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Third-Party Risk Compliance White Collar Crimes

The Volkov Law Group

“The New FCPA”: The Future Landscape of Sanctions Enforcement (Part II of IV)

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We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more

The Volkov Law Group

The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV)

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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 Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

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Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

Thomas Fox - Compliance Evangelist

Changing Sales Models

Over the past 12 months or so there have been a series of Foreign Corrupt Practices Act (FCPA) enforcement actions where the respondents have changed and/or modified their sales models to get away from external third parties...more

Thomas Fox - Compliance Evangelist

Managing Third Parties

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

The Volkov Law Group

Episode 304 -- Nathalie Druckmann, VP at Certa, on Artificial Intelligence Third-Party Risk Management

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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 Volkov Law Group

DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose

The Volkov Law Group on

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

Morgan Lewis

Anti-Bribery And Corruption Survey Report

Morgan Lewis on

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

Thomas Fox - Compliance Evangelist

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 4-A Training Program for 3rd Parties

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...more

The Volkov Law Group

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

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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

The Volkov Law Group

Practical Steps to Implement to Manage Third-Party Sanctions Risks (Part III of III)

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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

The Volkov Law Group

Managing Third-Party Sanctions Risks (Part I of III)

The Volkov Law Group on

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

The Volkov Law Group

Keeping Track of Third Party Risks – Bribery and Sanctions

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We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses.  Almost every FCPA enforcement action includes some form of third-party misconduct.  The current...more

The Volkov Law Group

The Evolution of Third-Party Risk Management

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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 Volkov Law Group

WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)

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The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more

The Volkov Law Group

Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III)

The Volkov Law Group on

We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues.  It does not take a rocket scientist to...more

The Volkov Law Group

Beam Suntory Bribery Scheme: Another Controls Failure (Part II of II)

The Volkov Law Group on

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

The Volkov Law Group

Letting Third Parties Do the Dirty Work

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We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe.  Let me give you a few examples....more

Orrick, Herrington & Sutcliffe LLP

Thoughts on Revised DOJ Corporate Compliance Guidance, and New Emphasis on Real-Time Risk Assessment, Use of Data, and 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

Foley Hoag LLP - White Collar Law &...

DOJ Updates Guidance on Evaluating Corporate Compliance Programs

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

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways From Updated DOJ Corporate Compliance Evaluation Guidance

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

The Volkov Law Group

Beneficial Ownership: Identification and Mitigation (Part IV of IV)

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We are finally reaching the end of the road on the beneficial ownership path.  In this last posting on the issue (for now), let’s start with a third-party population (third parties, vendors, suppliers) which have been...more

The Volkov Law Group

Practical Risk-Based Ranking Strategies to Beneficial Ownership Issues (Part III of IV)

The Volkov Law Group on

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

The Volkov Law Group

Rebalancing Third-Party Risk Strategies

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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

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

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