Corruption, Crime & Compliance

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29 Nov, 2018

Vantage Drilling Forks Over $5 Million for SEC FCPA Settlement

The SEC announced last week a $5 million FCPA settlement with Vantage Drilling International (“Vantage”), a Texas-based offshore drilling company. The violations involved Vantage’s predecessor company, Vantage Drilling Company (“VDC”), for transactions with its former outside director, largest shareholder and only supplier of drilling assets, and for failure to implement appropriate controls for its third-party marketing agents. The Justice Department closed its related investigation. The...

General

28 Nov, 2018

Your CEO Agrees the Company’s Culture is Important – Now What?

“The secret of getting ahead is getting started.” – Mark Twain “To succeed in life, you need two things: ignorance and confidence.” – Mark Twain Mark Twain would have been a great Chief Compliance Officer – he had an extraordinary ability to capture human behavior and motivation. He would have known how to use the right phrase at the right time. I can just imagine CCO Mark Twain meeting...

General

27 Nov, 2018

OFAC Completes Re-Imposition of Iran Sanctions

On November 5, 2018 the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) completed the process to re-impose the Iran sanctions program. The 180-day wind-down period for termination of the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) ended. As part of the re-imposition of U.S. sanctions, OFAC added more than 700 individuals, entities, aircraft, and vessels to the SDN List,...

General

26 Nov, 2018

Société Générale Pays $1.4 Billion for Systemic Sanctions Violations

Société Générale (“SocGen”) entered into two deferred prosecution agreements (“DPA”) (here) and agreed to pay $1.34 billion in penalties (here): $717 million to the Justice Department; $325 million to New York’s Department of Financial Services “DFS”); $163 million to the Manhattan District Attorney’s Office; $81 million to the U.S. Federal Reserve; and $54 million to the U.S Treasury’s Office of Foreign Assets Control (“OFAC”). The...

Podcasts

25 Nov, 2018

Episode 66 — Gifts, Meals, Entertainment and Travel Expense Compliance

Companies have to focus on compliance controls and non-material financial transactions to prevent fraud, bribery and other misuse of corporate funds. One particular risky area is the control of gifts, meals, entertainment, and travel expenses. In this new era of compliance, companies have to adopt proactive and automated strategies to mitigate risks of unauthorized GMET expenditures. In this episode, Michael Volkov discusses GMET risks and...

General

20 Nov, 2018

Effective Compliance is More than the Sum of a Program’s Parts

The beauty of an effective ethics and compliance program is captured in the well-known phrase that it is worth much more than the sum of its parts. I am reminded of the Beatles refrain, “All Together Now,” (HERE) which is an apt reminder of the importance of operationalizing an ethics and compliance program. Frankly, the life of an ethics and compliance program depends on the...

General

20 Nov, 2018

Behavioral Studies and Compliance

I am not a cynic when it comes to looking at the latest “fads” in compliance. Please do not get me wrong. Compliance is a fast-evolving field that is quickly moving beyond the limited perspective of legal into a new territory, coined by Donna Boehme (here), the subject-matter expert (“SME”). Donna has a great point – lawyers and other professionals cannot just willy-nilly decree themselves...

Podcasts

19 Nov, 2018

Episode 65 — Goldman Sachs and the 1MDB Corruption Scandal

Goldman Sachs’ role in the 1MDB scandal continues to draw scrutiny. Justice Department prosecutors are investigating the extent to which Goldman Sachs knew and participated in the 1MDB scandal, and what penalty, if any, Goldman Sachs should pay. The recent indictment and guilty plea of two former Goldman Sachs officials represents a significant development in the ongoing investigation. In this episode, Michael Volkov discusses recent...

General

16 Nov, 2018

Michael Volkov on FCPA Compliance Report Podcast and Compliance Next

Tom Fox recently posted a conversation on his blog, FCPA Compliance Report, reviewing FCPA enforcement practices and policies over the last five years, culminating in the FCPA Corporate Enforcement Policy. The podcast is available here. NAVEX Global’s compliance online community, Compliance Next, has posted a video I recorded on responding to potential misconduct. The video is available here. Thanks for your continuing support!!

General

16 Nov, 2018

Ethics and Compliance Initiative Report: The Importance of Ethics Communications and Accountability

The Ethics and Compliance Initiative (“ECI”) continues to publish important surveys and studies. In a recent report (available here), the ECI cited important research from its Q3 Global Business Ethics Survey (“GBES”) demonstrating the value of ethical communications and trust in an organization. In particular, the ECI study found that: Employees are 11 times more likely to speak up when faced with witnessing wrongdoing in...