Warning: Banks Need to Re-Examine KYC Risk Evaluation Procedures

A federal jury in New York recently handed down a verdict against the Arab Bank, Jordan’s largest bank,… [continue]

Warning:  Banks Need to Re-Examine KYC Risk Evaluation Procedures Warning:  Banks Need to Re-Examine KYC Risk Evaluation Procedures

GSK China: Did Case Finish with a Bang or a Whimper?

In typical Chinese fashion, the prosecution of GSK and several GSK executives ended after a one-day “trial.”… [continue]

GSK China:  Did Case Finish with a Bang or a Whimper? GSK China:  Did Case Finish with a Bang or a Whimper?

More Empty Words for an FCPA Compliance Defense

The difference between the almost right word & the right word is really a large matter--it's the… [continue]

More Empty Words for an FCPA Compliance Defense More Empty Words for an FCPA Compliance Defense

Upcoming Webinars: Due Diligence and Internal Investigations

The Volkov Law Group has two upcoming webinars in October 2014.  The details and sign up links are set… [continue]

Upcoming Webinars:  Due Diligence and Internal Investigations Upcoming Webinars:  Due Diligence and Internal Investigations

New RAND Publication: Transforming Compliance: Emerging Paradigms for Boards, Management, Compliance Officers, and Government

I was honored to participate in a RAND roundtable meeting on May 28, 2014, Transforming Compliance: Emerging… [continue]

New RAND Publication: Transforming Compliance: Emerging Paradigms for Boards, Management, Compliance Officers, and Government New RAND Publication: Transforming Compliance: Emerging Paradigms for Boards, Management, Compliance Officers, and Government
Latest Posts

Warning: Banks Need to Re-Examine KYC Risk Evaluation Procedures

kyc2

A federal jury in New York recently handed down a verdict against the Arab Bank, Jordan’s largest bank, for funding Hamas terrorism acts against Israel. The verdict is precedent setting and will encourage other plaintiffs to challenge bank conduct that enables terrorism. The plaintiffs put on evidence that the Arab … Continue Reading…

GSK China: Did Case Finish with a Bang or a Whimper?

china3

In typical Chinese fashion, the prosecution of GSK and several GSK executives ended after a one-day “trial.” GSK paid a $489 million fine; and four criminal sentences were handed out with suspension of jail time and orders of deportation. GSK also issued an apology. The question is whether the GSK … Continue Reading…

More Empty Words for an FCPA Compliance Defense

emptywords

The difference between the almost right word & the right word is really a large matter–it’s the difference between the lightning bug and the lightning — Mark Twain (1888). It is hard to understand why there are still advocates for an FCPA compliance defense. The issue is dead and gone, … Continue Reading…

Upcoming Webinars: Due Diligence and Internal Investigations

webinar

The Volkov Law Group has two upcoming webinars in October 2014.  The details and sign up links are set forth below. Webinar recordings are maintained on Michael Volkov’s You Tube Channel Here Webinar: Thursday, October 9, 2014, 12 Noon EST Taking Third Party Due Diligence to the Next Level  Sign … Continue Reading…

New RAND Publication: Transforming Compliance: Emerging Paradigms for Boards, Management, Compliance Officers, and Government

rand

I was honored to participate in a RAND roundtable meeting on May 28, 2014, Transforming Compliance: Emerging Paradigms for Boards, Management, Compliance Officers, and Government. The meeting included three white paper submissions, one of which I authored on the changing relationship between chief compliance officers and general counsels.  The report … Continue Reading…

Accountability: Where is the Board of Directors?

board accountability

Compliance professionals like to emphasize that accountability is essential to create an ethical culture. There is no question that if a company does not hold anyone accountable for ethics and compliance issues a company is unlikely to foster a meaningful culture. To put it another way, if senior management is … Continue Reading…

Important Employee Values: Integrity and Trust

integrity3

I have urged compliance professionals to avoid scare-tactics as a way to enhance their importance in the corporate organization. It is too easy to run around and spread fear about the importance of compliance to prevent a government investigation and prosecution. That message is too negative and turns off listeners. … Continue Reading…

Governance, Compliance and Simplicity

simplicity

I have always admired the ability of intelligent people to explain complex ideas in simple terms. Prosecutors have to explain complex facts and crimes to a jury. If you ever watch TED talks online, you can see a variety of speakers who have mastered difficult concepts and explain them in … Continue Reading…

International Coordination and Cooperation in Corruption Cases

global3

Global anti-corruption enforcement is fast becoming a complicated affair. No longer can companies just focus on the FCPA, with momentary blips of concern for the UK Bribery Act. The OECD and other international organizations want to see aggressive enforcement around the globe, and they are doing a great job of … Continue Reading…

More Than Due Diligence: Never-Ending Due Diligence

neverending2

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. You can start thinking that the movie, “The Shining” was a documentary depicting your third-party due … Continue Reading…