Corruption, Crime & Compliance https://blog.volkovlaw.com/ en-US Bribery, FCPA, AML https://megaphone.imgix.net/podcasts/83ef2b9e-3f70-11e9-a3df-73be43afb6b2/image/cd39f8bbdc25be622fc44763d131d796.jpg?ixlib=rails-4.3.1&max-w=3000&max-h=3000&fit=crop&auto=format,compress Corruption, Crime & Compliance https://blog.volkovlaw.com/ no episodic Bribery, FCPA, AML Corruption, Crime & Compliance Bribery, FCPA, AML Corruption, Crime & Compliance Episode 248 — Deep Dive into the GOL Brazil FCPA Enforcement Action https://blog.volkovlaw.com/2022/09/episode-248-deep-dive-into-the-gol-brazil-fcpa-enforcement-action/ 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 to pay law enforcement authorities in Brazil to resolve charges in Brazil. In a separate resolution, GOL agreed to pay $24.5 million over two years to the SEC. The SEC’s initial settlement calculation was for $70 million, but it was reduced to $24.5 million based on GOL’s financial condition. In this Episode, Michael Volkov reviews the DOJ and SEC FCPA settlement actions. The post Episode 248 — Deep Dive into the GOL Brazil FCPA Enforcement Action appeared first on Corruption, Crime & Compliance. Sun, 25 Sep 2022 15:02:45 -0000 full 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 prosecu... 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 to pay law enforcement authorities in Brazil to resolve charges in Brazil. In a separate resolution, GOL agreed to pay $24.5 million over two years to the SEC. The SEC’s initial settlement calculation was for $70 million, but it was reduced to $24.5 million based on GOL’s financial condition. In this Episode, Michael Volkov reviews the DOJ and SEC FCPA settlement actions. The post Episode 248 — Deep Dive into the GOL Brazil FCPA Enforcement Action 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 to pay law enforcement authorities in Brazil to resolve charges in Brazil.

In a separate resolution, GOL agreed to pay $24.5 million over two years to the SEC. The SEC’s initial settlement calculation was for $70 million, but it was reduced to $24.5 million based on GOL’s financial condition.

In this Episode, Michael Volkov reviews the DOJ and SEC FCPA settlement actions.

The post Episode 248 — Deep Dive into the GOL Brazil FCPA Enforcement Action appeared first on Corruption, Crime & Compliance.

]]> 1153 no Episode 247 — Corporate Culture Round Up https://blog.volkovlaw.com/2022/09/episode-247-corporate-culture-round-up/ 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 issues involving: Culture + Action Steps; Civility in the Workplace and What Happens when HR and Compliance are Disconnected. The post Episode 247 — Corporate Culture Round Up appeared first on Corruption, Crime & Compliance. Sun, 18 Sep 2022 14:47:11 -0000 full 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 ... 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 issues involving: Culture + Action Steps; Civility in the Workplace and What Happens when HR and Compliance are Disconnected. The post Episode 247 — Corporate Culture Round Up 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 issues involving: Culture + Action Steps; Civility in the Workplace and What Happens when HR and Compliance are Disconnected.

The post Episode 247 — Corporate Culture Round Up appeared first on Corruption, Crime & Compliance.

]]> 1093 no Episode 246 — NAVEX’s Annual Global Hotline Benchmarking Report https://blog.volkovlaw.com/2022/09/episode-246-navexs-annual-global-hotline-benchmarking-report/ 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 reviews the key findings from the 2022 report. HERE is a link to the Report to download The post Episode 246 — NAVEX’s Annual Global Hotline Benchmarking Report appeared first on Corruption, Crime & Compliance. Sun, 11 Sep 2022 12:14:49 -0000 full 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, 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 reviews the key findings from the 2022 report. HERE is a link to the Report to download The post Episode 246 — NAVEX’s Annual Global Hotline Benchmarking Report 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 reviews the key findings from the 2022 report.

HERE is a link to the Report to download

The post Episode 246 — NAVEX’s Annual Global Hotline Benchmarking Report appeared first on Corruption, Crime & Compliance.

