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Anti-Corruption Due Diligence White Collar Crimes

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

A&O Shearman

Top challenges for white collar crime and investigations lawyers in 2024

A&O Shearman on

We asked our global white collar crime team for their views on the key challenges in 2024 for in‑house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here is what they said. ...more

The Volkov Law Group

OFAC Screening and Internal Controls

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Companies have had over one year to review and implement a sanctions compliance guidance program.  This last year, however, has been difficult (to say the least) given the COVID-19 pandemic....more

Morgan Lewis

UK Serious Fraud Office Emphasizes Importance of Compliance Programs

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In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...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

New Year, New Compliance Game Plan

With a new year, many folks have been promoted to the CCO chair. What should be your plan starting the new year and a new job. The answer is found in the  eBook Compliance Program Game Plan by myself and Jonathan Marks. ...more

Thomas Fox - Compliance Evangelist

What is the Intersection of Star Wars and Compliance? Find Out This Week

On Monday, December 16, we begin with Episode IV-A New Hope and management of risk. We use Grand Moff Tarkin’s incorrect assessment that the risk presented by the Rebellion’s final attack on the Death Star was non-lethal. I...more

Ballard Spahr LLP

FinCEN Issues Advisory on Foreign Jurisdictions with AML Deficiencies

Ballard Spahr LLP on

On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more

Jones Day

Anti-Corruption Regulation Survey of 42 Countries 2019

Jones Day on

Welcome to the 2019 edition of the Jones Day Anti-Corruption Regulation Survey of Select Countries. Since the 2017–2018 edition of this Survey, there has continued to be an increasing awareness among multinational companies...more

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 2 – Risk Assessment

I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more

Thomas Fox - Compliance Evangelist

Just Who Are You Doing Business With In China?

How important is due diligence on those with whom you are doing business? Why does it matter if a company is owned or controlled by a foreign government or a political party member of a foreign government? ...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

The Volkov Law Group

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

The Volkov Law Group on

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

Orrick, Herrington & Sutcliffe LLP

DOJ Encourages Self-Disclosure Of FCPA Violations Discovered Through M&A Activity

Deputy Assistant Attorney General Matthew Miner, head of the DOJ’s Fraud Section, recently discussed the DOJ’s efforts to address corruption discovered during mergers and acquisitions....more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

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

Jones Day

Corporate Anticorruption Compliance Programs: Ten Questions Every Board Director Should Ask

Jones Day on

The United States Department of Justice, the U.S. Securities and Exchange Commission, and non-U.S. governments and agencies have recently emphasized their continued commitments to pursuing both corporate and individual...more

The Volkov Law Group

ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V)

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In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more

K2 Integrity

The DOJ Expects “Third-Party Management” from Compliance Programs

K2 Integrity on

2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more

The Volkov Law Group

Trends from 2016 Record FCPA Enforcement Year (Part II of III)

The Volkov Law Group on

No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands....more

Orrick, Herrington & Sutcliffe LLP

New French Anticorruption Legislation Affecting Large French and Foreign Groups of Companies and Their Top Management

On December 9th, 2016, France officially enacted the Law on transparency, anti-corruption and economic modernization (so-called "Sapin II bill") which introduces the following key changes...more

The Volkov Law Group

Building a Due Diligence Infrastructure (Part IV of IV)

The Volkov Law Group on

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

The Volkov Law Group

More Than Due Diligence: Never-Ending Due Diligence

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Due diligence of third parties can drive you crazy. You know you are in trouble when you start babbling to yourself and others about red flags, more red flags, and even more red flags....more

Thomas Fox - Compliance Evangelist

Getting Your Company Ready For M&A Compliance Due Diligence

Who was the absolute worst general during the Civil War? While there are many worthy candidates for this dubious honor, on the Southern side my vote goes to General John Bell Hood. ...more

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