An effective third-party risk management program has to include robust monitoring and auditing strategies.  This episode is a companion to Episode 129 on creating a third-party risk profile. In this episode, Michael Volkov outlines strategies for monitoring and auditing your third-party population.

An effective third-party risk management program has to include robust monitoring and auditing strategies.  This episode is a companion to Episode 129 on creating a third-party risk profile. In this episode, Michael Volkov outlines strategies for monitoring and auditing your third-party population.

Corruption Crime & Compliance

Episode 131 - Third-Party Risk Monitoring and Auditing Strategies

The Treasury Department's Office of Foreign Asset Control ("OFAC") is aggressively enforcing OFAC sanctions rules.  Last year, OFAC issued its Framework for Sanctions Compliance Programs, which includes a specific requirement for companies to conduct a "holistic" risk assessment. In this episode, Michael Volkov outlines practical strategies for conducting a sanctions risk assessment.

The Treasury Department's Office of Foreign Asset Control ("OFAC") is aggressively enforcing OFAC sanctions rules.  Last year, OFAC issued its Framework for Sanctions Compliance Programs, which includes a specific requirement for companies to conduct a "holistic" risk assessment. In this episode, Michael Volkov outlines practical strategies for conducting a sanctions risk assessment.

Episode 130 -- Practical Strategies for OFAC Sanctions Risk Assessments

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 parties. In this episode, Michael Volkov discusses how to review your third-party population and create a risk profile.

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 parties. In this episode, Michael Volkov discusses how to review your third-party population and create a risk profile.

Episode 129 -- Creating a Third-Party Risk Profile

Companies are rapidly implementing automated solutions for compliance program functions.  Technology accelerates compliance program performance and creates opportunities to measure and evaluate a company's compliance program. In this Episode, Michael Volkov discusses how to measure and evaluate a compliance program using data generated from automated platforms.

Companies are rapidly implementing automated solutions for compliance program functions.  Technology accelerates compliance program performance and creates opportunities to measure and evaluate a company's compliance program. In this Episode, Michael Volkov discusses how to measure and evaluate a compliance program using data generated from automated platforms.  

Episode 128 -- Compliance Automation and Program Measurement

In a comprehensive enforcement action, the Office of the Comptroller of Currency (OCC) announced a $17.5 million settlement with former Wells Fargo Bank CEO John Stumpf for his  role in the sales practices misconduct scandal. In addition, the OCC announced settlements with two other Wells Fargo executives: (1) Hope Hardison, former Chief Administrative Officer and Director of Human Resources, Cease and Desist Order and $2.25 million civil money penalty; and (2) Michael Loughlin, Chief Risk Officer, Cease and Desist Order and $1.25 million civil money order. In addition to the specific settlements, the OCC initiated penalty notices against five former Wells Fargo officials, including: (1) Carrie Tolstedt, Head of the Community Bank, Prohibition Order and $25 million civil money penalty; (2) Claudia Russ Anderson, Community Bank Group Risk Officer, Prohibition Order and $5 million civil money penalty; (3) James Strother, General Counsel, Personal Cease and Desist Order and $5 million civil money penalty; (4) David Julian, Chief Auditor, PC&amp;D Order and $2 million civil money penalty; and (5) Paul McLinko, Executive Audit Director, PC&amp;D Order and $500,000 civil money penalty. The facts outlined by the OCC in the enforcement actions paint a damning picture of misconduct.   In this Episode, Michael Volkov takes a deep dive into the scandal and the OCC's enforcement action.

 In a comprehensive enforcement action, the Office of the Comptroller of Currency (OCC) announced a $17.5 million settlement with former Wells Fargo Bank CEO John Stumpf for his  role in the sales practices misconduct scandal. In addition, the OCC announced settlements with two other Wells Fargo executives: (1) Hope Hardison, former Chief Administrative Officer and Director of Human Resources, Cease and Desist Order and $2.25 million civil money penalty; and (2) Michael Loughlin, Chief Risk Officer, Cease and Desist Order and $1.25 million civil money order. In addition to the specific settlements, the OCC initiated penalty notices against five former Wells Fargo officials, including: (1) Carrie Tolstedt, Head of the Community Bank, Prohibition Order and $25 million civil money penalty; (2) Claudia Russ Anderson, Community Bank Group Risk Officer, Prohibition Order and $5 million civil money penalty; (3) James Strother, General Counsel, Personal Cease and Desist Order and $5 million civil money penalty; (4) David Julian, Chief Auditor, PC&amp;D Order and $2 million civil money penalty; and (5) Paul McLinko, Executive Audit Director, PC&amp;D Order and $500,000 civil money penalty. The facts outlined by the OCC in the enforcement actions paint a damning picture of misconduct.   In this Episode, Michael Volkov takes a deep dive into the scandal and the OCC's enforcement action.  

