The Volkov Law Group is proud to contribute to the compliance media in order to promote compliance ideas and issues. Stephen Cheng, an Associate at The Volkov Law Group, recently published an article on the Justice Department new Evaluation of Corporate Compliance Programs. The article is available Here. Matt Stankiewicz, a Senior Associate at The Volkov Law Group, was quoted in a recent article on...
As a long-time Bob Dylan fan, I have suffered the ups and downs of his career. Well, not really “suffered” but empathized may be a better way to express my commitment. We all remember the days when Dylan embraced Christianity and recorded some great music with Dire Straits. Slow Train Coming was a great song (listen here). Now, to bring this analogy to corporate board...
We all know the phrase – “A fish rots from its head.” A perfectly accurate statement as to how corporate culture can suffer from leadership failures or C-Suite misconduct. But there is much more to corporate culture than just what happens in the C-Suite. Day-to-day events throughout the company can infect a corporate culture as well. A well-oiled machine means that corporate leadership establishes ethical...
Compliance officers and internal auditors are natural partners and allies in the compliance governance landscape. As the compliance profession and influence grew, compliance officers often leaned on internal auditors for help in assessing risks, uncovering financial misconduct, and assessing compliance functions and controls. Recently, however, I have noticed some changes in their relationship, suggesting that they both are maturing and gaining independence from each other. ...
Converge19 is scheduled for October 1 to October 3, 2019. I am proud to participate in the event and scheduled to speak on OFAC Sanctions Compliance. If interested in attending, please sign up here. The Agenda is here. CONVERGE19 is in its 4th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with...
This is likely to be a politically incorrect posting. I hope I do not offend too many people, especially those new data privacy professionals. As kids, we were always excited when an ice cream truck visited our neighborhood offering a new flavored ice cream. For a brief period of time, the new ice cream flavor was the popular rage. In the corporate legal and compliance...
The California Consumer Privacy Act (CCPA) presents numerous compliance challenges for businesses. Given the heightened focus on consumer privacy and ever-increasing enforcement risks, companies have to move quickly to ensure appropriate compliance programs are in place by January 1, 2020. Any business that collects, stores and processes consumer information is subject to significant risks. The importance of CCPA compliance is not limited to businesses that...
When the federal government fails to assume responsibility for establishing law and policy in important federal areas of jurisdiction, the individual states then spring into action to fill the vacuum. When the Framers considered the proper role of the federal government after the debacle of the misguided Articles of Confederation, the Framers adopted our Constitution premised on the foundation of a strong federal government. Unfortunately,...
In a major announcement and escalation of the sanctions regime targeting President Maduro and Venezuela, on August 5, 2019, the Trump Administration issued a new Executive Order 13884 (Here) to block all property of the Venezuela Government. The aggressive action was implemented to target the Maduro regime. At the same time, OFAC issued 12 amended general licenses (Here) and 13 new general licenses (Here), and...
Most compliance officers will admit that they have more than enough responsibilities in their purview. They are usually not looking for more. I have some bad or good news on this front depending on your perspective. As companies struggle with cybersecurity and data privacy issues, companies should naturally turn to compliance to play a larger role in overall risk mitigation strategies. Up to now, it...
