Corruption, Crime & Compliance

Featured Articles:

28 Sep, 2016

Free webinar: Unravelling Corporate Structures: Understanding beneficial ownership and introducing new tools for due diligence

Beneficial ownership remains a compliance hot topic. While understanding beneficial ownership of an entity – a corporate or fund – is a key element in many compliance activities, it’s a daunting challenge. Countries vary in the amount of financial data private companies are required to disclose, and disclosure of ownership is not yet mandatory. Join us for a free webinar on October 12 (Register Here) during...

General

27 Sep, 2016

Match Made in Heaven: Compliance and Human Resources

The corporate compliance function is only as successful as its partnerships with key internal constituencies. Depending on the company and the personnel involved, compliance has to establish and maintain effective working partnerships with key functions, such as human resources, legal, finance, and security. All of the relationships are mutually beneficial. Each component works better when it is able to partner and work seamlessly with another...

General

26 Sep, 2016

Who is Responsible for a Company’s Mood in the Middle? – the Wells Fargo Fiasco

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on the Wells Fargo scandal. Lauren can be reached at [email protected]. Wells Fargo’s cultural tone is not easily segregated between “top,” “middle” and “bottom.” Despite the recent cross-selling scandal, in which the CFPB led an enforcement action whose fines total a whopping $185 million, Wells Fargo’s CEO John Stumpf reluctantly...

General

25 Sep, 2016

Trust But Verify — Due Diligence with a Jaded Eye

Ronald Reagan’s mantra with respect to US-Soviet relations in the 1980s applies with equal force to today’s world of due diligence. (I know it shows my age that I can recall this statement). Not all due diligence cases require a skeptical eye. But most compliance professionals know when they are digging into a due diligence review that will require a substantial investigation. Government enforcement agencies...

General

22 Sep, 2016

Three Key Takeaways from the Nu Skin FCPA Settlement for a Corrupt Charitable Donation

In a rare enforcement action, the SEC settled an FCPA enforcement action for $766,000 for a charitable donation of $154,000 to improperly influence a high-ranking Chiese Communist party official to prevent a provincial agency investigation of Nu-Skin’s Chinese subsidiary. Nu-Skin China was being investigated in China for violating provincial direct sale restrictions. The Chinese Administration of Industry and Commerce investigated the matter and proposed to...

General

20 Sep, 2016

Sampling as a Compliance Strategy

In the technology age in which we live, CCOs often come face to face with a new phenomenon – too much information or data. TMI is not something to laugh at nor ignore. CCOs often face situations where they need to understand what is occurring through a monitoring or audit function. In those cases, CCOs have to decide whether it is worth the cost in...

General

19 Sep, 2016

President Obama Pledges to Lift Myanmar Sanctions

Jacqui Merrill, an associate at The Volkov Law Group, rejoins us for a posting on the Myanmar Sanctions. Jacqui can be reached at [email protected]. On September 14, 2016, President Obama met with Myanmar’s leader, State Counsellor Daw Aung Suu Kyi, at the White House and announced the United States’ intent to remove economic sanctions against Myanmar (formerly known as Burma) in the near future. The President...

General

18 Sep, 2016

Talking with Your Feet – The CCO’s Ethical Dilemmas

Chief compliance officers are optimistic and committed to “doing the right thing.” It is in their blood and may be at the core of their professional fabric. My guess is that there are far fewer CCOs who like to push the envelope than their legal counterparts. Some lawyers are capable of accepting certain levels of risk for defined benefits. CCOs are more risk averse. The...

General

15 Sep, 2016

Third-Party Risk Management – Part 2: Contract Termination

Cristina Muehl’s second part of her series addresses third-party risk management relating to contract termination. Cristina is a Senior Corporate Auditor at Delphi Corporation. Her Linked In profile is here. She can be reached at [email protected]. This second part of the series will take a look at the last phase in the lifecycle of third-party business relationship and that is contract termination. This is a...

General

14 Sep, 2016

Third-Party Risk Management – Part 1: Contract Extension

I am pleased to welcome Cristina Muehl as a guest contributor. Cristina has provided a two-part series on third-party risk management relating to contract extensions and contract termination. Cristina is a Senior Corporate Auditor at Delphi Corporation. Her Linked In profile is here. She can be reached at [email protected]. Risk Management is a constant theme for top management as it might make the difference between...