Tagged: podcast

Episode 136 — Justice Department Fraud Enforcement in the Pandemic Era

The Justice Department and the FBI have quickly acted to focus on fraudsters and hoarders who are preying on the public panic in response to the pandemic. DOJ has focused on new fraud schemes promising miracle cures and other means to take advantage of the public on the Internet.  At the same time, DOJ and the FBI have targeted hoarders of critical medical supplies who...

Episode 92 — How to Implement a Sanctions Compliance Program

OFAC’s new  Framework for Sanctions Compliance Programs is a game changer.   When it comes to sanctions compliance programs, most companies are well behind the curve.  OFAC’s new framework raises the bar by creating a well-crafted framework for companies to assess their current program and then re-design important elements to meet OFAC’s standards.    To the extent that a company’s sanctions compliance program operates as part of an overall...

Episode 69 — Update on DOJ Corporate Enforcement Policies

The Department of Justice (DOJ) has announced a number of modifications to its policies governing prosecution of corporations for criminal and civil violations of law.  In 2017, DOJ announced its FCPA Corporate Enforcement Policy.  Over the last year, DOJ expanded this policy to apply to non-FCPA corporate violations, as well as mergers and acquisitions.  In addition, DOJ recently announced the adoption of an Anti-Piling On...

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Episode 19 — 2017 FCPA Year in Review

FCPA enforcement continued in 2017 with an increased emphasis on individual enforcement. Despite early questions as to the new administration’s commitment to FCPA enforcement, the Justice Department and the SEC continued to push aggressive enforcement cases, building on well-established relationships with global law enforcement partners. In a significant development, the Justice Department issued a new FCPA Corporate Enforcement Policy, which created a declination presumption for...

Episode 15 — The Justice Department’s New FCPA Corporate Enforcement Policy

On November 26, 2017, the Justice Department announced adoption of its new FCPA Corporate Enforcement Policy.  Deputy Attorney General Rod Rosenstein announced the new policy at an FCPA Conference in Washington, D.C. Under the new policy, corporations that voluntarily disclose potential FCPA violations, fully cooperate with the investigation and implement timely and appropriate remediation will earn a presumptive declination, subject to the absence of aggravating...

Episode 14 — What Every Compliance Officer Needs to Know About Data Privacy and the EU’s GDPR

Compliance officers have to be mindful of new and emerging threats.  In the past few years, cyber security and data privacy have been quickly rising as new and significant threats that corporations face in the global marketplace. The European Union has adopted a far-reaching new regulatory regime applicable to companies that conduct business in the European Union and collect any sensitive data relating to EU...

Episode 13 — Top 10 Rules for Conducting Internal investigation Interviews

To implement an effective ethics and compliance program, global companies have to establish an effective internal investigation program.  Whether conducting a critical or routine investigation, investigators have to be able to conduct interviews in a fair and effective manner.  The success of an internal investigation often depends on the interviews of subjects and witnesses. In this podcast, Michael Volkov reviews his top 10 rules for...

Episode 12 — OFAC Screening and Sanctions Compliance

Global companies face ever-increasing risks with sanctions screening and compliance.  The US Treasury Department’s Office of Foreign Asset Control (“OFAC”) has aggressively enforced complex sanctions regulations against global companies, including banks, manufacturing, oil service and technology companies.  In this aggressive enforcement era, companies have to implement robust screening and compliance controls to identify sanctioned entities and individuals among their business partners and customers. In this...