Tagged: ethics and compliance program

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function.  The Justice Department and SEC’s FCPA Guidance, and the specific Hallmarks of an Effective Compliance and Ethics Program is the most definitive statement on compliance expectations ever released by US prosecutors.  Since 2012, the Justice Department has built on...

Update on The Volkov Law Group

The Volkov Law Group continues to offer innovative legal services focused on ethics and compliance programs, enforcement defense, and internal investigations. See Firm website here. The Volkov Law Group team includes talented professionals: Lauren Connell, Managing Associate; Jacqui Martin (formerly Merrill), Senior Associate; Susan Simpson, Associate; Matt Stankiewicz, Associate; and Vincent Ruiz, Counsel. See Firm profiles here. The Volkov Law Group believes that every company...

FCPA Predictions for 2017 (Part III of III)

With the new incoming administration, everyone is busy predicting major changes in DOJ FCPA enforcement. I do not share this view. Frankly, FCPA enforcement is more bipartisan than other controversial enforcement programs (e.g. civil antitrust and merger enforcement), and DOJ’s FCPA program is very profitable. While there may be a renewed effort by the Chamber of Commerce to raise FCPA reform again, I do not...

Cleaning Up a Compliance Program Mess

You have just been hired as the new Chief Compliance Officer of a global company operating in over 80 countries, including numerous high-risk corruption countries. You have no staff and have been given a budget to hire 5 full-time professionals, support staff, and technology, if reasonably priced. When you look into the existing compliance program, you realize that everything is a mess. There are no...