The Department of Justice and the Treasury Department have stepped up AML/BSA and Sanctions Enforcement. With the ever-increasing expansion and modification of sanctions, risks for all businesses, not just financial institutions, have increased exponentially. DOJ and the Treasury Department have warned banks and financial institutions to increase AML/BSA compliance efforts. In addition, DOJ and OFAC have aggressively prosecuted companies for failure to comply with sanctions....

Global companies have to design and implement an efficient process for conducting internal investigations. An effective ethics and compliance program requires companies to screen complaints, assign appropriate resources to each, and resolve investigations in a fair and even-handed way. The internal investigation process provides important insights that can be used to improve a company’s ethics and compliance program. View more videos like this on the...

The foundation of every anti-corruption ethics and compliance program is a risk assessment. It is important to design and implement a process to conduct an initial risk assessment, to update the risk assessment, and to ensure that you maintain an accurate relative risk ranking system. A current risk assessment is critical for designing your anti-corruption compliance program and allocating resources to specific functions. View more...

In response to the aggressive enforcement environment, companies have adopted robust anti-corruption policies and procedures. As always, the effectiveness of a company’s policies depends on implementation, management and monitoring of its policies. Companies need to fine-tune, monitor and adapt their policies and procedures to their risk assessment, audit and monitoring process. View more videos like this on the Volkov Law Group YouTube Channel.

The Department of Justice and the SEC have emphasized the importance of designing an anti-corruption compliance program based on a company’s risk assessment. An effective program has to be tailored to the specific risks identified in the risk assessment. Companies that ignore this fundamental requirement are at increased risk of violations. View more videos like this on the Volkov Law Group YouTube Channel.

Companies recognize the need to develop robust due diligence procedures to review, monitor and audit third-party intermediaries, prospective acquisition and joint venture partners, and vendors/suppliers. A due diligence system, however, can get bogged down in details and procedures which have limited relevance. CCOs need to ensure that their due diligence system is designed in relation to relevant risks. View more videos like this on the...

Companies recognize the importance of maintaining effective compliance programs. With the increase in enforcement activity, companies have turned to their Chief Compliance Officers to design and implement effective compliance programs. View more videos like this on the Volkov Law Group YouTube Channel.

More and more companies need to conduct internal investigations as an important strategy to protect the company against serious government investigations. Not all internal investigations have to be conducted in the same way. The steps needed to conduct an effective internal investigation will vary depending on the nature of the alleged code or legal violation. View more videos like this on the Volkov Law Group...

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance programs. View more videos like this on the Volkov Law Group YouTube Channel.