Gifts, meals, entertainment, travel, and hospitality expenses (GMETH) are high-risk for bribery but have not received the same attention lately as third party risk management. The advancing capabilities of software solutions in this area make now the time to take a fresh look at how to leverage technology to strengthen your program. Join me and MyComplianceOffice for a free webinar to review: Best Practices to...

The COSO framework contains important principles for structuring a global organization and its internal controls, including compliance policies and procedures. Compliance officers have to learn and use the COSO framework when communicating and convincing the CFO to embrace a new world with both compliance and financial controls within an effective governance framework. Global companies are recognizing (sometimes slowly) that management silos in a company prevent...

Global companies need to actively work to prevent fraud and corruption. Fraud and corruption go hand-in-hand. To commit bribery, bad actors have to gain access to money for unauthorized (illegal) purposes. A failure to prevent fraud and corruption can have significant legal, financial and reputational consequences. Luckily, companies are devoting additional resources to assess fraud and bribery risks with specific focus on internal financial and...

Chief compliance officers are politicians and have to possess great interpersonal skills. They have to “get along” and persuade key constituencies — most especially their business partners – to commit and devote time and resources to ethics and compliance. In order to operationalize their programs, CCOs have to build relationships with important partners – human resources, legal, internal audit, procurement, and finance. Up to this...

The Volkov Law Group continues to offer innovative legal services focused on ethics and compliance programs, enforcement defense, and internal investigations. See Firm website here. The Volkov Law Group team includes talented professionals: Lauren Connell, Managing Associate; Jacqui Martin (formerly Merrill), Senior Associate; Susan Simpson, Associate; Matt Stankiewicz, Associate; and Vincent Ruiz, Counsel. See Firm profiles here. The Volkov Law Group believes that every company...

Global companies and corporate officers and employees face significant criminal antitrust risks.  The US Department of Justice’s Antitrust Division has a mature and aggressive enforcement program targeting illegal cartel activity.  Unfortunately, companies have been slow to implement ethics and compliance programs that are adequately focused on these serious criminal risks. In this episode, Michael Volkov discusses the need for robust ethics and compliance programs and...

Human resources and compliance professionals share many common objectives and interests. They need to coordinate and operationalize their joint interests in a variety of ways. One area that demands more focus is the hiring of ethical employees. The ISO 37001 Anti-Bribery Management System includes important requirements for the hiring (or transfer) of employees to functions that involve bribery risks. So much attention has been paid...

Over the last year, we have seen the Justice Department and SEC’s international coordination efforts bear fruit. DOJ has expended time and efforts to train prosecutors and law enforcement on anti-corruption investigations and prosecutions strategy. These programs inevitably foster cooperation and coordination through personal and professional relationships. In particular, DOJ and the FBI have established working relationships with colleagues in the United Kingdom, France, Germany,...