Global Companies face a complex set of data breach notification requirements.  In the absence of a uniform federal standard, companies have to tailor their data breach notification procedures to meet the requirements of 50 U.S. states.  With respect to European Union residents, global companies have to meet stringent requirements established by the General Data Protection Regulations. In this episode, Michael Volkov reviews the data breach...

FCPA enforcement in the first half of 2018 continued at a steady pace.  The first half of 2018 included several significant corporate and individual prosecutions for FCPA violations.  Tom Fox and Michael Volkov review FCPA enforcement and identify significant trends and enforcement actions. Tom Fox has released his new compliance book — The Compliance Handbook, which is available at HERE

Companies face evolving and significant cyber risks. The FBI estimates that ransomware will generate at least $1 billion for criminals.  Businesses stand to lose at least $400 billion each year from hacks.  The cyber defense, forensics and insurance industry will be worth nearly $200 billion by the end of this decade.  Each year there is an average of 1.5 million cyber attacks, or approximately 4000 per day....

Companies have to implement a robust policy management program.  In today’s risky environment, companies should automate a robust policy management program that requires regular review, assessment and updating of policies and procedures.  A policy management program should be created consisting of key constituencies to ensure that policies and procedures are current, effective, and appropriately tailored to the company’s risk profile. In this episode, Michael Volkov...

In a special podcast episode, I take time out from the legal and compliance world to discuss the wonderful island of Sicily, Italy.  To explain and provide an introduction to Sicily, and in particular the western region, I interview my wife, Rosetta Sciacca, about Sicily, its people, its culture and its cuisine. Happy Fourth of July!!!

The Justice Department has released two important documents that provide guidance to compliance practitioners as to compliance program best practices: (1) The FCPA Guidance; and (2) The Evaluation of Corporate Compliance Programs.  In combination, these two documents provide important compliance program guidance. In this episode, Michael Volkov discusses various issues related to ethics and compliance program best practices.

Global companies face serious challenges in the design and implementation of compliance programs to meet increasing risks in emerging markets.  As global companies grow, so do compliance programs. The specific design and structure of a global compliance programs presents numerous challenges requiring balancing of various factors, including consistency across the organization, economies of scale and scope, and flexibility to meet local needs and concerns.  In...

An increasing number of chief compliance officers report directly on a monthly basis to the Chief Executive Officer.  As the compliance profession has earned independence and empowerment, CCOs are now part of the C-Suite and need to develop a positive relationship with the CEO to support the company’s ethics and compliance program. In doing so, CCOs need to ask themselves two important questions: (1) what...

Compliance professionals are learning about new technologies that are quickly evolving to aid the compliance function.  We hear regularly about the promise of artificial intelligence and block chain technology.  These new developments will have a significant impact on compliance.  But for now there are other areas where technology can help compliance programs today, including automation, data collection and analytics and monitoring capabilities. In this episode,...

Research has consistently demonstrated that an ethical corporate culture results in increased profits and sustainable growth.  Companies with a positive culture have lower rates of employee misconduct, increased employee productivity, and lower employee turnover.  All of these factors lead to higher growth rates, improved employee morale, and a reduced risk of misconduct and government investigation. This basic premise holds true: when ethical values are embedded in a company’s...