Tagged: Department of Justice

5 Signs Your Anti-Corruption Compliance Program is Suffering from “Tunnel Vision”

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...

Berger FCPA Settlement: Back to the Future

The recent Louis Berger International FCPA settlement highlighted once again the serious consequences from systemic bribery violations, the ease with which bribery schemes can be carried out, and the risks facing all global companies, especially those involved in high-risk industries like construction projects. Berger agreed to pay $17 million to settle the case and agreed to a three-year corporate monitor. Interestingly, at the same time...

Private Equity’s Corruption Risk Underbelly — Portfolio Companies

FCPA enforcement will likely take a turn into the private equity industry. I know this is a regular claim by FCPA practitioners but we already can see the beginning of the trend. The “princeling” investigations are ongoing and the industry is fighting back, claiming that internships awarded to family members of foreign officials were not given with corrupt intent or were not of any value...

New E-Book: The Art of the Internal Investigation

I am pleased to announce the release of my new e-book — The Art of the Internal Investigation — by Corporate Compliance Insights.  To download a free copy, please visit here. Conducting an internal investigation in today’s risky enforcement environment requires numerous — if not continuous — judgement calls.  Stakes are high, and answers are never black-and-white. In this free eBook, Michael Volkov wields his...

Ten Key Elements of an AML Compliance Program

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...

LexisNexis CLE-Eligible Webinar: A Holistic Approach to Due Diligence and Third-Party Risk Management

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...

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...

The Important Distinction Between Legal and Business Ethics

We all know the jokes about lawyers – I have to repeat just one of them:  Q.  Why won’t sharks eat lawyers? A. Professional courtesy. The Chief Legal Officer is a vital player in a corporate compliance program. There is no question about this issue. However, lawyers can get a little defensive and insecure (no, really?) when they are not the center of attention, or viewed...

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...