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...
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...
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...
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...
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...
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...
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...
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...
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...
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...
