Tagged: internal investigations

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...

ISO 37001: Training, Employee Concerns, and Internal Investigations (Part V of V)

In my final posting on ISO 37001, I review requirements for training, raising concerns and internal investigations as part of a company’s anti-bribery risk management system. I could certainly write more on ISO 37001 because there are other issues that I have not addressed, including audits, assessments and reviews of the anti-bribery risk management system. In this posting, it is important to identify and tailor...

5 Telltale Signs of a Weak Corporate Culture

We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do. With increasing emphasis and understanding of the tangible benefits of an ethical culture, companies are striving to achieve such a goal. Unfortunately, there is no single solution to companies that want to establish...

Hiding Behind the Privilege – A Cloak or a Dagger?

CCOs face many challenges in their jobs. One area that is difficult but usually can be solved with common sense is where to draw the line on attorney-client privilege issues. As a practicing attorney, I can attest to the importance of the attorney-client privilege. It is a principle that is critical to the functioning of a corporation or any other organization. Communications for the purpose...

Three-Part Webinar Series: Speak Up Culture, Internal investigations Systems and Witness Interviews

Sign Up for Three-Part Webinar Series:   Internal Investigations Systems (Part I):  November 29, 2016, 12 PM EST Sign Up Here   Interviews and Internal Investigations (Part II): December 6, 2016, 12 PM EST Sign Up Here   Speak Up Culture (Part III) December 13, 2013, 12 PM EST Sign Up Here Companies are struggling to establish and embed a Speak Up culture.  Companies need...

Match Made in Heaven: Compliance and Human Resources

The corporate compliance function is only as successful as its partnerships with key internal constituencies. Depending on the company and the personnel involved, compliance has to establish and maintain effective working partnerships with key functions, such as human resources, legal, finance, and security. All of the relationships are mutually beneficial. Each component works better when it is able to partner and work seamlessly with another...

Thinking Like a Prosecutor – Yates and Internal Investigations

I respect prosecutors, most of them at least. I had the fortunate opportunity to work with a number of terrific prosecutors. Most are intelligent, hard working and committed to doing the right thing. I recognize that there are times when a prosecutor crosses the line, and for those prosecutors, I have no sympathy. Whatever punishment they receive is usually well deserved. But a very high...

Conflicts Of Interest After the Yates Memorandum

As we continue to operate under the Yates Memorandum, a number of interesting and difficult issues are sure to develop surrounding internal investigations and individual culpability. Corporate internal investigations have to focus on all potentially culpable individuals. Many commentators have incorrectly suggested that the Yates Memorandum will not have an impact on corporate internal investigations and the Justice Department’s prosecution of individuals. These commentators are...

RESCHEDULED Webinar: Conducting Internal Investigations in the Yates Memorandum Era

New Date: June 21, 2016, 12 Noon EST Sign Up HERE The Justice Department’s release of the Yates Memorandum will have a significant impact on corporate internal investigations. Under the new requirements of the Yates Memorandum, investigators will have to prioritize the investigation’s focus on culpable individuals. This new focus will require careful consideration of a range of issues that arise when conducting an internal...

Derailing Internal Reviews, Audits, Assessments and Investigations

Following FCPA enforcement actions provides important insights that can be translated into corporate compliance program best practices. One key element of an effective ethics and compliance program is conducting periodic assessments, and implementing an efficient and responsive internal investigation protocol. Under the Sentencing Guidelines, an effective ethics and compliance program has to prevent and detect potential violations of law and the company’s code of conduct....