You don’t need a weatherman to know which way the wind blows. – Bob Dylan, Subterranean Homesick Blues Political winds are important for a number of reasons. When working in the government, you have to seize the political opportunities to advance practical proposals. When it comes to requiring banks and financial institutions to collect beneficial ownership information from account holders and customers, the Panama Papers...
Let’s start with a big “If.” I know that sounds like a real turn off but bear with me. Assuming that the Justice Department is ready to turn over a new approach to criminal enforcement and aggressively prosecute culpable individuals in white collar crime investigations, would it be a good idea to offer a pass, or leniency to the company if the company self-reports the...
Just to add to the cacophony of voices campaigning during this primary season, DOJ, SEC, FINRA, and CFTC officials launched their own campaign promoting recent initiatives to increase corporate self-reporting of potential violations. After months of announcements, which were preceded by internal wrangling and bureaucratic leaks, DOJ has put in place its new initiative – the Yates memorandum to focus on individual culpability and a...
I am excited to announce a new sponsor of Corruption Crime and Compliance, Bureau van Dijk (BvD). 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, detailing company hierarchies and standardized financial reports so you can compare companies across international borders. BvD’s product range...
Job: Compliance Manager (Columbus, Ohio, metro area) A leading industrial growth company that delivers a comprehensive set of products for use in the construction and infrastructure sectors is seeking a Compliance Manager to oversee the day-to-day operation of its compliance program and internal controls procedures. This position is suited for a self-motivated individual seeking to help structure and manage a program from the ground up. ...
There is something a little surreal when a CCO, while negotiating to join a company, raises the issue of his or her own termination. Not to be maudlin, but it is an important issue to consider. The dangerous scenario is not so far-fetched. A CEO or someone from the C-Suite pushes to terminate a CCO because a CCO is likely to uncover some potentially improper...
Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on DOJ’s recent FCPA guidance announcement. Lauren can be reached at [email protected]. Her bio is here. Lots of people are talking about the DOJ’s new self-disclosure pilot program, but it was only the last of three steps announced in the DOJ’s Fraud Section FCPA Enforcement Plan and Guidance. One...
We all have heard the scenario involving a compliance professional. A new CCO joins a company with promises from the board, the CEO and senior executives of cooperation, compensation and support for a robust independent compliance function. The new CCO arrives with an idealistic spirit only to discover that he or she has been misled. Sure, the CCO has a title, and a nice salary,...
The FCPA Paparazzi have a thick head and a stubborn chin. They just do not understand the significance of Compliance 2.0 to corporate governance and they blindly adhere to simplistic, yet unexplained, solutions to complex problems – kind of sounds like a presidential candidate we all know. Without getting into politics, which I avoid here on this blog, DOJ’s recent FCPA guidance on voluntary, disclosure,...
How to Conduct FCPA Audits May 4, 2016, 12 Noon EST Sign Up Here As companies implement anti-corruption compliance programs, the need for auditing and monitoring of their compliance programs increases. Companies have to structure an audit program to address significant risks and to identify potential weaknesses and problems. Mitigating those deficiencies can be a real challenge. Join Michael Volkov, CEO of The Volkov...
