Michael Volkov tackles the current and hot topics in the legal realms of corruption, crime, and compliance.
Episode 206 -- Update on Sanctions Compliance and Enforcement
The Department of Treasury's Office of Foreign Asset Control ("OFAC") continues to bring sanctions enforcement actions. At the same time, OFAC is reiterating the importance of sanctions compliance program. Building on its May 2019 Framework for Sanctions Compliance Program, OFAC is sticking to its word -- setting forth sanctions compliance program requirements and holding companies accountable for sanctions program violations.In this Episode, Michael Volkov reviews recent enforcement actions, expanded Belarus sanctions, and continuing compliance expectations.
Episode 205 -- How to Audit a Compliance Program
Chief compliance officers recognize the importance of conducting robust audits of their compliance programs. The audit process requires a delicate balance between qualitative and quantitative measures.
As corporate compliance programs build data analytics and technological capabilities, CCOs have to tailor the audit program to incorporate data as an effective measure of a compliance program.
In this Episode, Michael Volkov reviews strategies for conducting compliance program audits.
Episode 204 -- The Way Forward on Corporate Culture
The culture bandwagon is picking up steam. Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations. In its latest corporate compliance guidance, the Justice Department, along with numerous regulatory agencies continue to cite the importance of a company’s “culture of compliance.”
But when it comes to defining the terms, how to manage a company’s culture and how to measure, monitor and measure a company’s culture – everyone responds with a blank stare. That is when we hear the Justice Potter Stewart famous definition of obscenity, “I know it when I see it.”
To provide my own perspective on some of these issues, I am dedicating this podcast episode to corporate culture. My answers may not be “correct” or even “persuasive,” but the dialogue has to begin. I have long advocated for practical approaches to defining, managing and maintaining a company’s culture. As I often write, culture is a company’s most important “internal control.”
Episode 203 -- David Greenberg on LRN’s Report on Corporate Boards and Compliance Program Engagement
LRN recently issued its second of three annual reports on ethics and compliance program effectiveness. The second report focuses on board engagement with ethics and compliance and lessons learned from the COVID-19 pandemic.
David Greenberg, a Special Advisor to LRN, joins us to discuss the interesting results of the LRN report.
The LRN report can be downloaded at https://lrn.com/
Episode 202 -- A Deep Dive into the Alfa Laval OFAC Enforcement Case
In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran Sanctions Program. AL US enlisted its then subsidiary (now operating unit), Alfa Laval Tank, Inc, based in Exton, Pennsylvania (AL Tank), to participate in the scheme.
The Alfa Laval enforcement action underscores the dangers for global companies in compliance with US-based sanctions programs as part of global operations. The parent company, Alfa Laval AB is based in Sweden (AL Sweden). AL Middle East agreed to pay OFAC $415,695, and AL US agreed to pay OFAC $16,875.
In this Episode, MIchael Volkov reviews the OFAC enforcement action and points out interesting aspects and trends.
Episode 201 -- DOJ Brings Flurry of False Claims Act Cases
The False Claims Act is a powerful enforcement tool. The Justice Department with its partner agencies are ramping up enforcement efforts. The Biden DOJ is preparing to implement an aggressive FCA program across healthcare, defense industries and other government contractors.
The False Claims Act stands as a major risk – businesses that depend on government business, including healthcare, defense and other contractors, have to address proactively the risks associated with False Claims Act liability. Compounding this situation is an active and major whistleblower bar that generates qui tam relators needed to fuel Lengthy and costly government investigations.
In this Episode, Mike Volkov reviews the flurry of recent False Claims Act cases brought by the Justice Department.
Timely, insightful and actionable! 👏👏👏
Whether you’re well established as a compliance innovator, or just getting started as a catalyst for change - this is a must-listen podcast for you! Michael does an incredible job leading conversations that cover a huge breadth of topics related to the ins and outs of navigating an evolving legal landscape - with leaders who’ve actually experienced success themselves. Highly recommend listening and subscribing!
Helpful Resource for Compliance Professionals
It’s great to have an on-demand resource that discusses timely compliance topics. Mike does a great job - always nice to hear insight from a former federal prosecutor!
Insightful and succinct
Very interesting material presented in an easily digestible manner. Good use of your time!