Category: Podcasts

Episode 11 — Seven Individuals Charged with FCPA Criminal Violations

In a watershed week for FCPA enforcement, the US Department of Justice announced FCPA criminal charges against seven individuals.  Specifically, the Justice Department announced four guilty pleas and one indictment as follow on prosecutions to the January 2017 Rolls Royce FCPA enforcement action, and two guilty pleas in a yet to be announced enforcement action against SBM Offshore. The Justice Department’s unprecedented week underscored that...

Episode 10 — How to Conduct a Risk and Compliance Program Assessment

An effective ethics and compliance program requires a careful assessment of risks and existing controls.  In order to design and implement an effective program, a chief compliance officer has to identify and prioritize company risks.  In addition, a CCO has to review and understand how existing compliance controls mitigate existing risks. A risk assessment is the foundation of a compliance program, but has to incorporate a...

Episode 9 — The Need for a Robust Criminal Antitrust Compliance Program

Global companies and corporate officers and employees face significant criminal antitrust risks.  The US Department of Justice’s Antitrust Division has a mature and aggressive enforcement program targeting illegal cartel activity.  Unfortunately, companies have been slow to implement ethics and compliance programs that are adequately focused on these serious criminal risks. In this episode, Michael Volkov discusses the need for robust ethics and compliance programs and...

Episode 8 — The Critical Importance of Beneficial Ownership to Compliance

In the aftermath of the Panama Papers scandal and increased focus on shell companies and hidden ownership interests, US enforcement and regulatory agencies are increasing focus on beneficial ownership of related entities.  In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers in order to ensure full compliance with anti-corruption,...

Episode 7 — The Perils of Compliance with the Russia Sanctions Program

The Ukraine-Russia Sanctions program is a complex set of executives orders, statutes and regulations defining prohibited business transactions with Russian entities and individuals.  The sanctions program was instituted in 2014 in response to Russia’s invasion of the Ukraine and annexation of Crimea.  In August 2017, Congress enacted statues and directed OFAC to implement additional regulations.  Congress acted in response to fears that the Trump Administration...

Podcast Episode 6 — ISO 37001 — Anti-Bribery Risk Management System: Something Old or Something New?

Podcast Episode 6 examines ISO 37001 — Anti-Bribery Risk Management System.  Please sign up HERE for our free webinar on ISO 37001 scheduled for October 24, 2017 at 12 Noon EST. The ISO 37001anti-bribery risk management system was issued in 2016.  The standard provides additional guidance on anti-bribery risk management systems and creates a certification process for organizations. Even after one year, there are still...

Podcast Episode 5 — Interview of Tom Fox

Corruption, Crime & Compliance is pleased to welcome Tom Fox, the Compliance Evangelist, for an interesting interview on Tom’s career, his vast compliance program and writing network, and his interesting perspectives on the compliance profession.

Podcast Episode 4 — Too Big To Fail, Too Big To Jail, DOJ’s Outsourcing of Criminal Investigations

The Department of Justice’s approach to criminal prosecution of corporations and individuals has evolved over the last 20 years. Beginning with the traditional model of building criminal cases, brick-by-brick, by investigating and prosecuting individuals, traditionally used to dismantle organized crime and drug trafficking/gang organizations, the Justice Department has now embraced a new model of enlisting corporations to conduct internal investigations, usually with the assistance of...

Podcast 3 — The Latest FCPA Undercover Sting — John Baptiste Case

Recently, the Justice Department announced the arrest of John Baptiste as part of an ongoing investigation into corruption in Haiti.  The arrest warrant affidavit outlines an undercover investigation, including Title III wiretaps of John Baptiste’s cellphone. In this podcast, Michael Volkov reviews the investigation of Baptiste, culminating in the arrest of Baptiste on August 28, 2017. A copy of the arrest warrant affidavit is here.

Podcast Episode 2 — Ethics and Profits

With the increased focus on corporate culture, chief compliance officers have to educate the board and senior management on the inextricable link between an ethical culture and financial profitability. In this episode of Corruption, Crime & Compliance, Michael Volkov outlines the link between ethical culture and sustainable growth.  During the episode, Michael refers to two studies on the subject.  The studies are noted below with...