As the old saying goes, “don’t break your arm patting yourself on your back.” Everyone is pretty happy about their due diligence systems for screening third parties. I understand how they feel but there is still a long way to go. It is one thing to screen a third-party at the on boarding process; it is quite another to build out an entire due diligence...

I have been writing lately about the rise of OFAC sanctions enforcement. OFAC and the Justice Department have started to build a close working relationship similar to that between the SEC and the Justice Department relating to FCPA enforcement. For years, the blockbuster OFAC sanctions enforcement cases have involved the financial industry. DOJ’s recent settlement with Schlumberger Oilfield for $232 million demonstrates DOJ’s commitment to...

I am proud to announce that the Volkov Law Group and The Claro Group have teamed up to offer companies a new and important service — internal controls assessments. Our proven experience in corruption investigations and compliance initiatives can help you put together the pieces The Environment The Justice Department and the SEC have keyed anti‐corruption investigations to reviewing a company’s internal controls. In fact,...

Lauren Connell from The Volkov Law Group rejoins us with a posting on third-party questionnaires and due diligence. Lauren’s profile is here and she be reached at [email protected]. Third Party questionnaires are a standard part of any due diligence process.  They are emailed to the potential third-party business partner, filled out and sent back, or the third-party enters the information through an Internet portal.  Compliance...

I am happy to welcome a new sponsor to Corruption, Crime & Compliance — Click 4 Compliance.  Click 4 Compliance’s website is here. Click 4 Compliance is an online compliance training company founded by Farzad Barkhordari and Robin Campbell. Mr. Barkhordari is the former head of global anti-corruption at Sun Microsystems, Inc., and Ms. Campbell is a Privacy and Data Protection expert, having assisted European and...

Whatever your political viewpoints may be on the dividing line between federal and state responsibilities, or the interpretation of the 10th Amendment to our Constitution, there is no question the Framers saw an important role for the federal government. To test everyone’s knowledge in this area, don’t forget the Framers were drafting the US Constitution in the aftermath of the failed Articles of Confederation experiment,...

One of many pet peeves I have in the compliance space is the lack of creativity in compliance program measurement. Chief Compliance Officers have to take a fresh approach to this issue. They have to break out of the old mold and bring about some innovative approaches in this area. I hate to be such a nay-sayer but something has to be done. If I...

I know I am like a broken record (ask my wife and kids). Sometimes I know I am repeating myself but I enjoy telling the same story or giving the same advice. I understand that can be frustrating for people. A compliance program requires comprehensive documentation. We all know that. Tom Fox, my colleague, repeats the mantra of “document, document and document.” He and I...

Prosecutors have taken a few lumps lately. Based on my own experience, most prosecutors are dedicated, hard-working, public servants who are committed to “doing the right thing.” I admired and respected many if not all of my colleagues at the US Attorney’s Offices and the Department of Justice throughout my career. Prosecutors have a lot of power. They can ruin an individual’s life very easily....