Tagged: Compliance

18 May, 2021

Webinar: Policy Management, Governance and Leveraging Your Culture of Compliance

Webinar: Policy Management, Governance and Leveraging Your Culture of Compliance June 16, 2021, 2 PM EST SIGN UP HERE Companies today face increasing pressure to build effective ethics and compliance programs as part of an overall governance structure. Investors, activists and key stakeholders are pushing for transformative reforms built around environmental, social and governance principles. An essential part of this initiative is a well-designed policy...

General

3 Dec, 2020

Gatekeeper Misfires and Corporate Governance Failures

Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures. Internal controls are not just for show, or not just limited to financial reporting. A compliance program is a subset of a company’s internal controls. So, all this is well and good. But it appears that a number of companies have been getting into trouble because they...

Events

9 Aug, 2020

Webinar Reminder: Effective Management of Employee Reporting Systems

Effective Management of Employee Reporting Systems August 12, 2020, Noon EST Sign Up Here. The compliance and ethics hotline represents one of the most integral tools available to a high-functioning Compliance Department. Companies that implement and properly manage their reporting hotlines create a more positive and robust organizational culture. In this webinar, Michael Volkov explains how to effectively manage your employee reporting system to create...

General

4 Sep, 2017

Compliance Missed Opportunities: CCOs and HR

A chief compliance officer can get overwhelmed with responsibilities and initiatives. CCOs have a never-ending to-do list – once an initiative is finished, the CCO has to jump to another “priority.” CCOs are responsible for operationalizing the company’s compliance program. The CCO’s success depends on the cooperation of related functions – procurement, legal, human resources, security, finance, internal audit, and information technology. While there has...

General

12 Mar, 2017

FCPA Pilot Program Motors On

No one was really surprised when Kenneth Blanco, Acting Assistant Attorney General for the Criminal Division, US Department of Justice, announced last week that DOJ was planning to continue the FCPA Pilot Program past April 5, 2017, the scheduled expiration date. Blanco stated in a speech given at the annual White Collar Crime Conference: Before I conclude, I would be remiss if I did not...

General

20 Dec, 2016

Hiding Behind the Privilege – A Cloak or a Dagger?

CCOs face many challenges in their jobs. One area that is difficult but usually can be solved with common sense is where to draw the line on attorney-client privilege issues. As a practicing attorney, I can attest to the importance of the attorney-client privilege. It is a principle that is critical to the functioning of a corporation or any other organization. Communications for the purpose...

General

4 Oct, 2016

Double Play, Double Declinations: DOJ Pushes FCPA Pilot Program Benefits

DOJ’s FCPA Pilot Program was panned when it was announced in April 2016. Critics contended that the incentive for voluntary disclosure of FCPA violations to DOJ was inadequate. Under the FCPA Pilot Program, a company can earn up to a 50 percent reduction from the bottom of the applicable range for calculation of a criminal fine. DOJ also noted the possibility of a declination with...

General

11 Jul, 2016

Podcast: Convergence of Audit and Compliance Functions

I was honored to participate in a brief podcast conducted by the MIS Training Institute, the International Leader in Audit and Security Training. The link to the podcast is here.

General

6 Jun, 2016

DOJ’s Pilot Program – The Five Factors Designed to Nurture the Compliance Function

Perhaps the most positive and important aspect of the FCPA Pilot Program was the announcement of forward-looking and innovative remediation requirements for corporate compliance programs. As an aside, DOJ’s FCPA Pilot Program was a disappointment and failed to deliver meaningful incentives for companies to self-disclose FCPA violations to the Justice Department. The difference between 25, 50 and 75 percent from the bottom of the sentencing...

General

24 May, 2016

Global Construction and Corruption

With increasing focus on infrastructure projects and greater public demand for improvements, governments are preparing to ramp up construction projects. Part of the budgeting process has to acknowledge the cost of corruption. It does not take a rocket scientist to figure out that construction and corruption go hand-in-hand. Corruption occurs in construction projects because of the incendiary mix of money, government bureaucracy, and lack of...