Corruption, Crime & Compliance

Featured Articles:

18 Aug, 2021

Measuring and Reporting on the Organization’s Culture (Part III of IV)

While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures. Let’s start with a simple proposition – if a company’s culture is its most important internal control and its most valuable intangible asset, a chief compliance officer (CCO) should devote commensurate time and energy to promote...

General

16 Aug, 2021

Practical Approaches to Managing Culture: Defining the Organization’s Mission (Part I of IV)

The culture bandwagon is picking up steam. Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations. In its latest corporate compliance guidance, the Justice Department, along with numerous regulatory agencies, continue to cite the importance of a company’s “culture of compliance.” But when it comes to defining the terms, how to...

Podcasts

15 Aug, 2021

Episode 203 — Interview of David Greenberg on LRN’s Report on Corporate Boards and Compliance Program Engagement

LRN recently issued its second of three annual reports on ethics and compliance program effectiveness. The second report focuses on board engagement with ethics and compliance and lessons learned from the COVID-19 pandemic. David Greenberg, a Special Advisor to LRN, joins us to discuss the interesting results of the LRN report. The LRN report can be downloaded HERE.

General

12 Aug, 2021

ITAR Brokering Activities Demystified

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a posting on ITAR brokering activities. Alex can be reached at [email protected]. Part 129 of the International Traffic in Arms Regulations (“ITAR”) requires certain persons engaged in “brokering activities” to register with, and pay a fee to, the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”). ITAR Part 129.2 broadly defines...

General

11 Aug, 2021

DOJ Takes Stock of Criminal Cartel Prosecution Program

The Justice Department’s Antitrust Division has a long and rich history. For years, “the Division” as it liked to refer to itself, charted its own path in antitrust enforcement, especially when it comes to criminal prosecutions. The transformative event was the Antitrust Division’s revision and expansion of the Corporate Leniency Program in 1993 and prosecution of international cartel cases. The Antitrust Division’s Leniency Program was...

General

10 Aug, 2021

Internal Investigation Trap – When Does “Oversight” Turn into Control

Corporate boards face a number of risks. In the face of a high-stakes or important internal investigation, corporate boards, a designated committee, or a special committee often are assigned the important role of authorizing and monitoring the investigation. Board supervision is reserved for important internal investigations, especially when an investigation focuses on potential senior management misconduct or other high-risk issues. Law firms welcome these assignments...

Events

9 Aug, 2021

Two-Part Webinar: A Deep Dive into the Foreign Corrupt Practices Act

Session 1 September 14, 2021, 12 Noon EST Sign Up HERE Session 2 October 5, 2021, 12 Noon EST Sign up HERE Global companies continue to face aggressive FCPA enforcement risks. The Biden Administration has defined global anti-corruption as a national security threat and is in the process of leading a robust initiative to increase global enforcement. The FCPA is the global foundation for anti-corruption...

General

9 Aug, 2021

The CEO Sets, Defines and Manages a Company’s Performance and Culture

We always read about the superstar CEO. The company’s leader who is paid millions and is the rock star of business success. Board members, shareholders and stakeholders support the leader because he/she has brought “success,” meaning the company’s stock price is increasing, the company continues to grow and no one would ever challenge the company’s reliance on the CEO to lead the company. But there...

Podcasts

8 Aug, 2021

Episode 202 — A Deep Dive into the Alfa Laval OFAC Enforcement Action

In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran Sanctions Program. AL US enlisted its then subsidiary (now operating unit), Alfa Laval Tank, Inc, based in Exton, Pennsylvania (AL Tank), to participate in the scheme. The Alfa Laval enforcement...