Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws. Like most cases, I always...more
10/31/2024
/ Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Corruption ,
Criminal Investigations ,
Defense Sector ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Fraud ,
Leadership ,
Pricing ,
Raytheon
How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges?
In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more
“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies — add them to Wells Fargo, Wirecard, Volkswagen, General Motors,...more
10/16/2024
/ BSA/AML ,
Compliance ,
Corporate Culture ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Guilty Pleas ,
Money Laundering
Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...more
8/1/2024
/ Aircraft ,
Airplane Accidents ,
Anti-Fraud Provisions ,
Aviation Industry ,
Boeing ,
Compliance ,
Corporate Culture ,
Corruption ,
Deferred Prosecution Agreements ,
Federal Aviation Administration (FAA) ,
Internal Controls ,
White Collar Crimes
DOJ and Boeing have entered into a proposed plea agreement that will require judicial scrutiny and determinations of the public interest and the victims’ rights under the Crime Victims’ Rights Act, 18 U.S.C. § 3771 [“CVRA”]. ...more
7/31/2024
/ Airplane Accidents ,
Aviation Industry ,
Boeing ,
Corporate Culture ,
Crime Victims ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Internal Controls ,
Plea Agreements ,
Safety Standards ,
White Collar Crimes
NAVEX delivers quality studies and important insights on ethics and compliance topics. In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more
NAVEX delivers quality studies and important insights on ethics and compliance topics. In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more
7/19/2024
/ Acquisitions ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Employee Training ,
Environmental Social & Governance (ESG) ,
Ethics ,
Mergers ,
Risk Management ,
Voluntary Disclosure
LRN has issued another important report -- in its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture. LRN is a pacesetter and the leader in reliable...more
LRN’s research consistently paints a picture that every board member, senior executive and middle manager should view — corporate culture is an organization’s most valuable intangible asset and is a significant determinant...more
In its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture. LRN is a pacesetter and the leader in reliable studies on complex ethics and compliance issues....more
LRN’s latest report was based on a survey of more than 1,400 ethics and compliance professionals, most of whom were employed at organizations with at least 1000 employees in 19 different countries and 26 industries across...more
Boeing continues to struggle. As troubles mount for Boeing, it is clear that it suffers from real and pervasive culture issues that have been reflected in serious safety failures, financial difficulties, regulatory...more
3/6/2024
/ Aviation Industry ,
Boeing ,
Compliance ,
Corporate Counsel ,
Corporate Culture ,
Corruption ,
Directorate of Defense Trade Controls (DDTC) ,
Ethics ,
Export Controls ,
Exports ,
ITAR ,
Regulatory Violations ,
Settlement ,
US Department of State
One of the many great experiences I have been fortunate to have in my career is to meet some impressive leaders – at the Department of Justice, on Capitol Hill, and in corporations. To focus on the latter, I have met some...more
One of the benefits of old(er) age is perspective and experience. (As we age, we have to find the positive reasons to tout). If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more
We all agree on the importance of corporate culture. Everyone gets it – corporate leaders mouth the words but rarely understand the nuances, and the need to attend to a company’s culture. Compliance professionals want to...more
The Ethics and Compliance Initiative (“ECI”) is a terrific organization that provides important ethics and compliance insights and leadership. Starting in 1994, ECI has conducted a longitudinal, cross-section study of...more
Corporate leaders know what to say and when to say it – for example, a CEO may state at an employee meeting, “We want to hear your concerns. We want you to bring these concerns forward and we will address them. We are...more
Corporate governance frameworks seek to maximize management efficiency, risk mitigation, and business success. The most important tool for accomplishing these objectives is straightforward – a Culture of Ethics and...more
Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives. These steps are not just suggestions nor items that can be prioritized...more
Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone. To the contrary, as the business adapts through growth, innovation or in response to outside market and...more
As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture. In these...more
Everyone has jumped on the corporate culture bandwagon. For some new converts, they like to espouse corporate culture as a recent discovery, or a new-fangled approach for compliance programs....more
NAVEX Global always provides insightful and important whitepapers and annual reports. One of the more important annual reports is NAVEX’s Hotline and Incident Management Report. Given Navex’s important position in the...more
4/18/2023
/ Annual Reports ,
Anonymity ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Corruption ,
Employees ,
Employment Discrimination ,
Hotlines ,
Oral Complaints ,
Retaliation ,
Whistleblower Hotlines ,
Workplace Harassment Guidance
The Justice Department’s recent emphasis on ethics and compliance culture, along with greater specificity on “consequence management” is a welcome breath of fresh air. It is a policy coming for a long time and will bring...more
Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more
4/5/2023
/ Banks ,
Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Economic Sanctions ,
Enforcement Actions ,
Ethics ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Wachovia ,
Wells Fargo