The headline on Medicare last week was astounding — $60 billion (not million) was lost each year to Medicare fraud, large numbers of fraudulent providers were providing fake or badd addresses – meaning locations including hamburger stands, vacant lots, mailbox shops. According to a recent GAO report (here), Medicare pays money to fraudsters at approximately 23,400 fake or bad addresses (22 percent of all provider...
FCPA enforcement will likely take a turn into the private equity industry. I know this is a regular claim by FCPA practitioners but we already can see the beginning of the trend. The “princeling” investigations are ongoing and the industry is fighting back, claiming that internships awarded to family members of foreign officials were not given with corrupt intent or were not of any value...
I am pleased to announce the release of my new e-book — The Art of the Internal Investigation — by Corporate Compliance Insights. To download a free copy, please visit here. Conducting an internal investigation in today’s risky enforcement environment requires numerous — if not continuous — judgement calls. Stakes are high, and answers are never black-and-white. In this free eBook, Michael Volkov wields his...
A compliance program without CEO support is almost doomed to be ineffective. We all live by the standard of an “effective” ethics and compliance program. I am always reluctant to embrace a dogmatic expression but the support, and hands-on participation of a CEO, can be the difference between an effective and ineffective compliance program. A CEO not only has to embrace the importance of an...
Volkov Law TV announces new subscription options and pricing for on-demand Webinars. We know our scheduled webinars do not always fit your busy schedule: Learn What You Want, When You Want It! Volkov Law TV Here We now offer pricing for individual webinars and have reduced our subscription fees. In addition, we offer Flexible Enterprise Rates for companies and organizations if needed. Individual Webinars are...
AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go (view episode here) – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of the end of the pipe, and so on — you will get the picture. We all know about the...
One thing about maintaining a blog – you have nightmares (alright something a little less than that) about consistency in writing. All of us can be accused of having “evolving” positions, so maybe that is my rationalization. If you had to boil down the lessons of compliance, the reasons for its exponential growth in corporate governance, and the impact that compliance has had in corporate...
As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as regulators have paid more attention to the issue, and companies have recognized the importance of training as an effective means to communicate directly to managers and employees about ethics and compliance expectations. The FCPA...
Multinational companies cannot employ and maintain a sufficient number of dedicated compliance staff to ensure the effectiveness of an ethics and compliance program. That is a reality and we all know that is true. Instead, global companies have to figure out ways to leverage other personnel from other functions to serve as some part of a global compliance functions. This regularly occurs with respect to...
You can observe a lot by just watching – Yogi Berra There is way too much time being spent on esoteric arguments about corporate board reporting responsibilities for Chief Compliance Officers. Let’s agree and move on to more important and difficult issues. I hate to be dogmatic but when it comes to this issue, there really is one obvious solution. Varying alternatives are less than...
