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...

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...

In a watershed week for FCPA enforcement, the US Department of Justice announced FCPA criminal charges against seven individuals.  Specifically, the Justice Department announced four guilty pleas and one indictment as follow on prosecutions to the January 2017 Rolls Royce FCPA enforcement action, and two guilty pleas in a yet to be announced enforcement action against SBM Offshore. The Justice Department’s unprecedented week underscored that...

An effective ethics and compliance program requires a careful assessment of risks and existing controls.  In order to design and implement an effective program, a chief compliance officer has to identify and prioritize company risks.  In addition, a CCO has to review and understand how existing compliance controls mitigate existing risks. A risk assessment is the foundation of a compliance program, but has to incorporate a...

Global companies and corporate officers and employees face significant criminal antitrust risks.  The US Department of Justice’s Antitrust Division has a mature and aggressive enforcement program targeting illegal cartel activity.  Unfortunately, companies have been slow to implement ethics and compliance programs that are adequately focused on these serious criminal risks. In this episode, Michael Volkov discusses the need for robust ethics and compliance programs and...

In the aftermath of the Panama Papers scandal and increased focus on shell companies and hidden ownership interests, US enforcement and regulatory agencies are increasing focus on beneficial ownership of related entities.  In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers in order to ensure full compliance with anti-corruption,...

The Ukraine-Russia Sanctions program is a complex set of executives orders, statutes and regulations defining prohibited business transactions with Russian entities and individuals.  The sanctions program was instituted in 2014 in response to Russia’s invasion of the Ukraine and annexation of Crimea.  In August 2017, Congress enacted statues and directed OFAC to implement additional regulations.  Congress acted in response to fears that the Trump Administration...

Podcast Episode 6 examines ISO 37001 — Anti-Bribery Risk Management System.  Please sign up HERE for our free webinar on ISO 37001 scheduled for October 24, 2017 at 12 Noon EST. The ISO 37001anti-bribery risk management system was issued in 2016.  The standard provides additional guidance on anti-bribery risk management systems and creates a certification process for organizations. Even after one year, there are still...

I am pleased to offer a free podcast service under the same title as the blog — Corruption, Crime and Compliance. We have added a button on the left slide of the blog to make subscribing easy. Here is link to Episode 2, which includes subscription buttons: Here We have released two episodes so far, and a third episode will be released on Sunday. Episode...