Despite the COVID-19 pandemic, the SEC entered into a settlement with Eni for $24.5 million for FCPA violations. In another matter, the SEC filed an FCPA case against a former Goldman Sachs executive for bribery in connection with business on behalf of a client in Ghana. In this episode, Michael Volkov reviews these two enforcement actions.
The Justice Department and the FBI have quickly acted to focus on fraudsters and hoarders who are preying on the public panic in response to the pandemic. DOJ has focused on new fraud schemes promising miracle cures and other means to take advantage of the public on the Internet. At the same time, DOJ and the FBI have targeted hoarders of critical medical supplies who...
Judge Stanley Sporkin, a mentor, friend and professional colleague, died at age 88 on March 23, 2020. In a personal tribute to Judge Sporkin, I recount some highlights of my relationship with Judge Sporkin.
Companies need to review and enhance their antitrust compliance programs, especially those companies with tangible antitrust risks. In designing an effective antitrust compliance program, there are five key elements to an antitrust compliance program: (1) Risk Assessment; (2) Culture and Senior Management Buy-In; (3) Monitoring and Testing; (4) Training; and (5) Speak Up and Reporting Systems. In this Episode, Michael Volkov discusses the key elements of an...
An effective third-party risk management program has to include robust monitoring and auditing strategies. This episode is a companion to Episode 129 on creating a third-party risk profile. In this episode, Michael Volkov outlines strategies for monitoring and auditing your third-party population.
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) is aggressively enforcing OFAC sanctions rules. Last year, OFAC issued its Framework for Sanctions Compliance Programs, which includes a specific requirement for companies to conduct a “holistic” risk assessment. In this episode, Michael Volkov outlines practical strategies for conducting a sanctions risk assessment.
Companies continue to refine their third-party risk management programs. As an initial step, companies have to create a third-party risk profile for its population. To accomplish this task, companies have to classify and stratify their third parties. In this episode, Michael Volkov discusses how to review your third-party population and create a risk profile.
Companies are rapidly implementing automated solutions for compliance program functions. Technology accelerates compliance program performance and creates opportunities to measure and evaluate a company’s compliance program. In this Episode, Michael Volkov discusses how to measure and evaluate a compliance program using data generated from automated platforms.
In a comprehensive enforcement action, the Office of the Comptroller of Currency (OCC) announced a $17.5 million settlement with former Wells Fargo Bank CEO John Stumpf for his role in the sales practices misconduct scandal. In addition, the OCC announced settlements with two other Wells Fargo executives: (1) Hope Hardison, former Chief Administrative Officer and Director of Human Resources, Cease and Desist Order and $2.25 million...
In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve charges with the United States, France, and the United Kingdom for its role in a bribery scheme, and to resolve Airbus’ violation of the International Trade in Arms Regulations...
