Tagged: Chief Compliance Officer

LRN 2024 Program Effectiveness Report Underscores Importance of Values, Adaptation and Accountability

LRN 2024 Program Effectiveness Report Underscores Importance of Values, Adaptation and Accountability

LRN continues to set the standard for ethics and compliance program research.  Volkov Law is  a supporter of, and advocate for, LRN’s research because it has consistently confirmed what we all know and believe — ethical companies perform better in the marketplace over the long run.  It is an intuitive fact that employees respond better to values-based leadership than a rules-based environment and culture.  Volkov...

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement.  While I have questioned DOJ’s commitment to its corporate enforcement policy in recent high-profile settlements (ABB and SAP, in particular), DOJ’s Gunvor settlement of $661 million stands as the ninth largest FCPA settlement in history.  DOJ’s settlement is proportionate to the misconduct and...

Episode 311: Tom Fox on FCPA Enforcement — DOJ’s Approach to Recidivism and Self-Disclosure

Episode 311: Tom Fox on FCPA Enforcement — DOJ’s Approach to Recidivism and Self-Disclosure

In this special episode of Corruption, Crime, and Compliance, Michael Volkov joins colleague and long-time friend Tom Fox as they delve into the intricacies of recent FCPA enforcement actions, shedding light on the evolving landscape of corporate compliance. From the ABB case to the SAP settlement, Michael and Tom dissect the nuances of voluntary disclosure, extensive remediation, and the shifting priorities of the Department of...

Maintaining Focus on Cyber Risks (Part II of IV)

Maintaining Focus on Cyber Risks (Part II of IV)

If you read about the world of hackers and cyber threats, you will quickly become numb to the creativity and variety of techniques that may threaten your organization.  Like all risks, however, the key is to consider practically the real and significant threats to your organization.  If you attempt to address each and every possible threat, you will drive yourself crazy.  It is important to...

Volkov Law TV Offers New You Tube Compliance Channel

The Volkov Law Group is pleased to announce its new free, Volkov Law You Tube Channel, which offers a library of nearly ten (10) years of webinar videos. Volkov Law TV includes 132 webinar videos on a variety of enforcement and compliance topics. Please Subscribe to the Volkov Law TV Channel Here. The topics include:

A Five Step Program for Every Company to Address the New Enforcement Threats

A Five Step Program for Every Company to Address the New Enforcement Threats

Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized based on resources.  Instead, these are essential and basic requirements that will inevitably result in significant benefits across the company.  Step 1: Define, Embed and Monitor Corporate Culture...

Episode 270 — DOJ Mandates Greater Cooperation Between CCOs and HR

Episode 270 — DOJ Mandates Greater Cooperation Between CCOs and HR

The Justice Department’s recent emphasis on ethics and compliance culture, along with greater specificity on “consequence management” is a welcome breath of fresh air.  It is a policy coming for a long time and will bring about significant improvements.  Do not get me wrong – there will be bumps and bruises along the way, hurt egos and turf battles, but in the end HR and...

A Window into Corporate Boards’ Views for 2023

A Window into Corporate Boards’ Views for 2023

It is fun to follow all the early year views of trends, predictions and survey results.  The beginning of the year includes lots of perspectives and analyses.  Corporate boards are at the center of these important views.  In a recent survey released by National Association of Corporate Directors, the top trends unsurprisingly referred to economic worries – inflation, a potential recession and continuing business disruptions....

Lessons Learned and the Big Picture: ABB – the Three-Time Loser – Settles Yet Another FCPA Case (Part III of III)

Lessons Learned and the Big Picture: ABB – the Three-Time Loser – Settles Yet Another FCPA Case (Part III of III)

The ABB case, like most significant FCPA enforcement actions, sets important precedent and policy reminders. With time, and looking back, ABB gives companies with a prior criminal history a way forward to seek a fair resolution notwithstanding huge obstacles based on past performance.  If you are ABB, you dodged a significant bullet – the appointment of an independent compliance monitor, which DOJ has been regularly...

The Importance of Independence to a CCO’s Role

It is easy to be dogmatic in blog postings — to express an unvarnished opinion that sounds valid.  While it may not be supported by hard data or valid evidence, compliance officers are used to trusting their “gut feelings,” when it comes to compliance.  Compliance professionals with experience agree largely on big ticket issues, and this view often reflects lots of real-world experience.  Sometimes the...