Claim OwnershipPodcasts Archives - Corruption, Crime & Compliance
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Bribery, FCPA, AML
170 Episodes
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As the dust settles on the U.S. Election, companies are quickly analyzing the implications for the economy, business environment, new enforcement priorities and compliance implications. When new Administrations come into power, change is inevitable. Given the change with President Trump’s return to the White House, and in light of several of his stated intentions, companies should prepare for this new environment. The Trump Administration’s priorities...
The post Episode 346: Forecasting the 2nd Trump Administration Enforcement and Compliance Impact appeared first on Corruption, Crime & Compliance.
The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges. GOL entered into a three-year deferred prosecution agreement (“DPA”) with DOJ in exchange for payment of a $17 million criminal penalty. DOJ credited $1.7 million of that penalty against a $3.4 million fine that GOL agreed...
The post Episode 248 — Deep Dive into the GOL Brazil FCPA Enforcement Action appeared first on Corruption, Crime & Compliance.
Corporate culture is all the rage now, meaning it is an often used topic to signal commitment, sensitivity to issues of employee concern, and an awareness of governance trends. In practice, as we all know, culture is not just about words — it is about action. As the often repeated phrase goes — talk is cheap. In this Corporate Culture Roundup Episode, Michael Volkov examines some culture-related...
The post Episode 247 — Corporate Culture Round Up appeared first on Corruption, Crime & Compliance.
As the leading hotline provider in the global market, NAVEX is in the unique position of collecting and analyzing employee reporting trends. Each year, NAVEX issues an important report on current trends in employee reporting, whistleblowers, internal investigations and potential retaliation. NAVEX’s most recent report is interesting. NAVEX’s database consists of 1.37 million reports made in 2021 at organizations around the world. In this Episode, Michael Volkov...
The post Episode 246 — NAVEX’s Annual Global Hotline Benchmarking Report appeared first on Corruption, Crime & Compliance.
The Second Circuit Court of Appeals affirmed the district judge’s post-conviction dismissal of FCPA counts against Lawrence Hoskins, a former Alston executive, for his involvement in bribery scheme to secure a $118 million energy contract in Indonesia. The Hoskins FCPA case has had a long and tortious path through the court system, and the Second Circuit’s decision, which was decided by a 2 to 1...
The post Episode 245 — Second Circuit Affirms Trial Judge Dismissal of FCPA Verdicts Against Alstom Executive appeared first on Corruption, Crime & Compliance.
Chief compliance officers have access to a vast amount of data generated by their compliance programs. CCOs have to establish effective monitoring processes. A critical part of this process is to build a compliance program dashboard. This is a practical issue of real importance. In this Episode, Michael Volkov reviews this important issue.
The post Episode 244 — Building a Compliance Program Dashboard appeared first on Corruption, Crime & Compliance.
In a bipartisan success story, the House recently passed The Enablers Act, which is a far-reaching reform bill aimed at reducing AML and corrupt financial activity in the United States. Scott Greytak, Advocacy Director at Transparency International USA, and Erica Hanichak, Director of Government Affairs at the FACT Coalition, join Michael Volkov for a discussion of this legislative accomplishment and the implications for the battle...
The post Episode 243 — Scott Greytak, Transparency USA, and Erica Hanichak, the FACT Coalition, on House Passage of The Enablers Act appeared first on Corruption, Crime & Compliance.
LRN has released a new and informative report on Assessing Corporate Culture. LRN’s report provides invaluable guidance and practical steps for corporate boards to lead in the management, oversight and monitoring of corporate culture. A link to the report is below, along with an earlier LRN report on Benchmarking Ethical Culture. In this Episode, Michael Volkov interviews Ty Francis, Chief Advisory Officer at LRN, concerning...
The post Episode 242 — LRN Report on Assessing Corporate Culture — Interview of Ty Francis, LRN Chief Advisory Officer appeared first on Corruption, Crime & Compliance.
The Justice Department and various regulatory agencies continue to emphasize the importance of continuous improvement, testing and review as part of robust assessment procedures in an effective compliance program. The Treasury Department’s Office of Foreign Asset Control has specifically stated that a sanctions compliance program should include “a comprehensive, independent, and objective testing or audit function” so that a company can determine “how their program[]...
The post Episode 241 — Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program appeared first on Corruption, Crime & Compliance.
1I have been — and continue to be– hyper-focused on the proper role and responsibilities for Chief Compliance Officers. Not that I see any cause for alarm, but it is easy to lose focus in the sea of so-called hot issues — ESG, Diversity, Climate Change, Threats to Democracy, Cybersecurity and Data Privacy, each of which is an important component and focus for organizations. All of these...
