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The Volkov Law Group

Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review

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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

Thomas Fox - Compliance Evangelist

When New Business Risks Emerge: Lessons for Compliance from The Creature from the Black Lagoon

This week, leading up to Halloween, I will examine lessons for compliance professionals through the lens of the great Universal Movie Monsters: Frankenstein, Wolfman, Dracula, and The Mummy. Today, we consider what compliance...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 9, Internal Controls

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Tailored Risk Management in the Third Sector

Compliance and risk management are crucial aspects of any organization, and the third sector is no exception. In this week’s episode of Great Women in Compliance, hosted by Hemma Lomax, she visited with Sabrina Segal on the...more

Thomas Fox - Compliance Evangelist

Compliance Lessons from The Adventure of the Crooked Man

One of the great things about having a podcast network is that I get to not only explore topics that I love but I get to tie them into compliance. Perhaps the best example is my award-winning series, Trekking Through...more

The Volkov Law Group

The Evolution of the Compliance Profession

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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

The Volkov Law Group

A Compliance Reminder: Focus on Your Culture

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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

Thomas Fox - Compliance Evangelist

What is Corporate Culture?

Welcome to a special five-part blog series on building a stronger culture of compliance, sponsored by Diligent. In this series I will visit with Yvette Hollingsworth-Clark, Viktor Cuijak, Jessica Czeczuga; Michael Parker; and...more

The Volkov Law Group

ECI’s New Survey – The State of Ethics & Compliance in the Workplace

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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

The Volkov Law Group

Episode 284 -- How to Implement a Compliance Compensation System

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The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management.  The theoretical...more

Cohen & Gresser LLP

Enquête interne anticorruption et coopération judiciaire

Cohen & Gresser LLP on

L’Agence française anticorruption (AFA) et le Parquet national financier (PNF) ont publié conjointement en mars 2023 un guide pratique visant à apporter aux entreprises un éclairage sur l’objet et la conduite d’une enquête...more

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

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Let’s move beyond the headline – trade compliance is the new FCPA.  We get it.  The next step is to do something about it.  The Justice Department has repeated this refrain – it is one of its greatest hits.  In addition, DOJ,...more

The Volkov Law Group

The Importance of Accounting and Internal Controls (Part I of II)

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Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more

Holland & Knight LLP

Programa de Transparencia y Ética Empresarial para las ESAL en Bogotá, Colombia

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A partir de la expedición de la Ley 2196 de 2022, las entidades sin ánimo de lucro (ESAL) en Colombia por parte de las entidades obligadas a contar con un Programa de Transparencia y Ética Empresarial (PTEE o el Programa)...more

The Volkov Law Group

Tracking Ethics and Compliance Program Performance (Part II of II)

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Chief compliance officers rely on several important sources for feedback — internal data and communications (reviews with board, senior managers, employees); and benchmarking against comparable organizations.  An internal...more

The Volkov Law Group

Compliance Program Monitoring, Testing, Audits, Assessments and Continuous Improvement (Part I of IV)

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Chief compliance officers have a lot of issues to balance on their plate.  Experienced CCOs know that it is not possible to complete every objective, balance every changing risk, and continuously improve their respective...more

The Volkov Law Group

The Importance of Ethics and Compliance to the Overall Corporate Mission (Part II of IV)

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There are lots of sources for compliance guidance — prosecutors, regulators, compliance organizations, and many others have set forth important and valuable guidance for the design and implementation of an effective ethics...more

Dechert LLP

Sanctions are “the New FCPA”: A Heightened Focus for DOJ Enforcement

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At a New York City Bar Association event on April 27, Deputy Attorney General Lisa Monaco described economic sanctions as “the new FCPA.” Her characterization should put corporate compliance departments on notice. ...more

The Volkov Law Group

KT Corp. Settles SEC FCPA Case for $6.3 Million (Part I of III)

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The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations.  As part of the settlement, KT Corp. agreed to pay...more

Foley Hoag LLP - White Collar Law &...

Anti-Corruption in 2022: A Look Ahead

This is the second post in this year’s series examining important trends and new development in white collar law and investigations. Our previous post discussed health care enforcement. Up next: trends in tax enforcement. ...more

Society of Corporate Compliance and Ethics...

Salvador Dahan on the Journey of Petrobras

Operation Lava Jato (Carwash) had a profound effect on business in Brazil, with countless companies caught up in one way or another in the corruption scandal. State oil company Petrobras was no exception, but, as is the case...more

Goodwin

2021 Year in Review: FCPA

Goodwin on

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

Dechert LLP

Nouvelle réforme des lois anti-corruption en France : Les temps changent (de nouveau !)

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Il y a presque cinq ans, la France a promulgué sa loi anti-corruption, dite loi Sapin II. Cette loi, considérée comme disruptive à l'époque, a introduit des innovations importantes, y compris la possibilité pour les...more

Dechert LLP

Reforming France’s Anti-Corruption Laws: Times are Changing (Again!)

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Almost five years ago, France enacted its anti-corruption legislation, Sapin II. The law was considered ground-breaking at the time and introduced a number of important innovations, including the ability for companies to be...more

The Volkov Law Group

Monitoring and Measuring A Company’s Ethical Culture: Relevant Survey Strategies (Part I of II)

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Chief compliance officers play a key role in managing a company’s ethical culture. Most companies fail to pay proper attention to its culture because it is difficult to define, measure and monitor. Such an approach is...more

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