Corruption Crime & Compliance

Companies have to implement a robust policy management program.  In today's risky environment, companies should automate a robust policy management program that requires regular review, assessment and updating of policies and procedures.  A policy management program should be created consisting of key constituencies to ensure that policies and procedures are current, effective, and appropriately tailored to the company's risk profile. In this episode, Michael Volkov outlines considerations in establishing and implementing a robust policy and procedures management program.

In a special podcast episode, I take time out from the legal and compliance world to discuss the wonderful island of Sicily, Italy.  To explain and provide an introduction to Sicily, and in particular the western region, I interview my wife, Rosetta Sciacca, about Sicily, its people, its culture and its cuisine. Happy Fourth of July!!!

The Justice Department has released two important documents that provide guidance to compliance practitioners as to compliance program best practices: (1) The FCPA Guidance; and (2) The Evaluation of Corporate Compliance Programs.  In combination, these two documents provide important compliance program guidance. In this episode, Michael Volkov discusses various issues related to ethics and compliance program best practices.

Global companies face serious challenges in the design and implementation of compliance programs to meet increasing risks in emerging markets.  As global companies grow, so do compliance programs. The specific design and structure of a global compliance programs presents numerous challenges requiring balancing of various factors, including consistency across the organization, economies of scale and scope, and flexibility to meet local needs and concerns.  In carrying out this process, a compliance program has to maintain the support of its primary audience -- the business. In this episode, Michael Volkov discusses the issues that have to be addressed, and the balancing of competing interests in the delicate design of a global compliance program.

An increasing number of chief compliance officers report directly on a monthly basis to the Chief Executive Officer.  As the compliance profession has earned independence and empowerment, CCOs are now part of the C-Suite and need to develop a positive relationship with the CEO to support the company's ethics and compliance program. In doing so, CCOs need to ask themselves two important questions: (1) what type of CEO does the company have?; and (2) how should the CCO position the ethics and compliance program to gain the maximum support from the CEO? In this episode, Michael Volkov discusses strategies for a CCO to maximize the CEO's support of the company's ethics and compliance program.

Compliance professionals are learning about new technologies that are quickly evolving to aid the compliance function.  We hear regularly about the promise of artificial intelligence and block chain technology.  These new developments will have a significant impact on compliance.  But for now there are other areas where technology can help compliance programs today, including automation, data collection and analytics and monitoring capabilities. In this episode, Michael Volkov discusses the technology horizon and practical steps that can be taken today to leverage compliance program activities using technology.

Research has consistently demonstrated that an ethical corporate culture results in increased profits and sustainable growth.  Companies with a positive culture have lower rates of employee misconduct, increased employee productivity, and lower employee turnover.  All of these factors lead to higher growth rates, improved employee morale, and a reduced risk of misconduct and government investigation. This basic premise holds true: when ethical values are embedded in a company’s culture, respected in the company’s day-to-day operations and decision-making, and reflected in the trust among managers and employees, the company’s financial performance improves. While the value of a strong corporate culture is clear, a positive corporate culture does not always develop organically.  Companies have to devote attention to measure, manage, and promote an ethical culture.  Culture is a critical element of a compliance program and should be managed as such. In this episode, Michael Volkov discusses how to conduct a corporate culture assessment.    

Tom Fox is a thought leader for the ethics and compliance profession.  He is a prolific writer who has produced a steady body of work -- podcasts, books, blogs, articles -- to advance the compliance function.  He is knowledgeable, practical and insightful on how to implement and maintain an effective compliance program. Tom has just released a new and important book -- The Complete Compliance Handbook.  His latest book is the culmination of years of writing, insights and leadership. In this episode, Mike Volkov interviews Tom about his new book, his perspective on the compliance function and the insights he has gained over the years. To purchase a copy of The Complete Compliance Handbook on Amazon.com click here. To purchase an autographed copy of The Complete Compliance Handbook from the author click here.  

Special Counsel Mueller's investigation of possible connections between the Trump campaign and Russia has been dominating the country's attention.  in recent weeks, the US Attorney's separate investigation of Michael Cohen's activities has been gaining attention as well.  These two significant investigations are moving at a rapid pace with new developments each day. Michael Volkov discusses these investigations and provides his insights as a former prosecutor as to the likely course of the investigations and current topics of interest.

Two recent ethics and compliance surveys and studies provide important information on ethics and compliance program trends.  The first is LRN’s 2018 Ethics and Compliance Program Effectiveness Report.  The second is the Ethics and Compliance Initiative Global Business Ethics Survey. In this episode, Michael Volkov reviews the two surveys and studies and the implications for ethics and compliance program practitioners.