]]> 1028 no Episode 245 — Second Circuit Affirms Trial Judge Dismissal of FCPA Verdicts Against Alstom Executive https://blog.volkovlaw.com/2022/08/episode-245-second-circuit-affirms-trial-judge-dismissal-of-fcpa-verdicts-against-alstom-executive/ 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 majority, ended with a fractured court decision that raised more questions than provided answers. The majority decision appeared to reflect a pre-ordained decision searching for legal and factual arguments to support the resolution. Indeed, the dissent presented a cogent and more defensible position. In this Episode, Michael Volkov reviews the Second Circuit’s decision. The post Episode 245 — Second Circuit Affirms Trial Judge Dismissal of FCPA Verdicts Against Alstom Executive appeared first on Corruption, Crime & Compliance. Sun, 28 Aug 2022 07:47:00 -0000 full 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 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 majority, ended with a fractured court decision that raised more questions than provided answers. The majority decision appeared to reflect a pre-ordained decision searching for legal and factual arguments to support the resolution. Indeed, the dissent presented a cogent and more defensible position. In this Episode, Michael Volkov reviews the Second Circuit’s decision. The post Episode 245 — Second Circuit Affirms Trial Judge Dismissal of FCPA Verdicts Against Alstom Executive 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 majority, ended with a fractured court decision that raised more questions than provided answers. The majority decision appeared to reflect a pre-ordained decision searching for legal and factual arguments to support the resolution. Indeed, the dissent presented a cogent and more defensible position.

In this Episode, Michael Volkov reviews the Second Circuit’s decision.

The post Episode 245 — Second Circuit Affirms Trial Judge Dismissal of FCPA Verdicts Against Alstom Executive appeared first on Corruption, Crime & Compliance.

]]> 1202 no Episode 244 — Building a Compliance Program Dashboard https://blog.volkovlaw.com/2022/08/episode-244-building-a-compliance-program-dashboard/ 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. Sun, 21 Aug 2022 08:02:16 -0000 full 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. 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. 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.

]]> 1782 no Episode 243 — Scott Greytak, Transparency USA, and Erica Hanichak, the FACT Coalition, on House Passage of The Enablers Act https://blog.volkovlaw.com/2022/08/episode-243-scott-greytak-transparency-usa-and-erica-hanichak-the-fact-coalition-on-house-passage-of-the-enablers-act/ 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 against corruption. 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. Sun, 14 Aug 2022 08:04:42 -0000 full 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... 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 against corruption. 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. 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 against corruption.

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.

]]> 2205 no Episode 242 — LRN Report on Assessing Corporate Culture — Interview of Ty Francis, LRN Chief Advisory Officer https://blog.volkovlaw.com/2022/08/episode-242-lrn-report-on-assessing-corporate-culture-interview-of-ty-francis-lrn-chief-advisory-officer/ 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 LRN’s recent report on Assessing Corporate Culture. LRN Report Assessing Corporate Culture — Available Here LRN Report on Benchmarking Ethical Culture — Available Here The post Episode 242 — LRN Report on Assessing Corporate Culture — Interview of Ty Francis, LRN Chief Advisory Officer appeared first on Corruption, Crime & Compliance. Sun, 07 Aug 2022 07:54:06 -0000 full 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. 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 LRN’s recent report on Assessing Corporate Culture. LRN Report Assessing Corporate Culture — Available Here LRN Report on Benchmarking Ethical Culture — Available Here The post Episode 242 — LRN Report on Assessing Corporate Culture — Interview of Ty Francis, LRN Chief Advisory Officer 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 LRN’s recent report on Assessing Corporate Culture.

LRN Report Assessing Corporate Culture — Available Here

LRN Report on Benchmarking Ethical Culture — Available Here

The post Episode 242 — LRN Report on Assessing Corporate Culture — Interview of Ty Francis, LRN Chief Advisory Officer appeared first on Corruption, Crime & Compliance.

]]> 2481 no Episode 241 — Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program https://blog.volkovlaw.com/2022/07/episode-241-continuous-improvement-testing-and-auditing-of-your-ethics-and-compliance-program/ 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[] [is] performing and should be updated, enhanced, or recalibrated to account for a changing risk assessment or sanctions environment.”  The Health and Human Services — Office of Inspector General has made similar statements underscoring the need to conduct compliance audits and testing. An important part of every compliance program focuses beyond the design and operation of the program to the important issue of whether the program itself is working.  In this respect, DOJ and regulatory agencies have noted that CCOs should be striving to develop “continuous” monitoring systems and avoid “snapshots” in time.  In order to execute such monitoring, compliance has to maintain broad access to operational data across all key functions in a company.  This data has to be used to update regularly risk assessments, compliance policies and procedures and financial controls. The post Episode 241 — Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program appeared first on Corruption, Crime & Compliance. Sun, 31 Jul 2022 14:09:35 -0000 full 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 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[] [is] performing and should be updated, enhanced, or recalibrated to account for a changing risk assessment or sanctions environment.”  The Health and Human Services — Office of Inspector General has made similar statements underscoring the need to conduct compliance audits and testing. An important part of every compliance program focuses beyond the design and operation of the program to the important issue of whether the program itself is working.  In this respect, DOJ and regulatory agencies have noted that CCOs should be striving to develop “continuous” monitoring systems and avoid “snapshots” in time.  In order to execute such monitoring, compliance has to maintain broad access to operational data across all key functions in a company.  This data has to be used to update regularly risk assessments, compliance policies and procedures and financial controls. The post Episode 241 — Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program 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[] [is] performing and should be updated, enhanced, or recalibrated to account for a changing risk assessment or sanctions environment.”  The Health and Human Services — Office of Inspector General has made similar statements underscoring the need to conduct compliance audits and testing.

