Compliance Man Chooses the Target

Compliance Man is back for a new season! Get ready for a EuroTrip with Tom Fox and Tim Khasanov-Batirov on their hit podcast, Compliance Man! Join Tom Fox and co-host Timur Khasanov-Batirov on a Euro trip as they delve into the world of Poland's Compliance Revolution with guest Piotr Żyłka. The implementation of the Whistleblowing Directive and the Corporate Sustainability Due Diligence Directive into the Polish Legal System could be a major step forward in the fight against corruption. Tom Fox and Tim Khasinov-Batirov had a conversation with Piotr Żyłka, an author of the It's All About Compliance blog, publisher, and compliance platform in Europe, to discuss the Polish compliance scene and the need for a Polish FCPA. Piotr discussed the banking law requirements, the DOJ guidelines, the New York City Bar Association paper, and the influence of foreign companies on compliance controls in Poland. He also highlighted the need for trainings, engagement of top management, and internal controls like KYC. Tom and Tim thanked Piotr for his time and knowledge and invited him to come back on the podcast to share his views.  Key Highlights ·      Internal Controls in Poland ·      Compliance in Poland ·      Sanctions Compliance ·      A Polish FCPA Needed?  Resources  Piotr Żyłka on LinkedIn It's All About Compliance  Tim Khasanov-Batirov on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance Man is back for a new season! Get ready for a EuroTrip with Tom Fox and Tim Khasanov-Batirov on their hit podcast, Compliance Man! Join Tom Fox and co-host Tim Khasanov-Batirov on a Euro trip as they delve into the world of internal controls in Europe, with special guest Alex Movchan, president of the Institute for Internal Controls in Central Europe and chief risk officer at a global medical device company. They discuss internal control strategies and best practices, including SOX and COSO frameworks, the importance of IT general controls, and adapting to changes in the market. The episode also explores the challenges of merging companies with different internal control frameworks, tailoring internal controls to specific country offices, and promoting compliance initiatives to top management. Don't miss out on this insightful conversation about compliance and risk management. Tune in to the “Compliance Man: Eurotrip-Internal Controls in Europe,” hosted by Tom Fox and Tim Khasanov-Batirov. Key Highlights: Internal Controls in Different Regions Importance of Internal Controls in Emerging Markets Compliance Frameworks in Europe Updating Internal Control Frameworks in Response to ESG Structuring Internal Controls for Decision-making Mechanisms Importance of Compliance Officer and Internal Control Collaboration Notable Quotes: “Internal controls are the backbone of every compliance program; what we need is to have control over the situation, which means that you have to have internal controls in place.” “When it comes to private owners and family-owned business, this is like a very different owner to owner.” “We need to adapt faster as the internal controls professionals and as business managers, we need to update to the changes faster because the ones who update faster, the internal control frameworks, will be on the top of the markets.” “Half of the companies just don't know how to start.”  Resources  Alex Movchan on LinkedIn  Tim Khasanov-Batirov on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance Man is back for a new season! Get ready for a EuroTrip with Tom Fox and Tim Khasanov-Batirov on their hit podcast, Compliance Man! Join Tom Tim as they chat with Andrea Cardoso, a compliance officer in the medical devices industry, about healthcare compliance in Europe. In their Euro trip series, they explore hot topics and share best practices, focusing on interactions with healthcare professionals and fair market value. With years of experience, Andrea highlights the importance of transparency and following certain principles to ensure compliance. Listen as they discuss the challenges of maintaining professionalism in the healthcare industry, understanding different rules and limitations in each country, and implementing effective compliance programs in multiple markets. Don't miss out on the insightful tips and suggestions, and reach out to be part of the discussion. Tune in to the Compliance Man podcast for valuable insights and expert advice. Key Highlights: Healthcare Compliance in Europe Compliance with event expenses and regulations in healthcare Compliance with HCP rules in Europe Video Calls and Challenges in Healthcare Industry Empowering Teams for Informed Decision Making What a difference 300 meters can make  Resources  Andrea Cardoso on LinkedIn  Tim Khasanov-Batirov on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance Man is back for a new season! Get ready for a EuroTrip with Tom Fox and Tim Khasanov-Batirov on their hit podcast, Compliance Man! In this episode, Compliance Man podcast hosts, Tom Fox and Tim Khasanov-Batirov, speak with compliance professional and founder of the Integrity Coordinator, Geert Vermeulen, about the challenges of implementing effective whistleblower policies in Europe. They discuss cultural differences, strict requirements on external whistleblowing, and the burden of proof on companies to show that retaliation did not occur. The speakers emphasize the importance of understanding cultural differences and developing precise policies to promote a speak-up culture. The conversation ends with a reflection on the evolution of whistleblower procedures in Europe and thoughts on where things might be headed in the future. This is a must-listen podcast for anyone interested in compliance and corporate culture.  