LRN’s  research consistently paints a picture that every board member, senior executive and middle manager should view — corporate culture is an organization’s most valuable intangible asset and is a significant determinant of success in the marketplace. Corporate leaders know how to mouth the words to express their commitment to ethical values, principles and culture.  The disconnect between words and action is easy to spot...

LRN continues to set the standard for ethics and compliance program research.  Volkov Law is  a supporter of, and advocate for, LRN’s research because it has consistently confirmed what we all know and believe — ethical companies perform better in the marketplace over the long run.  It is an intuitive fact that employees respond better to values-based leadership than a rules-based environment and culture.  Volkov...

Gunvor’s bribery scheme is not very surprising nor ingenious.  After all, a number of energy trading companies have been prosecuted for bribery over the years, including Glencore, Vitol, Freepoint.  Numerous individuals have been prosecuted, convicted and some have cooperated.  The global energy trading market presents numerous risk factors — large and valuable energy products (oil, gas etc.) are controlled by foreign-owned companies.  All of these...

After a long-running investigation, Koninklijke Philips (“Philips), a Dutch company, resolved FCPA violations in China by agreeing to pay the SEC $62 million.  Philips is a global manufacturer of medical equipment. Philips agreed to pay $15 million in civil penalties and more than $47 million in disgorgement and prejudgment interest. According to Philips, DOJ has declined to prosecute charges in the current case. Philips’ recent...

Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program.  Instead, a number of companies have stitched together a basic sanctions compliance program that centers on a screening tool and little beyond that.  Such a limited program provides just a  false comfort of compliance.  Many companies are not even conducting the mandated basic...