Tagged: Risk Assessments

HHS-OIG Guidance — Practical Steps to Achieve Effective Compliance (Part III of III)

Within the specific element discussions in HHS-OIG’s Guidance, are important operational details and strategies for an effective compliance program.  GCPG provides important suggestions and innovations for consideration by all compliance professionals. Effective Lines of Communication The GCPG stresses the importance of an open line of communication between the compliance officer and entity personnel as a means to reduce potential fraud, waste and abuse.  To this...

Episode 130 — Practical Strategies for OFAC Sanctions Risk Assessments

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) is aggressively enforcing OFAC sanctions rules.  Last year, OFAC issued its Framework for Sanctions Compliance Programs, which includes a specific requirement for companies to conduct a “holistic” risk assessment. In this episode, Michael Volkov outlines practical strategies for conducting a sanctions risk assessment.

OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV)

The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s Framework for Sanctions Controls Program is a heightening of the importance of ethics and compliance program and reflects significant expectations for implementing effective compliance strategies.  Risk Assessment In Risk Assessment, OFAC recommends that organizations conduct...

Episode 46 — Implementing a Policy Management Program

Companies have to implement a robust policy management program.  In today’s risky environment, companies should automate a robust policy management program that requires regular review, assessment and updating of policies and procedures.  A policy management program should be created consisting of key constituencies to ensure that policies and procedures are current, effective, and appropriately tailored to the company’s risk profile. In this episode, Michael Volkov...

The Vital Role of Internal Audit to Compliance

A chief compliance officer can only succeed with the support of other important compliance partners.  Another way to put it – in the words of Blanche Dubois from A Streetcar Named Desire, “I have always depended on the kindness of strangers.”  This observation, while dramatic in license, applies to the place of the compliance officer in the corporate governance world. A key partner for compliance...

ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V)

In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk assessments. ISO 37001 requires companies to conduct regular risk assessments in order to identify the bribery risks the company might reasonably anticipate; analyze, assess and prioritize the identified bribery risks; and evaluate...