Episode 127 -- Deep Dive into the Office of the Comptroller of Currency's Enforcement Action Against Former Wells Fargo Executives

In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve charges with the United States, France, and the United Kingdom for its role in a bribery scheme, and to resolve Airbus’ violation of the International Trade in Arms Regulations (“ITAR”).   In this Episode, Michael Volkov reviews the Airbus bribery and ITAR settlement.

 In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve charges with the United States, France, and the United Kingdom for its role in a bribery scheme, and to resolve Airbus’ violation of the International Trade in Arms Regulations (“ITAR”).   In this Episode, Michael Volkov reviews the Airbus bribery and ITAR settlement.  

Episode 126 -- The Airbus Global Settlement for $4 Billion for Bribery and ITAR Violations

Elizabeth Slim, Senior Consultant at the Volkov Law Group, discusses Anti-Money Laundering and Financial Compliance trends.  Liz recently joined the Volkov Law Group and has extensive experience in the banking and financial compliance industry.  She is major thought leader in anti-money laundering compliance and enforcement, and a leader at ACAMS. In this Episode, Michael Volkov discusses Liz's career and her thoughts on AML and financial compliance trends.

Elizabeth Slim, Senior Consultant at the Volkov Law Group, discusses Anti-Money Laundering and Financial Compliance trends.  Liz recently joined the Volkov Law Group and has extensive experience in the banking and financial compliance industry.  She is major thought leader in anti-money laundering compliance and enforcement, and a leader at ACAMS. In this Episode, Michael Volkov discusses Liz's career and her thoughts on AML and financial compliance trends.

Episode 125 -- Interview of Elizabeth Slim of the Volkov Law Group: Anti-Money Laundering and Financial Compliance Trends

The Justice Department continues to aggressively pursue False Claims Act cases.  In 2019, DOJ recovered over $3 billion from healthcare, defense and financial companies.  The heath care sector -- pharmaceutical, medical device, hospitals and healthcare providers -- continues to be the primary focus of False Claims Act cases.  At the same time, qui tam relators initiate a significant percentage of False Claims Act cases. In this episode, Michael Volkov reviews DOJ's False Claims Act enforcement in 2019 and significant trends.

The Justice Department continues to aggressively pursue False Claims Act cases.  In 2019, DOJ recovered over $3 billion from healthcare, defense and financial companies.  The heath care sector -- pharmaceutical, medical device, hospitals and healthcare providers -- continues to be the primary focus of False Claims Act cases.  At the same time, qui tam relators initiate a significant percentage of False Claims Act cases. In this episode, Michael Volkov reviews DOJ's False Claims Act enforcement in 2019 and significant trends.

Episode 124 -- False Claims Act 2019 Review

2019 was a big year for OFAC enforcement and compliance -- OFAC collected $1.28 billion in fines and penalties in a total of 26 separate enforcement actions.  OFAC also issued important compliance program guidance, mandating a number of important requirements for compliance programs. OFAC's enforcement record for 2019 focused on supply chain sourcing; acquisition of foreign companies engaged in transactions with prohibited countries and customers; third-party distributors which re-sold to prohibited countries and customers; and compliance with specific Russia sectoral sanctions. In this Episode, Michael Volkov reviews OFAC enforcement actions and trends and significant compliance requirements.

2019 was a big year for OFAC enforcement and compliance -- OFAC collected $1.28 billion in fines and penalties in a total of 26 separate enforcement actions.  OFAC also issued important compliance program guidance, mandating a number of important requirements for compliance programs. OFAC's enforcement record for 2019 focused on supply chain sourcing; acquisition of foreign companies engaged in transactions with prohibited countries and customers; third-party distributors which re-sold to prohibited countries and customers; and compliance with specific Russia sectoral sanctions. In this Episode, Michael Volkov reviews OFAC enforcement actions and trends and significant compliance requirements.

