The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Episode 335 -- The New DOJ Whistleblower Program
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
INTERPOL Red Notices and Immigration. Can You Obtain Immigration Relief in the U.S. Even with a Red Notice?
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
The Presumption of Innocence Podcast: Episode 43 - New Horizons: Impact of Recent Appellate Circuit Rulings on White-Collar Criminal Defense Law
INTERPOL and Politically Motivated Red Notices - What We Can Learn from INTERPOL’s Annual Reports.
Episode 333 -- The Boeing Proposed Plea Agreement
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
What to do when finding that you are the subject of a RedNotice?
Episode 324 -- Third-Party Risks and Sanctions Compliance
The Justice Insiders Podcast: DOJ’s Cacophony of Whistles
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
AGG Talks: Antitrust and White-Collar Crime Roundup Podcast - Episode 9: Exploring the DA’s Proof, Michael Cohen’s Cross-Examination, and Jury Scenarios in Trump’s Election Interference Trial
How long will it take to get a response to my Red Notice request?
Supreme Court to Settle Circuit Split Regarding RICO Damages Arising From Personal Injuries — RICO Report Podcast
Episode 321 -- Review of the EU Whistleblowing Directive wih Alex Cotoia and Daniela Melendez
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
Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks? Well,...more
Over the past 12 months or so there have been a series of Foreign Corrupt Practices Act (FCPA) enforcement actions where the respondents have changed and/or modified their sales models to get away from external third parties...more
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
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
Hosted by American Conference Institute, the 11th Annual Advanced Forum on False Claims and Qui Tam Enforcement returns for another exciting year for lively discussions on FCA enforcement including the ramifications of two...more
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
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
Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...more
Compliance professionals are always looking for ways to collaborate and support internal business partners. Through the years, compliance professionals have devoted significant energy to building partnerships with the...more
Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more
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
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
We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses. Almost every FCPA enforcement action includes some form of third-party misconduct. The current...more
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 SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more
We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues. It does not take a rocket scientist to...more
FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more
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
We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe. Let me give you a few examples....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
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
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
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
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