Featured Articles:

Episode 16 — Michael Volkov’s Perspective on the Russian Investigation — Analysis and Review of Manafort/Gates Indictment and Papadopolous Plea (Part I of III)

Michael Volkov provides his perspective, based on 25 years as a federal prosecutor, on Special Counsel Mueller’s ongoing investigation of the Trump Administration and potential crimes involving illegal collaboration with the Russian government and obstruction of justice. Michael Volkov provides a fresh overview of the ongoing investigation, and focuses this initial episode on the background and tactics used in the investigation, the Manafort and Gates...

Ethics and Mitigating Reputation Risks

A basic truism is – ethics and compliance reinforce each other. An ethical culture is an effective control against violations of law and a company’s code of conduct. Conversely, legal compliance promotes a company’s commitment to an ethical culture. Larger global companies are more likely to identify reputational risks as its greatest threat. (See Here NAVEX Global Third Party Benchmark Report). My favorite Warren Buffet...

Episode 15 — The Justice Department’s New FCPA Corporate Enforcement Policy

On November 26, 2017, the Justice Department announced adoption of its new FCPA Corporate Enforcement Policy.  Deputy Attorney General Rod Rosenstein announced the new policy at an FCPA Conference in Washington, D.C. Under the new policy, corporations that voluntarily disclose potential FCPA violations, fully cooperate with the investigation and implement timely and appropriate remediation will earn a presumptive declination, subject to the absence of aggravating...

May 2018: D-Day for FinCEN Customer Due Diligence and EU’s General Data Privacy Regulations

Chief compliance officers for financial institutions are going to have a rough May 2018. First, on May 11, 2018, the new CDD Rule for beneficial ownership becomes effective.  Two weeks later, on May 25, 2018, the EU’s General Data Protection Regulation becomes effective. FinCEN CDD Rule FinCEN’s new Customer Due Diligence rules will have a significant impact on the collection of beneficial ownership information and...

Calculating the New Balance Between Disclosure and Non-Disclosure of Potential FCPA Violations

The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations.  How is that for a profound grasp of the obvious? All kidding aside, the question is how much has the balance been changed?  I am not sure there will be a significant increase in the number of companies deciding to seek the benefits under the new...

Sponsored Product Update: NAVEX Global’s RiskRate 6.0

I am excited to announce a recent product development launch for our sponsor, NAVEX Global, an innovative leader in the ethics and compliance field.  We are proud to work with NAVEX Global, a company that works hard to create products that deliver practical solutions for ethics and compliance professionals. Although third-party risk management is a top  concern for many organizations, it is common to hear that...

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function.  The Justice Department and SEC’s FCPA Guidance, and the specific Hallmarks of an Effective Compliance and Ethics Program is the most definitive statement on compliance expectations ever released by US prosecutors.  Since 2012, the Justice Department has built on...

Episode 14 — What Every Compliance Officer Needs to Know About Data Privacy and the EU’s GDPR

Compliance officers have to be mindful of new and emerging threats.  In the past few years, cyber security and data privacy have been quickly rising as new and significant threats that corporations face in the global marketplace. The European Union has adopted a far-reaching new regulatory regime applicable to companies that conduct business in the European Union and collect any sensitive data relating to EU...