Tom Fox, Matt Kelly, Jonathan Armstrong and Jay Rose recently recorded Episode 3 of Everything Compliance. Here is a link to the Episode — HERE. In this episode, we discuss a variety of topics including anti-corruption enforcement across the globe, the new French anti-corruption law, Sapin II, the Agricultural Bank of China compliance enforcement action by the state of New York Department of Financial Services;...
Compliance officers have to avoid professional myopia. The focus of compliance these days has been on anti-corruption, antitrust, and AML, depending on your company’s industry. They fit nicely together under an anti-corruption umbrella. But limiting your compliance program to these areas is shortsighted. Other legal and regulatory requirements require careful attention for compliance and can impose harsh penalties for noncompliance – export compliance is a...
Chief compliance officers face imposing tasks on a daily basis. The tasks often look insurmountable and it is easy for CCOs to just turn away and find a more manageable set of tasks. Compliance requires resources and those resources are not limitless. In other words, a CCO has to decide how to allocate limited resources. A CCO has to be an efficiency expert, especially when...
I am pleased to announce the availability of a new ebook, Trump and Compliance, which includes contributions from the podcast crew at Everything Compliance: Tom Fox, Matt Kelly, Jay Rosen, Jonathan Armstrong and myself. Many thanks to Corporate Compliance Insights for making this ebook available. The book is available here.
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I am pleased to announce our new website for The Volkov Law Group — Here Many thanks to Volkov Law Team members: Managing Associate, Lauren Connell; Associates, Jacqui Merrill and Susan Simpson; and Counsel, Vincent Ruiz. We offer the following services: Corporate and individual criminal defense Corporate ethics and compliance programs Internal investigations Please contact us if you are interested in would like to discuss...
Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the risk created by third party intermediaries. In the last five years, companies have embraced new technologies to automate their third party screening and monitoring programs. Companies are slowly but steadily replacing...
There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has committed itself to increasing transparency. That is a very good thing. If you go back and review FCPA settlement actions from years ago, you will not find any structured...
Two executives were charged last week with criminal violations in the Southern District of New York relating to Valeant Pharmaceuticals activities. These charges are the first of more to come in an ongoing investigation focusing on Valeant’s corporate demise from a high-flying pharmaceutical company. I have written before about Valeant’s rotten culture, slavish devotion to quarterly performance, and short-sighted management culture that ultimately bred a...
In the risk mitigation business, we often focus on legal risks, such as anti-corruption, sanctions, export controls, antitrust and AML. As compliance programs mature, and the CCOs focus on proactive strategies, one key issue is conflict of interest. My experience with conflict of interest issues has confirmed that such conflicts often mask more serious compliance issues relating to fraud and even legal violations. As such,...
