No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands. We are witnessing a significant turning point in FCPA enforcement in which the Justice Department and the SEC are slowly but surely pushing companies to embrace a more robust ethics...

We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017. From the narrow perspective of FCPA enforcement, the Justice Department and the SEC have demonstrated yet again the maturation of their respective aggressive FCPA enforcement programs. As in 2014 (but not...

2016 FCPE Enforcement and Compliance Year in Review January 10, 2017 12 Noon EST Sign Up HERE The Justice Department and the SEC returned a big year in 2016 FCPA enforcement.  In April 2016, DOJ adopted its FCPA Pilot Program to encourage companies to self-disclose FCPA violations and cooperate with government investigations. Despite a slowdown in 2015 and early 2016, DOJ and the SEC brought...

It is always a pleasure to participate in FCPA and compliance discussions with Tom Fox. Tom and I recorded a podcast on the Odebrecht and Teva Pharmaceuticals FCPA enforcement actions. A copy of the recording is available here. Happy New Year!!!!

You know this has been a big year in FCPA enforcement when DOJ and the SEC announce two FCPA settlements during the usually sleepy week between Christmas and New Years. And what a year it has been – more to follow in my post-New Years series of postings. General Cable The SEC and DOJ announced a $75 million settlement for FCPA violations with General Cable...

Corruption Crime & Compliance and The Volkov Law Group wish everyone happy holidays, peace and a wonderful New Year. We appreciate all the support from our readers and clients. We hope you enjoy your holidays with your family and friends. See you next year in 2017!!!

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made.  Groucho Marx We are all taught the importance of honesty. But there are very different aspects to this otherwise simple proposition. People are sometimes honest with each other, and sometimes they are not. Honesty, however, is a much harder concept when speaking to your self – you...

CCOs face many challenges in their jobs. One area that is difficult but usually can be solved with common sense is where to draw the line on attorney-client privilege issues. As a practicing attorney, I can attest to the importance of the attorney-client privilege. It is a principle that is critical to the functioning of a corporation or any other organization. Communications for the purpose...

It is hard to imagine how prosecutors were able to bring cases before there was email communications. When I was a prosecutor, we looked for evidence in a lot of other sources, internal memos, calendars and other places where people would write incriminating messages. The routine use of emails, texting and instant messaging systems has changed everything. Each of these technologies are often used by...

A Chief Compliance Officer can get lost in terms, titles, risk management solutions, effective services, magic bullets, absolute requirements and ultimately confusion. Whether the strategy is called lines of defense or some other moniker of professionalism and deep thought, the real work occurs in the trenches and with a practical eye to minimizing risks while protecting the company.  When a CCO adheres to common sense...