Interviews and Internal Investigations (Part II): December 6, 2016, 12 PM EST Sign Up Here The Volkov Law Group is pleased to offer a three-part series of free webinars on the essential aspects of a Speak Up culture: a prompt, efficient and fair internal investigation system; effective interview strategies; and the elements of a Speak Up culture in which employees report misconduct, investigations are...
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I am pleased to announce our new website for The Volkov Law Group — Here Many thanks to Volkov Law Team members: Managing Associate, Lauren Connell; Associates, Jacqui Merrill and Susan Simpson; and Counsel, Vincent Ruiz. We offer the following services: Corporate and individual criminal defense Corporate ethics and compliance programs Internal investigations Please contact us if you are interested in would like to discuss...
Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the risk created by third party intermediaries. In the last five years, companies have embraced new technologies to automate their third party screening and monitoring programs. Companies are slowly but steadily replacing...
There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has committed itself to increasing transparency. That is a very good thing. If you go back and review FCPA settlement actions from years ago, you will not find any structured...
Two executives were charged last week with criminal violations in the Southern District of New York relating to Valeant Pharmaceuticals activities. These charges are the first of more to come in an ongoing investigation focusing on Valeant’s corporate demise from a high-flying pharmaceutical company. I have written before about Valeant’s rotten culture, slavish devotion to quarterly performance, and short-sighted management culture that ultimately bred a...
In the risk mitigation business, we often focus on legal risks, such as anti-corruption, sanctions, export controls, antitrust and AML. As compliance programs mature, and the CCOs focus on proactive strategies, one key issue is conflict of interest. My experience with conflict of interest issues has confirmed that such conflicts often mask more serious compliance issues relating to fraud and even legal violations. As such,...
Sign Up for Three-Part Webinar Series: Internal Investigations Systems (Part I): November 29, 2016, 12 PM EST Sign Up Here Interviews and Internal Investigations (Part II): December 6, 2016, 12 PM EST Sign Up Here Speak Up Culture (Part III) December 13, 2013, 12 PM EST Sign Up Here Companies are struggling to establish and embed a Speak Up culture. Companies need...
Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved. For months (and even years), we have followed this investigation and its twists and turns. Several years ago, press reports revealed an interesting piece of evidence discovered during the investigation – a spreadsheet kept...
Chief compliance officers have a difficult job. That is a real profound grasp of the obvious. CCOs face an unending onslaught of tasks, risks and juggling of concerns and activities. On many respects, a CCO’s job is never done – once they accomplish a project, they have an unending list of tasks to address. CCOs are the unsung heroes of corporate governance. They get little...
