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Risk Assessment Compliance White Collar Crimes

Thomas Fox - Compliance Evangelist

Risk Assessment Lessons from Star Trek: Balance of Terror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

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

J.S. Held

INDEPTH FEATURE: Anti-Money Laundering 2024

J.S. Held on

Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more

Thomas Fox - Compliance Evangelist

Risk Assessments

One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on a risk assessment, on an understanding of your...more

K&L Gates LLP

Why Corporates Are Now More Likely to Face Criminal Prosecution for the Actions of Their Employees

K&L Gates LLP on

Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more

Farella Braun + Martel LLP

What Nonprofit Board Leadership Needs To Know About Internal Investigations

Welcome to EO Radio Show – Your Nonprofit Legal Resource. I'm Cynthia Rowland, and today, we'll cover an important governance topic for all nonprofit organizations. That is, what leadership needs to know about internal...more

The Volkov Law Group

Do We Really Need an ISO Standard for Internal Investigations?

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Call me a skeptic. Call me cynical. I understand that the International Organization for Standardization (ISO) provides valuable standardization services and guidance.  The ISO is comprised of 169 member countries....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

Five Practical Steps to Elevate Your Sanctions Compliance Program (Part III of III)

The Volkov Law Group on

Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program.  Instead, a number of companies have stitched together a basic sanctions...more

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

The Volkov Law Group on

Let’s move beyond the headline – trade compliance is the new FCPA.  We get it.  The next step is to do something about it.  The Justice Department has repeated this refrain – it is one of its greatest hits.  In addition, DOJ,...more

The Volkov Law Group

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

The Volkov Law Group on

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

WilmerHale

DOJ Announces Significant Guidance on Compliance, Compensation, Communications and Cooperation

WilmerHale on

On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more

The Volkov Law Group

Ethics and Compliance Trends and Predictions

The Volkov Law Group on

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

StoneTurn on

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

NAVEX

The Compliance Program’s Role in Anti-Fraud Efforts

NAVEX on

Corporate compliance professionals can learn a lot from the audit world. Our latest lesson comes in a statement from the Securities and Exchange Commission, warning auditors to do better at identifying the risk of fraud among...more

The Volkov Law Group

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

The Volkov Law Group on

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

Guidepost Solutions LLC

The Looming Bear Market is Likely to Bring More Prosecutions

When the tide goes out, as it appears to be doing now with the market down 20% percent from its highs in January, bad actors will be left exposed for everyone to see. Simply put, as the market drops those companies hiding...more

The Volkov Law Group

CCOs and Criminal Cartel Compliance Programs (Part II of III)

The Volkov Law Group on

Chief compliance officers have plenty of things to do and risks to manage.  CCOs have a unique remit and a set of skills that should be applied whenever needed.  While I am not trying to increase CCO workload (and forgive me...more

Skadden, Arps, Slate, Meagher & Flom LLP

Practical Steps To Address DOJ Changes to Corporate Enforcement Policies

In one of the first substantive speeches on corporate criminal enforcement under the Biden administration, Deputy Attorney General Lisa Monaco announced on October 28, 2021, several immediate changes to Department of Justice...more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Guidance on Evaluating Corporate Compliance Programs

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

Jones Day

DOJ Updates Its "Evaluation of Corporate Compliance Programs" Guidance

Jones Day on

The Situation: The Department of Justice ("DOJ") has updated its "Evaluation of Corporate Compliance Programs" guidance for prosecutors. The Result: The updates provide additional insights into the factors the DOJ is...more

Thomas Fox - Compliance Evangelist

The Digital Twin and P&L of One

Innovation in compliance can come in many forms. One such form was described by Vincent M. Walden, Managing Director at Alvarez and Marsal Holdings, LLC (A&M), in his article entitled “Profit & Loss-of-One”(P&L-of-One). In...more

Mitratech Holdings, Inc

5 Essential Elements of Corporate Compliance

Most experts agree that whichever regulatory jurisdiction an organisation is subject to, there are five common fundamentals involved in providing effective corporate compliance....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

Bridging the Gap in Compliance: Tribute to Irv Noren

From the HR and compliance perspective, there are four steps to undertaking a gap analysis: 1) understanding the compliance and HR environment in your organization; 2) taking a holistic approach to understanding the...more

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