Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.
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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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SEC Suffers Dismissal of Claims in Solarwinds Securities Fraud Case
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A New York federal district judge handed down a significant decision dismissing much of the SEC's securities fraud enforcement action against SolarWinds arising from its claims relating to SolarWinds' cybersecurity policies and disclosure of a significant cyberattack against the SolarWinds' network. In this episode of Corruption, Crime, and Complia…
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Have you heard of the recent controversies around Boeing 737 MAX and its safety? Have you wondered what is being done about the concerns around it? In this episode of Corruption, Crime, and Compliance, Michael Volkov delves into the latest developments in the Boeing 737 MAX case, highlighting the recent plea agreement proposed by the Department of …
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Deep Dive into the SEC's Settlement with R&R Donnelly on Cybersecurity Controls
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How does the SEC's recent settlement with R.R. Donnelly & Sons Company impact internal controls for cybersecurity incidents? In this episode of Corruption, Crime, and Compliance, Michael Volkow discusses a significant decision by the SEC involving a $2.1 million settlement with RR Donnelly & Sons Company (RRD) related to a 2021 ransomware attack. T…
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NAVEX State of Risk and Compliance Programs
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Is your HR department rolling their eyes at compliance? Does your company have a non-retaliation policy? The report, based on over 1,000 global responses, reveals growing maturity in compliance programs but notable gaps, such as only 61% having a hotline and 55% having a non-retaliation policy. Join us on this week’s Corruption Crime and Compliance…
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Halyna Senyk, from the CEELI on Anti-Corruption Progress in Ukraine
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Is the progress itself enough to consider the battle won? Are the ongoing scandals casting a shadow over the hard work against corruption? Despite challenges (such as limited resources due to the ongoing war) and recent scandals (such as overpriced eggs for the military), Ukraine maintains multiple institutions committed to transparency and integri…
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Bryn Sedlacek, Vice President at Aravo, on Holistic Third-Party Risk Management and Unitary Visibility
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Bryn Sedlacek, Vice President and Product Manager at Aravo, joins us on the podcast to discuss third-party risk management focusing on holistic risks and unified visibility. In a wide-ranging discussion, Mike Volkov and Bryn Sedlacek discuss the challenges in implementing a third-party risk management program that captures holistic risks and mainta…
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In this episode of Corruption, Crime and Compliance, we delve into the complex world of sanctions compliance and enforcement. In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increases. In contrast to the history of FCPA enforcement, DOJ and OFAC ha…
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Another Look at the Importance of Corporate Culture
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LRN has issued another important report. In its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture. LRN is a pacesetter and the leader in reliable studies on complex ethics and compliance issues. If not properly promoted or maintained, a defective culture can lead to serious misco…
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Dottie Schindlinger on Diligent's Report on Board Oversight of Cybersecurity Risks and Performance
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Dottie Schindlinger is Executive Director of Diligent Institute, the global corporate governance research arm of Diligent - the largest SaaS software company in the Governance, Risk, Compliance (GRC), and ESG space. She co-authored the book Governance in the Digital Age: A Guide for the Modern Corporate Board Director, co-hosts “The Corporate Direc…
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AI Risks and Emerging Compliance Frameworks
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A new compliance cottage industry surrounds artificial intelligence. We are at such an early stage of AI development, and companies are still figuring out how they can employ the technology. However, some industries, such as financial institutions, have been using AI for fraud detection and other issues. These early adopters will likely set the ton…
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Third-Party Risks and Sanctions Compliance
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With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just the same as FCPA legal requirements. As we embark on a new criminal enforcement era surrounding sanctions violations, compan…
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Carlos Villagran Discusses Rebuilding a Corporate Culture After a Corporate Crisis
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Carlos Villagrán is the Director of Compliance at CMPC, a 100-year-old Chilean-based holding company, one of the worldwide leading pulp, paper, packaging, personal care, and other forest products manufacturers. With more than 20,000 employees, CMPC has industrial operations in 9 countries (LatAm and the US) and commercial offices in the US, Europe,…
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Checking in on the Caremark Cases
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Over the last ten years, we have seen a marked shift from the Delaware Chancery Court chipping away at corporate board member liability claims. In a number of seminal cases involving Boeing airplane crashes (In re the Boeing Co. Derivative Litig., No. 2019-0907 (Del. Ch. Sept 7, 2021)), and deadly listeria outbreaks from tainted ice cream (Marchand…
