Tagged: Compliance Program

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...

IAP Worldwide FCPA Settlement: The Power of “Voluntary” Disclosure

Okay, everyone take out their tea leaves and let’s get started on the IAP corruption case – DOJ announced a Non-Prosecution Agreement with IAP Worldwide Services and the criminal plea of a former executive who funneled bribes through a third-party to a Kuwait government official. When you read the facts, the case is like many other FCPA fact patterns. Illegal bribes were paid to a...

Good People Do Bad Things

It is good to be an optimist. I am sure that optimistic people are happier, more loving and tend to live longer. All of this rings true. But not everyone is an angel, and not everyone at your company is a “good person.” When we refer to someone as a “good person,” that is our gut instinct speaking about our specific interactions with a person....

Crossing a New Bridge: Compliance Officers and Financial Controls

Compliance officers face plenty of challenges. The list of close allies always includes the General Counsel, Internal Audit, Human Resources and Procurement officials. In two recent surveys (here and here), CCOs reported that they do not have a strong working relationship with the CFO and typically do not get involved in the design and implementation of financial controls. That is a real significant problem. Lets start...

Warning: Keeping Compliance Simple

If you can’t explain it to a six-year-old, you don’t understand it yourself. — Albert Einstein Compliance professionals are in a heady state these days. Their stock is rising; they are gaining influence and authority, and even some additional resources. When given the time, compliance professionals can come up with new and innovative strategies for compliance programs. But I see a danger lurking in the...

Announcing Volkov Law TV — Webinars On-Demand

Watch What You Want and When You Want It!! Check Out Site Here The Volkov Law Group is pleased to announce the launch of Volkov Law TV, a subscription-based service that provides immediate access to 50 webinars on a variety of enforcement and compliance topics.  New webinars will be added each month — at least 20 new webinars each year. Monthly subscription fee for unlimited...

Encouraging Employees to Break the “Rules” to Do the Right Thing

Lauren Connell of The Volkov Law Group joins us again for a posting about corruption and gifts and hospitality.  Her profile is here and she can be reached at lconnell@volkovlaw.com. Laws and regulations draw black lines in often-gray areas. That is their purpose; they exist to make it easier to tell what is “wrong” and what is “right” (as defined by whoever made the law)....

Washington Politics and Compliance

Consider this posting a warning to everyone in the corporate governance field. I am not known for being a chicken little and screaming “the sky is falling, the sky is falling.” I tend to be a realist when it comes to politics and corporate governance. So with this caveat in mind, here is my warning for the future. With the rise of the Chief Compliance...

Parallel Prosecutions and U.S. Jurisdiction: Looking Beyond the Bribes in the FIFA Scandal

Lauren Connell from The Volkov Law Group joins us again for a posting about the implications of the FIFA Scandal.  Her profile is here and she can be reached at lconnell@volkovlaw.com. Everyone is talking about the latest corruption scandal, this one with world-wide impact. The scandal engulfed FIFA as seven organization officials were recently arrested in Switzerland. Charges include a range of money laundering, racketeering,...

Wall Street and Ethics

I have to confess that there is a part of me that was skeptical about a new survey released last week finding that banks and other financial institutions have not embraced a culture of integrity.  (Survey Here).   Indeed, the survey found that numerous individuals continue to operate with the idea that illegal or unethical behavior is a necessary part of succeeding in the financial markets....