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...
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...
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,...
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...
