A nickel ain’t worth a dime anymore. – Yogi Berra With all the hubbub about ethics and compliance, senior managers somehow are able to escape any focus or responsibility for compliance programs except in a managerial context. Senior managers need to be held accountable for their own personal ethics and compliance performance as senior executives with significant responsibilities. The GM debacle is a perfect example...
Compliance professionals love to bandy about the term “red flag.” It is a term with infinite meanings depending on the context. A red flag in a money-laundering context is different than a red flag in a corruption context. I like to say – not all red flags are created equal. Some red flags are more red than others – or in extreme cases, I use...
Companies are reluctant to go to trial in a criminal case. Instead, they look for alternatives short of a criminal guilty plea and DOJ has a suitcase full of options that they use. Please do not misunderstand my point – DOJ prosecutors are doing their job and they apply the law fairly. There is room for disagreement on their interpretations and application of the law...
Welcome!! I hope you like the new Corruption, Crime and Compliance website. I know how important it is to stay fresh on the Internet, and my hope was to provide an updated look, with some new features. One thing you will notice (hopefully) is that we have added access to all of our recorded webinars. We will maintain our You Tube channel but we wanted...
The Antitrust Division is nearing the end of its largest, record-setting criminal cartel investigation – global auto parts suppliers. It has been a sprawling investigation that has leaped from product-to-product in the auto parts industry. Nearly thirty companies have plead guilty (or agreed to do so) and over $2.3 billion in fines have been collected. Nearly forty individual have been charged, most of which have...
I am excited to announce the addition of three new members of The Volkov Law Group. When I launched the firm, I was committed to providing high-quality ethics and compliance, and enforcement defense services. With the help of my existing members, Lauren Connell, Dave Lusby, Evan Lee and Jon Umarov, we have been fortunate to grow and develop our services and capabilities. I am proud...
The FCPA Guidance turned two years old recently – November 14 to be exact. No one wrote about the milestone, nor has anyone praised the FCPA Guidance. To be the contrarian, I am writing to wish the FCPA Guidance a very happy birthday and to sing its praises. In honor of the FCPA Guidance’s birthday, I recently conducted a webinar on the FCPA Guidance. The...
It is important to acknowledge and respect your roots. It is great to welcome new and important legal bloggers. Starting out a blog for professionals is a challenging and fun process. Two new entrants on the blogosphere are worthy of everyone’s attention. Sidebars: Randall Eliason has started a terrific blog on white collar crime and federal criminal law. I have known Randy for over 25...
I am pleased to announce that The Volkov Law Group’s recorded webinars can now be downloaded from ITunes. As many of you know, The Volkov Law Group maintains a You Tube Channel that includes recordings of all the webinars we have conducted over the past two years. The You Tube Channel is here. To expand access to these recordings, we have created podcasts of the...
Companies and Chief Compliance Officers have taken significant actions to emphasize the importance of a company’s code of conduct. A well-designed code of conduct is a foundation for an effective ethics and compliance program. It is the core from which other policies and procedures are designed. It presents the company’s ethics and compliance program as a unified whole, without irrelevant detours into other topics. A...
