Category: Podcasts

Episode 65 — Goldman Sachs and the 1MDB Corruption Scandal

Goldman Sachs’ role in the 1MDB scandal continues to draw scrutiny.  Justice Department prosecutors are investigating the extent to which Goldman Sachs knew and participated in the 1MDB scandal, and what penalty, if any, Goldman Sachs should pay.  The recent indictment and guilty plea of two former Goldman Sachs officials represents a significant development in the ongoing investigation. In this episode, Michael Volkov discusses recent...

Episode 64: Stryker’s SEC FCPA Settlement

Stryker Corporation has suffered a second FCPA enforcement action, and will now bear the stigma of FCPA “recidivist.”  In reaching a settlement with the SEC and agreeing to pay a $7.8 million civil penalty, Stryker will now be subject to an SEC-imposed compliance monitor. In this episode, Michael Volkov reviews the facts surrounding the Stryker SEC settlement.

Episode 63 — The Epsilon Case and Third-Party Sanctions Risks

The Department of Treasury’s Office of Foreign Asset Control (OFAC) recently settled a long-active enforcement action with Epsilon relating to alleged violations of the Iran Sanctions Program.  After a mixed decision from the US Court of Appeals for the District of Columbia Circuit, OFAC negotiated a $1.5 settlement for 39 violations of the Iran Sanctions Program.  Along the way, however, OFAC secured favorable rulings affirming...

Episode 62 — Update on the Cuba and Venezuela OFAC Sanctions Programs

The Trump Administration has aggressively restricted commerce with Cuba and Venezuela.  With respect to Cuba, the Trump Administration has re-imposed strict regulations on commerce with Cuba, reversing several Obama-era regulations easing such restrictions.  At the same time, the Trump Administration has continued Obama era policies tightening trade with Venezuela and opposing the Maduro leadership in Venezuela. In this episode, Michael Volkov discusses recent updates to...

Episode 61 — How to Implement and Promote a Speak Up Culture

Companies face a myriad of risks that can cause significant legal and reputational risks.  A company’s employees are critical sources of concerns to prevent and detect problems.  Employees have to be encouraged to raise concerns to help the company address these problems proactively.  As a result, it is critical for companies to invest and promote its speak up culture to maximize employee communication and prevent...

Episode 60 — A Deep Dive into the SEC’s FCPA Settlement with United Technologies

United Technologies recently settled an FCPA enforcement action with the SEC by paying $13.9 million for bribes paid by its elevator and aircraft businesses. UT disclosed the investigation to DOJ and the SEC in late 2013 or early 2014. DOJ declined to prosecute in March 2018. UT agreed to disgorge $9 million, plus interest of about $919,000 and to pay a penalty of $4 million. The SEC’s FCPA settlement contains...

Episode 59 — Implementing an Internal Investigation Program

To promote a culture of integrity and a commitment to organizational justice, companies have to implement an effective, efficient and reliable internal investigation program.  Such a system has to respond to employee concerns promptly and investigate these concerns fairly and consistently.  Companies have to devote adequate resources and attention to its internal investigation program. In this episode, Michael Volkov discusses how to design and implement...

Episode 58 — Interview of Donna Boehme — The Future of the Independent, Empowered Chief Compliance Officer

Donna Boehme is our guest on this week’s podcast.  She is an advocate for an independent, and empowered Chief Compliance Officer. Donna is an internationally recognized authority in the field of organizational compliance and ethics with over 20 years’ experience designing and managing compliance and ethics solutions, within the US and globally. As Principal of Compliance Strategists LLC, she has advised a wide spectrum of private,...

Episode 57 — A Review of the Russia Sanctions and Recent Changes

Since 2014, the United States has put into place a comprehensive set of sanctions against Russia.  In response to Russia’s annexation of Crimea and its hostile activities in the Ukraine, President Obama put in place a set of sanctions focused against various sectors of the Russian economy.  Since the Trump Administration came to power, Congress enacted additional sanctions, and the Department of Treasury adopted targeted...

Episode 56 — Catching Up with Special Counsel Mueller’s Russia Investigation

Since my last update on the Russia investigation in December 2017, Special Counsel Mueller’s investigation has been gaining momentum — Paul Manafort has plead guilty and agreed to cooperate after he was convicted in the Eastern District of Virginia.  Michael Cohen entered into a plea agreement with the Southern District of New York prosecutors, including a specific admission that President Trump directed him to make...