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...
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...
Watch What You Want and When You Want It!! Check Out Site Here The Volkov Law Group is pleased to announce the launch of Volkov Law TV, a subscription-based service that provides immediate access to 50 webinars on a variety of enforcement and compliance topics. New webinars will be added each month — at least 20 new webinars each year. Monthly subscription fee for unlimited...
Lauren Connell of The Volkov Law Group joins us again for a posting about corruption and gifts and hospitality. Her profile is here and she can be reached at [email protected]. Laws and regulations draw black lines in often-gray areas. That is their purpose; they exist to make it easier to tell what is “wrong” and what is “right” (as defined by whoever made the law)....
Consider this posting a warning to everyone in the corporate governance field. I am not known for being a chicken little and screaming “the sky is falling, the sky is falling.” I tend to be a realist when it comes to politics and corporate governance. So with this caveat in mind, here is my warning for the future. With the rise of the Chief Compliance...
The SEC is on a mission – companies that engage in egregious payment schemes for gifts, hospitality and travel are going to get prosecuted for civil FCPA violations. Recent SEC enforcement actions against companies continue, and BHP Billiton’s settlement last week is another example of the SEC’s prosecution strategy. BHP Billiton agreed to pay a $25 million penalty to settle SEC charges for internal controls...
We all know our favorite things and people who fit together well – milk and cookies, peanut butter and jelly, chips and salsa, Tracy and Hepburn, Martin and Lewis, Abbott and Costello, and many other great combinations. In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate...
