Bobby Butler, a well-known and long-time compliance professional, joins Michael Volkov for a thought-provoking discussion on the rise of the compliance profession. Bobby has had a long and successful career in compliance. He provides important insights into the evolution of the compliance profession, strategies for building compliance programs and the future of compliance and the compliance profession.
The Justice Department has brought three corporate FCPA enforcement actions in 2023 (if you include the Ericsson DPA breach settlement). With its recent announcement of a declination under the Corporate Enforcement Policy, DOJ has declined two FCPA cases and one healthcare fraud case in 2023. DOJ publicizes the declination letters issued in accordance with the Corporate Enforcement Policy. DOJ officials have made numerous public statements...
Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable, and to protect the organization from potential private and government claims or investigations that may have serious direct or collateral consequences. Companies that want to use ephemeral messaging systems can do so but they have to understand the risks involved and tailor appropriate controls and procedures...
Matt Stankiewicz, Partner at The Volkov Law Group, provides a post on the latest fraud charges in the cryptocurrency industry, brought against SafeMoon. Matt can be reached at [email protected]. On November 1, 2023, the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) brought charges against cryptocurrency project SafeMoon LLC and its U.S. subsidiary SafeMoon US LLC, along with its three executives,...
The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious). The reasons for this may be a question of timing elements in the pipeline of cases. What is clear is that pushing through an enforcement action and settlement requires increased coordination with a growing number of international partners. That may be part of the explanation. In this environment,...
From Compliance to Sustainability December 6, 2023 10 am EST/4 pm CET SIGN UP HERE Gan Integrity and Control Risks have announced an important upcoming webinar addressing the evolving third-party risk management context — From Compliance to Sustainability. Third-party risk management has evolved at a rapid pace over the past decade. The regulatory environment has quickly followed suit. Enterprises, however, are struggling to keep up...
LRN’s annual Program Effectiveness Report is chock full of important findings. Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it). Susan and Michael discuss several important findings in LRN’s 2023 Report: High-performing ethics and compliance programs rely principally on values to motivate and guide ethical and compliant behavior — LRN’s Report confirms again...
Matt Stankiewicz, Partner at The Volkov Law Group PC, provides important context regarding OFAC’s new General Licenses under the Venezuela Sanctions Program. Matt can be reached at [email protected]. As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief. Specifically, OFAC issued General License 44 (among others) that broadly authorizes transactions related to...
The Biden Administration issued a sweeping Executive Order directing a broad set of government actions addressing consumer harms, discrimination, privacy protections and other issues stemming from the widespread use of artificial intelligence. While the Executive Order sets forth a set of requirements to various federal agencies, the actions will establish important standards and expectations applicable to the federal government and have a resulting impact on...
December 6, 2023 12 Noon EST SIGN UP HERE The Department of Justice recently announced revisions to its Merger and Acquisition Corporate Enforcement Policy to encourage voluntary self-disclosures. DOJ Deputy Attorney General Monaco outlined the new Mergers & Acquisitions Safe Harbor Policy. Under this new Policy, companies that promptly and voluntarily disclose criminal misconduct within the Safe Harbor period, and then cooperate with the resulting...
