Featured Articles:

CCOs and CFOs: Bringing Everyone Together

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...

Ominous Signs for the Future of the Compliance Profession

As we celebrate Ethics and Compliance Week in 2017, I wanted to offer my own assessment of where the compliance profession stands and the challenges facing the profession for the future. I am an eternal optimist – I will never fall to the dark side of cynicism and pessimism. Over the last ten years, the compliance profession has made great strides as a profession and...

Update on The Volkov Law Group

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...

Episode 9 — The Need for a Robust Criminal Antitrust Compliance Program

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...

Volkov Law TV — New Webinars For Low Monthly or Annual Fees

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...

HR and Compliance: Working Together to Hire Ethical Employees

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...

Anti-Corruption Risks: Global Enforcement Means Global Detection

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,...

Compliance and Technology – Rational Actors Need to Adopt Technology

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

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...

Episode 8 — The Critical Importance of Beneficial Ownership to Compliance

In the aftermath of the Panama Papers scandal and increased focus on shell companies and hidden ownership interests, US enforcement and regulatory agencies are increasing focus on beneficial ownership of related entities.  In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers in order to ensure full compliance with anti-corruption,...