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Compliance Supply Chain White Collar Crimes

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

The Volkov Law Group on

If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

The Volkov Law Group

Responding to Supply Chain Glitches and Increased Bribery Risks

The Volkov Law Group on

The evolution in the global economy is raising challenges for anti-corruption compliance.  In response to economic dislocations and disruptions stemming from the COVID-19 pandemic and Russian invasion of Ukraine, businesses...more

The Volkov Law Group

Adjusting Your Perspective — Identifying Your Real Third-Party Risks (Part II of V)

The Volkov Law Group on

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...more

Vinson & Elkins LLP

[Webinar] Corruption in the Time of COVID-19 - September 16th, 8:00 am - 9:00 am CT

Vinson & Elkins LLP on

While GDP and worldwide economies shrink under the continuing impact of COVID-19, government budgets have expanded to support healthcare responses to the pandemic and social-welfare in response to growing unemployment and...more

The Volkov Law Group

Bumble Bee CEO Sentenced to 40 Months in Prison for Price-Fixing

The Volkov Law Group on

After a lengthy sentencing hearing in federal court in San Francisco, Bumble Bee CEO Chris Lischewski was sentenced to 40 months in prison for his involvement in a tuna price-fixing conspiracy.  The judge rejected...more

Thomas Fox - Compliance Evangelist

The Wild Wild West and ComTech

Compliance has been pushed more to the forefront in anti-money laundering (AML). As banking institutions, financial institutions and the financial services industries continue to tighten and strengthen AML controls, criminals...more

Society of Corporate Compliance and Ethics...

Bumble Bee ex-CEO convicted for price-fixing

CEP Magazine (February 2020)  - Chris Lischewski, former CEO of Bumble Bee Foods, was found guilty of price-fixing by a jury on Dec. 3. The conviction caps a years-long investigation into price-fixing by the canned tuna...more

Thomas Fox - Compliance Evangelist

Compliance Responses to Bribery Schemes

Yesterday, I looked at some of the more creative bribery schemes identified in 2019 Foreign Corrupt Practices Act (FCPA) enforcement actions. They were schemes involving distributors, joint ventures (JVs) and fraudulent...more

The Volkov Law Group

Bumble Bee CEO Convicted of Participating in Price-Fixing Conspiracy

The Volkov Law Group on

Global companies are paying greater attention to criminal antitrust risks – and with good reason.  We often dwell on the impact to a company of a major FCPA investigation.  A global criminal antitrust investigation often in...more

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 2 – Risk Assessment

I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more

Thomas Fox - Compliance Evangelist

Miranda Rights and Instituting a Broader Supply Chain Risk Management Program

On of the most well known of all criminal procedural rights was established by the US Supreme Court on this day in 1966, when the Court handed down its Miranda v. Arizona decision. It established the legal principle that all...more

The Volkov Law Group

OFAC Fines US Company for Iran Sanctions Violations

The Volkov Law Group on

There is no question that OFAC continues to dominate the enforcement landscape this year.  OFAC has provided plenty of warning and notice to global companies, especially those in the manufacturing and industrial sectors....more

Thomas Fox - Compliance Evangelist

Inspiration for Band on the Run and Market Impacts Driving Supply Chain Management

As any compliance officer would tell you within the first few minutes of meeting them, regulations are becoming more prevalent and more complex.” A technological solution is now almost mandated from this complexity....more

The Volkov Law Group

Conducting a Sanctions Risk Assessment: A New Era for Analyzing Your Risks (Part II of IV)

The Volkov Law Group on

OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement.  This new approach reflects OFAC’s recent aggressive enforcement programs....more

Thomas Fox - Compliance Evangelist

FARs, Flow Downs and Supply Chain Compliance

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

Thomas Fox - Compliance Evangelist

Maintaining Market Access

Next week, in a five-part podcast series sponsored by Assent Compliance Inc. (Assent), I explore market access for supply chain. During the course of this series, I visit with several members of the Assent team to introduce...more

Thomas Fox - Compliance Evangelist

Farewell to a Court Jester and 800 Hours to a No-Deal Brexit

In the bigger than big category there are now approximately 35 days or just over 800 hours left before a no-deal Brexit is set to take effect. To say there is disarray in the British political establishment over this upcoming...more

Thomas Fox - Compliance Evangelist

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part II

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of...more

Thomas Fox - Compliance Evangelist

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

Thomas Fox - Compliance Evangelist

Monster Movie Month: Episode 2 – The Bride of Frankenstein and Upcoming Events

Welcome to my second installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series and today I want to explore and, indeed, honor the second in the series but what many viewers...more

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