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Third-Party Risk White Collar Crimes Anti-Corruption

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

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

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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

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)

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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

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

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

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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

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

DOJ’s Compliance Message: Implement Technology Solutions

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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

Troutman Pepper

DOJ Amplifies Compliance Guidance, Focusing on Customization, Continuous Improvement, Third-Party Relationships and Resourcing

Troutman Pepper on

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

Morgan Lewis

DOJ Updates Corporate Compliance Evaluation Guidance: New Refinements Stress that Programs Need to be 'Empowered to Function...

Morgan Lewis on

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

The Volkov Law Group

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

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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

The Volkov Law Group on

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

The Volkov Law Group

Keeping Your Eye on the Risk Ball

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

The Dutch Tulip Bubble and Internal Controls for Third Parties

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

The Volkov Law Group

Managing High-Risk Distributor Risks (Part I of II)

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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

Thomas Fox - Compliance Evangelist

Casebook of Sherlock Holmes: The Lion’s Mane and Risk-Based Monitoring

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

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

The Volkov Law Group

The Important Link Between Anti-Corruption Compliance and Effective Training Programs

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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

The Volkov Law Group

Tying Mitigation to Third Party Risks

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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

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

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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

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