LRN’s Program Effectiveness Report is an important annual event. LRN consistently provides important trend, benchmarking and program measurements. As an important leader in this area, LRN never pulls any punches. This...more
5/6/2025
/ Artificial Intelligence ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Due Diligence ,
Emerging Technologies ,
Employee Training ,
Ethics ,
Generation Z ,
Risk Management ,
Third-Party Risk
As if legal and compliance professionals had enough responsibilities on their plates, DOJ dropped another shoe (to join the tariffs, sanctions and export controls, and immigration issues) and upped the stakes for ethics and...more
4/25/2025
/ Audits ,
Compliance ,
Data Privacy ,
Data Security ,
Deadlines ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement ,
New Regulations ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management
What do you do when the headlines shift faster than your risk matrix can keep up? In this episode, Michael Volkov dives into the challenge of adapting compliance programs in the face of volatile and fast-changing global...more
Legal and compliance officers are used to adjustments and continuous improvement of their compliance programs. Building and maintaining an effective ethics and compliance program never ends — it is a continuous process. To...more
For compliance officers, this is a stressful time. How is that for another profound grasp of the obvious? Most compliance officers face a well-known assortment of risks — bribery, trade, False Claims Act, data privacy,...more
The Trump Administration is focused on change in the government’s role, the administrative state, and the political environment. With these changes, you can expect the Trump Administration to aggressively pursue violators —...more
Chief compliance officers are adjusting a new, risk world, where top risks include export controls, sanctions, and immigration enforcement. At the same time, some risks remain — third-party risks, conflict of interest, fair...more
3/25/2025
/ Chief Compliance Officers ,
Compliance ,
Department of Justice (DOJ) ,
Export Controls ,
Imports ,
International Trade ,
Regulatory Requirements ,
Risk Assessment ,
Risk Management ,
Tariffs ,
Third-Party Risk ,
Trump Administration
When assessing your third-party risks, it is important to start with one important division — a company’s supply chain and on the flip side, a company’s distribution chain. Sourcing materials and supply chain links present a...more
3/19/2025
/ Anti-Corruption ,
Anti-Money Laundering ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Distributors ,
Due Diligence ,
Financial Crimes ,
Human Trafficking ,
Risk Management ,
Supply Chain
How do you manage risk when the vulnerabilities are outside your organization aren’t in your hands?
In this episode of Corruption, Crime, and Compliance, we delve into the world of third-party risk management with our...more
We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs). Companies need to understand the laws used to...more
2/25/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
SDN List ,
Supply Chain
The scope of new import tariffs and regulations portends significant operational risks and disruptions. It is easy to imagine numerous companies that depend on imports for production purposes are facing a new set of...more
2/20/2025
/ Anti-Dumping Duty ,
Canada ,
China ,
Compliance ,
Customs and Border Protection ,
Exports ,
Imports ,
Mexico ,
Regulatory Reform ,
Risk Management ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
We live in a topsy-turvy world. This is an exaggeration but sets up my points in this blog post. We are now seeing the shuffling of corporate risks and every board, C-Suite and legal, compliance and risk management team has...more
2/18/2025
/ Anti-Corruption ,
Antitrust Division ,
Competition ,
Compliance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Foreign Corrupt Practices Act (FCPA) ,
Human Resources Professionals ,
Immigration Enforcement ,
International Trade ,
Risk Assessment ,
Risk Management ,
Trump Administration
The 1990s saw the explosion of the internet, transforming the global economy and social development in ways we could have never imagined. But will AI truly have the same impact?
While its potential is undeniable, the road...more
When evaluating AI risks, legal, ethics and compliance professionals need to divide the question into two — first, what are risks from legal, ethics and compliance internal use of AI? and second, what are business risks from...more
1/31/2025
/ Artificial Intelligence ,
Compliance ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Ethics ,
Intellectual Property Protection ,
Policies and Procedures ,
Risk Management ,
Risk Mitigation
Not to sound like a broken record — but we are consistently asking the compliance community the same question. As far back as March 2013, on this very blog, I wrote a posting — The Future of Compliance — What Will the New...more
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more
1/24/2025
/ Civil Monetary Penalty ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Sanction Violations ,
US Trade Policies ,
Voluntary Disclosure
C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more
1/14/2025
/ Acquisition Agreements ,
Civil Monetary Penalty ,
Compliance ,
Corporate Governance ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Ports ,
Regulatory Requirements ,
Risk Management ,
Sanction Violations ,
Settlement ,
Shipping
Have you ever wondered how different cultures and generations engage with a company's code of conduct? Do employees across the globe really follow ethical guidelines in the same way, or are there stark contrasts depending on...more
We continue to hear about the impact of apparent or real conflicts of interest — whether in government, in business, or in other organizations. It is an issue of significant importance. Within an organization, a perceived...more
You often hear chief compliance officers speak about benchmarking. CCOs often reveal their competitive streaks when they collect information about other companies’ compliance programs. It can easily come off as a little...more
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
The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more
10/4/2024
/ Anti-Corruption ,
Artificial Intelligence ,
Compliance ,
Compliance Management Systems ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enterprise Risks ,
Innovative Technology ,
Machine Learning ,
Risk Management ,
White Collar Crimes
Diligent conducted numerous board education sessions at which board members spoke about new and significant risks; these included increased stakeholder expectations and the burdensome review of education and documentation...more
The issue was a professional debate over the reporting relationship between the chief compliance officer (CCO) and the chief legal officer (CLO)/general counsel. After 20 years of debate, CCOs managed to sway the professional...more
Compliance lessons are life lessons. Compliance professionals are, by their nature, optimistic people. They see challenges as new opportunities to strive closer to an ideal. Compliance professionals live in the shadow of...more