An important part of every compliance program focuses beyond the design and operation of the program to the important issue of whether the program itself is working.  In this respect, DOJ and regulatory agencies have noted that CCOs should be striving to develop “continuous” monitoring systems and avoid “snapshots” in time.  In order to execute such monitoring, compliance has to maintain broad access to operational data across all key functions in a company.  This data has to be used to update regularly risk assessments, compliance policies and procedures and financial controls.

The post Episode 241 — Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program appeared first on Corruption, Crime & Compliance.

]]> 1908 no Episode 240 — The CCO’s Role in an Effective Compliance Program https://blog.volkovlaw.com/2022/07/episode-240-the-ccos-role-in-an-effective-compliance-program/ I 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 issues intersect, are interdependent and should be addressed through organizational commitment. But I want to take a step back and return to an issue of importance — the proper role of CCOs. To do so, we need to remind everyone about basic requirements, lessons learned and ways forward to meet the fast-changing times. CCOs have to maintain and then advance their positions. In my view, given the interdependence of all of the important issues mentioned above, the role of the CCO has become even more critical. In this Episode, Michael Volkov reviews the standards applicable to the CCOs function in an effective compliance program.  The post Episode 240 — The CCO’s Role in an Effective Compliance Program appeared first on Corruption, Crime & Compliance. Sun, 24 Jul 2022 12:38:51 -0000 full Corruption, Crime & Compliance I 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, I 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 issues intersect, are interdependent and should be addressed through organizational commitment. But I want to take a step back and return to an issue of importance — the proper role of CCOs. To do so, we need to remind everyone about basic requirements, lessons learned and ways forward to meet the fast-changing times. CCOs have to maintain and then advance their positions. In my view, given the interdependence of all of the important issues mentioned above, the role of the CCO has become even more critical. In this Episode, Michael Volkov reviews the standards applicable to the CCOs function in an effective compliance program.  The post Episode 240 — The CCO’s Role in an Effective Compliance Program appeared first on Corruption, Crime & Compliance. I 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 issues intersect, are interdependent and should be addressed through organizational commitment.

But I want to take a step back and return to an issue of importance — the proper role of CCOs. To do so, we need to remind everyone about basic requirements, lessons learned and ways forward to meet the fast-changing times. CCOs have to maintain and then advance their positions. In my view, given the interdependence of all of the important issues mentioned above, the role of the CCO has become even more critical.

In this Episode, Michael Volkov reviews the standards applicable to the CCOs function in an effective compliance program. 

The post Episode 240 — The CCO’s Role in an Effective Compliance Program appeared first on Corruption, Crime & Compliance.

]]> 1495 no Episode 239 — DOJ’s New CCO Certification Requirement https://blog.volkovlaw.com/2022/06/episode-239-dojs-new-cco-certification-requirement/ 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 by opening CCOs to internal pressure to execute a certification despite concerns about the status of a company’s compliance program. In this Episode, Michael Volkov reviews DOJ’s new CCO certification requirement. The post Episode 239 — DOJ’s New CCO Certification Requirement appeared first on Corruption, Crime & Compliance. Sun, 26 Jun 2022 15:07:24 -0000 full 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 ... 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 by opening CCOs to internal pressure to execute a certification despite concerns about the status of a company’s compliance program. In this Episode, Michael Volkov reviews DOJ’s new CCO certification requirement. The post Episode 239 — DOJ’s New CCO Certification Requirement 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 by opening CCOs to internal pressure to execute a certification despite concerns about the status of a company’s compliance program.

In this Episode, Michael Volkov reviews DOJ’s new CCO certification requirement.

The post Episode 239 — DOJ’s New CCO Certification Requirement appeared first on Corruption, Crime & Compliance.

]]> 1745 no