The Justice Department continues to be dogged by questions surrounding its conduct of criminal investigations. These concerns are being raised in the context of extreme cynicism given DOJ’s “failure” to prosecute individuals from the financial crisis last decade. Whether it is accurate or not, the public and many politicians view DOJ’s lack of aggressive prosecutions as a significant failure. I am not going to address...

The Treasury Department’s Financial Crimes Enforcement Network has been flexing its muscles lately to remind everyone of its important role in money laundering enforcement. Jennifer Shasky, the current Director, a former prosecutor from the Department, knows how to get things done and she is certainly pushing a number of buttons. In a recent speech, Shasky warned companies about illegal money laundering schemes involving real estate....

We all know our favorite things and people who fit together well – milk and cookies, peanut butter and jelly, chips and salsa, Tracy and Hepburn, Martin and Lewis, Abbott and Costello, and many other great combinations. In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate...

Chief Compliance Officers carry a lot of weight on their shoulders. Some days, I am sure, they have trouble getting up and soldiering on to tackle the next challenge. As I always quip, no one congratulates the CCO on a job well done – instead, when something goes wrong, everyone looks to the CCO and asks, “What happened?” Like every leader, CCOs are charged with...

There is something in a name. More people in the compliance industry, when referring to third-party due diligence, are labeling it “Third Party Risk Management.” I like it because it is more accurate. Due diligence screening of existing or new third parties is just an initial step – it is not an end unto itself. Assuming that the third-party passes the due diligence review, there...

Lauren Connell from The Volkov Law Group rejoins us with a posting on the recent New England Patriots scandal relating to deflated footballs.  Lauren can be reached at [email protected]. If only the New England Patriots had an Anti-Bribery and Anti-Corruption program, “Deflategate” might never have entered America’s vocabulary.  The long-running saga re-entered the media this past week with the release of the internal investigation results, undertaken...

My colleague, Tom Fox, is a prolific writer.  His talents extend from his new consulting firm, to his always interesting blog, and to his formal written volumes of work.  Tom is a major contributor to the compliance profession.  Everyone can always learn something from Tom, no matter what you level of experience. Compliance Week just released Tom’s new hardbound book — Doing Compliance: How to Design, Create,...

Webinar: Tuesday, May 19, 2015, 12 Noon EST How to Respond to a Potential FCPA Violation Sign Up Here   A company should adopt specific protocols for handling potential FCPA violations. The company’s immediate reaction to an apparent violation can be critical to the eventual outcome. Corporate decision-making depends on collecting relevant information as quickly as possible and making an informed strategic decision on follow-up...

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The future of compliance includes technology solutions. Do not get me wrong – technology is not a panacea but it is an important strategy for leveraging resources.   In the anti-corruption and sanctions compliance arenas, technology is an important tool, especially for third-party risk management and knowing who your business partners and customers are for sanctions compliance. AML and Bank Secrecy Act compliance heavily depends on...