Steve Kroloff

Title/s:  Adjunct Faculty



Steve Kroloff has spent most of his career as in-house counsel in the retail pharmacy sector, manufacturing and pharmaceuticals. Currently he is an attorney with Axiom, on assignment with Boehringer-Ingelheim. Most recently he was counsel with ScharfBanksMarmor, LLC. Prior to that he was a Senior Director of Compliance for Avanir Pharmaceuticals, which followed his role as a Director of Global Compliance and Investigations with Oshkosh Corporation, with operations in more than 170 global locations. At Walgreens he held leadership roles in Human Resources, Compliance, Loss Prevention, and Investigations. Additionally, while at Walgreens he helped facilitate the Helpline program and was responsible for the Oshkosh and Avanir Helpline programs. He is known for troubleshooting and solving complex, highly visible and sensitive matters.

While in-house, Mr. Kroloff identified weaknesses and pursued matters involving audit, fraud, financial, labor and employment law, EEO and ethics and compliance. Also, he has successfully managed a corporate integrity agreement. Further, he developed a global centralized reporting process and implemented a global training program on investigative best practices. Mr. Kroloff collaborates, advises and counsels stakeholders, primarily senior executives, on issues related to regulatory and compliance risk areas, trends, risk mitigation and brand protection, while providing strategies and action plans to address the respective trends or risks.

During a vendor, contract fraud investigation, Mr. Kroloff identified a loss of $5 million. More importantly, he had the know-how to recover the funds from the vendor. Additionally, he investigated allegations regarding the FCPA and the UK Bribery Act. To proactively improve compliance, he implemented and conducted trainings on anti-corruption, anti-bribery and risk mitigation. Mr. Kroloff is an expert at sensitive investigations involving high-level executives, including issues such as travel and expense fraud, workplace violence, sexual harassment, hostile work environment, discrimination, theft, dishonesty, false claims, falsified company documents, compliance and ethics violations, violation of gift policies and allegations of violations of the PhRMA Code. Moreover, while at Oshkosh Corporation, he also addressed matters involving associates working in the Defense section of the company.

Mr. Kroloff is experienced in managing global legal, compliance and regulatory risk areas, and revising and/or developing policy, while remaining focused on ensuring fair and consistent corrective action. At Walgreens he developed the pharmacy loss prevention division, created an industry leading criminal background check program and has conducted reviews of processes and procedures to identify inefficiencies, gaps or unethical behavior.