5 Practical Trade Compliance Steps to Save Time and Money
I recently posted an article on International Trade Matters — 5 Practical Trade Compliance Steps to Save Time and Money –– the article is here.
Featured Articles:
The Two Essential Requirements for Tone-At-The-Top
Everyone likes to give advice on the importance of tone-at-the-top. Like many things in life, it is easy to talk about but much more difficult to implement. There are lots of ways to describe or analyze the same issue. In the end the result has to be reached. To boil it down, tone-at-the-top requires leadership. That is pretty obvious. But, what kind of leadership? This...
Slowing Down the SEC Administrative Train
I am convinced that the law eventually reaches the “right” solution. There may be disastrous detours along the way, but in the end the law will adapt to reach the right result. Of course, our history is replete with instances of controversial, and ultimately embarrassing, court decisions (e.g. Plessy v. Ferguson). Nor do I mean to suggest that the SEC’s reliance on administrative hearings for...
FinCEN Proposes to Apply AML/BSA Requirements to Investment Advisers
FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership requirements for financial institutions is expected to be released before the end of the year. FinCEN’s proposal in this area will have a significant impact on companies subject to AML...
Hiring Practices: A New or Old FCPA Compliance Challenge?
Contrary to the opinion of many in the FCPA space, the BNY Mellon settlement and the looming actions against six major financial institutions for hiring practices is not a big shock or surprise. The SEC is not raising a new or novel interpretation of the FCPA. After all, assuming an actor has corrupt intent, there is no real question as to whether hiring a person...
Taking Charge of a Company’s Reputation: Assign a Single Person to Manage Reputational Risks (Part III of III)
One person who does not have a conflict in evaluating a company’s reputational risks should manage a company’s reputation. This approach starts with one basic requirement – the board and the CEO have to agree that a company’s reputational risks should be managed and mitigated. As an initial step, the company has to assign responsibility for reputational risk to a senior executive responsible for risk...
Managing Threats to Corporate Reputations (Part II of III)
Most companies do not adequately manage their reputations and the risks to their reputations. Too many companies are focused on “crisis” management, which is just another way to respond to a reputational risk that has already occurred. Such a focus is not reputational risk management but is more accurately labeled as crisis management, a reactive strategy. Companies have to change their perspectives and focus proactively...
Calculating the Incalculable: Reputational Damage (Part I of III)
Today I begin a three-part series on reputational damage. The first part tries to define the term “reputational damage;” the second part focuses on managing threats to a company’s reputation; and the final posting proposes creation of a senior risk manager in a corporate leadership team. If you ask CEOs and board members about the threats to a company resulting from a DOJ enforcement action,...
Reminders: Volkov Law TV, E-Mail Subscriptions, Books and Volkov Law for Ethics and Compliance
Here at Corruption, Crime and Compliance, we aim to please our readers, subscribers, clients, associates and friends. We are committed to promoting the importance of ethics and compliance strategies, to supporting corporate governance improvements, and to implementing effective ethics and compliance functions. At the same time, we offer clients representation in response to government inquiries, subpoenas, investigations, as well as civil litigation. Our legal services...
Webinar: Anti-Corruption Compliance in the High-Tech Sector
Webinar: Anti-Corruption Compliance in the High-Tech Sector Wednesday, September 9, 2015, 12 Noon EST Sign Up Here The Justice Department and the SEC have focused FCPA enforcement resources on high-tech companies. Several high-tech companies have settled FCPA enforcement actions, while others remain under investigation. In a recent enforcement action, an SAP former executive plead guilty to an FCPA conspiracy and is awaiting...