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Review of the EU Whistleblowing Directive with Alex Cotoia and Daniela Melendez
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Directive 2019/1937 of the European Parliament and Council dated 23 October 2019 on the “protection of persons who report breaches of Union law” (the “Directive”) is currently being implemented by EU Member States. The directive has broad applicability to organizations operating in the EU internal market and applies to both public and private secto…
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NAVEX's 2024 Whistleblower Report -- More Reports, Higher Substantiation Rates
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NAVEX continues to produce high-quality compliance reports, many of which are a must-read in the compliance industry. Its annual Whistleblower Report is of particular note -- NAVEX is the leading provider of hotline services in the world, and its data is invaluable as a source of trends in this industry. This year --2024 -- is no exception. NAVEX c…
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Deep Dive into SCG Plastics' $20 Million Settlement with OFAC to Resolve Violations of Iran Sanctions Program
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OFAC is capable of extending a long arm of enforcement, reaching sometimes non-U.S. companies that may "cause" another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no further than OFAC's recent settlement with SCG Plastics ("SCG"). In this settlement, SCG, a Thai company that sells plastic resins, …
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LRN's Latest Report Underscores Importance of Ethical Culture and Values-Based Leadership
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LRN continues to set the standard for ethics and compliance program research. Volkov Law is a supporter of, and advocate for, LRN’s research because it has consistently confirmed what we all know and believe - ethical companies perform better in the marketplace over the long run. It is an intuitive fact that employees respond better to values-based…
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Deep Dive into the Trafigura FCPA Settlement
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On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ's FCPA Sweep against the industry. Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions like Vitol, Sargeant Marine, Glencore, Freepoi…
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DOJ Adopts New Whistleblower Bounty Program and Encourages Voluntary Self-Disclosure
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In a recent speech on March 7, 2024, Deputy Attorney General Monaco announced that, in the next 90 days, DOJ would implement a new whistleblower program to reward reporting of criminal misconduct at public and private companies. In particular, DOJ will encourage reporting of potential violations of the Foreign Corrupt Practices Act ("FCPA") and the…
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Boeing Pays $51 Million for ITAR Violations
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Boeing continues to struggle with its core business activities. As troubles mount for Boeing, it is clear that it continues to suffer from real and pervasive culture issues that have been reflected in serious safety failures, financial difficulties, regulatory violations, and serious reputational damage. Boeing's troubles permeate every part of its…
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Deep Dive into the Gunvor FCPA Settlement
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You have to give the Justice Department credit - after two slow enforcement years, DOJ is starting off 2024 with a relative "bang;" first, DOJ reached a large settlement with SAP in January, and now, DOJ has reached a blockbuster settlement with Gunvor S.A. for $661 million. Gunvor is one of the world's largest commodities trading companies. DOJ's …
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The Coming Sanctions Enforcement Storm
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Whatever the cause, criminal sanctions enforcement will be an interesting area in 2024. The DOJ's planned aggressive push against companies and individuals for sanctions violations is about to be unleashed. There is no question that DOJ's enforcement initiative is coming—it is just a question of when. We have already seen several examples of what a…
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Eddie Green, CEO of SnippetSentry, on Communications Preservation Risks
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Companies have a vested interest in preserving internal communications for a variety of reasons -- to hold actors accountable and to protect the organization from potential private and government claims or investigations that may have serious direct or collateral consequences. Companies that want to use ephemeral messaging systems can do so, but th…
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DOJ's Shifting Approach to Recidivism and Self-Disclosure
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In this special episode of Corruption, Crime, and Compliance, Michael Volkov joins colleague and long-time friend Tom Fox as they delve into the intricacies of recent FCPA enforcement actions, shedding light on the evolving landscape of corporate compliance. From the ABB case to the SAP settlement, Michael and Tom dissect the nuances of voluntary d…
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Christian Focacci, Founder and CEO, Threat.Digital, on Artificial Intelligence and Compliance
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Christian Focacci is a leader in the artificial intelligence world and harnesses the capabilities for risk management. He is the founder and CEO of Threat.Digital, which has launched a new product DiligenAI. Threat.Digital is leveraging large language models and real-time data feeds to empower organizations to identify risk information confidently …
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Alex Cotoia on Compliance with the Uyghur Forced Labor Prevention Act
