March 14, 2023 12 Noon EST SIGN UP HERE In the ever-changing global economy, and in the aftermath of the pandemic and Russia’s invasion of the Ukraine, third-party risks continue to present significant risks and challenges. At the same time, global companies face escalating enforcement risks from the United States and foreign law enforcement. It is more important than ever for companies to embed third-party...
The Honeywell FCPA settlement underscored a number of important issues – lessons learned for compliance professionals. Every FCPA case carries important lessons learned, but some more than others. The Honeywell case with its focus on the large project in Brazil, and the contractual dispute in Algeria both provide important pointers relating to third party risk management. In addition to the third party issues, however, Honeywell...
Compliance professionals are always looking for ways to collaborate and support internal business partners. Through the years, compliance professionals have devoted significant energy to building partnerships with the business. Compliance has and should continue to build a strong relationship with business as a meaningful value-add. This process has been accelerated by the Covid and Ukraine crises and increasing cyber risks stemming from data breaches and...
When you get on the mailing lists for legal and compliance products, seminars, conferences and general palabra, I usually become transfixed. Millions of marketing and promotion dollars are being spent in an attempt to distinguish or highlight the subject of third-party risk, position a product or highlight the expertise of a speaker. Sometimes I take the time to read some of the emails — to...
After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million. The SEC’s resolution charges WPP with violations of the anti-bribery, books and records and internal accounting controls provisions of the FCPA. The Justice Department’s investigation of WPP appears to be ongoing. WPP has dual headquarters, in...
Deutsche Bank’s ethics and compliance function faces numerous challenges. Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs). When you review these matters, Deutsche Bank’s track record reflects serious culture and control deficiencies, including participation of high-level executives in bribery schemes. Deutsche Bank’s continuing legal and compliance failures are likely to continue unless...
Deutsche Bank, the infamous German bank connected to President Trump, settled FCPA and fraud cases with the Justice Department and the SEC, and agreed to pay a total of $130 million. The settlement included resolution of fraud charges against Deutsche Bank relating to a commodities fraud scheme, commonly referred to as “spoofing.” Under the global resolution, Deutsche Bank agreed to pay: (1) criminal penalties of...
We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe. Let me give you a few examples. Cognizant Technology In the Cognizant Technology FCPA enforcement action, the former President and General Counsel directed the scheme with two other C-Suite officers...
An effective third-party risk management program has to include robust monitoring and auditing strategies. This episode is a companion to Episode 129 on creating a third-party risk profile. In this episode, Michael Volkov outlines strategies for monitoring and auditing your third-party population.
February 18, 2020 1 PM EST/10 AM PST Sign Up HERE A comprehensive third party risk management program integrates with ethics and compliance activities across the enterprise to provide an accurate and actionable view of risk exposure. Implementing a holistic approach to due diligence extends beyond third party screening and monitoring. Effective risk management programs integrate with risk profiles across the organization, breaking down silos...
