Tagged: Compliance

Refining a CCO’s Reporting Relationship to a Corporate Board

You can observe a lot by just watching – Yogi Berra There is way too much time being spent on esoteric arguments about corporate board reporting responsibilities for Chief Compliance Officers. Let’s agree and move on to more important and difficult issues. I hate to be dogmatic but when it comes to this issue, there really is one obvious solution. Varying alternatives are less than...

Know Your Customer (“KYC”) Due Diligence Best Practices

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...

AML Risks and Compliance for Non-Financial Institutions

Consider yourself lucky if you work at a company that does not fall within the Title 31 of the US Code definition of a “financial institution.” I am being somewhat dramatic but it is important for every company to have an anti-money laundering compliance program. My suggestion is not designed to promote business or even “scare” companies into addressing this issue – it makes sense...

Happy 4th of July (from Sicily)

Happy 4th of July to Everyone!  We live in a great country.  It is important to express our gratitude for the amazing opportunities we share with our family, our community and our country. This year, my wife and I are in Sicily, enjoying my wife’s heritage and our family.  We may not be in the United States today, but we embrace the values we carry...

Shining a Light on Corporate Boardrooms and the Absence of Diversity

Some things are really clear in life – everyone knows something has to change but no one acts. Maybe it goes back to a common theme in corporate cultures – an unwillingness to stand out and instead rely on silence or what some like to call – “The GM Nod,” meaning everyone acts like they are in agreement but no one is “bold” enough to...

The Microeconomic Perspective on Bribery Incentives

I always enjoyed economics – understanding “rational” behavior and applying it to business situations can be very productive. Of course, there were many detractors who argued that economics is filled with assumptions that take the discipline away from reality, but I find those arguments unpersuasive. There has been a fair amount of research on corruption and the impact that bribery has on a functioning market....

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...

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...

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....

Diggin’ Your Company’s Culture

Some things are hard to define and measure in compliance. Culture is the prime example often cited by commentators. I do not share that opinion. Whether it is quantified or not, there is one unmistakable truth – you know when you have a positive culture and you know (but often try to ignore) when your company has a poor culture. When I work with companies...