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...
Happy Holidays to everyone!! The Volkov Law Group wishes you and your loved ones a happy holiday season. Corruption, Crime & Compliance will return in the New Year — 2018!! Thank you to our clients, our subscribers and followers. All the best.
Tom Fox, Matt Kelly, Jonathan Armstrong, Jay Rosen and myself recorded a new episode of Everything Compliance. In the first part of a two-part episode, Tom, Matt and I discuss the new FCPA corporate enforcement policy. You can listen Here. Thanks Tom, Matt, Jonathan and Jay.
I am pleased to announce the release of my new e-book: Pointing the Finger — How Corporate Boards are Dodging Accountability and What CCOs Can Do About It. My new e-book can be downloaded HERE. Thanks to Corporate Compliance Insights for publishing the book and its continuing support. The compliance revolution has had a dramatic impact on important actors in the compliance arena – the...
A basic truism is – ethics and compliance reinforce each other. An ethical culture is an effective control against violations of law and a company’s code of conduct. Conversely, legal compliance promotes a company’s commitment to an ethical culture. Larger global companies are more likely to identify reputational risks as its greatest threat. (See Here NAVEX Global Third Party Benchmark Report). My favorite Warren Buffet...
On November 26, 2017, the Justice Department announced adoption of its new FCPA Corporate Enforcement Policy. Deputy Attorney General Rod Rosenstein announced the new policy at an FCPA Conference in Washington, D.C. Under the new policy, corporations that voluntarily disclose potential FCPA violations, fully cooperate with the investigation and implement timely and appropriate remediation will earn a presumptive declination, subject to the absence of aggravating...
Chief compliance officers for financial institutions are going to have a rough May 2018. First, on May 11, 2018, the new CDD Rule for beneficial ownership becomes effective. Two weeks later, on May 25, 2018, the EU’s General Data Protection Regulation becomes effective. FinCEN CDD Rule FinCEN’s new Customer Due Diligence rules will have a significant impact on the collection of beneficial ownership information and...
The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations. How is that for a profound grasp of the obvious? All kidding aside, the question is how much has the balance been changed? I am not sure there will be a significant increase in the number of companies deciding to seek the benefits under the new...
I am excited to announce a recent product development launch for our sponsor, NAVEX Global, an innovative leader in the ethics and compliance field. We are proud to work with NAVEX Global, a company that works hard to create products that deliver practical solutions for ethics and compliance professionals. Although third-party risk management is a top concern for many organizations, it is common to hear that...
The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA Guidance, and the specific Hallmarks of an Effective Compliance and Ethics Program is the most definitive statement on compliance expectations ever released by US prosecutors. Since 2012, the Justice Department has built on...
