Corruption, Crime & Compliance

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5 Aug, 2016

Webinar: Best Practices for Effective Ethics and Compliance Training

August 18,2016 1 -2 PM EST Sign up Here Farzad Barkhordari, President of Workplace Answers, and Michael Volkov, CEO of The Volkov Law Group, LLC, are pleased to announce a joint webinar to discuss best practices for effective compliance training programs. Farzad and Mike plan to outline strategies and practical applications to successfully incorporate training into your overall compliance program. The webinar will cover: Legal...

General

5 Aug, 2016

Click 4 Compliance Joins Forces with Workplace Answers

We are pleased to announce that one of sponsors, Click 4 Compliance, has joined forces with Workplace Answers, the leading online compliance training solution for human resource professionals. Click 4 Compliance is a well-recognized name in providing eLearning training for corruption, bribery, due diligence, business ethics and other relevant topics. By joining forces, I am confident that Click 4 Compliance and Workplace answers will be...

General

4 Aug, 2016

Defining the Compliance Mission – More Than Just Preventing Violations

I am not one to beg but I have decided I have nothing to lose here – please, when it comes to compliance, everyone has to adopt a new mantra. The purpose of compliance is not to prevent legal and code of conduct violations. Such a purpose is way too limited in scope and almost guarantees failure, because at one time or another, company employees...

General

3 Aug, 2016

Getting Your Arms Around Antitrust Compliance (Part II of II)

Anti-corruption compliance programs are the rage now – is that a young person’s expression? Antitrust has been a forgotten stepchild, partly because of DOJ’s unwillingness to credit companies that maintain effective compliance programs. That is not a legitimate excuse since every company should be addressing antitrust compliance as part of an overall compliance program. Antitrust compliance, however, has been around for many years, and usually fell...

General

2 Aug, 2016

The Often Ignored Importance of Antitrust Compliance (Part I of II)

If you ask any Chief Compliance Officer whether their compliance program includes antitrust laws, they will respond quickly and tell you – “Of course we do.” If you follow up you initial question and ask how do you ensure compliance you will hear a single response – “We conduct training.” When you scratch the surface on antitrust compliance at major companies, you will usually hear...

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31 Jul, 2016

DOJ and SEC Collect $22 Million from LAN Airlines for Conduct in Resolving Labor Dispute

Last week, the Justice Department (here) and the SEC (here) announced parallel FCPA settlements totaling $22 million in fines, penalties and disgorgement against LAN Airlines, a Chile-based airline, for conduct in resolving a labor dispute in Argentina. In March 2016, the SEC settled a case with LAN’s CEO for approving payments to a consultant, an advisor to the Secretary of Argentina’s Ministry of Transportation, to...

General

28 Jul, 2016

The Real Value of Lawyers to Compliance

The legal profession is transforming itself, especially in the area of compliance. Lawyers are an invaluable part of a compliance program. They provide important perspective and understanding of risk, they help a company to assess and navigate legal risks and they interface with regulators and enforcement agencies. The most effective compliance programs usually are built around a strong partnership between a chief compliance officer and...

General

27 Jul, 2016

The Power of a Justice Department Declination

Tom Fox and I recorded a podcast recently on the Johnson Controls enforcement action. In our podcast we discuss a number of issues relating to the Justice Department’s decision to reward Johnson Controls with a declination. You can listen to our podcast here. It is always a pleasure to work with Tom and our discussion centered on a number of issues, including DOJ’s FCPA Pilot...

General

25 Jul, 2016

Building a Company Culture of Trust

The messaging behind the need for companies to implement robust compliance programs continues to suffer from a narrow conception of the overall compliance function. It is easy to get lost in the weeds on compliance programs and focus on compliance tasks, policies, resources, assessments and audits. I have promoted a different messaging approach – one that gives full credit and priority to a robust compliance...

General

25 Jul, 2016

The Importance of Risk Ranking to Compliance

We all face a number of risks every day. Yet, we do not respond to each and every risk. We engage in risk-ranking our responses. Some are more risk than others and some are more catastrophic than others. So, we engage in risk ranking each day and allocate our time and attention accordingly. The same applies, or should apply, when managing a compliance program. Resources...