Sam Finkelstein, an Associate at The Volkov Law Group, rejoins us for another posting about 3M’s recent settlement for violations of the Iran Sanctions Program. Sam can be reached at [email protected]. The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned...

LRN’s annual Program Effectiveness Report is chock full of important findings.  Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it). LRN’s Report notes that its large data set contains the survey results from 1,860 ethics and compliance professionals from organizations around the world.  As explained by LRN, the compliance industry continues to...

Sam Finkelstein, Associate at The Volkov Law Group, rejoins us for a new posting on OFAC’s announcement of new sanctions targeting Russia’s military-industrial complex.  Sam can be reached at [email protected]. The United States is determined to ensure that no one profits off of Russia’s war against Ukraine. To that end, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has widened the...

Mary Shirley, a leading voice in the legal and compliance field, has just released her new book — Living Your Best Compliance Life: 65 Hacks & Cheat Codes to Level Up Your Ethics & Compliance Program. Order Mary’s New Book Here. Mary is a well-known advocate, speaker and compliance professional. She regularly speaks at Compliance events. She is mentor to the Compliance Profession. In this Episode,...

Alex Cotoia, Regulatory Manager at The Volkov Law Group, joined Tom Fox for a Diligent-Sponsored Podcast on building a stronger culture of compliance. You can listen to the Podcast Here. Tom Fox conducted a special series this week on building a stronger culture of compliance through targeted and effective training sponsored by Diligent. This week, Tom visited with Yvette Hollingsworth-Clark, Viktor Culjak, Jessica Czeczuga, Michael...

October 24, 2023 12 Noon EST Sign up HERE The Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. DOJ’s message has been reinforced by the Departments of Treasury (Office of Foreign Asset Control, or “OFAC”) as to sanctions, and the Department of Commerce (Bureau of Industry and Security, or “BIS”), as to export controls....

Call me a skeptic.  Call me cynical. I understand that the International Organization for Standardization (ISO) provides valuable standardization services and guidance.  The ISO is comprised of 169 member countries. The ISO recently issued a new standard governing internal investigations.  From my vantage point, I was a critic of ISO 37001, anti-corruption compliance,  because of its over-generalization and failure to provide more specific guidance on...

We all agree on the importance of corporate culture.  Everyone gets it – corporate leaders mouth the words but rarely understand the nuances, and the need to attend to a company’s culture.  Compliance professionals want to devote more time to corporate culture but often are overburdened with less important tasks.  It is easy for compliance professionals to get lost  in the details, theory, and technology...

The United States continues to suffer from the absence of a federal data privacy and breach law.  Congress has tried for years to broker a deal here but has never been able to overcome strong lobbying forces — whether its high-tech, trial lawyers, law enforcement or other gadflies, the public continues to suffer. Instead, global businesses face a real mess, tracking data privacy laws state-by-state,...

The Department of Justice has been relatively quiet this year in announcing corporate FCPA enforcement actions and settlements.  Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana (“Corfico”) and Grupo Aval settlement is the first in 2023 involving a corporate FCPA resolution.  For the SEC, the Corfico and Grupo Aval settlement is the sixth corporate resolution in 2023. Corfico and its parent...