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White Collar Crimes Compliance Internal Controls

The Volkov Law Group

Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review

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How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges? In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more

Thomas Fox - Compliance Evangelist

When New Business Risks Emerge: Lessons for Compliance from The Creature from the Black Lagoon

This week, leading up to Halloween, I will examine lessons for compliance professionals through the lens of the great Universal Movie Monsters: Frankenstein, Wolfman, Dracula, and The Mummy. Today, we consider what compliance...more

Fenwick & West LLP

Don’t Wait for the DOJ to Come Knocking: Important Whistleblower Protection and AI Risk Management Updates

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In September 2024, the DOJ’s Criminal Division released an updated Evaluation of Corporate Compliance Programs (ECCP) guidance document to address emerging risks. The ECCP serves as a roadmap for how DOJ evaluates a company’s...more

Thomas Fox - Compliance Evangelist

The 2024 ECCP – Using Data Analytics to Determine Employee Engagement, Trust, and Corporate Culture

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke about the CWA and reviewed its early...more

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 5- A Case Study for Compliance

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 3-The Role of Internal Controls

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Thomas Fox - Compliance Evangelist

The Boeing Plea Agreement-A Major Disconnect

In its proposed Plea Agreement, the Department of Justice (DOJ) lays out the abject failures of Boeing which led the DOJ to conclude the underlying Deferred Prosecution Agreement (DPA) from 2021 has been breached. The DOJ...more

Thomas Fox - Compliance Evangelist

The Boeing Monitorship – Compliance, Accountability, and the Path Forward

When it comes to corporate accountability and the often murky waters of compliance, few cases are as illustrative and significant as the ongoing litigation involving Boeing. Since the 737 MAX safety scandal erupted in 2021,...more

The Volkov Law Group

Boeing’s Failure to Integrate Compliance Anti-Fraud Controls with Quality and Safety Functions (Part III of III)

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Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...more

Health Care Compliance Association (HCCA)

So many reporting systems!

By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more

Thomas Fox - Compliance Evangelist

Transforming a Corporate Culture in Crisis: Lessons from Boeing

There has not been a company which has had a run of worse publicity in 2024 than Boeing. Unfortunately it has been self-inflicted. I recently participated in a webinar with Sam Silverstein on what Boeing can do to try and...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 9, Internal Controls

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

Thomas Fox - Compliance Evangelist

Tailored Risk Management in the Third Sector

Compliance and risk management are crucial aspects of any organization, and the third sector is no exception. In this week’s episode of Great Women in Compliance, hosted by Hemma Lomax, she visited with Sabrina Segal on the...more

J.S. Held

INDEPTH FEATURE: Anti-Money Laundering 2024

J.S. Held on

Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Thomas Fox - Compliance Evangelist

Compliance Lessons from The Adventure of the Crooked Man

One of the great things about having a podcast network is that I get to not only explore topics that I love but I get to tie them into compliance. Perhaps the best example is my award-winning series, Trekking Through...more

The Volkov Law Group

Episode 297 -- Susan Divers on LRN's 2023 Program Effectiveness Report

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LRN’s annual Program Effectiveness Report is chock full of important findings. Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it). Susan and Michael...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Enforcement Division Director Clarifies Approach to Compliance Officer Liability

In a speech on October 24, 2023, the director of the Securities and Exchange Commission’s (SEC’s) Enforcement Division, Gurbir Grewal, described the scenarios in which the commission would bring an enforcement action against...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

Thomas Fox - Compliance Evangelist

2023 Global Business Ethics Survey: Part 5-Workplace Ethics Concerns and the Need for Compliance

In a recent ECI podcast series , I had the opportunity to visit with Pat Harned, President of ECI. We took a deep dive into the 2023 Global Business Ethics Survey (GBES) revealed concerning trends in workplace ethics. The...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 5-Lessons Learned

Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action.  We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 4 – Internal Control Failures

Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

The Volkov Law Group

A Compliance Reminder: Focus on Your Culture

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We all agree on the importance of corporate culture.  Everyone gets it – corporate leaders mouth the words but rarely understand the nuances, and the need to attend to a company’s culture.  Compliance professionals want to...more

Thomas Fox - Compliance Evangelist

What is Corporate Culture?

Welcome to a special five-part blog series on building a stronger culture of compliance, sponsored by Diligent. In this series I will visit with Yvette Hollingsworth-Clark, Viktor Cuijak, Jessica Czeczuga; Michael Parker; and...more

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