In response to aggressive FCPA enforcement, the compliance industry has embraced innovative strategies and tools. Whether your company is large, medium or small, it is important to stay abreast of industry best practices. Some of these new strategies can be modified for application in different size companies. Join Michael Volkov, CEO of The Volkov Law Group, for an examination of FCPA compliance program best practices....
In this era of aggressive FCPA enforcement, companies are adopting anti-corruption compliance programs. The Department of Justice and the SEC have warned companies against adopting “paper compliance programs” without meaningful and consistent implementation. In recent weeks, FCPA enforcement has focused on hiring of relatives of foreign officials and corruption schemes involving third parties. Join Michael Volkov, CEO of The Volkov Group, as he discusses ways...
Almost every FCPA enforcement action involves misconduct by third party agents and distributors. The Justice Department and the SEC have emphasized the importance of companies conducing appropriate due diligence. In the absence of proper due diligence procedures and documentation, companies face significant bribery and enforcement risks. Companies that design and implement due diligence policies and procedures are taking proper precautions to avoid costly government investigations...
The Department of Justice had a record year in criminal antitrust enforcement. Global enforcement and coordination continues to increase. As a result, global companies face significant antitrust risk from cartel activity. Unlike the anti-corruption area, companies have not devoted significant resources to improving their compliance programs and integrating antitrust compliance into an overall compliance and ethics program. Join Michael Volkov, CEO of The Volkov Group,...
Companies are devoting more resources to monitoring their compliance and ethics programs. Whether the audit is conducted at corporate headquarters or in the field, there are important issues which should be examined during the audit. Join Michael Volkov, CEO of The Volkov Group, as he discusses how to audit a compliance program. View more videos like this on the Volkov Law Group YouTube Channel.
FCPA risks are significant when companies acquire other companies. The Justice Department and the SEC have imposed “successor” liability on companies for past bribery violations committed by an acquired company. Pre-closing due diligence is critical when companies buy another company. Due diligence is an art, not a science, and critical for companies to identify and resolve potential FCPA liability. Join Michael Volkov, CEO of The...
My colleague Tom Fox is a fountain of wisdom on ethics and compliance issues. If you know Tom and hear him speak, you know he has seen a lot of corporate compliance situations – good and bad. With this perspective, it is always worth it to listen to Tom and heed his advice. Tom and I share a common perspective (or so I would like...
Companies are devoting more time and attention to building a robust anti-corruption compliance program. As they do so, it is important to design the right structure for the compliance program — from the Corporate Board, to the C-Suite and the role of the Chief Compliance Officer. An effective anti-corruption compliance program requires not only the right structure for an organization but important policies, procedures and...
On September 26, 2013, the Federal Acquisition Regulatory (FAR) Council published proposed rules to implement new human trafficking compliance requirements on government contractors and subcontractors. President Obama signed an Executive Order almost a year ago to eliminate human trafficking by government contractors and subcontractors. Similar requirements were imposed on Defense Department contractors several months later when Congress enacted, and the President signed, the Defense Reauthorization...
The recent headlines on China’s expanding anti-corruption investigation and enforcement action is a significant event in global anti-corruption enforcement. For companies operating in China, the risks have now increased exponentially. Companies need to redouble their compliance and ethics programs in China to minimize the risk of an enforcement action. Join Michael Volkov, CEO of The Volkov Law Group, as he discusses anti-corruption enforcement risks and...
