Corruption Crime & Compliance

Michael Volkov
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Corruption Crime & Compliance

Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.

  1. The Trump Administration's Expected Impact on Enforcement and Compliance

    -2 J

    The Trump Administration's Expected Impact on Enforcement and Compliance

    What does the new Trump administration mean for ethics, compliance, and enforcement? As the dust settles on the U.S. election, companies are evaluating the implications of President Trump’s return to the White House. With priorities such as spurring economic growth, reducing inflation, imposing stringent trade sanctions, and reforming the Department of Justice, businesses must prepare for significant changes. How will these initiatives impact compliance programs and enforcement priorities? You’ll hear Michael discuss: Key enforcement priorities under the second Trump administration, including changes to DOJ oversight and trade compliance.The implications of aggressive foreign policy shifts, including potential changes to sanctions on Russia, Iran, and China.The focus on immigration enforcement, workplace audits, and I-9 compliance.The anticipated reduction in environmental and workplace safety enforcement.Trends in corporate criminal enforcement, including a steady focus on healthcare fraud but limited activity in other areas.Strategies for companies to enhance trade compliance and prepare for expanded tariffs and sanctions. Resources Michael Volkov on LinkedIn | Twitter The Volkov Law Group

    19 min
  2. Raytheon Pays $950 Million to Resolve Fraud, FCPA, ITAR and False Claims Act Violations

    18 NOV.

    Raytheon Pays $950 Million to Resolve Fraud, FCPA, ITAR and False Claims Act Violations

    What happens when a major defense contractor faces scrutiny for ethics and compliance violations? In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into the high-stakes world of corporate accountability, exploring Raytheon's recent $428 million settlement with the U.S. Department of Justice. From fraudulent pricing to bribery and compliance lapses, we uncover the impact of these violations and the tough questions they raise about corporate governance, oversight, and ethical responsibility in high-stakes industries. Hear Michael talk about: Raytheon Company (Raytheon) -- a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into three areas of violation. The settlement addresses three main issues:A major government fraud scheme involving defective pricing on certain government contractsViolations of the Foreign Corrupt Practices Act (FCPA) the Arms Export Control Act (AECA) and its implementing regulations, the International Traffic in Arms Regulations (ITAR)As part of the settlement, Raytheon entered into a three-year deferred prosecution agreement (DPA) and agreed to the filing of criminal information in the District of Massachusetts charging Raytheon with two counts of major fraud against the United States. Raytheon admitted to engaging in two separate schemes to defraud the Department of Defense (DOD) relating to the provision of defense articles and services, including PATRIOT missile systems and a radar system. Separately, Raytheon entered into a three-year DPA in connection with a criminal information in the Eastern District of New York charging Raytheon with two counts: conspiracy to violate the anti-bribery provision of the FCPA for a scheme to bribe a government official in Qatar and conspiracy to violate the AECA for willfully failing to disclose the bribes in export licensing applications with the Department of State as required by part 130 of ITAR.The Justice Department’s FCPA and ITAR resolution is coordinated with the Securities and Exchange Commission (SEC). Both DPAs require that Raytheon retain an independent compliance monitor for three years, enhance its internal compliance program, report evidence of additional misconduct to the Justice Department, and cooperate in any ongoing or future criminal investigations. Raytheon also reached a separate False Claims Act settlement with the Justice Department relating to the defective pricing schemes. Resources Michael Volkov on LinkedIn | X (Twitter) The Volkov Law Group

