People are getting confused. A company’s ethical culture is not a touchy-feely concept that makes everyone warm and cozy all over. At the same time, compliance controls are not hard and fast rules that are mechanically enforced with no regard to purpose or results. I always get frustrated when people like to classify concepts as either black and white. People are uncomfortable with grey concepts,...
Recently, the Justice Department announced the arrest of John Baptiste as part of an ongoing investigation into corruption in Haiti. The arrest warrant affidavit outlines an undercover investigation, including Title III wiretaps of John Baptiste’s cellphone. In this podcast, Michael Volkov reviews the investigation of Baptiste, culminating in the arrest of Baptiste on August 28, 2017. A copy of the arrest warrant affidavit is here.
I am pleased to offer a free podcast service under the same title as the blog — Corruption, Crime and Compliance. We have added a button on the left slide of the blog to make subscribing easy. Here is link to Episode 2, which includes subscription buttons: Here We have released two episodes so far, and a third episode will be released on Sunday. Episode...
At the outset, let me concede that I am not a psychiatrist (although we all feel like one at times with family members and colleagues). My observations on CEO leadership come from my own life experiences, and professional experience. I know there are lots of so-called “leadership experts” but I think much of leadership is intuitive and requires intelligence and interpersonal skills. I have worked...
It is time for an honesty check – many CCOs do not like change. CCOs, however, need to embrace change as a powerful force. Compliance is an evolutionary process – it is constantly changing. A compliance program has to move like a shark and constantly take into account new trends, new risks, and new business developments. CCOs who resist change are doomed to fail. This...
Chief compliance officers have to devote more time to establish and maintain a positive relationship with the corporate board or audit/compliance committee. CCOs have a lot of responsibilities and feel a lot of pressure to address internal operational issues. It is easy to “ignore” the importance of a positive relationship with the corporate board. A CCO who has a strong relationship with the company’s board...
With the increased focus on corporate culture, chief compliance officers have to educate the board and senior management on the inextricable link between an ethical culture and financial profitability. In this episode of Corruption, Crime & Compliance, Michael Volkov outlines the link between ethical culture and sustainable growth. During the episode, Michael refers to two studies on the subject. The studies are noted below with...
I had the good fortune to spend time recently with Bureau van Dijk’s Alistair King for an interview. BvD recently posted the interview Here. BvD is a sponsor of this blog and a terrific compliance partner I have been impressed with BvD’s product offering – key tools in your third-party screening process that offer difficult to find information. BvD specializes in information on private companies,...
Let’s start out with something ironic – the C-Suite typically resists the need for ethics and compliance training, as well as other compliance controls, claiming that they know everything about ethics and compliance. Unfortunately, when a member or members of the C-Suite commit misconduct, the consequences can be devastating for the company. We all know high-profile instances of C-Suite misconduct involving bribery, fraud, and theft....
Criminologists have debated for years the efficacy of the law enforcement strategy of “broken windows.” In simple terms, the theory suggests that minor infractions or petty crimes should be vigorously prosecuted in order to deter more serious crime. In addition, the theory suggests that a deteriorating environment (e.g. where broken windows are not repaired and allowed to increase), creates an environment where serious misconduct is...
