Category: Podcasts

Episode 249 — DOJ Issues New Corporate Enforcement Policy

The Biden Administration promised a new, aggressive approach to corporate crime. Well, the Justice Department just delivered a new, comprehensive policy that raises a number of issues, some of which are likely to be controversial. The new policy incorporates reforms announced last October that largely centered on prior corporate criminal and civil records; appointment of independent compliance monitors and expanding review of responsible persons in an internal...

Episode 248 — Deep Dive into the GOL Brazil FCPA Enforcement Action

The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges. GOL entered into a three-year deferred prosecution agreement (“DPA”) with DOJ in exchange for payment of a $17 million criminal penalty. DOJ credited $1.7 million of that penalty against a $3.4 million fine that GOL agreed...

Episode 247 — Corporate Culture Round Up

Corporate culture is all the rage now, meaning it is an often used topic to signal commitment, sensitivity to issues of employee concern, and an awareness of governance trends. In practice, as we all know, culture is not just about words — it is about action. As the often repeated phrase goes — talk is cheap.  In this Corporate Culture Roundup Episode, Michael Volkov examines some culture-related...

Episode 246 — NAVEX’s Annual Global Hotline Benchmarking Report

As the leading hotline provider in the global market, NAVEX is in the unique position of collecting and analyzing employee reporting trends. Each year, NAVEX issues an important report on current trends in employee reporting, whistleblowers, internal investigations and potential retaliation. NAVEX’s most recent report is interesting. NAVEX’s database consists of 1.37 million reports made in 2021 at organizations around the world.  In this Episode, Michael Volkov...

Episode 245 — Second Circuit Affirms Trial Judge Dismissal of FCPA Verdicts Against Alstom Executive

The Second Circuit Court of Appeals affirmed the district judge’s post-conviction dismissal of FCPA counts against Lawrence Hoskins, a former Alston executive, for his involvement in bribery scheme to secure a $118 million energy contract in Indonesia.  The Hoskins FCPA case has had a long and tortious path through the court system, and the Second Circuit’s decision, which was decided by a 2 to 1...

Episode 244 — Building a Compliance Program Dashboard

Chief compliance officers have access to a vast amount of data generated by their compliance programs. CCOs have to establish effective monitoring processes. A critical part of this process is to build a compliance program dashboard. This is a practical issue of real importance.  In this Episode, Michael Volkov reviews this important issue.

Episode 243 — Scott Greytak, Transparency USA, and Erica Hanichak, the FACT Coalition, on House Passage of The Enablers Act

In a bipartisan success story, the House recently passed The Enablers Act, which is a far-reaching reform bill aimed at reducing AML and corrupt financial activity in the United States. Scott Greytak, Advocacy Director at Transparency International USA, and Erica Hanichak, Director of Government Affairs at the FACT Coalition, join Michael Volkov for a discussion of this legislative accomplishment and the implications for the battle...

Episode 242 — LRN Report on Assessing Corporate Culture — Interview of Ty Francis, LRN Chief Advisory Officer

LRN has released a new and informative report on Assessing Corporate Culture. LRN’s report provides invaluable guidance and practical steps for corporate boards to lead in the management, oversight and monitoring of corporate culture. A link to the report is below, along with an earlier LRN report on Benchmarking Ethical Culture. In this Episode, Michael Volkov interviews Ty Francis, Chief Advisory Officer at LRN, concerning...

Episode 241 — Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program

The Justice Department and various regulatory agencies continue to emphasize the importance of continuous improvement, testing and review as part of robust assessment procedures in an effective compliance program.  The Treasury Department’s Office of Foreign Asset Control has specifically stated that a sanctions compliance program should include “a comprehensive, independent, and objective testing or audit function” so that a company can determine “how their program[]...

Episode 240 — The CCO’s Role in an Effective Compliance Program

I have been — and continue to be– hyper-focused on the proper role and responsibilities for Chief Compliance Officers. Not that I see any cause for alarm, but it is easy to lose focus in the sea of so-called hot issues — ESG, Diversity, Climate Change, Threats to Democracy, Cybersecurity and Data Privacy, each of which is an important component and focus for organizations. All of these...