All for One and One for All – The Three Musketeers, Alexandre Dumas The famous swashbuckling adventure of The Three Musketeers should inspire chief compliance officers to pursue an important concept – the need for teamwork and collaboration is imperative for all compliance programs.  We all know the pernicious effect that operational silos can create for CCOs and their need to collaborate with operational partners...

Say What You Mean and . . . Mean What [You] Say – The March Hare in Lewis Caroll’s, Alice’s Adventures in Wonderland Matt Axelrod, the Assistant Secretary for Export Enforcement, at the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce, must be grinning with satisfaction that BIS delivered, in a big way, after he warned businesses that BIS would be...

The Supreme Court rejected a challenge by Halkbank, a Turkish state-owned bank, to its criminal prosecution for anti-money laundering violations and evasion of Iran Sanctions.  In a 7-2 decision, authored by Justice Kavanaugh, the Supreme Court rejected Halkbank’s claim that it was immune from U.S. federal criminal prosecution.  The Supreme Court remanded the case back to the Second Circuit to consider whether the common law...

Microsoft agreed to pay $2,980,265.86 for illegal exports of services and software to sanctioned jurisdictions and Specially Designated Nationals (“SDNs”) in violation of OFAC’s Cuba, Iran, Syria, and Ukraine-/Russia-Related sanctions programs. Most of the violations involved prohibited Russian entities or persons located in the Crimea region of Ukraine. Microsoft failed to identify and prevent the use of its products by prohibited parties. Microsoft voluntarily disclosed...

Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone.  To the contrary, as the business adapts through growth, innovation or in response to outside market and social forces, a company’s culture operates dynamically to reflect all of these influences.  Change is inevitable for businesses (and for individuals in life).  With this perspective, companies cannot just sit...

As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture.  In these situations, employee misconduct rates increase, wrongdoing and scandal surround the company, and corporate leaders ultimately fall from failing to sail the corporate ship in the right directions. There are tell-tale signs of...

Everyone has jumped on the corporate culture bandwagon.  For some new converts, they like to espouse corporate culture as a recent discovery, or a new-fangled approach for compliance programs. The story of corporate culture as a talismanic tool for ethics and compliance is really nothing new.  Chief compliance officers knew the importance of corporate culture from the beginning.  A number of companies separately called out...

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a posting on the recent international adoption of a human rights code of conduct. Alex can be reached at [email protected]. On March 30, 2023, the United States Department of State announced the adoption—in conjunction with a host of international partners—of a specific Code of Conduct related to human rights considerations in the context...