Category: Podcasts

Episode 27 — Internal Controls and Enforcement Risks

The FCPA includes a specific requirement that a public company maintain an adequate set of internal controls.  A company’s compliance program is one component of a company’s internal controls.  Sarbanes-Oxley expended and reinforced this important requirement. The Department of Justice and the SEC have aggressively enforced the internal controls requirement.  The SEC, in particular, has expansively enforced the internal controls requirement even where a failure...

Episode 26 — Federal Reserve Blocks Wells Fargo Growth In Response to Governance and Risk Management Disaster

In an unprecedented action, on February 2, 2018, the Federal Reserve restricted Wells Fargo’s ability to grow its business until it implements comprehensive improvements to its board governance and risk and compliance systems.  Citing Wells Fargo’s poor record of governance and risk management resulting in the community banking sales incentive scandal and continuing problems at the bank, the Federal Reserve imposed detailed governance and risk...

Episode 25 — Unraveling the KPMG Audit Scandal

In January 2018, the Department of Justice and the Securities and Exchange Commission announced criminal and civil charges against five KPMG and a Public Company Accounting Oversight Board employee arising from sharing of confidential audit inspection information by PCAOB employees with KPMG audit partners.  A sixth defendant, a KPMG official and former PCAOB employee plead guilty and agreed to cooperate with the government investigation.  The...

Episode 24 — Corporate Board Reform

The growth in ethics and compliance has had a dramatic impact on corporate actors, including the CEO, chief compliance officers, internal audit and chief financial officers.  The corporate board’s role in compliance continues to be deficient.  Corporate boards are in for a rude awakening — a new era of accountability for ethics and compliance is beginning. In this episode, Michael Volkov outlines the issues surrounding...

Episode 23 — Tom Fox and 2017 FCPA Year in Review

Tom Fox rejoins Corruption, Crime & Compliance for a 2017 FCPA Review.  Tom discusses important trends and events from 2017 in FCPA enforcement and compliance. Tom is the thought-leader on FCPA and compliance issues.  He maintains the popular blog, FCPA Compliance & Ethics, the Podcast Network and is a prolific author of numerous books, articles, and e-books.

Episode 22 — Testing and Evaluation of Your Compliance Program

As more companies implement ethics and compliance programs, chief compliance officers are increasingly focusing on the need to test and evaluate their compliance program.  An effective testing program provides important information that compliance officers can use to improve their respective compliance programs. In this episode, Michael Volkov and Jacqui Merrill, Senior Counsel at the Volkov Law Group, discuss how to test and evaluate your compliance...

Episode 21 — Interview of Jean-Michel Ferat, FCPA Forensic Accounting Expert, Senior Managing Director, Ankura Consulting

Jean-Michel Ferat, a leading FCPA Forensic Accountant, and Senior Managing Director at Ankura Consulting, joins Michael Volkov, in Episode 21 of the Podcast, Corruption Crime & Compliance. Jean-Michel Ferat is a leading forensic accountant and has vast experience in uncovering complex bribery schemes and financial crimes.  Jean-Michel also works with large, mid-size and small companies to design and implement effective financial accounting controls and remediate...

Episode 20 — Data Security and Privacy Compliance

Companies face increasing challenges from management and protection of data from hackers and breaches of sensitive commercial and personal data.  Recent headlines have underscored the threats to companies from such breaches.  The risk of reputational harm to companies is serious.  Complaince departments are starting to play an increased role in mitigating these serious risks. In this episode, Michael Volkov and Lauren Connell, Managing Associate from...

Episode 19 — 2017 FCPA Year in Review

FCPA enforcement continued in 2017 with an increased emphasis on individual enforcement. Despite early questions as to the new administration’s commitment to FCPA enforcement, the Justice Department and the SEC continued to push aggressive enforcement cases, building on well-established relationships with global law enforcement partners. In a significant development, the Justice Department issued a new FCPA Corporate Enforcement Policy, which created a declination presumption for...