We all know that businesses rely on a large number of third-party vendors to support their business operations. Many of these third parties require access to a company’s data and its internal information and technology systems. This digital fact of life creates a real cyber risk for illegal intrusions. Over half of all cyber-attacks are the direct or indirect result of third party access. Third-party...
Deepak Chopra, one of my favorite “thinkers” (if that is a word) reminds us that there is no such thing as a coincidence – there is what he terms a “synchronicity of the universe.” (See here and here for some additional explanation). Not to say, I told you so, but around the same time that the Capital One data breach occurred, I was reminding clients...
Juniper Networks agreed to pay the SEC $11.7 million to settle FCPA violations for conduct occurring in Russia and China. See Order Here. Under the settlement, Juniper Networks agreed to disgorgement of $4 million, a $6.5 million civil penalty, and pre-judgment interest of $1.3 million. The Juniper Networks investigation was initiated approximately six years ago in 2013. The Justice Department had declined to prosecute Juniper...
If there ever was a poster-child for reputational damage for a financial institution, Deutsche Bank would be the first and only candidate. Talk about a bank that is in trouble and continues to fall under government scrutiny. Last week, Deutsche Bank agreed to pay the SEC $16 million for its hiring of relatives of public officials in China and Russia. (Here). Deutsche Bank joins a...
In an interesting decision, well worth a read here, on August 9, 2019, the US Court of Appeals for the Second Circuit rejected Ng Lap Seng’s appeal of his 2017 conviction for bribery of united Nationals officials. In affirming the conviction, the Second Circuit ruled that the Supreme Court’s holding in McDonnell (see blog post here), in which the Court ruled that under 18 USC...
The Volkov Law Group is proud to contribute to the compliance media in order to promote compliance ideas and issues. Stephen Cheng, an Associate at The Volkov Law Group, recently published an article on the Justice Department new Evaluation of Corporate Compliance Programs. The article is available Here. Matt Stankiewicz, a Senior Associate at The Volkov Law Group, was quoted in a recent article on...
As a long-time Bob Dylan fan, I have suffered the ups and downs of his career. Well, not really “suffered” but empathized may be a better way to express my commitment. We all remember the days when Dylan embraced Christianity and recorded some great music with Dire Straits. Slow Train Coming was a great song (listen here). Now, to bring this analogy to corporate board...
We all know the phrase – “A fish rots from its head.” A perfectly accurate statement as to how corporate culture can suffer from leadership failures or C-Suite misconduct. But there is much more to corporate culture than just what happens in the C-Suite. Day-to-day events throughout the company can infect a corporate culture as well. A well-oiled machine means that corporate leadership establishes ethical...
Compliance officers and internal auditors are natural partners and allies in the compliance governance landscape. As the compliance profession and influence grew, compliance officers often leaned on internal auditors for help in assessing risks, uncovering financial misconduct, and assessing compliance functions and controls. Recently, however, I have noticed some changes in their relationship, suggesting that they both are maturing and gaining independence from each other. ...
Converge19 is scheduled for October 1 to October 3, 2019. I am proud to participate in the event and scheduled to speak on OFAC Sanctions Compliance. If interested in attending, please sign up here. The Agenda is here. CONVERGE19 is in its 4th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with...
