I am pleased to announce the release of my new e-book:  Question Everything — Effective Due Diligence and Third-Party Risk Management. With almost every FCPA enforcement action involving third party misconduct in one form or another, shouldn’t companies devote more resources than ever to due diligence and third-party risk management systems? There’s no magic formula to implementing an effective system. It just takes two things:...

Contrary to the opinion of many in the FCPA space, the BNY Mellon settlement and the looming actions against six major financial institutions for hiring practices is not a big shock or surprise. The SEC is not raising a new or novel interpretation of the FCPA. After all, assuming an actor has corrupt intent, there is no real question as to whether hiring a person...

Webinar: Anti-Corruption Compliance in the High-Tech Sector   Wednesday, September 9, 2015, 12 Noon EST    Sign Up Here   The Justice Department and the SEC have focused FCPA enforcement resources on high-tech companies. Several high-tech companies have settled FCPA enforcement actions, while others remain under investigation. In a recent enforcement action, an SAP former executive plead guilty to an FCPA conspiracy and is awaiting...

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...

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...