As the old adage provides – better late than never. (Same applies for my somewhat tardy posting on this case). Telefônica Brasil settled FCPA violations with the SEC for a pretty penny — $4.125 million in civil penalties in connection its hospitality program for the 2014 World Cup and 2013 Confederations Cup According to the settlement agreement, Telefônica Brasil failed to maintain adequate internal controls...
Data privacy has become a hot topic lately. Companies have built massive fortunes by selling users’ personal information to the highest bidder. Meanwhile, they often fail to secure that same data while hackers run amok, putting the users at risk. What’s a person to do? Enter ImagineBC. In the ImagineBC community, you’re in control of your personal information – and free to monetize it. Built on...
On June 5, 2019, The Volkov Law Group conducted a webinar on ITAR Compliance: Navigating Complex Risks. A free recording of the webinar is here. Mike can be contacted at [email protected].
Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices and Industry Trends June 25, 2019, 12 Noon EST SIGN UP HERE The compliance industry is evolving. Recent DOJ and OFAC Guidance are just one influence. At the same technology and innovative strategies using data analytics are quickly eclipsing government guidance, especially in the area of compliance program monitoring, testing and auditing. Companies...
When providing compliance program guidance, the Justice Department and OFAC, like every compliance practitioner, will pay homage to the relatively obvious point that there is no one-size-fits-all compliance solution. In other words, as is often repeated, a company’s compliance program will vary depending on a variety of factors, including the company’s size, sophistication, products and services, and geographic configuration. These factors eventually form the basis...
The term “internal controls” is a loaded one – it morphs in various ways depending on the context. Sometimes it is a shorthand for financial accounting controls; other times it encompasses a company’s compliance controls (i.e. policies and procedures). OFAC embraced the term to equate with a company’s policies and procedures for sanctions compliance. OFAC recognized that OFAC compliance functions have to begin with the...
OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement. This new approach reflects OFAC’s recent aggressive enforcement programs. In recognition of the importance of various economic sanctions programs, particularly Iran, North Korea and Venezuela, OFAC has laid out some important markers. These enforcement actions, e.g. the Epsilon case (here), and the elf Cosmetics case (here), and the...
If you follow my blog, you know I am not one to embrace hyperbole. So, forgive me for stretching a little here, but the OFAC Framework for Sanctions Compliance Programs is a game changer. Let me explain why I am saying that. When it comes to sanctions compliance programs, most companies are well behind the curve; I am not saying they do nothing, but most...
OFAC’s new Framework for Sanctions Compliance Programs is a game changer. When it comes to sanctions compliance programs, most companies are well behind the curve. OFAC’s new framework raises the bar by creating a well-crafted framework for companies to assess their current program and then re-design important elements to meet OFAC’s standards. To the extent that a company’s sanctions compliance program operates as part of an overall...
An audit program of a company’s internal investigation function provides valuable insights for its internal investigation program and the company’s overall ethics and compliance program. It is a critical part of ensuring that a companies speak up culture is adequately supported and promoted by an efficient and reliable internal investigation function. A company learns a lot about its overall operations from its employee complaints and...
