It is curious that physical courage should be so common in the world and moral courage so rare. Mark Twain Frankly, I have to admit my reaction to the recent Business Roundtable’s issuance of a new Statement on the Purpose of a Corporation, which was signed by 181 CEOs who committed to lead their companies for the benefit of all stakeholders – customers, employees, suppliers,...
Capital One suffered a serious data breach as a result of the actions of one individual who downloaded nearly 30 GB of 100 million Capital One Financial Corporation credit applications from an Amazon cloud data server. The Capital One data breach underscores the risk of cyber breaches caused by a single bad actor who gained unauthorized access through Amazon’s could data server. This unfortunate data breach demonstrates...
From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the...
We all know that businesses rely on a large number of third-party vendors to support their business operations. Many of these third parties require access to a company’s data and its internal information and technology systems. This digital fact of life creates a real cyber risk for illegal intrusions. Over half of all cyber-attacks are the direct or indirect result of third party access. Third-party...
Deepak Chopra, one of my favorite “thinkers” (if that is a word) reminds us that there is no such thing as a coincidence – there is what he terms a “synchronicity of the universe.” (See here and here for some additional explanation). Not to say, I told you so, but around the same time that the Capital One data breach occurred, I was reminding clients...
In this episode, Michael Volkov provides an update on FCPA issues, including: (1) Juniper Networks’ FCPA settlement with the SEC for $11.7 million for conduct in Russia and China: (2) Deutsche Bank’s FCPA settlement with the SEC for $16 million for hiring of relatives of foreign officials in China and Russia; and (3) the Second Circuit Court of Appeals decision affirming the conviction and sentence...
Juniper Networks agreed to pay the SEC $11.7 million to settle FCPA violations for conduct occurring in Russia and China. See Order Here. Under the settlement, Juniper Networks agreed to disgorgement of $4 million, a $6.5 million civil penalty, and pre-judgment interest of $1.3 million. The Juniper Networks investigation was initiated approximately six years ago in 2013. The Justice Department had declined to prosecute Juniper...
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...
