If there ever was a poster-child for reputational damage for a financial institution, Deutsche Bank would be the first and only candidate. Talk about a bank that is in trouble and continues to fall under government scrutiny. Last week, Deutsche Bank agreed to pay the SEC $16 million for its hiring of relatives of public officials in China and Russia. (Here). Deutsche Bank joins a...
In an interesting decision, well worth a read here, on August 9, 2019, the US Court of Appeals for the Second Circuit rejected Ng Lap Seng’s appeal of his 2017 conviction for bribery of united Nationals officials. In affirming the conviction, the Second Circuit ruled that the Supreme Court’s holding in McDonnell (see blog post here), in which the Court ruled that under 18 USC...
The Volkov Law Group is proud to contribute to the compliance media in order to promote compliance ideas and issues. Stephen Cheng, an Associate at The Volkov Law Group, recently published an article on the Justice Department new Evaluation of Corporate Compliance Programs. The article is available Here. Matt Stankiewicz, a Senior Associate at The Volkov Law Group, was quoted in a recent article on...
On January 1, 2020, companies will be facing a compliance requirement established by the California Consumer Privacy Act. In practice, California’s CCPA will create a new “national” standard. The CCPA is designed to give consumers more information and control over their personal information. Specifically, businesses will be required to be more transparent in their handling of personal information and to provide robust disclosures to consumers about how...
As a long-time Bob Dylan fan, I have suffered the ups and downs of his career. Well, not really “suffered” but empathized may be a better way to express my commitment. We all remember the days when Dylan embraced Christianity and recorded some great music with Dire Straits. Slow Train Coming was a great song (listen here). Now, to bring this analogy to corporate board...
We all know the phrase – “A fish rots from its head.” A perfectly accurate statement as to how corporate culture can suffer from leadership failures or C-Suite misconduct. But there is much more to corporate culture than just what happens in the C-Suite. Day-to-day events throughout the company can infect a corporate culture as well. A well-oiled machine means that corporate leadership establishes ethical...
Compliance officers and internal auditors are natural partners and allies in the compliance governance landscape. As the compliance profession and influence grew, compliance officers often leaned on internal auditors for help in assessing risks, uncovering financial misconduct, and assessing compliance functions and controls. Recently, however, I have noticed some changes in their relationship, suggesting that they both are maturing and gaining independence from each other. ...
Converge19 is scheduled for October 1 to October 3, 2019. I am proud to participate in the event and scheduled to speak on OFAC Sanctions Compliance. If interested in attending, please sign up here. The Agenda is here. CONVERGE19 is in its 4th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with...
Listen to Episode 105 HERE. Bill Hauserman and Ted Datta from Bureau van Dijk, a Moody’s Analytics Company, join us for an interesting discussion on third-party risk management, issues surrounding beneficial ownership, trends in the industry and the importance of validating ownership and data quality. Bill and Ted explain their interesting perspective on third-party risk challenges, regulator expectations and a fascinating view from the global...
This is likely to be a politically incorrect posting. I hope I do not offend too many people, especially those new data privacy professionals. As kids, we were always excited when an ice cream truck visited our neighborhood offering a new flavored ice cream. For a brief period of time, the new ice cream flavor was the popular rage. In the corporate legal and compliance...
