Author: Michael Volkov

Challenges in Global Compliance Operations: Structure and Responsibilities (Part I of II)

Global companies face ever-increasing challenges when building and implementing global ethics and compliance programs.  From my vantage point, the set of challenges can be different depending on the industry.  Global regulated companies, such as pharmaceutical, medical device or financial institutions, face a different constellation of challenges than a global manufacturing company. Notwithstanding the risk and compliance differences among the specific industries, there are a number...

Webinar: Making Your Board of Directors a Partner in Compliance

Webinar:  Making Your Board of Directors a Partner in Compliance Tuesday, February 20, 2018, 12 Noon EST Sign Up HERE Corporate boards set the tone for a company’s compliance program. Directors are responsible for overseeing and monitoring the company’s compliance program. Yet, corporate boards are not actively fulfilling their responsibilities. Chief compliance officers have to engage the company’s board, educate the board and secure a...

Resources, Resources, and More Resources – The True Test of an Effective Ethics and Compliance Program

An effective ethics and compliance program depends on the Chief Compliance Officer’s authority, independence, and resources.  A company’s commitment to a compliance program requires money and employees – there is no question that words of support, organizational status in the C-Suite and a robust board reporting relationship are all important.  However, all those elements are important but, in the end, those principles mean relatively little...

“Trust Better Be Your Most Important Value” – Marc Benioff, Salesforce CEO

Given the turbulent times we live in, it is refreshing when we hear a corporate leader explain the importance of trust as a corporate value.  Marc Benioff is the CEO at Salesforce who is aggressively pushing his company to meet a target revenue of $20 billion by 2022. More importantly, at a recent panel discussion at the Davos World Economic Meeting, Benioff gave a powerful...

Episode 24 — Corporate Board Reform

The growth in ethics and compliance has had a dramatic impact on corporate actors, including the CEO, chief compliance officers, internal audit and chief financial officers.  The corporate board’s role in compliance continues to be deficient.  Corporate boards are in for a rude awakening — a new era of accountability for ethics and compliance is beginning. In this episode, Michael Volkov outlines the issues surrounding...

Criminal Enforcement Against Senior Executives: The Fish Rots from the Head

The compliance community is well aware of the risks in the C-Suite.  As you move up the corporate ladder, the level of risk from executive misconduct increases.  A rotten executive can quickly bring down a company, destroy its reputation, and raise a host of legal and reputational problems.  I have written numerous times on the importance of assessing C-Suite risks and building compliance and financial...

Cybersecurity Compliance for Financial Institutions

The New York Department of Financial Services has adopted detailed cybersecurity regulations for financial institutions.  (Here).  The NYDFS has filled a vacuum created by the failure of the federal government to act in this important area.  Congress has failed to enact any specific requirements; the federal government continues to rely on voluntary efforts and recommended standards.  As long as this vacuum continues, state regulators and...

The KPMG Debacle – Five Former KPMG Employees and Former PCAOB Employees Indicted for Fraud and Conspiracy

KPMG has been taking it on the chin lately – and apparently for good reason.  KPMG is enmeshed in an unfolding corruption scandal in South Africa.  Add to that the indictment last week of five individuals (four KPMG employees and a Public Company Accounting Oversight Board (“PCAOB”)) and the unsealing of a guilty plea by another individual from KPMG and a former PCAOB employee.  (See...

Episode 23 — Tom Fox and 2017 FCPA Year in Review

Tom Fox rejoins Corruption, Crime & Compliance for a 2017 FCPA Review.  Tom discusses important trends and events from 2017 in FCPA enforcement and compliance. Tom is the thought-leader on FCPA and compliance issues.  He maintains the popular blog, FCPA Compliance & Ethics, the Podcast Network and is a prolific author of numerous books, articles, and e-books.

Cybersecurity: The Law and Regulatory Framework

Cybersecurity law is a patchwork of global statutes and regulations.  Unfortunately, Congress has failed to act in this area, leaving the EU and US States to “lead.”  As a result, companies are often required to follow the lowest (or highest) common denominator, depending on your perspective. At the US federal level, we have specific industries that have requirements for protecting sensitive personal information.  The Health...