Corruption, Crime & Compliance

Featured Articles:

17 Oct, 2021

Episode 210 — HR and CCOs Watch Out!! DOJ’s Aggressive Antitrust Enforcement in Labor Markets

The Justice Department’s Antitrust Division has targeted collusion in labor markets for criminal prosecution. This was not unexpected. Indeed, the Antitrust Division gave plenty of warning to the high-tech industry and other companies that criminal prosecutions were on the horizon. DOJ handled initial prosecutions of labor market collusion in the high-tech sector by civil prosecutions and resolutions. Out of an abundance of caution, DOJ recognized that it wanted...

General

15 Oct, 2021

FINRA Reminds Broker-Dealers on Importance of Compliance with New AML Rules

The new Anti-Money Laundering laws and regulations continue to roll out with new risks, liabilities and compliance requirements. There is a coming AML enforcement storm, fueled by a new AML whistleblower program that will operate in a manner similar to the SEC’s successful whistleblower program. The AML Act of 2020 increased penalties for AML offenses, adopted investigative improvements to expand the reach of AML investigations...

General

14 Oct, 2021

CCOs: Expert Problem Solvers

If you follow my blog, you know that I am passionate about the compliance profession. Chief compliance officers have unique talents, expertise and leadership qualities. CCOs are committed ethics warriors. No one else can claim that same mission. CCOs are the natural stewards of a company’s ethical culture. Of course, a company can appoint a separate chief ethics officer to distinguish between the ethics and...

General

13 Oct, 2021

The Impact of the Pandemic on Corporate Work Culture

David Friedman, an expert in workforce culture, joins us for a guest posting on the impact of the pandemic and workforce culture. David can be reached at www.culturewise.com. David is the author of Culture by Design: How to Build a High-Performing Culture Even in the New Remote Work Environment. As many workers flee their current jobs, burnout and lack of growth opportunities are being cited as...

General

12 Oct, 2021

The Evolution of Third-Party Risk Management

Third-party risk management is a favorite topic for compliance professionals. And for good reason. Third parties create significant risks. To state the obvious, companies have less control over third parties than employees. But for many reasons companies engage third parties as a more effective solution than hiring employees. In this situation, risk multiplies exponentially. The third-party risk issue, however, has multiplied exponentially for a number...

General

11 Oct, 2021

The Elevation of Sanctions Compliance

This has been an interesting enforcement year. The Biden Administration promised a renewal of aggressive enforcement. The difficult transition from the last administration and political resistance to confirmation of political appointees has delayed the transition process. Consequently, enforcement has gotten off to a slow start. But companies would make a big mistake in embracing complacency or just waiting for enforcement to pick up before elevating...

Podcasts

10 Oct, 2021

Episode 209 — Schlumberger Settles Two OFAC Enforcement Actions

In a pair of enforcement actions, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second, Schlumberger Rod Lift, Inc., a former subsidiary, that was acquired by Lufkin Rod Lift, Inc. In this Episode, MIchael Volkov reviews the two OFAC enforcement actions.

General

7 Oct, 2021

Taro, Sandoz and Apotex Pay $447.2 Million to Settle False Claims Act Liability for Price-Fixing of Generic Drugs

The healthcare industry faces cascading risks – one risk flows to another with compounding financial results. Three generic drug companies just experienced this cascading liability. As part of the Justice Department Antitrust Division’s investigation of the generic drug industry, Taro, Sandoz and Apotex settled criminal antitrust cases by entering into a deferred prosecution agreement, paying a financial settlement and agreeing to cooperate with the ongoing...