    17 min
  3. SEC Settles FCPA Case with Moog, Inc. for Nearly $1.7 Million

    11 NOV.

    SEC Settles FCPA Case with Moog, Inc. for Nearly $1.7 Million

    The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases. In the meantime, the Justice Department has been silent in the FCPA enforcement arena. In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into the SEC’s recent FCPA settlement with Moog, a global manufacturer that faced severe bribery allegations within its Indian subsidiary. From navigating India's complex tender processes to revealing corrupt practices and hefty penalties, Michael dissects Moog's compliance failures and highlights the critical role of ethics in international business dealings. Listen in as he discusses:  Moog, Inc. ("Moog"), a New York-based global manufacturer of motion controls systems for aerospace, defense, industrial, and medical markets, agreed to pay a civil penalty of $1.1 million and disgorge nearly $600,000 for a total of $1.7 million, to resolve FCPA charges arising out of bribes paid by its wholly owned Indian subsidiary, Moog Motion Controls Private Limited (Moog Motion Controls).Moog India allegedly bribed officials from the South Central Railway (SCR) and Hindustan Aeronautics Limited (HAL) to influence tender processes and exclude competitors. These bribes were often disguised as “contractor services.”From 2020 to 2022, Moog employees bribed various Indian officials to win business. Also, they used a variety of schemes to make improper payments, including funneling them through third-party agents and distributors. These same Moog employees also offered cash bribes to Indian officials in an attempt to cause public tenders in India to favor Moog’s products and exclude competitors.The case highlights significant gaps in Moog’s internal controls, including improper invoice recording, inadequate oversight of third-party agents, and a lack of compliance training.Moog self-reported the misconduct, terminated those involved, enhanced its compliance program, and strengthened accounting controls and auditing procedures for third-party interactions. Resources Michael Volkov on LinkedIn | X (Twitter) The Volkov Law Group

    14 min
  4. TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations

    4 NOV.

    TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations

    How does a respected financial institution turn into a criminal operation? In this episode of Corruption, Crime, and Compliance, host Michael Volkov dives into the record-breaking $3 billion settlement between TD Bank and the Department of Justice over pervasive violations of the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) laws. Highlighting TD Bank's systemic failures, Michael explores how the bank's compliance and oversight lapses led to criminal conduct within its operations, making it a case study on the dangers of prioritizing growth over legal compliance. From failed AML programs to enabling money laundering on a massive scale, this episode sheds light on the regulatory crackdown TD Bank now faces.  Hear him discuss:  TD Bank’s $3 billion penalty sets a new high for banking compliance cases. In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion settlement with TD Bank companies to resolve systemic and pervasive Bank Secrecy Act ("BSA") and money laundering violations.TD Bank’s internal culture sidelined AML compliance, leading to massive oversights, including unmonitored transactions worth $18.3 trillion from 2018 to 2024. TD Bank enforced a “flat-cost paradigm,” restricting the compliance budget, which prevented updates and adaptations needed to meet new risk levels.TDBUSH pleaded guilty to causing TDBNA to fail to maintain an AML program that complies with the BSA and to fail to file accurate Currency Transaction Reports ("CTRs").Despite multiple warnings from internal audits and third-party consultants, the bank maintained its flawed AML protocols without significant action.TD Bank earned the ignominious record: TD Bank is the largest bank in U.S. history to plead guilty to Bank Secrecy Act program failures, and the first US bank in history to plead guilty to conspiracy to commit money laundering.   With this settlement, TD Bank joins a list of high-profile compliance failures alongside companies like Wells Fargo and Wirecard, furthering the call for financial institutions to prioritize ethical compliance in their growth models. Resources Michael Volkov on LinkedIn | Twitter The Volkov Law Group

    16 min
  5. How to Conduct an Internal Compliance Site Visit and Review

    28 OCT.

    How to Conduct an Internal Compliance Site Visit and Review

    How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges? In this episode, Michael Volkov dives into the critical components of conducting an internal compliance site visit and review. He highlights the significance of these visits in understanding operational risks and compliance culture. With real-world examples, Michael emphasizes the need for a proactive approach to compliance, ensuring that organizations are not only following regulations but also fostering an ethical environment. Listen in as Michael talks about: Conducting personal interviews with key staff to assess the compliance culture and operational challenges.Reviewing and testing transactions across various vendor categories to ensure compliance with protocols.Evaluating the effectiveness of training programs and employee understanding of ethical standards and compliance awareness.Verifying compliance with internal policies and conduct due diligence on charitable contributions.Assessing the compliance processes surrounding sponsorships and their alignment with company policies.Implementing thorough due diligence practices for third-party vendors to mitigate risks.Reviewing employee expense reports to ensure proper documentation and compliance with gift, meals, entertainment, and hospitality policies. Resources Michael Volkov on LinkedIn | Twitter The Volkov Law Group

    16 min
  6. DOJ Charges Visa with Monopolization and Exclusionary Conduct in the Debit Card Market

    21 OCT.

    DOJ Charges Visa with Monopolization and Exclusionary Conduct in the Debit Card Market

