Chief compliance officers recognize the importance of conducting robust audits of their compliance programs. The audit process requires a delicate balance between qualitative and quantitative measures. As corporate compliance programs build data analytics and technological capabilities, CCOs have to tailor the audit program to incorporate data as an effective measure of a compliance program. In this Episode, Michael Volkov reviews strategies for conducting compliance program...

The culture bandwagon is picking up steam.  Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations.  In its latest corporate compliance guidance, the Justice Department, along with numerous regulatory agencies continue to cite the importance of a company’s  “culture of compliance.” But when it comes to defining the terms, how to...

LRN recently issued its second of three annual reports on ethics and compliance program effectiveness.  The second report focuses on board engagement with ethics and compliance and lessons learned from the COVID-19 pandemic.   David Greenberg, a Special Advisor to LRN, joins us to discuss the interesting results of the LRN report. The LRN report can be downloaded HERE.

In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran Sanctions Program. AL US enlisted its then subsidiary (now operating unit), Alfa Laval Tank, Inc, based in Exton, Pennsylvania (AL Tank), to participate in the scheme.  The Alfa Laval enforcement...

The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021. The first case against a corporate entity in 2021 is an interesting one because it reflects a coordinated settlement not only between DOJ and the SEC but the U.K.’s Serious Fraud Office and Brazil’s Ministério Público Federal (MPF),...

Under Armour settled its long-pending SEC investigation by agreeing to pay $9 million surrounding misleading statements and practices relating to its revenue growth and uncertainties as to future growth. As part of the settlement, the SEC declined to bring charges against its CEO, Kevin Plank, and its CFO, David Bergman. The Justice Department inquiry appears to have lost steam since the middle of last year, and...

In a far-reaching action, the Biden Administration elevated the global fight against corruption as a national security interest. In an Executive Memorandum, the Biden Administration made a strong statement against corruption, citing the devastating impact that corruption has on democratic institutions, democratic governments, economic development, and other public interest objectives. The Administration launched a robust inter-agency review of the anti-corruption battle, including increased international cooperation,...

LRN and NAVEX Global release two important annual surveys.  LRN issues a yearly report on ethics and compliance program effectiveness.  NAVEX Global issues an important annual report on incident management trends based on its large database of hotline data. In this Episode, Michael Volkov review these two reports and the important ethics and compliance trends.