Michael Volkov

When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts. Some would argue that DOJ has been consistent all along. The truth, like most issues, lies somewhere between the extremes.

As always, I tend to repeat myself. However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals. DOJ has warned everyone, repeated this message in various speeches and, most importantly, assigned the resources — 25 new federal prosecutors to enforce sanctions and export controls — to back up its enforcement program.

I always enjoy retrospective “year in review” postings to start off the new year. For years, I have sought to identify and capture important compliance trends, typically focused on specific professionals in the compliance arena. This year, however, is a little different.

A Top 5 list should be viewed with suspicion — it is often just a headline grabbing posting with the clear purpose to gain readers’ attention. In...

When it comes to data privacy and regulation of personal information, United States companies face a number of major challenges. Compliance is not easy when you have fast-moving targets. The single biggest cause of this complex environment is the failure of the United States Congress to enact a federal data privacy law. Trust me, on this point, I know how difficult this can be — decades ago, a bipartisan effort was made to enact such legislation, only to be derailed by various lobbying interests representing significant stakeholders on the issue. I will not bore you on exactly how these interests lined up, but suffice it to say, these interests are still present and actively pushing against a federal data privacy regime.

The technology revolution and the rise of information and data permeates every aspect of our economy and daily lives. It is not surprising then that the Department of Justice and other law enforcement agencies are embracing data analytics as a new enforcement tool. DOJ is fast embracing data as a new and valuable source of detection.

LRN’s “2024 Ethics & Compliance Program Effectiveness Report” validates a central lesson from over 10 years of primary research — values-based programs are not only the most effective but also correlate strongly with reduced risk and better business outcomes.

There are some things you learn best in calm, and some in storm. Willa Cather

If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm. However,...

The past two years brought heightened scrutiny to supply chain risks and human rights violations, and time is running out to ensure your organization...