Author: Michael Volkov

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...

Webinar: 2018 Ethics and Compliance Program Trends and Expectations

Webinar: 2018 Ethics and Compliance Trends and Expectations Tuesday, January 16, 2018, 12 noon EST SIGN UP HERE The compliance profession continues to increase its influence in the corporate governance landscape.  The Justice Department’s aggressive prosecution of global companies for anti-corruption violations, as well as international enforcement and compliance developments, has created a comprehensive set of compliance trends and government expectations as to compliance functions....

Time to Test and Audit Your Compliance Program

We all enjoy citing government sources for guidance on an effective ethics and compliance program.  Whether it is the United States Sentencing Guidelines, the Justice Department’s and SEC’s FCPA Guidance, Health and Human Services – Office of Inspector General, or the many other sources for guidance, companies have to test and audit their compliance programs to ensure that the program reflects the company’s changing constellation...

Five Major Compliance Predictions for 2018

When you look back on the rise of the ethics and compliance profession, you cannot ignore the history of accomplishments.  It is easy to minimize these accomplishments as a reaction to the government’s aggressive FCPA enforcement program. Companies are starting to embrace ethics and compliance as a positive force to build sustainable financial growth – which is the true calling of a robust ethics and...

Episode 20 — Data Security and Privacy Compliance

Companies face increasing challenges from management and protection of data from hackers and breaches of sensitive commercial and personal data.  Recent headlines have underscored the threats to companies from such breaches.  The risk of reputational harm to companies is serious.  Complaince departments are starting to play an increased role in mitigating these serious risks. In this episode, Michael Volkov and Lauren Connell, Managing Associate from...

Justice Department Closes Out 2017 with 2 FCPA Actions: Keppel Offshore and Marine and Embraer Individual

The Department of Justice finished 2017 with two significant FCPA enforcement actions, and fittingly, one was a corporate settlement and another was an individual criminal guilty plea.  The Justice Department’s final FCPA enforcement actions for 2017 included an interesting settlement with Keppel Offshore and Marine Ltd. (KOM), a Singapore based, global shipyard and repair company, and a criminal guilty plea from a sales executive involved...

2018 FCPA Predictions (Part II of II)

I always take a deep breath when starting this posting – not that I am the kiss of death, but sometimes my predictions come true and most times they do not.  But with that caveat, I am brave enough to venture into 2018 and offer some predictions. First, and this may not be so surprising, individual FCPA criminal prosecutions will continue to increase.  In fact,...

2017 FCPA Year in Review (Part I of II)

With the close of 2017, FCPA enforcement continues as a major priority for the US Department of Justice.  Notwithstanding fears and concerns that the new administration would turn its back on FCPA enforcement, the Justice Department’s work continues unabated and unhindered.  All the doomsayers have to admit that no big changes have occurred in the Justice Department’s commitment to battle global corruption. The Numbers Looking...