Tagged: AntiBribery

5 Signs Your Anti-Corruption Compliance Program is Suffering from “Tunnel Vision”

Many companies, depending on the industry, have implemented anti-corruption compliance programs. Some of the programs meet the standard for an “effective” anti-corruption compliance program. There is a vast difference between getting a program implemented on paper and an “effective” anti-corruption compliance program. After all, when you boil it down, anti-corruption compliance is not as difficult a task as everyone thinks. Some programs are immature, some...

Mead Johnson: Baby Formula and Bribes

Last week, the SEC announced a settlement of an FCPA enforcement action for $12 million against Mead Johnson Nutrition for payment of bribes in China to health care professionals at state-owned hospitals. Mead Johnson’s illegal payments were intended to increase referrals by Chinese physicians and healthcare officials of Mead Johnson products, and obtain access to marketing and personal information about expectant and recent mothers. Over...

Berger FCPA Settlement: Back to the Future

The recent Louis Berger International FCPA settlement highlighted once again the serious consequences from systemic bribery violations, the ease with which bribery schemes can be carried out, and the risks facing all global companies, especially those involved in high-risk industries like construction projects. Berger agreed to pay $17 million to settle the case and agreed to a three-year corporate monitor. Interestingly, at the same time...

New E-Book: The Art of the Internal Investigation

I am pleased to announce the release of my new e-book — The Art of the Internal Investigation — by Corporate Compliance Insights.  To download a free copy, please visit here. Conducting an internal investigation in today’s risky enforcement environment requires numerous — if not continuous — judgement calls.  Stakes are high, and answers are never black-and-white. In this free eBook, Michael Volkov wields his...

Volkov Law TV — Announces New Subscription Options and Pricing for On-Demand Webinars

Volkov Law TV announces new subscription options and pricing for on-demand Webinars.  We know our scheduled webinars do not always fit your busy schedule: Learn What You Want, When You Want It!  Volkov Law TV Here We now offer pricing for individual webinars and have reduced our subscription fees. In addition, we offer Flexible Enterprise Rates for companies and organizations if needed. Individual Webinars are...

Webinar: Managing Private Equity Corruption Risks

Date: Tuesday, August 11, 2015 Time: 12 Noon EST Sign Up Here Justice Department and SEC prosecutors are devoting greater attention to private equity FCPA enforcement. This coincides with increased SEC regulation and examination of the private equity industry. Private equity companies face significant corruption risks in global markets. From sovereign wealth funds to portfolio companies, private equity compliance officers have to design and implement...

Scrutinizing Third-Party Payments

It is often hard to convince people that receiving money can be a problem. Everyone likes to receive money, especially when they are being paid for something they did. In the area of compliance priorities, companies do not normally treat third-party payments as a high-risk activity. However, with increasing focus on illicit proceeds and tightening of AML/Terrorist Financing requirements, companies have to focus on this issue....

AML Risk Assessments

I am a strong proponent of conducting a risks assessment as part of an overall ethics and compliance program. However, I often caution companies to balance benefits and costs, and not to conduct a glitzy, high-priced risk assessment. Instead, I encourage companies to conduct a cost-effective risk and compliance program assessment that focuses on risk, mitigation of such risks and measurement of residual risks. Too...

Update on Petrobas Scandal – Recent Arrests of Construction Company Executives

The sprawling Petrobas corruption scandal continues to grow and stretch across Brazil’s political and economic landscape. Prosecutors handling the case continue to reach new targets and arrest more individuals who profited from the corruption schemes. For global companies that conducted business with Petrobas, there are real enforcement risks as investigators uncover bribery activity. Recently, it was reported that Brazil prosecutors referred four companies to US...