Legal News

The Department of Justice quietly issued revisions to its Corporate Compliance Program Guidance. DOJ's revisions underscore important new trends in corporate compliance -- the importance of resources and empowerment, continuous monitoring, proactive...By: Michael Volkov

DOJ is catching up to compliance officers and evolving best practices.  Say what you want, DOJ is behind the curve of the compliance industry.  But you have to give DOJ credit – they are moving quickly to update its Guidance....By: Michael Volkov

In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks. Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to...By: Michael Volkov

Companies continue to refine their third-party risk management programs. As an initial step, companies have to create a third-party risk profile for its population. To accomplish this task, companies have to classify and stratify their third...By: Michael Volkov

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase over 2018 when OFAC...By: Michael Volkov

As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy....By: Michael Volkov

The Justice Department has been very busy in FCPA enforcement matters -- (1) Samsung Heavy Industries paid $75 million to settle FCPA violations; (2) Braskem's former CEO was indicted on FCPA charges; and (3) after a three-week trial, Transport's...By: Michael Volkov

The government has stated that a well-designed compliance program includes “appropriately tailored training and communications.” Compliance policies cannot work unless effectively communicated throughout a company. Communications and training...By: Michael Volkov

In an interesting SEC FCPA settlement action, Sridhar Thiruvengadam, the former COO of Cognizant Technology, agreed to pay a $50K penalty for his role in the bribery scheme involving the payment of $2 million to a government official in India in...By: Michael Volkov

In yet another major compliance development, the Justice Department announced the adoption of a new policy to credit effective compliance programs in resolving criminal cartel prosecutions against corporations. Since the 1990s, the Antitrust...By: Michael Volkov