An internal investigation is like reading a good novel. You begin the journey with a general expectation of what the novel or the “investigation” is about. As you learn more, the investigation gains momentum filled with moments of discovery, surprise and ultimately a basis for understanding.

In some cases, the end of the story (e.g. an oil well explosion) or dramatic event is known. In others, for example, a hotline report of alleged misconduct is substantiated after a thorough investigation involving a slow but steady understanding of what occurred, who was involved and how the scheme was executed.

In this Episode, Michael Volkov reviews the 5 common pitfalls in conducting an internal investigation.

The Department of Treasury's Office of Foreign Asset Control ("OFAC") continues to bring sanctions enforcement actions. At the same time, OFAC is reiterating the importance of sanctions compliance program. Building on its May 2019 Framework for Sanctions Compliance Program, OFAC is sticking to its word -- setting forth sanctions compliance program requirements and holding companies accountable for sanctions program violations.

In this Episode, Michael Volkov reviews recent enforcement actions, expanded Belarus sanctions, and continuing compliance expectations.

Chief compliance officers recognize the importance of conducting robust audits of their compliance programs. The audit process requires a delicate balance between qualitative and quantitative measures.

As corporate compliance programs build data analytics and technological capabilities, CCOs have to tailor the audit program to incorporate data as an effective measure of a compliance program.

In this Episode, Michael Volkov reviews strategies for conducting compliance program audits.

The culture bandwagon is picking up steam.  Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations.  In its latest corporate compliance guidance, the Justice Department, along with numerous regulatory agencies continue to cite the importance of a company’s  “culture of compliance.”

But when it comes to defining the terms, how to manage a company’s culture and how to measure, monitor and measure a company’s culture – everyone responds with a blank stare.  That is when we hear the Justice Potter Stewart famous definition of obscenity, “I know it when I see it.”

To provide my own perspective on some of these issues, I am dedicating this podcast episode to corporate culture.  My answers may not be “correct” or even “persuasive,” but the dialogue has to begin.  I have long advocated for practical approaches to defining, managing and maintaining a company’s culture.  As I often write, culture is a company’s most important “internal control.”  

LRN recently issued its second of three annual reports on ethics and compliance program effectiveness.  The second report focuses on board engagement with ethics and compliance and lessons learned from the COVID-19 pandemic.

David Greenberg, a Special Advisor to LRN, joins us to discuss the interesting results of the LRN report.

The LRN report can be downloaded at https://lrn.com/