Category: General

10 Jan, 2017

Predicting the Future: What Would Truly Global Anti-Corruption Enforcement Look Like?

Lauren Connell, Managing Associate at The Volkov Law Group, joins us with a posting on the recent Odebrecht settlement. Lauren can be reached at [email protected]. Within the SEC and DOJ’s blockbuster ending to 2016 was the Odebrecht settlement. The amount involved, a stunning $4.5 billion (pending a possible reduction for inability to pay), grabbed headlines around the world. But more interesting than the final figure...

General

9 Jan, 2017

Compliance Trends and Predictions for 2017

The past year was another great success for the compliance profession and related technologies. Compliance continues to grow as the “professionalization” of compliance continues to skyrocket. As my good friend Donna Boehme always reminds me, compliance professionals have the requisite subject matter expertise that many other professionals such as lawyers and auditors lack. I often remind compliance professionals of the old saying – “Be careful...

General

8 Jan, 2017

FCPA Predictions for 2017 (Part III of III)

With the new incoming administration, everyone is busy predicting major changes in DOJ FCPA enforcement. I do not share this view. Frankly, FCPA enforcement is more bipartisan than other controversial enforcement programs (e.g. civil antitrust and merger enforcement), and DOJ’s FCPA program is very profitable. While there may be a renewed effort by the Chamber of Commerce to raise FCPA reform again, I do not...

General

4 Jan, 2017

Trends from 2016 Record FCPA Enforcement Year (Part II of III)

No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands. We are witnessing a significant turning point in FCPA enforcement in which the Justice Department and the SEC are slowly but surely pushing companies to embrace a more robust ethics...

General

4 Jan, 2017

Badda Bing, Badda Boom!! — DOJ and SEC Make 2016 a Record Year for FCPA Enforcement (Part I of III)

We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017. From the narrow perspective of FCPA enforcement, the Justice Department and the SEC have demonstrated yet again the maturation of their respective aggressive FCPA enforcement programs. As in 2014 (but not...

General

1 Jan, 2017

Tom Fox and Mike Volkov Podcast on the Odebrecht and Teva FCPA Settlements

It is always a pleasure to participate in FCPA and compliance discussions with Tom Fox. Tom and I recorded a podcast on the Odebrecht and Teva Pharmaceuticals FCPA enforcement actions. A copy of the recording is available here. Happy New Year!!!!

General

29 Dec, 2016

T’Was the Week After Christmas: General Cable and Mexico Aviation FCPA Prosecutions

You know this has been a big year in FCPA enforcement when DOJ and the SEC announce two FCPA settlements during the usually sleepy week between Christmas and New Years. And what a year it has been – more to follow in my post-New Years series of postings. General Cable The SEC and DOJ announced a $75 million settlement for FCPA violations with General Cable...

General

23 Dec, 2016

Happy Holidays and New Year

Corruption Crime & Compliance and The Volkov Law Group wish everyone happy holidays, peace and a wonderful New Year. We appreciate all the support from our readers and clients. We hope you enjoy your holidays with your family and friends. See you next year in 2017!!!

General

22 Dec, 2016

The Power of Honesty – A Candid Assessment of Your Compliance Program

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. Groucho Marx We are all taught the importance of honesty. But there are very different aspects to this otherwise simple proposition. People are sometimes honest with each other, and sometimes they are not. Honesty, however, is a much harder concept when speaking to your self – you...

General

20 Dec, 2016

Hiding Behind the Privilege – A Cloak or a Dagger?

CCOs face many challenges in their jobs. One area that is difficult but usually can be solved with common sense is where to draw the line on attorney-client privilege issues. As a practicing attorney, I can attest to the importance of the attorney-client privilege. It is a principle that is critical to the functioning of a corporation or any other organization. Communications for the purpose...