Admit It – Your Compliance Program is Not Really “Effective”

Despite his praise for chief compliance officers' character, commitment, and resourcefulness, Michael Volkov makes a candid and sobering assessment: "Your compliance program does not meet the requirements for an 'effective' program as set forth in the DOJ and OFAC guidance documents, nor does it satisfy best practices." Despite this, every CCO routinely describes their program as effective, Volkov notes.