One of the many challenges in the compliance profession centers on coordination and integration. There are plenty of compliance experts who can describe a perfect world – how to design a specific program and procedures to implement the program. Vendors are ready to line up at a chief compliance officer’s door and sell them products which will carry out a specific program. The challenge for...
Consider it one of my (many) pet peeves – companies claim they have an “ethical” culture and cite the consistent statements by the CEO of his or her commitment to “ethics and integrity.” That’s it, that’s all, we have an ethical culture. Case closed, deal done, let’s move on to the next issue. Talk about bloviating and hot air – it is the prime example...
I am pleased to announce the launch of the new Volkov Law Group website (Here), Facebook Page (Here), Linked In Profile (Here) and You Tube Channel (Here). My practice has grown from largely a solo practice to a boutique practice, and currently includes three talented associates. Our firm focuses on compliance, enforcement defense and internal investigations. We have created a platform which will assist our...
Forgive me for this column in advance but I had to chuckle a little bit when I read that JP Morgan was creating global compliance SWAT teams who, on a moment’s notice, would travel around the globe to respond to compliance emergencies. I know I have written on behalf of Chief Compliance Officers and the important role they play in every company, but I was...
You have to admire chief compliance officers for their tenacity and ability to multi-task. They are the consummate jugglers of important projects, strategies and tasks. They can never completely finish their tasks – when one is finished, the list continues to grow with more to dos. Over the last few years, companies have paid more attention to third-party due diligence. As a result, companies have...
As I have frequently stated, if your business is operating in China, chances are you are violating the FCPA. That sounds very cynical but there is a measure of reality to my claim. With all the recent attention from the GSK investigation in China which is rapidly extending to other drug companies, China should be on every company’s mind. There are several important aspects to...
June 19, 2013 12 Noon – 1 PM Register Here FCPA enforcement started out slowly this year and then exploded in the second quarter. DOJ indicted individuals from the BizJet case, revealed undercover operations in another case, and settled the fourth largest case in FCPA enforcement history. All of this activity should come as no surprise to companies and practitioners. Join Michael Volkov, CEO, The...
Every company has its share of internal politics, rivalries and tensions. No organization is free from internal strife. For a company to be successful, you need talented, ambitious and intelligent people. It is hard for a company to avoid internal struggles, turf wars and competition among rivals. It is part of the healthy energy which drives a company forward. Occasionally, internal jockeying can be damaging...
Timing is everything. Woody Allen said it best – 80 percent of life is just showing up. Unless you are the Chamber of Commerce. Talk about bad timing and sour grapes. The Chamber just does not get the message. After the Justice Department and the SEC issued its FCPA Resource Guide, the Chamber is still not satisfied. Whatever you may say about the FCPA Resource...
In this era of whistleblower risk, companies need to prepare for whistleblower complaints which are made outside the company. Whistleblowers are not required to report complaints internally nor wait for any specific period of time to benefit under the SEC whistleblower program. Instead, whistleblowers have an incentive to wait for 120 days before contacting the government. Under the SEC’s whistleblower regulations, a whistleblower is entitled...
