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...

As we come to the close of the Obama Administration, the Justice Department will certainly be able to point to its record of aggressive white-collar enforcement in a variety of areas. One glaring claim omission from that list will be prosecution of senior executives tied to financial institutions responsible for the financial demise in the late 2000s. With that one big exception, across the board...

A compliance program without CEO support is almost doomed to be ineffective. We all live by the standard of an “effective” ethics and compliance program. I am always reluctant to embrace a dogmatic expression but the support, and hands-on participation of a CEO, can be the difference between an effective and ineffective compliance program. A CEO not only has to embrace the importance of an...

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...

AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go (view episode here) – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of the end of the pipe, and so on — you will get the picture. We all know about the...

Date: August 6, 2015  Time: 2 pm – 335 EST Sign Up Here Many companies have implemented robust due diligence vetting, monitoring and auditing strategies for managing third-party risk.  No due diligence system is foolproof in identifying high-risk business partners or predicting which partners will engage in bribery.   Join Michael Volkov and Richard Bistrong as they discuss how due diligence systems and monitoring and...

We all know the importance of promoting a culture of compliance and ethics. The benefits of an ethical culture are substantial and worth every penny of investment in creating and promoting such a culture. We do not need to spend time justifying why an ethical culture is important to company financial success – it is critical for corporate sustainability and profitability. Not every company has...

Financial institutions have a lengthy list of Anti-Money Laundering compliance requirements. They face a mountain of risks from a large number of financial transactions, each of which can carry significant risks. AML compliance programs are built on a systematic review of a large number of financial transactions. The focus of this review has to be on triggers that identify suspicious transactions or customers. Know Your...

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...