Corruption, Crime & Compliance

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28 Aug, 2022

Episode 245 — Second Circuit Affirms Trial Judge Dismissal of FCPA Verdicts Against Alstom Executive

The Second Circuit Court of Appeals affirmed the district judge’s post-conviction dismissal of FCPA counts against Lawrence Hoskins, a former Alston executive, for his involvement in bribery scheme to secure a $118 million energy contract in Indonesia. The Hoskins FCPA case has had a long and tortious path through the court system, and the Second Circuit’s decision, which was decided by a 2 to 1...

General

26 Aug, 2022

Michael Volkov Featured on Diligent’s Corporate Director Podcast

This week, I was honored to appear on Diligent’s The Corporate Director Podcast to discuss corporate ethics, corporate boards and compliance. You can access the episode HERE. Thank you to the wonderful people at Diligent for the opportunity.

General

24 Aug, 2022

Tracking Ethics and Compliance Program Performance (Part II of II)

Chief compliance officers rely on several important sources for feedback — internal data and communications (reviews with board, senior managers, employees); and benchmarking against comparable organizations. An internal compliance dashboard is an important part of this feedback loop and brings consistency to measurement and trend analysis. Policies and Procedures: Assuming that the organization has adopted a policy management program (often using an automated program), for...

General

23 Aug, 2022

Building a Compliance Dashboard (Part I of II)

This is a topic that every compliance professional has to address in one form or another. Chief compliance officers are so busy that they often cannot even take the time to tackle this difficult issue. This is a real practical issue of importance. Just to define terms and the focus of this blog posting — we have to define the issues and purposes of the...

General

22 Aug, 2022

New York’s Department of Financial Services Proposes New Cyber Compliance Requirements

The New York Department of Financial Services (“DFS”) has proposed rule changes to increase cyber compliance requirements. DFS has been the leading regulatory force in the cybersecurity industry. DFS first issued comprehensive cybersecurity rules in March 2017. Many other regulators and international organizations have adopted many of these regulations as best practices for cybersecurity requirements. The proposed rules would impose some significant requirements, including: Expansion...

Podcasts

21 Aug, 2022

Episode 244 — Building a Compliance Program Dashboard

Chief compliance officers have access to a vast amount of data generated by their compliance programs. CCOs have to establish effective monitoring processes. A critical part of this process is to build a compliance program dashboard. This is a practical issue of real importance. In this Episode, Michael Volkov reviews this important issue.

General

17 Aug, 2022

LRN and Tapestry Networks Issue Important Guidance for Corporate Boards and CEOs to Build and Manage Ethical Cultures

You can always count on LRN. No ifs, ands or buts, LRN continues to issue the highest-quality and most meaningful research and guidance on ethics and compliance programs. LRN digs in to ask the hard questions, measures important trends and consistently provides importance support and guidance for corporate governance. LRN is a must read in these areas. Now that I finished by promotional rant, let’s...

General

17 Aug, 2022

Department of Commerce Bureau of Industry and Security Brings Enforcement Actions Reflecting New Policies

The Commerce Department has adjusted its export control enforcement program. The Bureau of Industry and Security (“BIS”) announced the new administrative policies and gave notice to the industry and public. BIS is now bringing enforcement actions under this new regime. Luis Fernando Garcia BIS entered into a settlement agreement with Luis Fernando Garcia, the owner of GE Equipos de Seguridad, who sought to illegally export...