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White Collar Crimes Risk Assessment Ethics

Thomas Fox - Compliance Evangelist

Adventures in Compliance: The Novels – The Hound of the Baskervilles, Introduction and Compliance Lessons Learned

In this new season of Adventures in Compliance, host Tom Fox takes a deep dive into the Sherlock Holmes novels. Throughout this season, Tom will delve into each novel in a four-part series. The four novels we will consider...more

StoneTurn

Meeting DOJ and SEC Post-Settlement Obligations: A Practical Guide

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No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more

Thomas Fox - Compliance Evangelist

PCAOB Proposed Rule on Compliance Audits

In the realm of auditors intersecting compliance and fraud risk audits, a fierce battle of perspectives rages on. Compliance professionals yearn for a bigger role, a seat at the table to tackle potential compliance...more

The Volkov Law Group

A Five Step Program for Every Company to Address the New Enforcement Threats

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Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized...more

The Volkov Law Group

Ethics and Compliance Trends and Predictions

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I always enjoy pulling out the crystal ball and looking forward with due consideration of last year’s trends.  It is a perspective that gives us all the opportunity  to identify important trends and to set an agenda for the...more

StoneTurn

5 Tips For Meeting DOJ’s New CCO Certification Requirements

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The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more

The Volkov Law Group

Tracking Ethics and Compliance Program Performance (Part II of II)

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Chief compliance officers rely on several important sources for feedback — internal data and communications (reviews with board, senior managers, employees); and benchmarking against comparable organizations.  An internal...more

Seyfarth Shaw LLP

Department of Justice Issues Updated Guidance on Evaluation of Corporate Compliance Programs

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On June 1, 2020, the Criminal Division of the US Department of Justice (“DOJ”) released  an updated guidance document for white-collar prosecutors on the evaluation of corporate compliance programs....more

The Volkov Law Group

Conducting a Sanctions Risk Assessment: A New Era for Analyzing Your Risks (Part II of IV)

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OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement.  This new approach reflects OFAC’s recent aggressive enforcement programs....more

The Volkov Law Group

2019 Ethics and Compliance Predictions

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This is my favorite topic. New trends come and go in the compliance field, while effective solutions and strategies slowly but surely take hold. Eventually, an effective compliance practice or strategy becomes a “best...more

The Volkov Law Group

The Importance of Pre-Acquisition FCPA Due Diligence (Part II of III)

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Several years ago (or in the recent past as some would say), pre-acquisition due diligence was a major compliance focus for global companies that grew through aggressive merger and acquisition strategies. ...more

The Volkov Law Group

The Vital Role of Internal Audit to Compliance

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A chief compliance officer can only succeed with the support of other important compliance partners. Another way to put it – in the words of Blanche Dubois from A Streetcar Named Desire, “I have always depended on the...more

Mitratech Holdings, Inc

Industry Expert Hui Chen on Ethics & Compliance

As the first-ever Compliance Counsel Expert at the United States Department of Justice (DOJ), Hui Chen served as exclusive consultant to the Fraud Section’s white-collar crime federal prosecutors. She reviewed corporate...more

The Volkov Law Group

FCPA Compliance: The Importance of Relativity to Risk Ranking (Part I of V)

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This week I am posting a five-part series on FCPA compliance issues. While there have been many advances in the anti-corruption ethics and compliance field, there is still more work to do to advance effective strategies for...more

Thomas Fox - Compliance Evangelist

Sgt. Pepper’s and Andi Simon on Changing a Corporate Culture

What your culture is today? You should consider what you value in terms of six key areas: dominant characteristics; organizational leadership; management of employees; the glue that holds the organization together; strategic...more

The Volkov Law Group

Time to Test and Audit Your Compliance Program

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We all enjoy citing government sources for guidance on an effective ethics and compliance program. Whether it is the United States Sentencing Guidelines, the Justice Department’s and SEC’s FCPA Guidance, Health and Human...more

The Volkov Law Group

Five Major Compliance Predictions for 2018

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When you look back on the rise of the ethics and compliance profession, you cannot ignore the history of accomplishments. It is easy to minimize these accomplishments as a reaction to the government’s aggressive FCPA...more

Thomas Fox - Compliance Evangelist

SCCE Wrap Up – Final Reflections on CEI 2017

The 2017 SCCE Compliance and Ethics Institute (CEI) is now in the books. Once again, the organization had record setting attendance with over 1,800 attendees from some 41 different countries. During the event, I had the...more

The Volkov Law Group

Is Your Company At-Risk for a Government Enforcement Action?

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For some reason, I have always believed that picking successful stocks should not be very difficult. Unfortunately, my record in the stock market does not back up my self-assessment. On the other hand, when it comes to...more

Thomas Fox - Compliance Evangelist

LRN Compliance Program Effectiveness Report: Part III

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

The Volkov Law Group

Lessons Learned and Compliance Trends from the VW and Takata Scandals (Part III of III)

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When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more

Thomas Fox - Compliance Evangelist

Spikes in Sales and Compliance

What is risk and how should it be evaluated? What is the data that should be reviewed to determine if an increase in sales is based on unethical or even illegal behavior? Finally, what happens when you migrate company...more

The Volkov Law Group

Misconduct in the C-Suite: The United Airlines Scandal

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It was like a bolt out of the blue – United Airlines’ CEO and two senior executives hastily announced their resignation as a result of their involvement in a bribery scandal with the New York Port Authority....more

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