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Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 3, Extensive Remediation

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

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

Corporate Culture = Talk + Action

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Corporate culture is all the rage now, meaning it is an often used topic to signal commitment, sensitivity to issues of employee concern, and an awareness of governance trends.  In practice, as we all know, culture is not...more

The Volkov Law Group

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

The Volkov Law Group on

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

Dechert LLP

Measure Twice, Cut Once: New DOJ Compliance Certifications Put CEOs and CCOs at Risk of Individual Criminal Liability

Dechert LLP on

Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more

The Volkov Law Group

5 Common Internal Investigation Pitfalls

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An internal investigation is like reading a good novel.  You begin the journey with a general expectation of what the novel or the “investigation” is about.  As every reader knows, the exhilaration is the result of following...more

Thomas Fox - Compliance Evangelist

The Memoirs of Sherlock Holmes – The Stock-Brokers Clerk and Foundational Code of Conduct

This week, we return to Sherlock Holmes-themed blog posts. We finished the review of The Adventures of Sherlock Holmes and now move on to The Memoirs of Sherlock Holmes. Today we move on to The Adventure of the Stock-Brokers...more

The Volkov Law Group

The Future of Compliance: Building Bridges (Part II of III)

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As a passionate supporter of the compliance function, I continue to advocate for compliance officers and the importance of compliance to overall governance.  Good compliance means good business – we all know that....more

The Volkov Law Group

The Future of Compliance: Re-Branding Compliance from Reactive to Proactive (Part I of III)

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As everyone knows, I am an eternal optimist.  Being a cynic always leads to negative energy and results.  As a former federal prosecutor, I am deeply committed to the idea of doing the right thing....more

Thomas Fox - Compliance Evangelist

CCO Lessons from A Charlie Brown Christmas

Delegation is always a key technique in improving productivity. However, you should not simply “shove things off your plate” but use the opportunity to give specific and new challenges to employees to help in their own career...more

Hanzo

The Compliance Implications of Operation Varsity Blues: A Conversation with AP Capaldo-Aoun, LPEC

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On the afternoon of Monday, April 8th, 2019, I spoke with AP Capaldo-Aoun, a global compliance attorney and director of E&C at a Fortune 100 technology company, about the compliance implications of Operation Varsity Blues....more

The Volkov Law Group

Third Party Risk Management: Require ISO 37001 Certification from Your Third Parties

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A lot of the focus on ISO 37001 so far has been on its value for companies considering certification as evidence of the quality of their own compliance program. With the SEC and DOJ both providing ample guidance to companies...more

K2 Integrity

The DOJ Expects “Third-Party Management” from Compliance Programs

K2 Integrity on

2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more

Foley & Lardner LLP

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

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Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

The Volkov Law Group

Match Made in Heaven: Compliance and Human Resources

The Volkov Law Group on

The corporate compliance function is only as successful as its partnerships with key internal constituencies. Depending on the company and the personnel involved, compliance has to establish and maintain effective working...more

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