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The Dark Patterns Behind Corporate Scandals

Professors Guido Palazzo and Ulrich Hoffrage are skeptical. When they hear that there was a bad apple at the core of a scandal, they are hesitant to accept that explanation. Instead, they argue in this podcast and in their...more

Thomas Fox - Compliance Evangelist

Because that's what heroes Do: Deep Space 9 – Episode 31: Extreme Measures – Great Sci Fi and Moral Dilemmas

This season, they take a deep dive into their favorite episodes of Deep Space 9. In this exploration, Tom and Megan are joined by Star Trek maven Alex Murphy (Murphy) from Montreal, a local historian, and a cinema and TV fan...more

Thomas Fox - Compliance Evangelist

Why the 2024 ECCP Update is a Game-Changer for Compliance

In the DOJ’s 2024 update to the Evaluation of Corporate Compliance Programs (2024 ECCP), compliance professionals face new expectations that could reshape how we approach compliance programs. In this latest update, the DOJ...more

The Volkov Law Group

Raytheon’s Defective Pricing Fraud and Resolution (Part II of IV)

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Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws. Like most cases, I always...more

Thomas Fox - Compliance Evangelist

Supporting Whistleblowers: Lessons from Lon Chaney’s The Wolfman

Ed. Note: 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 use Lon...more

Thomas Fox - Compliance Evangelist

Deere FCPA Enforcement Action: Lessons on Pre-Acquisition Due Diligence in M&A

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...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

Transforming Culture: Part 1-From Merger to Culture Toxicity

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other...more

Thomas Fox - Compliance Evangelist

Leadership’s Conduct at the Top

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Thomas Fox - Compliance Evangelist

Global Business Ethics Survey: Part 2 – Addressing Workplace Misconduct

The Global Business Ethics Survey (GBES) conducted by the Ethics & Compliance Initiative (ECI) provides valuable insights into workplace ethics and compliance from the perspective of employees. I recently had the opportunity...more

The Volkov Law Group

Corporate Culture: Monitor, Intervene and Remediate (Part III of III)

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Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone.  To the contrary, as the business adapts through growth, innovation or in response to outside market and...more

The Volkov Law Group

Carrie Tolstedt, former Wells Fargo Community Banking Head, Agrees to Plead Guilty and Pay a $17 Million Fine for Obstruction of...

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If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class.  Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct. ...more

Robinson & Cole LLP

DOJ Announces Significant Corporate Compliance Initiatives

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The U.S. Department of Justice (DOJ) recently announced several new policies and programs aimed at incentivizing corporate compliance. These programs underscore the need for companies to investigate, mitigate and resolve...more

The Volkov Law Group

Glencore’s Bribery Schemes (Part III of V)

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The broad and pervasive scope of Glencore’s bribery conduct is obvious.  The scope of its misconduct reflects Glencore’s fatal culture and commitment to profits at any and all cost.  Glencore’s board and senior executive team...more

The Volkov Law Group

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

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On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more

The Volkov Law Group

Here Comes DOJ – Corporate Crime Enforcement

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Lisa Monaco, the Deputy Attorney General (No. 2 in DOJ), delivered an important speech at the National Institute of White Collar Summit.  Lisa was part of the Enron Task Force years ago and has a strong professional...more

The Volkov Law Group

Remediating the Organization’s Culture (Part IV of IV)

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“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more

The Volkov Law Group

Measuring and Reporting on the Organization’s Culture (Part III of IV)

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While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures....more

Latham & Watkins LLP

White Collar & Compliance Academy 2021 - Die Zukunft

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Compliance & Investigations im Jahr 2025 - „Wirksame Compliance erfordert ganzheitliche Ansätze.“ Was ist für die Themen „Compliance & Investigations“ im Jahr 2025 zu erwarten? Fünf Thesen von Prof. Dr. Thomas Grützner...more

The Volkov Law Group

Danger! Danger!: Retaliation Against Employees is Increasing (Part II of II)

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The FCPA Guidance issued by the Justice Department and the SEC says it best – “The truest measure of an effective compliance program is how it responds to misconduct.” ...more

The Volkov Law Group

Boeing’s Culture of Neglect and Disregard of Safety: The House Transportation Committee Report Findings (Part II of II)

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Boeing’s culture and safety performance continues to undermine its ability to move forward and regain trust from regulators, the aviation industry and the flying public....more

The Volkov Law Group

Boeing and the 737 Max Scandal (Part II of III)

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Boeing’s 737 Max problems began over ten years ago.  Facing competitive pressure from Airbus, Boeing embraced the 737 Max as its competitive savior.  After two horrific crashes killing a total of 346 people, the FAA ordered...more

The Volkov Law Group

The Boeing Scandal and the Demise of a Corporate Culture (Part I of III)

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When a company suffers from serious misconduct, the source of such a failure usually lies in its corporate culture.  I know this theory sounds relatively obvious, but bear with me here....more

The Volkov Law Group

“Paralysis” and a Culture of Wrongdoing

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We all are familiar with the “horror” stories circling numerous infamous corporate scandals – Wells Fargo, Boeing, General Motors, Airbus, Ericsson, HSBC and on and on.  When you read about each of these scandals, layer by...more

The Volkov Law Group

A Speak Up Culture Depends on Follow Through and Accountability

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Corporate leaders often talk to the talk when it comes to a Speak Up culture.  In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more

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