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 neither bitter nor cynical but I do wish there was less immaturity in political thinking – Franklin D. Roosevelt. Maybe I am turning cynical in my old age. Maybe I just do not believe that government agencies make decisions for the right reason without sticking a finger in the air to see which way the wind is blowing. I really do not know...
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...
Volkov Law TV announces new subscription options and pricing for on-demand Webinars. We know our scheduled webinars do not always fit your busy schedule: Learn What You Want, When You Want It! Volkov Law TV Here We now offer pricing for individual webinars and have reduced our subscription fees. In addition, we offer Flexible Enterprise Rates for companies and organizations if needed. Individual Webinars are...
Date: Tuesday, August 11, 2015 Time: 12 Noon EST Sign Up Here Justice Department and SEC prosecutors are devoting greater attention to private equity FCPA enforcement. This coincides with increased SEC regulation and examination of the private equity industry. Private equity companies face significant corruption risks in global markets. From sovereign wealth funds to portfolio companies, private equity compliance officers have to design and implement...
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...
We all know the importance of promoting a culture of compliance and ethics. The benefits of an ethical culture are substantial and worth every penny of investment in creating and promoting such a culture. We do not need to spend time justifying why an ethical culture is important to company financial success – it is critical for corporate sustainability and profitability. Not every company has...
I am a strong proponent of conducting a risks assessment as part of an overall ethics and compliance program. However, I often caution companies to balance benefits and costs, and not to conduct a glitzy, high-priced risk assessment. Instead, I encourage companies to conduct a cost-effective risk and compliance program assessment that focuses on risk, mitigation of such risks and measurement of residual risks. Too...
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...
