I am neither bitter nor cynical but I do wish there was less immaturity in political thinking – Franklin D. Roosevelt. Maybe I am turning cynical in my old age. Maybe I just do not believe that government agencies make decisions for the right reason without sticking a finger in the air to see which way the wind is blowing. I really do not know...
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...
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...
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...
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...
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 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...
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...
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....
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...