    What happens when a single company dominates a crucial segment of the financial market? In this episode, Michael Volkov explores the Justice Department's recent antitrust lawsuit against Visa, highlighting allegations of monopolization and exclusionary practices in the debit card market. With Visa controlling over 60% of debit transactions in the U.S., the DOJ aims to restore competition and prevent further stifling of innovation in this vital financial sector. Tune in as Michael breaks down the case details, Visa’s strategic responses, and the implications for the broader financial landscape. Listen in as Michael discusses: The DOJ has charged Visa with monopolization and exclusionary conduct under Sections 1 and 2 of the Sherman Act.Visa holds over 60% of the U.S. debit transaction market, with MasterCard as its closest competitor at 25%.The complaint alleges Visa engages in exclusionary agreements that penalize banks and merchants for using alternative debit networks.The 2010 Durbin Amendment aimed to increase competition but has had minimal effect on Visa’s dominance, leading to ongoing scrutiny.Visa's strategies include partnering with potential competitors while leveraging significant market power to suppress competition.Following successes in technology sector enforcement, the DOJ is now expanding its scrutiny into financial markets, indicating a potential shift in antitrust enforcement dynamics. Resources Michael Volkov on LinkedIn | Twitter The Volkov Law Group

    11 min
  7. DOJ Updates Evaluation of Corporate Compliance Programs

    14 OCT.

    DOJ Updates Evaluation of Corporate Compliance Programs

    How prepared is your company to handle the evolving risks of artificial intelligence and other emerging technologies in its compliance program? In this episode of Corruption, Crime and Compliance, Michael Volkov delves into the Department of Justice's 2024 updates to its evaluation of corporate compliance programs. As the DOJ continues to set global standards, Michael discusses key updates related to risk management, especially around AI and other technologies. He also covers important shifts in training, whistleblower protections, third-party management, and data analytics, offering a comprehensive overview of what businesses need to consider for effective compliance. You’ll hear him discuss: The DOJ raises the bar for corporate compliance, including technology risk management through their updated Compliance Guidance (2024).Companies must evaluate AI in both business and compliance contexts, ensuring controls for trustworthiness and legal alignment.Firms need to incorporate lessons from other companies and adapt policies and procedures to reflect emerging tech.Employee training must now be interactive, tailored, and measured for effectiveness.With their focus on whistleblower protection, the DOJ emphasizes tracking employee comfort in reporting issues and ensuring protection from retaliation.Companies are encouraged to continuously monitor third-party relationships beyond the onboarding phase.Stronger processes are needed for compliance audits and integration after mergers.DOJ pushes for the use of data analytics tools in compliance and better coordination between HR and compliance teams. Resources: Michael Volkov on LinkedIn | Twitter The Volkov Law Group DOJ Evaluation of Corporate Compliance Programs

    13 min
  8. Four Sanctions Cases That Everyone Should Know

    7 OCT.

    Four Sanctions Cases That Everyone Should Know

    How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their implications for global companies. He discusses four significant cases that underscore the necessity of robust compliance programs, particularly in light of increased DOJ enforcement actions. Through these examples, he breaks down the consequences of third-party liability, supply chain risks, and the dangers of inadequate compliance measures, offering valuable insights into how companies can proactively avoid similar pitfalls. Cases discussed: British American Tobacco (BAT): The company faced a staggering $629 million settlement for circumventing North Korean trade sanctions. This case illustrates how corporate prosecutions are evolving to resemble Foreign Corrupt Practices Act (FCPA) cases, emphasizing the growing scrutiny on multinational corporations.Epsilon Electronics: This case clarifies the liabilities companies face when third-party distributors divert products to prohibited countries, such as Iran. Even if the company had no direct involvement in the diversion, it still bears responsibility, underscoring the importance of diligent monitoring of distribution channels.ELF Cosmetics: The company received a $1 million fine for importing goods containing materials sourced from North Korea. This case underscores the critical importance of conducting thorough supply chain due diligence to ensure compliance with international sanctions.Murad LLC: This case focuses on post-acquisition compliance failures, demonstrating the urgent need for thorough pre- and post-acquisition audits. These audits are essential to uncover potential sanctions violations and ensure that newly acquired companies adhere to compliance standards. Resources: Michael Volkov on LinkedIn | Twitter The Volkov Law Group Links to the four cases: British American Tobacco I Epsilon Electronics I Elf Cosmetics I Murad LLC A Framework for OFAC Compliance Commitments (May 2019)

    21 min
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À propos

Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.

Informations

  • Création
    Michael Volkov
  • Années d’activité
    2017 - 2024
  • Épisodes
    327
  • Classification
    Tous publics
  • Copyright
    © Copyright 2022 Corruption Crime & Compliance
  • Site web de l’émission
    Corruption Crime & Compliance

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