Last week, the SEC announced a settlement of an FCPA enforcement action for $12 million against Mead Johnson Nutrition for payment of bribes in China to health care professionals at state-owned hospitals. Mead Johnson’s illegal payments were intended to increase referrals by Chinese physicians and healthcare officials of Mead Johnson products, and obtain access to marketing and personal information about expectant and recent mothers. Over...
Lauren Connell, Managing Associate at the Volkov Law Group, joins us again for a guest post. Lauren’s profile is here and she can be reached at [email protected]. The “I didn’t know” defense is a tough one to sustain. Maybe you didn’t “know,” but should you have known? Were all the signs there but you looked the other way? Should you have asked more questions? Is...
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...
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...
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...
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...
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....
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...
