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...

Elizabeth Slim, Senior Consultant at the Volkov Law Group, discusses Anti-Money Laundering and Financial Compliance trends.  Liz recently joined the Volkov Law Group and has extensive experience in the banking and financial compliance industry.  She is major thought leader in anti-money laundering compliance and enforcement, and a leader at ACAMS. In this Episode, Michael Volkov discusses Liz’s career and her thoughts on AML and financial...

The Justice Department continues to aggressively pursue False Claims Act cases.  In 2019, DOJ recovered over $3 billion from healthcare, defense and financial companies.  The heath care sector — pharmaceutical, medical device, hospitals and healthcare providers — continues to be the primary focus of False Claims Act cases.  Qui tam relators initiate a significant percentage of all False Claims Act cases. In this episode, Michael Volkov...

2019 was a big year for OFAC enforcement and compliance — OFAC collected $1.28 billion in fines and penalties in a total of 26 separate enforcement actions.  OFAC also issued important compliance program guidance, mandating a number of important requirements for compliance programs. OFAC’s enforcement record for 2019 focused on supply chain sourcing; acquisition of foreign companies engaged in transactions with prohibited countries and customers;...