Exclusive to Corporate Compliance Insights The Justice Department and SEC were very clear in the FCPA Guidance – they have no patience for a “paper” compliance program. Here is the relevant quote: “DOJ and SEC have often encountered companies with compliance programs that are strong on paper but that nevertheless…

This article originally appeared in Michael Volkov’s blog, Corruption, Crime & Compliance, and is reprinted with permission. Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance. The FCPA Guidance…

This article was reprinted with permission from Michael Volkov’s Corruption Crime & Compliance. I continue to be astounded by one simple fact (candidly there are others) – companies do not understand that creating and maintaining an ethical culture improves bottom-line financial performance. A commitment to ethics as an enhancement to…

This article originally appeared in Michael Volkov’s blog, Corruption, Crime & Compliance, and is reprinted with permission. People love to make mountains out of mole hills. Or to put in another way (as my daughter might say), “She/he is a drama freak.” When it comes to structuring a compliance and…