We all agree on the importance of corporate culture. Everyone gets it – corporate leaders mouth the words but rarely understand the nuances, and the need to attend to a company’s culture. Compliance professionals want to devote more time to corporate culture but often are overburdened with less important tasks. It is easy for compliance professionals to get lost in the details, theory, and technology...
The United States continues to suffer from the absence of a federal data privacy and breach law. Congress has tried for years to broker a deal here but has never been able to overcome strong lobbying forces — whether its high-tech, trial lawyers, law enforcement or other gadflies, the public continues to suffer. Instead, global businesses face a real mess, tracking data privacy laws state-by-state,...
Michael Volkov recently was a guest on David Noah’s Podcast, Passages: International Trade, to discuss the SEC’s 3M FCPA Case. You can watch their discussion HERE — A Deeper Look: 3M Corp. Pays SEC $6.5 Million to Resolve FCPA Violations.
Sam Finkelstein, an associate at The Volkov Law Group, rejoins us for a posting on DOJ’s initiative to increase corporate prosecution of sanctions, export controls and national security issues. Sam can be reached at [email protected]. The marriage of corporate enforcement and national security has been a defining feature of the DOJ under the Biden Administration. The Justice Department’s commitment to prosecuting corporate crimes that implicate...
Alex Cotoia, Regulatory Compliance Manager at The Volkov Law Group, rejoins us for an interesting posting on BIS’ recent enforcement action against Pratt & Whitney for violation of the antiboycott regulations. Alex can be reached at [email protected]. On September 27, 2023, the United States Department of Commerce’s Office of Antiboycott Compliance, a division of the Bureau of Industry and Security (“BIS”), publicized an unanticipated and...
Daniela Melendez, a new Associate at The Volkov Law Group, rejoins us for another blog post on DOJ’s first corporate prosecution for violations of the Iran Sanctions Program. Daniela can be reached at [email protected]. The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message...
Daniela Melendez, a new Associate at The Volkov Law Group, joins us for her first blog posting. If you want to contact Daneila, she can be reached at [email protected]. The Ethics and Compliance Initiative (“ECI”) is a terrific organization that provides important ethics and compliance insights and leadership. Starting in 1994, ECI has conducted a longitudinal, cross-section study of workplace conduct. ECI recently issued its...
Mary Shirley, a leading voice in the legal and compliance field, has just released her new book — Living Your Best Compliance Life: 65 Hacks & Cheat Codes to Level Up Your Ethics & Compliance Program. Order Mary’s New Book Here. Mary is a well-known advocate, speaker and compliance professional. She regularly speaks at Compliance events. She is mentor to the Compliance Profession. Whether you’re...
The Justice Department’s Opinion Release procedure has provided important guidance over the years. The library of Opinion Release letters is well-organized and accessible to the legal and compliance community. In its most recent Opinion Release, 23-1, DOJ affirms its prior determinations and sets forth some best practices governing payment for foreign official travel and related expenses. The focus of the Opinion Release is the FCPA’s...
The Antitrust Division has been active – like any aggressive prosecution strategy, however, its results have been mixed. Its record in criminal cases has taken serious hits – a stunning set of losses in the chicken price-fixing cases and defeats in criminal labor market cases. DOJ has been quietly and steadily building cases in the generic pharmaceutical industry. DOJ’s most significant criminal case charged both...
