Menu1/4/16: Michael Volkov cuts to the chase better than many of his colleagues. That’s true in a post in which he references Tom Fox (another cut-to-the-bone expert) to examine SEC’s newest tool to catch and prosecute domestic corruption. Based on this new SEC tool, the most surprising source of the misconduct is a company’s Code of Conduct. Say “What?” Volkov answers that and offers insight into how, when and why a company’s Code can introduce risks of noncompliance. More to the point, he points out the policies and procedures companies that should signal caution when a company develops its Code of Conduct. To read his full post, click
Compliance Communications Blog
Jan 04, 2017 •
1/4/16: Many aspects of regulation and enforcement are likely to change in the upcoming years, but the only place to start is where we are now and that is DOJ’s enhanced cooperation with the UK’s Serious Fraud Office (SFO) and Financial Conduct Authority (FCA).
Jan 04, 2017 •
1/4/16: Two settlements with the US Securities and Exchange Commission (SEC) – one with a technology company and the other an oil and gas company – gave evidence that the federal agency has taken protection of whistleblowers seriously.
Jan 04, 2017 •
1/4/16: It’s been a long time since the Enron corruption scandal made front page news but, according to an article published in the Harvard Law School Forum on Corporate Governance and Financial Regulation, the company’s experience continues to provide lessons for compliance professionals.
Dec 01, 2016 •
12/1/16: Tom Fox’ November 27 post on the FCPA Compliance and Ethics website (“Spikes in Sales and Compliance”) drills into the case of Wells Fargo to focus on a core compliance issue: “Every Chief Compliance Officer (CCO) and compliance practitioner understands that the sales side of a business is where the highest risk is located because that is most generally the side of the business which generates the most money and potential profit.” Yes, but here’s the upshot. Fox writes that looking at sales numbers is “… not something which compliance professionals will generally have access to as a part of a compliance program.
