Category: General

17 May, 2019

Watch Bureau Van Dijk Webinar Replay — “Is Power and Control the New Beneficial Ownership?”

On May 16, 2019, I participated in a live webinar sponsored by Bureau Van Dijk, “Is Power and Control the New Beneficial Ownership?” The panel discussion was interesting and insightful. Ted Datta, Director, Governance, Risk and Compliance Solutions, Bureau van Dijk, Bill Hauserman, Senior Director, Compliance Solutions, Bureau van Dijk, and myself. The replay is available HERE. (Replay begins at 14:00) The discussion covered a...

General

16 May, 2019

The Positive and Negative Mix of Corporate Compliance Trends

We all like to believe in straight-forward and consistent trends and developments. For example, compliance programs are improving, budgets are increasing, and CCOs are embracing new technologies. Everything is just rosy when it comes to compliance. But reality is far from consistent and far from simple trend lines and straight-forward explanations. Please do not get me wrong – over the last ten years, the rise...

General

15 May, 2019

Report from SEC Conference: Compliance, Cooperation and Culture

Jessica Sanderson, Senior Counsel at The Volkov Law Group, recently attended the Rocky Mountain Securities Conference in Denver, Colorado. Jessica’s posting summarizes the major compliance themes from the conference. Jessica can be reached at jsanderson@volkovlaw.com. On Friday May 3, 2019, I attended the Rocky Mountain Securities Conference in Denver and heard from a number of regulators and industry experts, including SEC Commissioner Hester Peirce. SEC...

General

14 May, 2019

OFAC Framework for Sanctions Compliance Programs – Review of Lessons Learned from Enforcement Actions (Part IV of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s new compliance framework includes a valuable section on common root causes of OFAC violations. OFAC has included this discussion to assist companies in designing, updating and amending their respective Sanctions Compliance Programs (SCPs). The discussion...

General

13 May, 2019

OFAC Framework for Sanctions Compliance Programs – Testing and Auditing and Training (Part III of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s new Framework for Sanctions Compliance Programs incorporates a number of important principles from Justice Department and US Sentencing Guideline requirements for effective compliance programs. Today, I am going to review the requirements relating to Testing...

General

9 May, 2019

OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s Framework for Sanctions Controls Program is a heightening of the importance of ethics and compliance program and reflects significant expectations for implementing effective compliance strategies. Risk Assessment In Risk Assessment, OFAC recommends that organizations conduct...

General

8 May, 2019

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”) (Here). ...

General

8 May, 2019

DOJ’s New Corporate Compliance Guidance: Does Your Compliance Program Work? (Part V of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 14, 2019, at 12 noon EST. Sign up HERE. The final issue discussed in the new DOJ Corporate Compliance Guidance is the assessment of whether a company’s compliance program is working – at the time of the offense and at the time of the resolution of an enforcement...

General

6 May, 2019

DOJ’s New Corporate Compliance Guidance: Implementation, Operationalization and Effectiveness (Part IV of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 9, 2019, at 12 noon EST. Sign up HERE. While I hate to start out a posting with such “mumbo jumbo” terms, I had to come up with short hand descriptions of some otherwise fairly complex and robust topics under the new DOJ Guidance. In evaluating whether a...

General

3 May, 2019

DOJ’s New Corporate Compliance Guidance: Training and Communications, Reporting and Investigations, Third-Party Management and Mergers and Acquisitions (Part III of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 9, 2019, at 12 noon EST. Sign up HERE. The Justice Department’s new Corporate Compliance Guidance is keyed to the concept of a “well-designed compliance program.” Under this concept, we first examined risk assessments and policies and procedures. DOJ’s Corporate Compliance Guidance also addresses training and communications, reporting...

Category: General

Watch Bureau Van Dijk Webinar Replay — “Is Power and Control the New Beneficial Ownership?”

The Positive and Negative Mix of Corporate Compliance Trends

Report from SEC Conference: Compliance, Cooperation and Culture

OFAC Framework for Sanctions Compliance Programs – Review of Lessons Learned from Enforcement Actions (Part IV of IV)

OFAC Framework for Sanctions Compliance Programs – Testing and Auditing and Training (Part III of IV)

OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV)

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

DOJ’s New Corporate Compliance Guidance: Does Your Compliance Program Work? (Part V of V)

DOJ’s New Corporate Compliance Guidance: Implementation, Operationalization and Effectiveness (Part IV of V)

DOJ’s New Corporate Compliance Guidance: Training and Communications, Reporting and Investigations, Third-Party Management and Mergers and Acquisitions (Part III of V)

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It’s the Culture, Stupid

Pointing the Finger

Moving the Goalposts

A Return to Common Sense