Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
Leadership Lessons From The West Wing — Hiring to Firing Podcast
Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review
Wicked Coin: FIFA: Soccer, Scandal, and Sportswashing
The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger
Public-Private Partnerships to Stem Corruption
Why Privacy is Your Secret Weapon Against Third-Party Risk
Due Diligence in AI: 3 things you need to survive AI scrutiny
Episode 337 -- Nicolas Garcia, GC at Orica, on Compliance Trends and Challenges in Latin America
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
A Third Party's Perspective on Third Party Risk
Cannabis Law Now Podcast: Cannabis Companies and the Corporate Transparency Act
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility
Episode 328 -- Sanctions Enforcement Risks and Redlines
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Examining FinCEN FAQs, Proposed Legislation and Other CTA Developments
Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
It may seem like a Herculean task — but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason —...more
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a...more
Nathalie Druckmann, Vice President at Certa, joins Michael Volkov to discuss third-party risk management and the use of advanced artificial intelligence to implement effective risk mitigation strategies. Nathalie sets the...more
The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious). The reasons for this may be a question of timing elements in the pipeline of cases....more
Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more
Facing the myriad third-party sanctions risks can be daunting. Many global organizations rely on a network of third-party intermediaries that pose a variety of risks. To mitigate those risks, companies have to implement...more
If there is one issue that is repeated over and over (and over), it is third-party risks. Over the last ten years, we have witnessed an explosion in anti-corruption enforcement around the world. And with this enforcement...more
Third-party risk management is a favorite topic for compliance professionals. And for good reason. Third parties create significant risks. To state the obvious, companies have less control over third parties than...more
The Beam Suntory case is yet another example of a failure of internal and external auditors, and legal and compliance professionals. Reviewing cases involves a focus on how and why a compliance failure occurred....more
New guidance for prosecutors from the U.S. Department of Justice (“DOJ”), Criminal Division, highlights increasing expectations that companies continuously and in real-time reassess fraud and corruption risk and adjust their...more
Earlier this month, the Criminal Division of the United States Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs guidance. In considering enforcement actions against companies, prosecutors...more
On June 1, 2020, the Criminal Division of the U.S. Department of Justice (DOJ) released updates to its Evaluation of Corporate Compliance Programs guidance (Guidance), last revised in April 2019. ...more
DOJ’s revised Evaluation of Corporate Compliance Program Guidance (“DOJ Guidance”) is yet another reminder on how far compliance has evolved and the path forward. Compliance programs have to incorporate real-time monitoring,...more
On June 1, the U.S. Department of Justice updated its guidance on the Evaluation of Corporate Compliance Programs (DOJ Compliance Guidance). While the changes are modest, they reflect DOJ’s evolving expectations regarding...more
The US Department of Justice’s (DOJ’s) Criminal Division published an update on June 1 to its Evaluation of Corporate Compliance Programs guidance, which is used by its prosecutors to assess the adequacy and effectiveness of...more
At the outset, if you have a headache after reading my first two posts on the beneficial ownership issue, I apologize. The issues twist and turn depending on whether the situation involves OFAC sanctions or corruption risks,...more
As companies move forward on third-party risk management programs, and as automated third-party risk solutions are being implemented, compliance professionals have to re-examine and re-balance the allocation of resources and...more
Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces. I am exaggerating a little bit to make...more
Internal controls are a key tool to operationalize your third-party risk management program. The basic internal controls, that should be a part of any financial controls system. There were four significant controls the...more
Companies will often rely on a network of distributors to help sell their products in emerging markets. From a business economics standpoint, engaging a distributor is often more cost efficient than investing in a sales...more
By using risk-based monitoring, you can begin to see things in “almost real-time, time-based trends of real data that you can then jump on and try to make adjustments before things get really wacky.” The implications to the...more
I recently had the chance to visit with Travis Miller, General Counsel (GC), and I discuss how the regulatory requirements of the Federal Acquisitions Regulations (FARs) impact access to markets and supply chain compliance....more
Global anti-corruption risks are increasing at the same time that global cooperation among prosecutors and law enforcement agencies are facilitating the detection and penalization of companies and individual bad actors that...more
Companies are hyper-focused on identifying risks during the onboarding process, the use of automated platforms to organize and conduct such screening, and continuous monitoring through an automated platform. ...more
Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more