The post Episode 240 — The CCO’s Role in an Effective Compliance Program appeared first on Corruption, Crime & Compliance.
The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to “empower” CCOs and to ensure that CCOs have a “seat at the [senior management] table.” While these are all laudable goals, CCOs continue to question whether DOJ’s new certification requirement will undermine their authority...
The post Episode 239 — DOJ’s New CCO Certification Requirement appeared first on Corruption, Crime & Compliance.
In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on tea leave patterns in tea sediments). Despite a slow initial year in 2021, the Biden Administration’s stamp and push on FCPA enforcement is becoming clear. Keep in mind, DOJ and SEC officials have...
The post Episode 238: 2022 FCPA Enforcement Trends . . . So Far appeared first on Corruption, Crime & Compliance.
The SEC announced another FCPA settlement in 2022. FCPA enforcement, in general, is picking up. Tenaris, a global supplier of steel pipes and related services for the energy industry agreed to pay the SEC $78 million to resolve FCPA violations that occurred in Brazil. The US Department of Justice closed its investigation without bringing charges. In this Episode, Michael Volkov reviews the SEC settlement.
The post Episode 237 — The Tenaris SEC FCPA Settlement appeared first on Corruption, Crime & Compliance.
In a long-anticipated and major enforcement action, the Justice Department and the Commodities and Futures Trading Commission resolved a sprawling investigation with Glencore International A.G. and Glencore Ltd, a Swiss-based commodity trading and mining company. Glencore entered guilty pleas for FCPA violations and a commodity price manipulation scheme. Glencore paid over $1.1 billion to resolve these two major investigations. The resolution in the U.S. was part of...
The post Episode 236 — The Glencore FCPA and Fraud Settlement appeared first on Corruption, Crime & Compliance.
The global economy has suffered two significant shocks — first, the pandemic sent shockwaves through every organization, and second, the war in Ukraine. Both of these events exposed the importance of risk management, especially with regard to supply chain and distribution operations. Hence, the renewed focus on third-party risk management and the repetitive description of “holistic” third-party risk management. Reality has a way of forcing change and...
The post Episode 235 — Third-Party Risk Management appeared first on Corruption, Crime & Compliance.
The Justice Department ended its FCPA enforcement drought by announcing its first corporate settlement in 2022. In a parallel action, the SEC announced its settlement with Stericycle for $28 million for FCPA violations. The SEC’s settlement was its second with a company for 2022 (the first was KT Corp.). Under the settlement, Stericycle resolved investigations being conducted by the Department of Justice, the Securities and...
The post Episode 234 — A Deep Dive into the Stericycle FCPA Enforcement Action appeared first on Corruption, Crime & Compliance.
Federal prosecutors know that their job – to represent the United States – is the highlight of their legal career. Speaking from experience, federal prosecutors are a privileged lot – they can announce in court they represent the United States. It is a heady experience and an absolute privilege. It is hard not to repeat the Spiderman quote, “With great power comes great responsibility” – but...
The post Episode 233 — Tom Fox and Mike Volkov Discuss DOJ Criminal Trial Wins, Losses and Stumbles appeared first on Corruption, Crime & Compliance.
OFAC recently announced a settlement with S&P Global for $78,750 for violations of the Ukraine-Russia Sanctions Program. The enforcement action provides important reminders relating to compliance with various “debt” maturity restrictions and how OFAC construes this restriction. In this Episode, Michael Volkov reviews OFAC’s enforcement action against S&P Global.
The post Episode 232 — OFAC Settles with S&P Global for $78,750 for Violations of Ukraine-Russia Sanctions appeared first on Corruption, Crime & Compliance.
The SEC is a very busy enforcement agency. While promising more aggressive enforcement of securities rules, the SEC has issued two set of comprehensive rule amendments. The first proposes new rules governing cyber incident reporting, disclosures and governance. In the second major policy action, the SEC issued its long-awaited rules governing climate change and greenhouse gas emissions. in this Episode, Michael Volkov reviews the two...
The post Episode 231 — SEC Update: Climate Change and Cyber Incident Reporting Rules appeared first on Corruption, Crime & Compliance.
The Antitrust Division’s Assistant Attorney General Jonathan Kanter promised a new era in antitrust enforcement. He won bi-partisan support from both Republicans and Democrats. Across the antitrust field, he promised aggressive merger enforcement, civil enforcement against digital markets, and constraint of market power in numerous industries. AAG Kanter promised a new approach and he is delivering. In this Episode, Michael Volkov reviews the Antitrust Division’s...
The post Episode 230 — Catching Up with DOJ’s Antitrust Division Enforcement Efforts appeared first on Corruption, Crime & Compliance.
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