Category: General

Renewing Corporate Vows to the Chief Compliance Officer

Our goals can only be reached through a vehicle of a plan, in which we must fervently believe, and upon which we must vigorously act. There is no other route to success — Pablo Picasso The chief compliance officer is at an important professional juncture – 2018 is an important year for the profession.  In this era of growth, and after corporate tax relief, companies...

The Need for Anti-Money Laundering Regulatory Reform

It is rare these days for Republicans and Democrats to agree on political priorities – another profound grasp of the obvious.  Recently, on Capitol Hill there appears to be some common ground on the issue of reforming AML laws and regulations. The motivation is to make financial AML regulations “smarter” and increase focus on beneficial ownership, terrorist financing and proactive detection of money laundering.  Some...

Financial Institutions Are Playing Catch-Up in AML and Sanctions Compliance

Compliance officers are a much more collaborative group of professionals than lawyers.  Compliance officers share information with colleagues about compliance experiences, best practices and strategies.  The compliance industry benefits from this sharing of information. On occasion, however, this sharing of a company’s performance in one area can lead to unfair judgments by a recipient of the information.  For example, one company may conduct an in-depth...

Regulators Slap Banks, MSBs and Card Club with AML Violation Penalties

Financial institutions face enormous pressures with respect to anti-money laundering compliance.  These burdens are about to grow with implementation of customer due diligence rules.  In 2017, federal and state regulators stepped up AML enforcement.  Here is a quick rundown of some of the enforcement actions: Citibank paid a $70 million penalty  to the Office of the Comptroller of the Currency (here) for violating its 2012...

Three Simple Steps to Improve Your Corporate Culture

Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us and provides a posting on corporate culture.  Lauren can be reached at lconnell@volkovlaw.com. What exactly does “corporate culture” mean?  Compliance professionals often talk about how important “tone from the top” or the “mood in the middle” is, but what does that really mean? Improving corporate culture has been directly tied to higher profits and...

Time to Test and Audit Your Compliance Program

We all enjoy citing government sources for guidance on an effective ethics and compliance program.  Whether it is the United States Sentencing Guidelines, the Justice Department’s and SEC’s FCPA Guidance, Health and Human Services – Office of Inspector General, or the many other sources for guidance, companies have to test and audit their compliance programs to ensure that the program reflects the company’s changing constellation...

Five Major Compliance Predictions for 2018

When you look back on the rise of the ethics and compliance profession, you cannot ignore the history of accomplishments.  It is easy to minimize these accomplishments as a reaction to the government’s aggressive FCPA enforcement program. Companies are starting to embrace ethics and compliance as a positive force to build sustainable financial growth – which is the true calling of a robust ethics and...

Justice Department Closes Out 2017 with 2 FCPA Actions: Keppel Offshore and Marine and Embraer Individual

The Department of Justice finished 2017 with two significant FCPA enforcement actions, and fittingly, one was a corporate settlement and another was an individual criminal guilty plea.  The Justice Department’s final FCPA enforcement actions for 2017 included an interesting settlement with Keppel Offshore and Marine Ltd. (KOM), a Singapore based, global shipyard and repair company, and a criminal guilty plea from a sales executive involved...

2018 FCPA Predictions (Part II of II)

I always take a deep breath when starting this posting – not that I am the kiss of death, but sometimes my predictions come true and most times they do not.  But with that caveat, I am brave enough to venture into 2018 and offer some predictions. First, and this may not be so surprising, individual FCPA criminal prosecutions will continue to increase.  In fact,...