Author: Michael Volkov

La Bella Vita in Sicilia

In the immortal words of Goethe, “To have seen Italy without having seen Sicily is not to have seen Italy at all, for Sicily is the clue to everything.” In my experience, I would add to have experienced Sicily is to understand one’s own heart and soul. On this Fourth of July holiday, it is helpful to focus on gratitude and thankfulness. In these turbulent...

Webinar: The Importance of a Risk and Compliance Program Assessment

The Importance of a Risk and Compliance Program Assessment Wednesday, July 13, 2017, 12 noon EST Sign Up HERE An effective ethics and compliance program requires a careful assessment of risks and existing controls.  In order to design and implement an effective program, a chief compliance officer has to identify and prioritize company risks.  In addition, a CCO has to review and understand how existing compliance...

Will the Justice Department Continue to Use DPAs and NPAs?

“Those who cannot change their minds cannot change anything.” ― George Bernard Shaw With a new administration at the Department of Justice, practitioners and commentators are looking for signs of change. Given the current politics of the new administration, the Justice Department will undergo changes in civil rights, antitrust, and criminal enforcement. These “new” or return to old policy announcements were not surprising since they went hand-in-hand...

The Importance of Compliance Program Audits

Chief compliance officers spend a significant amount of time comparing their compliance programs with other companies’ programs. CCOs often find solace when benchmarking their respective programs against other companies’ programs. I often refer to “benchmarking” as a process designed to reduce anxiety. CCOs need feedback on their efforts. CCOs want to know where they stand and develop priorities for initiatives. So where should CCOs turn?...

Working in a “Happy Talk” Corporate Culture

Honesty is the best policy – when there is money in it. – Mark Twain Compliance professionals encounter a diverse range of corporate personalities in their work. To be sure, compliance officers have to rely on their abilities to analyze, lead, persuade, understand and motivate different functions in a company to contribute to the company’s ethics and compliance function. In doing so, compliance officers have...

Poor Performing CEOs and Boards and Compliance Disasters

The business headlines are filled with the latest corporate scandal – Uber’s defective culture, CEO misconduct and reprehensible comments by supervising board members. Uber is just one of several significant companies caught in the headlines. Wells Fargo has been caught in another scandal just when it was thought to be dealing with the sales incentives scandal. Many high-profile companies are facing difficulties, usually self-inflicted from...

CCOs and Resources: Put Your Money Where Your Mouth Is!

The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot commodities in the in the corporate governance world. It is an intoxicating time for compliance professionals. In this environment, CCOs have to be wary. CEOs and other corporate leaders know how to talk the...

Are Risk Assessments Just a Report on the Obvious?

If you give a Chief Compliance Officer truth serum and ask him/her whether they believe a risk assessment is valuable, what do you think the CCO say? Let’s start with the cynical side – not that I am a pessimist. Many CCOs will candidly tell you that a risk assessment provides them with a colorful and expensive report on the company’s risks that contains no...