Tom Fox, the Compliance Evangelist, has announced the release of his Compliance Handbook, Second Edition. Tom is a compliance leader and his handbook is a must read for all ethics and compliance professionals. The Second Edition provides practical and helpful solutions on important ethics and compliance issues. It is comprehensive, accessible and a must-have for every ethics and compliance professional. Tom has teamed up with...
Alex Cotoia, who recently joined The Volkov Law Group, as a Regulatory Manager and Compliance Consultant, joins us for a posting on Transparency International’s 2020 Corruption Perceptions Index. Alex can be reached at [email protected]. On January 28, 2021, Transparency International (“TI”), a non-governmental organization globally renowned for its work in combatting corruption in both the public and private sectors, released its much-awaited Corruption Perceptions Index...
I have always played down the issue of CCO liability and prosecutions. I dismiss these concerns often because the reporting of CCO prosecutions are usually exaggerated and meant to instill fear in compliance professionals. In my simplistic approach, I have followed the general rule of thumb – if you do something wrong, you pay the price. In a number of cases involving compliance officer prosecutions,...
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns. We have to recognize that 2020 was a difficult and unusual year for CCOs, given the panoply of risks, the disruption to every organization, and devastating impact of the COVID-19 pandemic. CCOs were forced into a new environment where health and safety issues,...
To start the New Year, it is a good idea to review the trends in the role and status of Chief Compliance Officers. As we witness the continuing growth in stature of the CCO, we need to exercise caution. Some troubling concerns are becoming apparent. With a new Attorney General and Biden Administration, CCOs have to be mindful of their ever increasing responsibilities and concomitant...
Webinar: The Anti-Money Laundering Act — Enforcement and Compliance Implications March 4, 2021, 12 Noon EST Sign Up Here The Anti-Money Laundering Act of 2020 (AMLA) was enacted on Jan. 2, 2020, when Congress overrode President Donald Trump’s veto of the National Defense Authorization Act. The AMLA is the most significant revision of U.S. anti-money laws since the USA PATRIOT Act in 2001. The AMLA:...
Jessica Sanderson, Partner, The Volkov Law Group and Michael Volkov review significant developments in the civil False Claims Act (“FCA”) area from the past year. With mind-boggling federal spending in FY 2020 and the obvious potential for fraud, abuse, and misuse of the trillions of dollars of federal stimulus funds, we undoubtedly will see a considerable increase in FCA audits, investigations, enforcement actions, qui tam...
The Volkov Law Group is proud to announce that Alexander Cotoia has joined the firm as a Regulatory Manager and Compliance Consultant. Alexander specializes in corporate risk assessments, evaluation of general compliance programs, and the remediation of compliance deficiencies. He also specializes in trade (export) compliance and is familiar with a broad range of issues arising under both the Arms Export Control Act and its...
Boeing’s settlement with DOJ raises more questions than answers. While I understand that a criminal case against Boeing requires DOJ to identify one or more individuals who have committed a crime that can be fairly attributed to the Boeing corporation. The doctrine of respondeat superior is the mechanism by which this legal attribution occurs. Boeing has been praised for its remediation efforts and its end...
Boeing’s criminal conduct, as described in the settlement papers, centered on two of its 737 MAX Flight Technical Pilots, who deceived the FAA about an important aircraft part called the Maneuvering Characteristics Augmentation System (MCAS) that impacted the flight control system of the Boeing 737 MAX. Because of their deception, a critical document published by the FAA lacked information about MCAS, and in turn, airplane...
