Two recent ethics and compliance surveys and studies provide important information on ethics and compliance program trends. The first is LRN’s 2018 Ethics and Compliance Program Effectiveness Report. The second is the Ethics and Compliance Initiative Global Business Ethics Survey. In this episode, Michael Volkov reviews the two surveys and studies and the implications for ethics and compliance program practitioners.
When a company learns that the government is investigating the company’s activities, a company has to move quickly to respond to the government and engage prosecutors about the investigation. Depending on how the company learns about the government investigation, the company’s strategy and immediate steps may differ. Once the company learns it is under investigation, the company has to collect information about the activity and business...
In the early part of 2018, the Justice Department brought two significant AML criminal enforcement actions against US Bancorp and Rabobank, respectively. These two cases, coupled with the new beneficial ownership regulations effective May 11, 2018, raise significant changes in the AML compliance and enforcement landscape. In addition, the SEC and FINRA brought AML enforcement actions against Aegis Corporation and three individuals, two of whom were...
On August 9, 2018, FBI agents executed search warrants at Michael Cohen’s office, hotel, residence, safety deposit box and electronic devices. Since then, we learned that the US Attorney’s Office in New York City have an ongoing criminal investigation against Michael Cohen. The full scope of this investigation has yet to be disclosed but it is clear that Cohen will face significant and serious charges....
Cryptocurrencies, including Bitcoin, are exploding on the marketplace. Cryptocurrencies are promising huge technological advances in our economy by relying on the new blockchain technology. Initial coin offerings raised $7 billion in capital last year, and this year ICOs are expected to raise over $20 billion in capital. Bitcoin and other established cryptocurrencies have increased in value. Bitcoin reached a high of nearly $20,000 and is now trading just...
As part of the aggressive enforcement of white collar crime cases, federal law enforcement officers are executing more search warrants at company offices. Companies should plan in advance for such an event. A company can learn valuable information about an ongoing investigation. Just as important, company officials have to preserve and assert objections when federal agents conduct a search. In this episode, Michael Volkov outlines...
Haiti continues to suffer from significant corruption. In Transparency International’s recent Corruption Perception Index, Haiti ranked 157 out of 180 countries on the corruption perception index. Angelo Viard, a longtime expert in business development in Haiti sees a different picture — business opportunities in Haiti are present but corruption risks have to be acknowledged and addressed. Angelo Virad provides practical insights on how to navigate...
Companies continue to face significant risks from their third parties. In response, companies are implementing sophisticated due diligence and third party risk management systems. FCPA enforcement risks are only one of several risks created by a company’s third parties. Companies have to screen and review their third parties for corruption, sanctions, money laundering, antitrust, human trafficking, child labor and reputational risks. In this three-part series,...
Companies continue to face significant risks from their third parties. In response, companies are implementing sophisticated due diligence and third party risk management systems. FCPA enforcement risks are only one of several risks created by a company’s third parties. Companies have to screen and review their third parties for corruption, sanctions, money laundering, antitrust, human trafficking, child labor and reputational risks. In this three-part series,...
Companies continue to face significant risks from their third parties. In response, companies are implementing sophisticated due diligence and third party risk management systems. FCPA enforcement risks are only one of several risks created by a company’s third parties. Companies have to screen and review their third parties for corruption, sanctions, money laundering, antitrust, human trafficking, child labor and reputational risks. In this three-part series,...
