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...
We all know the jokes about lawyers. We have heard them over and over, at parties, with friends, and among colleagues. Right now, they seem particularly on point. The Valukas Report lays out an ugly picture of in-house counsel at GM. If you have the stomach to read the entire report, it will make you sick and sad for our profession. It is a depressing...
“What we’ve got here is a failure to communicate”—Captain in Cool Hand Luke Sometimes Chief Ethics and Compliance Officers need to zero in on an issue because it is critical to the operation of an ethics and compliance program. I am not suggesting that CECOs should never focus on an issue but I am reluctant to urge micro managing because of the danger of getting...
The Valukas Report to the General Motors Board of Directors Regarding Ignition Switch Recalls is a lengthy report that describes in excruciating detail how GM failed to uncover and remedy significant safety issues relating to an ignition switch used in various GM model cars. It is easy to lose perspective when reading the report but GM’s basic safety breakdown directly led to the death of...
The Volkov Law Group is offering a great opportunity for experienced attorneys seeking a position with a nationally-recognized boutique law firm. A leader in anti-corruption compliance and defense, the Volkov Law Group offers an innovative work environment with virtual offices on both east and west coasts. The Firm specializes in ethics and compliance services, including anti-corruption, trade compliance and AML services, as well as white...
Chief compliance officers are under intense pressure. They are being watched inside every company to make sure they deliver on their “compliance” program, and outside observers are ready to comment on any misstep or breakdown in corporate compliance. It is a wonder that CCOs can get their job done. They are pulled in a million directions, given inadequate resources, and held accountable for an unrealistic...
The bedrock of a compliance program is corporate culture. Let’s all agree to throw away the following often-repeated phrases: ”tone-at-the-top” and “buzz at the bottom.” I would argue that we replace those trite and meaningless phrases with the all-important one – “culture of ethics.” There is no rational reason to continue segregating culture into distinct levels of the company — top or bottom. A more...
Corporate boards have been under siege. If you ask a Board member about the changes in corporate governance, risk and accountability, they roll their eyes and lament that the job of a board member has become more complicated and difficult. Let’s try and look at the experience from their perspective. Board members usually enjoy focusing on a company’s financial performance and some of the more...
