The global economy has suffered two significant shocks — first, the pandemic sent shockwaves through every organization, and second, the war in Ukraine. Both of these events exposed the importance of risk management, especially with regard to supply chain and distribution operations. Hence, the renewed focus on third-party risk management and the repetitive description of “holistic” third-party risk management. Reality has a way of forcing change and...
In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks. Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes. Companies have to develop strategies that practically address the risks without dedicating disproportionate resources to the problem. In the first episode, Michael Volkov discusses beneficial ownership risks and...
The SEC continues to exercise its powerful enforcement tool – internal controls violations – in FCPA enforcement actions against public companies. Kinross Gold Corporation is the latest company to enter into an FCPA settlement. Kinross agreed to pay $950,000 for inadequate internal controls and books and records violations centered on the activities of two mining companies Kinross acquired. The SEC cited no evidence of any...
Compliance practitioners are opportunists. They have to look for openings in the corporate resource world to build partnerships with related functions. To put it another way, they are purveyors of compliance thinking – they inject the compliance mindset into functions that can advance the effectiveness of compliance controls. When it comes to the vendor onboarding process, compliance practitioners need to participate in the design and...
