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Volkswagen Compliance Foreign Corrupt Practices Act (FCPA)

The Volkov Law Group

Criminal Enforcement Against Senior Executives: The Fish Rots from the Head

The Volkov Law Group on

The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more

The Volkov Law Group

“Too Important to Jail,” the Yates Memorandum and FCPA Criminal Prosecutions

The Volkov Law Group on

The Justice Department’s continuing lack of individual criminal prosecutions in the FCPA arena continues to raise serious questions. DOJ’s issuance of the Yates memorandum was seen as a new and important reiteration of DOJ’s...more

The Volkov Law Group

The FCPA Enforcement Run Continues into 2017

The Volkov Law Group on

Just when we thought 2016 was over and we could all breathe a sigh of relief, DOJ and the SEC have continued to run with a string of new enforcement actions. To all of those prognosticators, paparazzi, commentators, chicken...more

The Volkov Law Group

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

The Volkov Law Group on

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

Burr & Forman

VW's $4.3BN Plea to Obstruction for Botched Litigation Hold

Burr & Forman on

One of three counts in Volkswagen’s recent $4.3 billion guilty-plea was for obstruction of justice arising from a litigation-hold botched by house counsel. As VW prepared to admit the defeat-device problems to US...more

The Volkov Law Group

Volkswagen: When Car Companies Veer Off Course (Part I of III)

The Volkov Law Group on

Corporate misconduct occurs in a variety of forms. Starting with the basic truism – companies act through people, and when companies engage in misconduct it requires the coordination and collaboration of multiple actors. The...more

Thomas Fox - Compliance Evangelist

Honey, I Think We Should Vacation at Home This Year

That may well be the line most used by Volkswagen (VW) executives after the arrest of their fellow executive, Oliver Schmidt, this past week at the Miami airport. According to an article in the New York Times (NYT), entitled...more

The Volkov Law Group

For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives

The Volkov Law Group on

Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more

Thomas Fox - Compliance Evangelist

New Yorker Cartoon Caption Contest, Origins of Corporate Culture and Compliance

I hope everyone had a great 4th of July. One of the small pleasures I take each week is reading the New Yorker’s Cartoon Caption contest. I have entered most weeks for the past 10 years or so when the spirit moved me with a...more

Thomas Fox - Compliance Evangelist

Shakespeare Week – Part V: Lear’s Fool and Power Points

I conclude my week honoring the 400th anniversary of the death of Shakespeare by using my favorite character in all his work to introduce today’s post. He is The Fool from King Lear. Of Shakespeare’s many theatrical...more

Thomas Fox - Compliance Evangelist

Prog Rock Week – Part V: Pink Floyd and VW’s Trip the Dark Side of the Moon

There is no dark side of the moon really. Matter of fact it’s all dark.” If you went to college in the 70s or 80s (or maybe even the 90s) you know what the next album is, Pink Floyd’s Dark Side of the Moon. For in the...more

Thomas Fox - Compliance Evangelist

The VW Scandal: Crisis and the CCO

One of the areas where my thinking has evolved in the compliance arena is around the area of reputational damage. Of course commentators, such as Andrea Bonime-Blanc, have written and spoken about preventing damage to a...more

Thomas Fox - Compliance Evangelist

Star Wars Week Part V – Mistakes of the Galactic Empire (and VW)

Today, we conclude our week long exploration of the original Star Wars trilogy, all posted in conjunction with three podcasts, subtitled May The Podcast Be With You, where we use one movie as a staring point to review Foreign...more

Thomas Fox - Compliance Evangelist

Whom Should You Suspend During an Internal Investigation?

Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more

Thomas Fox - Compliance Evangelist

Compliance Connected – Line of Sight, Part I

Sometimes the simplest visual can provide the greatest insight about transformation. I had that particular insight when I recently had the chance to catch up with Scott Lane, Chief Executive of the Red Flag Group, at the SCCE...more

Thomas Fox - Compliance Evangelist

Compliance at the Tipping Point, Part V – Protection Afforded From a Compliance Program

Today, I wrap up my series on why I think compliance is at the Tipping Point. However as it is a Friday in October, I continue my tribute to the Man in the Shadows, producer Val Lewton, whose films for RKO had some of the...more

Thomas Fox - Compliance Evangelist

Compliance at the Tipping Point, Part III – The VW Emissions-Testing Scandal

I continue my series on why I believe that compliance is at the ‘Tipping Point’ with a discussion of the Volkswagen (VW) emissions-testing scandal and its effect on the greater compliance world. Myself and many other...more

Thomas Fox - Compliance Evangelist

The Psychology of Cheating and FCPA Compliance

In the movie Margin Call, Jeremy Irons intones that there are three ways to win in business: (1) be the smartest; (2) be the fastest; and (3) cheat. I am currently out at the SCCE 2015 Compliance and Ethics Institute and as...more

Thomas Fox - Compliance Evangelist

VW Emissions Testing Scandal – View from the Board

The Board of Directors role in the Volkswagen (VW) emissions test scandal is one that is only now being scrutinized. In an article in the New York Times (NYT), entitled “Problems at VW Start at the Boardroom”, James B....more

The Volkov Law Group

The VW Scandal: Insular Senior Management and Ethical Breakdowns

The Volkov Law Group on

The Volkswagen scandal will be studied for years. One of many themes from the Volkswagen scandal will rest on the complete absence of any commitment to corporate governance. Volkswagen’s weird corporate structure (it is owned...more

Thomas Fox - Compliance Evangelist

The Defeat Device: Compliance and Ethics in the Auto Industry

Things are seriously bad when one of the world’s most respected business focused publications, the Financial Times (FT), asks if the auto “industry faces ‘Libor moment’”? Yet that was a headline yesterday in the lead article...more

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