As Chief Compliance Officers rise in the corporate hierarchy, they will become the focus of more enforcement actions. This increased focus on prosecution of CCOs could have a chilling effect on their performance and the rapidly increasing pool of talent seeking to enter the compliance profession. As always, the devil is in the details. Just because a CCO has the title CCO, does not mean...

When reading about corporate governance, it is hard not to get frustrated. So-called “experts” in the field provide little practical advice but are filled with platitudes that apply to corporate boards, senior management and governance. Acronyms are bandied about as a special language is only understood by the great thinkers in the GRC discipline. Everyone needs to take a step back, agree on some basic...

As the old adage goes, appearances can be deceiving. Sometimes when you peel back the layers on an issue, you find out that everyone, even the Justice Department, can engage in “spin.” With trumpets and fanfare, the Department of Justice announced the Credit Suisse guilty plea for criminal tax evasion. Puff pieces were circulating in the press announcing the $2.6 billion criminal fine paid by...

With all the attention on ethics and compliance, it is interesting to take account of the vocabulary — terms like “culture, governance, access, processes, diligence, independence, and empowerment” are all bandied about. One term that is even more critical and frequently ignored is “accountability.” Ethics and compliance is so frequently tied to joint concepts, it is a gestalt that has little room for individual considerations...

“There is nothing more difficult to take in hand, more perilous to conduct, or more uncertain in its success, than to take the lead in the introduction of a new order of things.” —  Niccolo Machiavelli, The Prince (1532) We all have been following the “turn around” projects at some of the big companies — Walmart, Morgan Stanley, SNC-Lavalin, just to name a few. Changing a corporate...

I am pleased to announce that I will be hosting the first day of an exciting anti-corruption conference sponsored by American Leaders on September 10 and 11, 2014, in Washington, D.C.: Enhancing FCPA and Anti-Corruption Compliance for Life Sciences Conference.   The Sign Up for the Conference is Here.  Also, if you use the Promotional Code VOLK25, you will receive a 25 percent discount on...

I am pleased to announce that I will be hosting the first day of an exciting anti-corruption conference sponsored by American Leaders on September 10 and 11, 2014, in Washington, D.C.: Enhancing Anti-Corruption Compliance for Life Sciences Conference.   The Sign Up for the Conference is Here.  Also, if you use the Promotional Code VOLK25, you will receive a 25 percent discount on the conference...

The Justice Department’s aggressive enforcement program has had a profound impact on corporate governance. As a consequence, the last there has been a significant change in emphasis in the C-Suite, among general counsel and chief compliance officers. The last bastion of clinging to the old ways has been the corporate boardroom. Change has been much slower. Most people try to avoid change and cling to...

White collar criminal investigations take time. Corruption investigations are no different. Everyone expected UK Bribery enforcement to quickly increase and cause complex headaches for companies operating in the global marketplace. Looking back, many of us knew that without political support and resources, UK Bribery Act enforcement was destined to be a dud. No one would have expected for Canada to rise from the ashes, like...

Jon Umarov, Associate at The Volkov Law Group, returns as a guest contributor.  His profile is available here.  Jon can be reached at [email protected]. The Russian government adopted significant reforms to the country’s pharmaceutical industry starting in 2008. According to a 2012 survey of the Russian pharmaceutical industry conducted by Ernst & Young, both foreign and domestic manufacturers projected significant growth in Russia’s pharmaceutical markets. The...