There are a lot of talented CEOs.  Some remarkable leaders, innovators and eloquent spokespeople for their companies.  In several recent experiences, I have been befuddled by some CEOs. When a CEO addresses a global ethics and compliance staff or has the opportunity to address a large staff or division meeting, the CEO should take the opportunity to reinforce the company’s culture and compliance program message. ...

Congratulations on your new position as the chief compliance officer.  You successfully interviewed with the company, met the senior executive team and the audit committee chair, and negotiated a nice compensation package.  You are feeling “pretty, pretty good” (ala Larry David) about your new job and looking forward to starting your new position. So, now, what do you do? My first question for you is...

Lawyers know about conflicts of interest.  They face significant risks when handling clients and have to scrupulously follow principles surrounding conflict of interest.  The two categories of conflicts of interest are defined as “appearance of a conflict,” and an “actual conflict.”  Both can undermine the independence of an attorney who must zealously advocate on behalf of each individual client. Beyond lawyers, in the corporate business...

Sometimes a fraudster is just a fraudster – they are dangerous because they can manipulate without remorse or conscience. The rise and fall of Elizabeth Holmes and Theranos is a classic story of a manipulative CEO engaged in nothing more than a classic fraud. Holmes was once the Silicon Valley star who claimed to be a billionaire.  Her fortunes started to unravel quickly in response...

Tom Fox, Matt Kelly, Jonathan Armstrong, Jay Rosen and myself recently recorded a new episode of Everything Compliance — Four of a Kind Edition.  You can listen to it here. Everything Compliance is the only roundtable podcast in compliance, with four of the top compliance practitioners around. This week the gang returns to its four focused topics on its Four of a Kind edition. After...

Global companies face serious challenges in the design and implementation of compliance programs to meet increasing risks in emerging markets.  As global companies grow, so do compliance programs. The specific design and structure of a global compliance programs presents numerous challenges requiring balancing of various factors, including consistency across the organization, economies of scale and scope, and flexibility to meet local needs and concerns.  In...

I am pleased to announce the release by NAVEX Global of a new white paper that I authored — How to Develop the Business Case for a Third-Party Risk Management System. Download the white paper HERE. This comprehensive white paper helps you make an educated case to senior management and your board to budget for an automated system. You’ll also learn how to set up...

I will admit it – I changed this posting from its original draft.  I intended to write about the absence of any OFAC enforcement actions for 2018.  I went to double-check the OFAC enforcement website (here), and lo and behold, OFAC snuck its first enforcement action of 2018 – dated June 6, 2018 against Ericsson, Inc. for $145,983. Before the Ericsson enforcement action, OFAC had...

Greetings, We’re proud to announce the Volkov Law Group is now an official partner of Compliance Next. Compliance Next is a community-driven network supporting compliance professionals at any stage of their careers with regulatory updates, legally approved policy templates, and how-to resources that drive program and career growth. If you haven’t already, become a member of this free community to access hundreds of valuable resources,...

Webinar: Update on Iran Sanctions Program Tuesday, June 26, 2018, 12 Noon EST Sign Up Here On May 8, 2018, the Trump Administration withdrew from the Joint Comprehensive Plan of Action (JCPOA), and to began to reimpose the U.S. nuclear-related sanctions that were lifted to effectuate the JCPOA sanctions relief, following a wind-down period. Global companies have to update their trade compliance programs to ensure...