Tom Fox and Michael Volkov Look at Incentives for Self-Disclosure

Tom Fox and Michael Volkov Look at Incentives for Self-Disclosure

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom Fox welcomes back Michael Volkov as they take a deep dive into the ABB, Albemarle and SAP FCPA enforcement actions to try and unpack the DOJ’s pivot away from heavy penalties for recidivists to prioritizing self-disclosure above all else. Volkov's perspective on the Department of Justice's (DOJ) FCPA enforcement actions is both critical and analytical, shaped by his extensive experience. He underscores the necessity of transparency and explanation in the factors considered by the DOJ, highlighting its significance to practitioners in the field. Volkov also recognizes the shift in DOJ policy towards data-driven compliance, requiring companies to provide data to substantiate their conclusions and demonstrate their compliance efforts. He further notes the evolving landscape of voluntary disclosure and remediation, suggesting these areas are now pivotal in the DOJ's enforcement approach. Volkov's insights reflect a nuanced understanding of the changing dynamics in FCPA enforcement and the imperative for companies to adapt to these shifts. Key Highlights: Importance of Cooperation in Corporate Enforcement Cases Incentivizing Self-Disclosure in DOJ's FCPA Enforcement Increased Penalty Reduction for Voluntary Self-Disclosure DOJ's Evolving Approach to Corporate Penalties Benefits of Voluntary Self-Disclosure in Enforcement Resources: Volkov Law Group Corruption, Crime and Compliance Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on Ethico and a free White Paper on top compliance issues in 2024, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices

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9/11 Twenty-Five Years Later: Part 6: John Lee Dumas - “I Knew I Was Going to War”

9/11 Twenty-Five Years Later: Part 6: John Lee Dumas - “I Knew I Was Going to War”

Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast series so that we never forget. ...

11 Sep 19min

9/11 Twenty-Five Years Later: Part 5: Scott Moritz – It Changed Overnight

9/11 Twenty-Five Years Later: Part 5: Scott Moritz – It Changed Overnight

Ed. Note: Five years ago, Tom Fox looked back on 9/11 in a 20-year retrospective. This week is the 25th anniversary of that event. We will be rerunning this award-winning podcast so we never forget. ...

10 Sep 23min

9/11 Twenty-Five Years Later: Part 4: Eric Feldman – A Wake Up Call

9/11 Twenty-Five Years Later: Part 4: Eric Feldman – A Wake Up Call

Ed. Note: Five years ago, Tom Fox looked back on 9/11 in a 20-year retrospective. This week is the 25th anniversary of that event. We will be rerunning this award-winning podcast so we never forget. ...

9 Sep 17min

9/11 Twenty-Five Years Later: Part 3: Alex Dill – Patriot Act: The AML Response to Terrorist Threats

9/11 Twenty-Five Years Later: Part 3: Alex Dill – Patriot Act: The AML Response to Terrorist Threats

Ed. Note: Five years ago, Tom Fox looked back on 9/11 in a 20-year retrospective. This week is the 25th anniversary of that event. We will be rerunning this award-winning podcast so we never forget. ...

8 Sep 19min

9/11 Twenty-Five Years Later: Part 2: Juan Zarate - The Treasury Department Responds

9/11 Twenty-Five Years Later: Part 2: Juan Zarate - The Treasury Department Responds

Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast so that we never forget. On the ...

7 Sep 18min

9/11 Twenty-Five Years Later: Part 1: Gabe Hidalgo - Needing to Make a Difference

9/11 Twenty-Five Years Later: Part 1: Gabe Hidalgo - Needing to Make a Difference

Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast so that we never forget. On the ...

6 Sep 20min

Mara Senn on AI-Native, Human-in-the-Loop Investigations for Compliance

Mara Senn on AI-Native, Human-in-the-Loop Investigations for Compliance

In this episode, Tom Fox welcomes Mara Senn, founder and CEO of Ethakos, about her path from big law and a decade as a partner at Arnold & Porter to anti-corruption work at the Kleptocracy Initiative,...

31 Aug 31min

Charisma Doesn’t Scale, Controls Do: Compliance Lessons from Ted Lasso

Charisma Doesn’t Scale, Controls Do: Compliance Lessons from Ted Lasso

In this episode, I take things in a very different direction. Last week I did a 5-part blog post series on leadership lessons from the hit TV show Ted Lasso. I took those 5 blog posts and fed them int...

24 Aug 24min

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