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On December 31, 2021, President Joseph R. Biden, Jr. signed the the Uyghur Forced Labor Prevention Act (“UFLPA”) into law to address the ongoing exploitation of the ethnic minority Uyghur population by the government of the People’s Republic of China (“PRC”). Among other things, the UFLPA creates a rebuttable presumption that all goods, wares, arti…
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Trade Compliance Trends and Expectations with Gabrielle Griffith
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Gabrielle Griffith, Director BPE Global, is an expert in trade compliance issues. Gabrielle assists clients in implementing effective trade compliance programs by addressing improvements within organizations’ people, processes, and systems. In the area of U.S. export controls, she advises clients on compliance with the International Traffic in Arms…
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DOJ and OFAC Sanctions Enforcement Review for 2023
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The Justice Department and the Office of Foreign Assets Control had a big year in 2023. Criminal and civil enforcement continue to increase. The DOJ has warned corporations that aggressive sanctions enforcement actions are coming -- to that end, the DOJ assigned 25 new prosecutors to the National Security Division to execute on its promise. Meanwhi…
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For the Justice Department and the SEC, 2023 was a slow year in FCPA enforcement. Despite promises of aggressive enforcement, DOJ and the SEC failed to achieve increases in FCPA enforcement. DOJ and the SEC issued no blockbuster enforcement actions or settlements. The SEC's number of enforcement actions was steady and eclipsed its 2022 number by on…
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Deep Dive into DOJ and SEC's SAP FCPA Enforcement Action
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Bribery is rampant in many countries around the world, and in this episode of Corruption, Crime, and Compliance, we take a look at a recent FCPA case involving SAP, a global software company. SAP’s violations spanned multiple countries, including South Africa and Indonesia, and resulted in prosecution and a hefty $220 million dollar penalty. Howeve…
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Natalie Druckman from Certa on AI-Enhanced Third-Party Risk Management
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How do you manage risk when the vulnerabilities are outside your organization’t in your hands? In this episode of Corruption, Crime, and Compliance, we delve into the world of third-party risk management with our guest, Natalie Druckmann, from Certa. As we discuss the regulatory landscape in EMEA and the US, Natalie highlights the higher regulatory…
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Deep Dive into HHS-OIG Compliance Program Guidance
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In this week's episode of Corruption, Crime, and Compliance, we usher in the New Year with a deep dive into something that happened in November of last year. As we begin 2024, it's crucial to reflect on the substantial shifts in the healthcare industry's compliance framework. The HHS Office of Inspector General's Comprehensive Compliance Guidance, …
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Matt Stankiewicz on the Groundbreaking Binance Criminal Settlement for $4.3 Billion
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What is the cost of ignoring compliance? For the world’s largest cryptocurrency exchange, it’s $4.3 billion dollars. In this episode of Corruption, Crime and Compliance, Michael Volkov and his guest, Matt Stankiewicz, delve into one of the most significant financial crime prosecutions in the history of the Justice Department: Binance Holdings. Unde…
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Steve Naughton on Compliance and Compliance Education Program at Loyola School of Law
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How can we build a culture that motivates people to do the right thing? In this episode of Corruption, Crime and Compliance, Michael Volkov and guest Steve Naughton, explore crucial questions about fostering ethical cultures within companies and practical steps compliance leaders can take to transform performance. Steve shares insights from his jou…
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DOJ Settles FCPA Cases with Two UK-Based Reinsurance Companies
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In the 300th episode of Crime, Corruption and Compliance, Michael Volkov examines the recent FCPA settlements with two major UK reinsurance brokers - Tysers and H.W. Wood - for their involvement in a bribery scheme in Ecuador. The DOJ took an unorthodox approach by going after individual people before the companies. This helped them get cooperation…
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Bobby Butler on the Compliance Profession and the Future of Compliance
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Bobby Butler joins Michael Volkov on this episode of Corruption, Crime and Compliance, to explore the evolution of compliance over 20 years. While enforcement actions sparked major progress, Bobby contends compliance is moving firmly into the realm of competitive advantage and performance multiplier. Millennials and younger generations ‘vote with t…
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Electronics Communications Risks in the Era of Ephemeral Messaging
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Ephemeral messaging applications like Snapchat, WhatsApp, and Telegram have presented a complex challenge for compliance professionals and legal counsel. On one hand, these technologies can reduce data storage and preservation costs, minimize breach exposure, and allow prioritization of communications data. On the other hand, they can create blind …
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Susan Divers on LRN's 2023 Compliance Program Effectiveness Report
