Category: General

Report from SEC Conference: Compliance, Cooperation and Culture

Jessica Sanderson, Senior Counsel at The Volkov Law Group, recently attended the Rocky Mountain Securities Conference in Denver, Colorado.  Jessica’s posting summarizes the major compliance themes from the conference.  Jessica can be reached at jsanderson@volkovlaw.com. On Friday May 3, 2019, I attended the Rocky Mountain Securities Conference in Denver and heard from a number of regulators and industry experts, including SEC Commissioner Hester Peirce. SEC...

OFAC Framework for Sanctions Compliance Programs – Review of Lessons Learned from Enforcement Actions (Part IV of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s new compliance framework includes a valuable section on common root causes of OFAC violations.  OFAC has included this discussion to assist companies in designing, updating and amending their respective Sanctions Compliance Programs (SCPs).  The discussion...

OFAC Framework for Sanctions Compliance Programs – Testing and Auditing and Training (Part III of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s new Framework for Sanctions Compliance Programs incorporates a number of important principles from Justice Department and US Sentencing Guideline requirements for effective compliance programs.  Today, I am going to review the requirements relating to Testing...

OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s Framework for Sanctions Controls Program is a heightening of the importance of ethics and compliance program and reflects significant expectations for implementing effective compliance strategies.  Risk Assessment In Risk Assessment, OFAC recommends that organizations conduct...

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”) (Here). ...

DOJ’s New Corporate Compliance Guidance: Training and Communications, Reporting and Investigations, Third-Party Management and Mergers and Acquisitions (Part III of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 9, 2019, at 12 noon EST. Sign up HERE. The Justice Department’s new Corporate Compliance Guidance is keyed to the concept of a “well-designed compliance program.”  Under this concept, we first examined risk assessments and policies and procedures.  DOJ’s Corporate Compliance Guidance also addresses training and communications, reporting...

DOJ’s New Corporate Compliance Guidance: Risk Assessments and Policies and Procedures (Part II of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 9, 2019, at 12 noon EST. Sign up HERE. The Justice Department’s new Corporate Compliance Guidance is keyed to three topics:  Design of a Corporate Compliance Program  Effective Implementation  Does the Compliance Program “Work in Practice”? Part 1 of the Corporate Compliance Guidance addresses the following elements of...

DOJ Issues New and More Robust Guidance on Evaluation of Corporate Compliance Programs (Part I of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 9, 2019, at 12 noon EST. Sign up HERE. In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs (HERE).  The new Evaluation Guidance supersedes the prior document issued in...