Author: Michael Volkov

Cybersecurity Threats and Risks

Companies are correctly focused on cybersecurity risks.  Notwithstanding this focus, companies are struggling with how to respond to threats and risks.  Cybersecurity threats are quickly evolving – akin to the time when countries engaged in military arms races.  As they evolve, companies have to embrace proactive strategies and cannot rely on a compliance strategy that reacts to events and threats. Cyber criminals are quickly embracing...

Renewing Corporate Vows to the Chief Compliance Officer

Our goals can only be reached through a vehicle of a plan, in which we must fervently believe, and upon which we must vigorously act. There is no other route to success — Pablo Picasso The chief compliance officer is at an important professional juncture – 2018 is an important year for the profession.  In this era of growth, and after corporate tax relief, companies...

Episode 22 — Testing and Evaluation of Your Compliance Program

As more companies implement ethics and compliance programs, chief compliance officers are increasingly focusing on the need to test and evaluate their compliance program.  An effective testing program provides important information that compliance officers can use to improve their respective compliance programs. In this episode, Michael Volkov and Jacqui Merrill, Senior Counsel at the Volkov Law Group, discuss how to test and evaluate your compliance...

The Need for Anti-Money Laundering Regulatory Reform

It is rare these days for Republicans and Democrats to agree on political priorities – another profound grasp of the obvious.  Recently, on Capitol Hill there appears to be some common ground on the issue of reforming AML laws and regulations. The motivation is to make financial AML regulations “smarter” and increase focus on beneficial ownership, terrorist financing and proactive detection of money laundering.  Some...

Financial Institutions Are Playing Catch-Up in AML and Sanctions Compliance

Compliance officers are a much more collaborative group of professionals than lawyers.  Compliance officers share information with colleagues about compliance experiences, best practices and strategies.  The compliance industry benefits from this sharing of information. On occasion, however, this sharing of a company’s performance in one area can lead to unfair judgments by a recipient of the information.  For example, one company may conduct an in-depth...

Webinar: How to Implement an Effective Internal Investigation Program

Webinar: How to Implement an Effective Internal Investigation Program Tuesday, February 6, 2018, 12 noon EST SIGN UP HERE An effective ethics and compliance program depends on an efficient internal investigation function. Corporations have to design and implement an internal investigation system that is fair, timely and reliable. To do so, companies need to identify risks, assign resources, monitor investigations and mete out disciplinary actions....

Regulators Slap Banks, MSBs and Card Club with AML Violation Penalties

Financial institutions face enormous pressures with respect to anti-money laundering compliance.  These burdens are about to grow with implementation of customer due diligence rules.  In 2017, federal and state regulators stepped up AML enforcement.  Here is a quick rundown of some of the enforcement actions: Citibank paid a $70 million penalty  to the Office of the Comptroller of the Currency (here) for violating its 2012...

Episode 21 — Interview of Jean-Michel Ferat, FCPA Forensic Accounting Expert, Senior Managing Director, Ankura Consulting

Jean-Michel Ferat, a leading FCPA Forensic Accountant, and Senior Managing Director at Ankura Consulting, joins Michael Volkov, in Episode 21 of the Podcast, Corruption Crime & Compliance. Jean-Michel Ferat is a leading forensic accountant and has vast experience in uncovering complex bribery schemes and financial crimes.  Jean-Michel also works with large, mid-size and small companies to design and implement effective financial accounting controls and remediate...

Three Simple Steps to Improve Your Corporate Culture

Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us and provides a posting on corporate culture.  Lauren can be reached at lconnell@volkovlaw.com. What exactly does “corporate culture” mean?  Compliance professionals often talk about how important “tone from the top” or the “mood in the middle” is, but what does that really mean? Improving corporate culture has been directly tied to higher profits and...