Episode 123 -- 2019 OFAC Enforcement and Compliance Review

Ethics and compliance had a big year -- new compliance guidance was issued by the Justice Department's Criminal and Antitrust Divisions and by the Department of Treasury's Office of Foreign Asset Control.  The compliance profession continues to innovate and new automated technologies are rapidly becoming available. In this Episode, Michael Volkov reviews ethics and compliance trends.

Ethics and compliance had a big year -- new compliance guidance was issued by the Justice Department's Criminal and Antitrust Divisions and by the Department of Treasury's Office of Foreign Asset Control.  The compliance profession continues to innovate and new automated technologies are rapidly becoming available. In this Episode, Michael Volkov reviews ethics and compliance trends.    

Exhibit 122 -- 2020 Ethics and Compliance Predictions and Trends

The Justice Department and the SEC had a record year in FCPA enforcement — the largest amount of penalties against corporate defendants and the most individuals charged in one year.  DOJ also adopted new guidance on corporate compliance programs. The Justice Department's enforcement year included several major prosecutions, including Ericsson, Walmart, Fresenius Medical and Cognizant Technology. In this Episode, Michael Volkov reviews 2019 FCPA enforcement and compliance trends.

The Justice Department and the SEC had a record year in FCPA enforcement — the largest amount of penalties against corporate defendants and the most individuals charged in one year.  DOJ also adopted new guidance on corporate compliance programs. The Justice Department's enforcement year included several major prosecutions, including Ericsson, Walmart, Fresenius Medical and Cognizant Technology. In this Episode, Michael Volkov reviews 2019 FCPA enforcement and compliance trends.

Episode 121 -- 2019: FCPA Year in Review

Global companies face extraordinary risks through their reliance on third-party agents, distributors, consultants and vendors/suppliers.  Federal prosecutors and regulators have had a record year in FCPA and sanctions enforcement.  To mitigate these risks, global companies are quickly adopting automated platforms to manage their third-party risks.  NAVEX Global is at the forefront of this effort through its RiskRate automated platform. Chris Bailey, Product Manager, NAVEX Global, RiskRate Manager, and Stephen Gooding, Senior Director, Sales Specialist, NAVEX Global RiskRate, join Michael Volkov to discuss current third-party risk trends and developments, including common issues that need to be addressed.  Chris and Stephen have several years experience working with companies to develop and implement efficient solutions to the third-party risk issue.

Global companies face extraordinary risks through their reliance on third-party agents, distributors, consultants and vendors/suppliers.  Federal prosecutors and regulators have had a record year in FCPA and sanctions enforcement.  To mitigate these risks, global companies are quickly adopting automated platforms to manage their third-party risks.  NAVEX Global is at the forefront of this effort through its RiskRate automated platform. Chris Bailey, Product Manager, NAVEX Global, RiskRate Manager, and Stephen Gooding, Senior Director, Sales Specialist, NAVEX Global RiskRate, join Michael Volkov to discuss current third-party risk trends and developments, including common issues that need to be addressed.  Chris and Stephen have several years experience working with companies to develop and implement efficient solutions to the third-party risk issue.      

Episode 120 -- Interview of NAVEX Global Chris Bailey and Stephen Gooding

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Episode 119 -- The Ericsson FCPA Settlement

OFAC's aggressive enforcement program continues.  Recently, OFAC announced settlements with Apollo Aviation and Apple.  Both of these cases underscore the importance of enhancing OFAC compliance programs. In this Episode, Michael Volkov reviews the two cases and the specific lessons learned.

OFAC's aggressive enforcement program continues.  Recently, OFAC announced settlements with Apollo Aviation and Apple.  Both of these cases underscore the importance of enhancing OFAC compliance programs. In this Episode, Michael Volkov reviews the two cases and the specific lessons learned.    

Episode 118 -- OFAC Enforcement Update and Lessons Learned

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 co-CEO was convicted of FCPA charges. In this episode, Michael Volkov catches up on recent FCPA enforcement actions.

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 co-CEO was convicted of FCPA charges. In this episode, Michael Volkov catches up on recent FCPA enforcement actions.

Episode 117 -- FCPA Update: Samsung Settles FCPA Case; Braskem Former CEO Indicted; and Transport CEO Convicted

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

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Corruption Crime & Compliance

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