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Is your company's compliance program truly effective, or is it just ticking boxes? In this episode of Corruption, Crime, and Compliance, Michael Volkov dives deep into LRN's PEI survey with Susan Divers. Susan sheds light on the global nature of ethics and compliance programs, challenging the misconception that they are solely US-centric. They disc…
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A Deep Dive into Clear Channel's SEC FCPA Settlement
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Clear Channel, a San Antonio based advertising company, is settling with the SEC for $26 million, for bribery violations committed by its former Chinese subsidiary, Clear Media. In this episode of Corruption, Crime and Compliance, Michael Volkov explores the details of this case, from covert cash funds to internal audit challenges, shedding light o…
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The Albemarle DOJ and SEC FCPA Settlement
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Albemarle, a prominent specialty chemicals company, recently settled a case for $218 million, unraveling a web of bribery payments across Vietnam, Indonesia, and India. The repercussions of this case extend beyond the financial penalty, encompassing a three-year non-prosecution agreement and the application of the Compensation, Incentives, and Claw…
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Catch up on OFAC Enforcement -- 3M and Emigrant Banks Cases
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3M faced a dual settlement, first with the SEC and then with OFAC, over alleged Iranian sanctions violations stemming from misconceptions and oversights in a license plate deal with a German intermediary. Despite the gravity of the case, 3M took proactive remedial actions, including voluntary disclosure and internal changes. Similarly, Emigrant Ban…
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Catching Up with California and State Data Privacy Laws
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California's data privacy regulations, primarily embodied in the California Consumer Privacy Act (CCPA) and its extension through the California Privacy Rights Act (CPRA), constitute a pioneering and influential framework. These regulations, effective from 2018 and further strengthened in 2020, set a standard for data protection not only within the…
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3M’s recent $6 million settlement with the SEC for violating the FCPA serves as a stark reminder of the risks global companies face in today's economy and underscores the crucial role of ethics and compliance programs. In this episode of Corruption, Crime and Compliance, Michael Volkov sheds light on the unethical conduct that led to legal repercus…
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Interview of Mary Shirley on Her New Book -- Living Your Best Compliance Life
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CEOs play a pivotal role in shaping an organization's commitment to ethical practices. Involving CEOs in compliance training, having them share their experiences, and demonstrating a personal commitment to compliance initiatives sets a strong tone from the top. This engagement fosters a culture of ethics and compliance throughout the organization, …
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Corficolombiana DOJ and SEC FCPA Settlements
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When operations span across borders, navigating local regulations and ethical standards becomes even more crucial. As evidenced by Corficolombiana's case, neglecting these measures can lead to hefty legal ramifications and significant economic repercussions. In this episode of Corruption, Crime and Compliance, Michael Volkov unravels the Corficolom…
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Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export Control Violations
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Companies must take a proactive approach to sanctions and export control compliance to mitigate potential risks. This includes implementing rigorous compliance programs, cooperating with the DOJ, and promptly disclosing and remedying violations. In this episode of Corruption, Crime and Compliance, Michael Volkov explores the latest joint compliance…
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SEC Adopts Robust New Cybersecurity Disclosure Rules
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In this episode of Corruption, Crime and Compliance, Michael Volkov delves into the SEC’s groundbreaking adoption of robust cybersecurity disclosure rules. This pivotal change marks a significant shift in the compliance landscape, requiring public companies to not only disclose cybersecurity incidents but also unveil their governance policies and p…
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Board Oversight and Monitoring of AI Risks
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As companies rapidly adopt artificial intelligence (AI), it becomes paramount to have robust governance frameworks in place. Not only can AI bring about vast business benefits, but it also carries significant risks—such as spreading disinformation, racial discrimination, and potential privacy invasions. In this episode of Corruption, Crime and Comp…
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Matt Stankiewicz on Ripple Decision and Indictment Against Celsius Networks’ CEO
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According to critics, there are a lot of gray areas surrounding compliance and the SEC's position on cryptocurrency regulations. Such uncertainty poses challenges for legitimate crypto projects and creates room for fraudulent activities to thrive. Such is the case for Ripple and Celsius, two recent controversies making waves in the crypto world. Ma…
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The Importance of a Consequence Management System
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Transparency, ethics, and compliance are more than just corporate buzzwords; they're foundational to building trust in today's global organizations. Consequence management systems encompass elements like transparency, robust employee reporting, protective measures for whistleblowers, and effective internal investigations. These are all essential fo…
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