supply Chain Risks
• Corporate Shell Games and KYC Requirements
• Wait a Minute – The FCPA Enforcement Sky Did Not Fall?
• Compliance and Financial Audits – Distinctions With Substance
• What is the Real Risk of an FCPA Enforcement Action?
• The Revolution in Compliance Training – It is Not Just About Your ABCs
• Knowing Your Employees and Incident Management Systems
• Compliance is Not “Rocket Science”
• Yates, AG Sessions and Individual Criminal Prosecutions
• What Compliance Needs to Know About Data Privacy and Security
• Congrats to the New International Association of Independent Corporate Monitors
• Beneficial Ownership Due Diligence Requirements
• Dutch Prosecutors Record Shell CEO and Ensnare Shell in Nigeria Bribery Scandal
• Corporate Culture and Whistleblowers: A Reliable Barometer of a Company’s Culture
• United’s Crisis Mismanagement and Corporate Culture
• TD Bank and Sanctions Violations
• Wells Fargo’s Desperate Need for a Compliance and Business Ethics Function (Part III of III)
• Mike Volkov’s New E-Book — Moving the Goalposts: The Justice Department Redefines Effective Compliance
• The Axe Falls on Wells Fargo – A Scathing Independent Report (Part II of III)
• Can Wells Fargo Fix its Defective Culture? (Part I of III)
• A Money Laundering Nightmare: Western Union Ponies Up $770 Million to Settle with DOJ, FTC and FinCEN
• New White Paper — Online Compliance Training: Making the Right Choice
• A Strategy for Non-Disclosure of FCPA Violations
• Webinar: Ten Essential Elements of a Third Party Risk Management System
• Human Trafficking and Smuggling – A Compliance Requirement
• AML Enforcement and Compliance Trends
• FCPA Remediation Focus on Supervisory Personnel
• The Three Lines of Compliance Offense Versus The Three Lines of Compliance Defense
• Compliance, Technology and Data Analytics
• Lawyers and Culture in the Financial Services Industry
• Legal and Compliance Coordination – An Essential Foundation to an Effective Compliance Program (Part IV of IV)
• Webinar: Antitrust Training: Avoiding Criminal Cartel Risks
• Getting to Know You, Getting to Know All About You — Business Buy-In to Compliance Functions (Part III of IV)
• Bridging the Gap: Uniting Compliance and Financial Controls (Part II of IV)
• Operationalizing Compliance – Natural Partners and Breaking Down Walls (Part I of IV)
• DOJ’s Compliance Program Evaluation Guidance
• Managing Your Ethical Culture: Measure, Intervene and Remediate
• Welcome to New Sponsor: Exiger, a Global Governance, Risk and Compliance Leader
• ZTE Pays the Price for Circumventing Sanctions and Export Controls
• FCPA Pilot Program Motors On
• Compliance and Private Equity: An Oxymoron?
• The Two Most important Words in a Compliance Dictionary: Trust and Integrity
• Review, Revise and Re-Organize Your Company’s Internal Controls (Part II of II)
• A New Approach to Internal Controls (Part I of II)
• Webinar: DOJ Issues New Compliance Evaluation Guidance
• DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits (Part IV of IV)
• DOJ’s Compliance Program Evaluation: Risk Assessment, Policies and Procedures and Third-Party Risk Management (Part III of IV)
• DOJ’s Compliance Program Evaluation: the Role of the CCO (Part II of IV)
• Under the Dark of Night, DOJ Moves the Compliance Ball (Part I of IV)
• Parallel Universes: Antitrust Leniency and the FCPA Pilot Program
• Unpacking the Justice Department’s Compliance Remediation Standards (Part I of II)
• The FCPA Pilot Program Disciplinary Standards (Part II of II)
• Yikes: The Perils of Remediation and Corporate Monitors
• Focus on the Issue of “Corrupt Intent”
• The Test for Bad Actors in a Bad Company
• Webinar: Update on Healthcare Enforcement and Compliance Strategies
• The Challenges Facing the Antitrust Leniency Program and the Yates Memorandum
• SEC Snares Two “Masterminds” Behind Och-Ziff Bribery Scheme
• Walking the Walk and Talking the Talk – A CEO’s Commitment to Ethics and Compliance
• The Win-Win Argument: Compliance as a Marketing Advantage
• Las Vegas Sands Suffers Double Whammy and Resolves FCPA Action with DOJ for $7 Million
• Serious Fraud Office Makes Big Splash with UK Bribery Act Resolution with Rolls Royce
• C-Suite Misconduct Results in Sociedad Quimica Y Minera FCPA Resolution with DOJ and SEC
• FCPA Recidivists: Orthofix (Part II of II)
• Webinar: Lessons Learned from 2016 — Strategies to Improve Your Compliance Program
• FCPA Recidivists: Zimmer Biomet (Part I of II)
• The “New” Face of Corporate Misconduct
• The FCPA Enforcement Run Continues into 2017
• Lessons Learned and Compliance Trends from the VW and Takata Scandals (Part III of III)
• NAVEX Global Webinar: 2017 — An Evolving Landscape for Third Party Risk Management
• Takata – Criminal Airbag Scheme and Innocent Consumer Harm (Part II of III)
• Volkswagen: When Car Companies Veer Off Course (Part I of III)
• Multi-Jurisdictional Prosecutions and the SFO Show Teeth in Rolls Royce Settlement
• Mondelez FCPA Enforcement Action — An Abuse of Prosecutorial Discretion?
• The Real Explanation for the Record Year for FCPA Enforcement
• Tom Fox and Mike Volkov on FCPA Enforcement and Compliance Year in Review — 2016
• Predicting the Future: What Would Truly Global Anti-Corruption Enforcement Look Like?
• Compliance Trends and Predictions for 2017
• FCPA Predictions for 2017 (Part III of III)
• Trends from 2016 Record FCPA Enforcement Year (Part II of III)
• Badda Bing, Badda Boom!! — DOJ and SEC Make 2016 a Record Year for FCPA Enforcement (Part I of III)
• Webinar: 2016 FCPA Enforcement and Compliance Year in Review — January 10, 2017 12 Noon EST
• Tom Fox and Mike Volkov Podcast on the Odebrecht and Teva FCPA Settlements

2016

• 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 2016

2015

• 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 Bang

2014

• 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 – 2014

2013

• 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 & Compliance

2012

• 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 2012

2011

• 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