Featured Articles:

Watch Bureau Van Dijk Webinar Replay — “Is Power and Control the New Beneficial Ownership?”

On May 16, 2019, I participated in a live webinar sponsored by Bureau Van Dijk, “Is Power and Control the New Beneficial Ownership?” The panel discussion was interesting and insightful. Ted Datta, Director, Governance, Risk and Compliance Solutions, Bureau van Dijk, Bill Hauserman, Senior Director, Compliance Solutions, Bureau van Dijk, and myself. The replay is available HERE. (Replay begins at 14:00) The discussion covered a...

The Positive and Negative Mix of Corporate Compliance Trends

We all like to believe in straight-forward and consistent trends and developments.  For example, compliance programs are improving, budgets are increasing, and CCOs are embracing new technologies.  Everything is just rosy when it comes to compliance.  But reality is far from consistent and far from simple trend lines and straight-forward explanations. Please do not get me wrong – over the last ten years, the rise...

Report from SEC Conference: Compliance, Cooperation and Culture

Jessica Sanderson, Senior Counsel at The Volkov Law Group, recently attended the Rocky Mountain Securities Conference in Denver, Colorado.  Jessica’s posting summarizes the major compliance themes from the conference.  Jessica can be reached at jsanderson@volkovlaw.com. On Friday May 3, 2019, I attended the Rocky Mountain Securities Conference in Denver and heard from a number of regulators and industry experts, including SEC Commissioner Hester Peirce. SEC...

OFAC Framework for Sanctions Compliance Programs – Review of Lessons Learned from Enforcement Actions (Part IV of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s new compliance framework includes a valuable section on common root causes of OFAC violations.  OFAC has included this discussion to assist companies in designing, updating and amending their respective Sanctions Compliance Programs (SCPs).  The discussion...

Webinar: OFAC Issues New Framework for Sanctions Compliance Programs

Webinar: OFAC Issues New Framework for Sanctions Compliance Programs Sign Up HERE May 22, 2019, 12 Noon EST On May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”) (Here).  OFAC “strongly encourage[d]” companies subject to OFAC jurisdiction to implement a “risk- based approach to sanctions compliance by developing, implementing and routinely updating a...

OFAC Framework for Sanctions Compliance Programs – Testing and Auditing and Training (Part III of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s new Framework for Sanctions Compliance Programs incorporates a number of important principles from Justice Department and US Sentencing Guideline requirements for effective compliance programs.  Today, I am going to review the requirements relating to Testing...

Episode 89 — DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs

In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs . The new Evaluation Guidance supersedes the prior document issued in February 2017, which contained a lengthy list of questions on key topic areas. Join Michael Volkov as he discusses the new guidance and outlines the impact for...

OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s Framework for Sanctions Controls Program is a heightening of the importance of ethics and compliance program and reflects significant expectations for implementing effective compliance strategies.  Risk Assessment In Risk Assessment, OFAC recommends that organizations conduct...

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”) (Here). ...