No Result
View All Result
SUBSCRIBE | NO FEES, NO PAYWALLS
MANAGE MY SUBSCRIPTION
NEWSLETTER
Corporate Compliance Insights
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
No Result
View All Result
Corporate Compliance Insights
Home Compliance

Compliance Attitudes in High-Risk Markets

by Michael Volkov
December 12, 2014
in Compliance
Compliance Attitudes in High-Risk Markets

This article was republished with permission from Michael Volkov’s blog, Corruption, Crime & Compliance.

A Chief Compliance Officer has a direct responsibility to promote the company’s business. That sounds like a controversial statement, but it is not. Every officer and employee of a company has that responsibility.

A CCO has a job: to design and implement an effective ethics and compliance program to detect and prevent code of conduct and legal violations. As the business grows, the CCO’s responsibilities increase.

A company that decides not to enter a financially lucrative market, such as Brazil, Russia, India or China because of “compliance” concerns is suffering from narrow-mindedness. The CEO responsible for that decision should be terminated, unless the CEO’s analysis found that the “cost” of compliance was greater than the projected increase in profits.

Senior managers, however, rarely – if ever – look at the issue that way. Instead, they may react to gut-level factors that suggest a specific country is “risky.” That is a serious mistake.

A CCO should be able to design and implement an effective compliance program for any high-risk market.   The CCO’s job is not to recommend against entering a high-risk market – rather, the CCO’s job is to design a program and develop a realistic budget for implementing the ethics and compliance program in that particular market.

The business decision should be framed differently; assuming the company can enter the market and increase its revenues and profits from sales in that market, such benefits have to be weighed against the increased costs required for compliance. That is not a difficult analysis, nor is it an issue that senior management should avoid by generalized claims that a market is too “risky” because of corruption concerns.

For this systematic analysis to occur, a CCO has to have a seat at the business table with other senior managers.   The CCO has to have legitimacy in the business operations and the credibility to offer analysis critical to consideration of expanding a business into a new and risky market.

CCOs that do not have a seat at the business table are likely to be excluded from participating in this critical business decision. Instead of having the CCO’s important voice at the table, senior managers are likely to influence a decision by offering generalized assessments of risk without carefully considering the issues.

To those businesses that fail to see the value of having a CCO at the senior management level, they will suffer from a serious myopia that will narrow business opportunities and potential profits. As we all know, a CCO deserves a seat at the senior executive table and will provide important business information needed for critical decisions.

Global companies have a responsibility to their shareholders – to make wise business decisions based on all available information. When a decision is made not to enter a market because of compliance risks, the Board and senior executives need to ensure that such an important decision was made with full consideration of compliance information.

As one example, Russia’s economy is expected to grow significantly in the next 10 years. Over the next 10 years, Russia is projected to have the largest increase in consumer spending. The implication for health care, retail, technology and related companies is mind boggling.

At the same time, everyone knows that expanding into Russia means a significant increase in compliance risks. That is where the CCO must apply his or her specific expertise – the company must plan for entering into Russia and must implement specific compliance strategies to ensure that the company can earn increased profits while avoiding significant compliance and enforcement risks.


Previous Post

The New Frontier in Anti-Corruption Efforts

Next Post

Do You Have a Cybersecurity Problem?

Michael Volkov

Michael Volkov

Michael-Volkov-leclairryan Michael Volkov is the CEO of The Volkov Law Group LLC, where he provides compliance, internal investigation and white collar defense services.  He can be reached at mvolkov@volkovlaw.com. Michael has extensive experience representing clients on matters involving the Foreign Corrupt Practices Act, the UK Bribery Act, money laundering, Office of Foreign Asset Control (OFAC), export controls, sanctions and International Traffic in Arms, False Claims Act, Congressional investigations, online gambling and regulatory enforcement issues. Michael served for more than 17 years as a federal prosecutor in the U.S. Attorney’s Office in the District of Columbia; for five years as the Chief Crime and Terrorism Counsel for the Senate Judiciary Committee, and Chief Crime, Terrorism and Homeland Security Counsel for the Senate and House Judiciary Committees; and as a Trial Attorney in the Antitrust Division of the U.S. Department of Justice. Michael also maintains a well-known blog: Corruption Crime & Compliance, which is frequently cited by anti-corruption professionals and professionals in the compliance industry.

Related Posts

launch visual lease esg steward

Visual Lease Launches ESG Tool for Asset Portfolios

by Corporate Compliance Insights
March 31, 2023

Lease software provider Visual Lease announced it has launched a new product, VL ESG Steward,  designed to help organizations track...

PW FCPA Enforcement and Anticorruption 2022 Review_f

FCPA Enforcement & Anti-Corruption Developments

by Corporate Compliance Insights
March 30, 2023

The year that was in FCPA & anti-corruption efforts 2022: A Year in Review FCPA Enforcement & Anti-Corruption Developments What’s...

JTC ESG and Impact Investing_f

The Evolution of ESG & Impact Investing: Are You Ready?

by Corporate Compliance Insights
March 30, 2023

Making money *and* doing the right thing Survey Report The Evolution of ESG & Impact Investing: Are You Ready? What’s...

Regology 2023 State of Regulatory Compliance_f

2023 State of Regulatory Compliance

by Corporate Compliance Insights
March 30, 2023

Understanding the impact of regulatory challenges Survey Report 2023 State of Regulatory Compliance What’s in this report from Regology:As the...

Next Post
Do You Have a Cybersecurity Problem?

Do You Have a Cybersecurity Problem?

Compliance Job Interview Q&A

Jump to a Topic

AML Anti-Bribery Anti-Corruption Artificial Intelligence (AI) Automation Banking Board of Directors Board Risk Oversight Business Continuity Planning California Consumer Privacy Act (CCPA) Code of Conduct Communications Management Corporate Culture COVID-19 Cryptocurrency Culture of Ethics Cybercrime Cyber Risk Data Analytics Data Breach Data Governance DOJ Download Due Diligence Enterprise Risk Management (ERM) ESG FCPA Enforcement Actions Financial Crime Financial Crimes Enforcement Network (FinCEN) GDPR HIPAA Know Your Customer (KYC) Machine Learning Monitoring RegTech Reputation Risk Risk Assessment SEC Social Media Risk Supply Chain Technology Third Party Risk Management Tone at the Top Training Whistleblowing
No Result
View All Result

Privacy Policy

Founded in 2010, CCI is the web’s premier global independent news source for compliance, ethics, risk and information security. 

Got a news tip? Get in touch. Want a weekly round-up in your inbox? Sign up for free. No subscription fees, no paywalls. 

Follow Us

Browse Topics:

  • CCI Press
  • Compliance
  • Compliance Podcasts
  • Cybersecurity
  • Data Privacy
  • eBooks Published by CCI
  • Ethics
  • FCPA
  • Featured
  • Financial Services
  • Fraud
  • Governance
  • GRC Vendor News
  • HR Compliance
  • Internal Audit
  • Leadership and Career
  • On Demand Webinars
  • Opinion
  • Resource Library
  • Risk
  • Uncategorized
  • Videos
  • Webinars
  • Well-Being
  • Whitepapers

© 2022 Corporate Compliance Insights

No Result
View All Result
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe

© 2022 Corporate Compliance Insights

Welcome to CCI. This site uses cookies. Please click OK to accept. Privacy Policy
Cookie settingsACCEPT
Manage consent

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
CookieDurationDescription
cookielawinfo-checbox-analytics11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checbox-functional11 monthsThe cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checbox-others11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-necessary11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-performance11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy11 monthsThe cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
SAVE & ACCEPT