A fundamental requirement for an effective ethics and compliance program is that it is supported by “adequate resources.”  This does not mean a bare minimum requirement; nor is this requirement satisfied by flat-lining a compliance department’s annual budget.  Someone is not getting the message straight – a compliance program has to evolve – that does not mean that it has to suck up more resources...

On February 27, 2019, the University of St. Thomas Law School is holding an open house on its Organizational Ethics and Compliance Programs. Two days later, on March 1, 2019, the University of St. Thomas Law School is holding a virtual information session. The University of St. Thomas offers a unique curriculum for professionals interested in ethics and compliance. The flyer for the two events...

For me, the year-end retrospectives have become a rite of passage.  While there has been modest changes and trends in the enforcement arena, I am amazed each year at the pace at which compliance as a discipline and a profession continues to move forward. While there is much that is written about compliance and current or immediate trends, in reality, on the ground, compliance as...

The SEC and the Justice Department closed their respective 2018 books with resolution of three separate enforcement actions: Polycom, Eletrobras and Two Former Officers of Panasonic Avionics. In this episode, Michael Volkov reviews and discusses important lessons learned from these three separate FCPA enforcement actions.