Corruption, Crime & Compliance is a podcast for legal and compliance professionals who want to keep up to date with the world of corporate governance, ethics, compliance, corruption and white collar crime. In each episode, Michael Volkov, a former federal prosecutor, brings his unique perspective and practical experience to cutting-edge trends in the governance and risk management landscape. Whether you’re looking to understand the latest FCPA developments, hear expert analysis on important ...
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Matt Stankiewicz on the Bittrex OFAC and FinCEN Enforcement Action
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In this episode, cryptocurrency expert Matt Stankiewicz discusses why sanctions and AML compliance need to be taken seriously in the cryptocurrency industry. Matt Stankiewicz, a Partner at Volkov Law, is a leading industry expert on cryptocurrency. Bittrex, a leading cryptocurrency exchange, suffered twin enforcement actions for AML and Sanctions C…
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Training and Corporate Culture: Interview of Maria D’Avanzo, Chief Evangelist Officer, Traliant
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Does compliance training have to be boring? Our guest explains how your organization can make compliance training engaging and fun for your employees. Maria D’Avanzo is the Chief Evangelist Officer at Traliant. Maria provides key insights on corporate ethics and compliance training programs. Maria describes how to take your training program to the …
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Cybersecurity Risks Increase for FInancial Institutions Relying on the Cloud: A Discussion with Carlo Massimo
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Financial institutions are rapidly moving their operations to the cloud. In response to this development, and the increasing risks of cyber breaches, legislators and regulators are gearing up to impose significant cybersecurity requirements. Carlo Massimo is a journalist who covers Cyber Security and International Tech Policy. Carlo was a former co…
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Episode 249 -- DOJ Issues New Corporate Enforcement Policy
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The Biden Administration promised a new, aggressive approach to corporate crime. Well, the Justice Department just delivered a new, comprehensive policy that raises a number of issues, some of which are likely to be controversial. The new policy incorporates reforms announced last October that largely centered on prior corporate criminal and civil …
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Episode 248 -- Deep Dive into the GOL Brazil FCPA Settlement
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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 cre…
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Episode 247 -- Corporate Culture Round Up
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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 Epi…
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Episode 246 -- NAVEX's Global Hotline Benchmarking Report
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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 database consists of 1.37 million reports made in…
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Episode 245 -- Second Circuit Affirms Trial Judge's Dismissal of FCPA Counts Against Alstom Executive
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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 C…
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Episode 244 -- Building a Compliance Program Dashboard
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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.…
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Episode 243 -- Scott Greytak, Transparency USA, and Erica Hanichak, FACT Coalition, on House Passage of The Enablers Act
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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, from the FACT Coalition, join Michael Volkov…
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Episode 242 -- LRN Report on Assessing Corporate Culture -- Interview of Ty Francis, Chief Advisory Officer
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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, M…
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Episode 241 -- Continuous Improvement, Testing and Auditing of Your Ethics and Compliance Program
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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 …
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Episode 240 -- The CCO's Role in an Effective Compliance Program
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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 …
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Episode 239 - DOJ's New CCO Certification Requirement
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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…
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Episode 238 -- 2022 FCPA Enforcement Trends . . . So Far
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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…
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Episode 237 -- The Tenaris SEC FCPA Settlement
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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. I…
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Episode 236 - The Glencore FCPA and Fraud Settlement
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In a long-anticipated and major enforcement action, the Justice Department and the Commodities and Futures Exchange Commission resolved a sprawling investigation with Glencore International A.G. and Glencore Ltd, a Swiss-based commodity trading and mining company. Both companies entered guilty pleas for FCPA violations and a commodity price manipul…
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Episode 235 -- Third-Party Risk Management
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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 …
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Episode 234 -- A Deep Dive into the Stericycle FCPA Enforcement Action
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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 in…
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Episode 233 -- Tom Fox and Michael Volkov Discuss Recent DOJ Criminal Trials
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In this Episode Tom Fox and Mike Volkov review recent DOJ trial successes and stumbles -- Tom and Mike review DOJ trial strategy, successes and failures and approach of the antitrust division.By mvolkov@volkovlaw.com (Volkov Law)
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Episode 232 -- OFAC Settles with S&P Global for $78,750 for violation of Ukraine-Russia Sanctions
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OFAC recently announced a settlement with OFAC for $78,750 for violations of the Ukraine-Russia Sanctions Program. The enforcement action provides important reminders relating to compliance with various "deby" maturity restrictions and how OFAC construes this restriction. In this Episode, Michael Volkov reviews OFAC's enforcement action against S&P…
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Episode 231 -- SEC Update: Proposed Climate Change and Cyber Incident Rules
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The SEC is a very busy 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 an…
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Episode 230 -- Catching Up with DOJ's Antitrust Division
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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 …
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