Volkov Law TV continues to offer high-quality webinars on relevant ethics and compliance topics.  Over the last several months we have added a number of new webinars.  Subscribe and check them out.  Monthly access to a webinar is $8; monthly access to the full library is $29; and yearly access to all of the webinars is $299.  Click Here to Sign Up Now. Watch the webinars when...

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,...

I always enjoyed the assumption underlying economic models – assuming people are rational actors, then . . . Sometime people do not act rationally, and sometimes people react out of fear or make unrealistic assumptions. The compliance profession faces many challenges including unrealistic or unfounded assumptions. In many cases, compliance professionals have to reassure their constituencies about the specific implications of a compliance function, initiative...

Webinar: How to Conduct Periodic Reviews and Assessments of Your Compliance Program Wednesday, November 15, 2017, 12 Noon EST Sign Up Here An effective compliance program requires that companies review and improve their compliance programs. A company should regularly review and test its controls, and address potential weaknesses in its compliance program. The Justice Department and the SEC have encouraged companies to conduct regular tests...

A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other enforcement actions from the past; country (or regional) specific violations that involve a group of employees sometime limited to a specific function (e.g. Johnson Controls); and small group enforcement actions, sometimes...

The Justice Department has touted its efforts to bring greater transparency to FCPA enforcement. There is no question that in the last five years the Justice Department has moved the needle – the FCPA Guidance issued in 2012; the release of the April 5, 2016 Pilot Program; the Evaluation of Corporate Compliance Programs issued in February 2017; the release of letters confirming declinations awarded to...

I was pleased to participate in a live webinar with Exiger on artificial intelligence and third party risk management.  Watch the 60 minute webinar replay — here. The growing complexity of third party relationships and the immediate regulatory and reputational risks of those third parties has procurement teams, compliance officers and legal departments wondering what to do. When and how should they do due diligence?...

Corporate boards need to devote more energy to oversight and improvement of corporate culture and compliance. Over the last ten years, we have witnessed corporate scandals and misconduct that could have been prevented or, at least, mitigated by a corporate board’s proper oversight, and management of a company’s culture and compliance program. All too often, corporate boards fail to identify potential red flags of serious...