Vermeulen highlights the challenge of implementing the directives into the national laws of member states, which has resulted in differences between states. Each state has its own specifications about what can be reported and what must not be reported. For instance, every state has different rules regarding protection against retaliation. Here are some tips to help cope with this challenge:  1. Get familiarized with the national laws of the member states where your organization operates.  2. Set up a streamlined procedure and ensure that all employees are aware of the internal complaints and whistleblowing process.  3. Ensure that your whistleblowing process is confidential, and that whistleblowers are protected against retaliation.  Key Highlights ·      Lack of tradition of whistleblowing in Europe ·      Whistleblowing in emerging markets ·      One world-wide whistleblowing program? ·      Whistleblower protection and communication ·      Interplay of EU Whistleblower Directive and GDPR ·      The evolution of whistleblowing in Europe  Resources  Geert Vermeulen on LinkedIn The Integrity Coordinator  Tim Khasanov-Batirov on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance Man is back for a new season! Get ready for a EuroTrip with Tom Fox and Tim Khasanov-Batirov on their hit podcast, Compliance Man! In the latest season, the dynamic duo will give you an exclusive look into Europe's top 5 areas of compliance perspective, featuring the GDPR compliance as a priority. Want to join the podcast? Be an active listener and pay close attention! The hosts break down the key challenges faced by compliance professionals in Europe and the US, including anti-corruption, ethical business practices, ESG frameworks and much more! Don't miss the chance to engage in a global conversation on ethics and compliance. Tune in now to Compliance Man!  Key Highlights ·      Tim Moves to The Netherlands ·      Compliance in Europe ·      Top Compliance Priorities in Europe and US ·      Ethical Business Conduct and ESG ·      European Businesses' ESG Prioritization  Notable Quotes  “In this season of Compliance Man, we entitled EuroTrip, and we're going to focus on hot topics for Europe from the compliance practitioner point of view. “You probably we can think of the following as the most important pieces of legislation or compliance areas from the European perspective.” “Pay big attention to data privacy.” “In the EU, we have ESG that is almost regulatory driven.” Resources Tim Khasanov-Batirov on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a new season of Compliance Man. This season is called True or False? In this series, I am joined by Tim Khasanov-Batirov, a compliance practitioner who focuses on compliance at international markets for over 20 years. Based on his work experience at six countries as in house compliance officer Tim now consults senior managers and compliance officers globally on complex ethics and compliance matters as partner and Head of Compliance practice for ETERNA LAW.   Tim is a co-founder of Compliance Club, an international community of practitioners. You can learn more about Tim, his Compliance Manillustrated series, a YouTube channel and request advice from him by clicking at Timur Khasanov-Batirov on Linked in.  Check out his profile on the ETERNA Law page here.  Today we have Maria Bulycheva, Compliance Officer with compliance working experience in 3 countries in construction, energy, automotive and logistics businesses. Today we will find out whether it is true that gifts is very important cultural courtesy but may lead to corruption. Highlights include: Should compliance professionals have an additional Code of Conduct? If so what are the legal implications? What about existing requirements? Join us for the next episode of Compliance Man: True or False? episode. If you disagree or wish to share your views on whistleblower topic please comment below. We will be glad to hear from you. Let's have a sincere global conversation together. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a new season of Compliance Man. This season is called True or False? In this series, I am joined by Tim Khasanov-Batirov, a compliance practitioner who focuses on compliance at international markets for over 20 years. Based on his work experience at six countries as in house compliance officer Tim now consults senior managers and compliance officers globally on complex ethics and compliance matters as partner and Head of Compliance practice for ETERNA LAW.   Tim is a co-founder of Compliance Club, an international community of practitioners. You can learn more about Tim, his Compliance Manillustrated series, a YouTube channel and request advice from him by clicking at Timur Khasanov-Batirov on Linked in.  Check out his profile on the ETERNA Law page here. Today, as promised we invited one of our active listeners to join us to discuss hot topics. We are Alexandra Zaytseva, LLM, EMBA, Compliance Officer at PEWETE Group, an energy company. Today we will find out whether it is true that gifts is very important cultural courtesy but may lead to corruption. Highlights include: How do you deal with the cultural differences in a country as vast as Russia? Does a monoculture really exist? What is cultural courtesy? Does gift giving lead to reciprocity? Join us for the next episode of Compliance Man: True or False? episode. If you disagree or wish to share your views on whistleblower topic please comment below. We will be glad to hear from you. Let's have a sincere global conversation together. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a new season of Compliance Man. This season is called True or False? In this series, I am joined by Tim Khasanov-Batirov, a compliance practitioner who focuses on compliance at international markets for over 20 years. Based on his work experience at six countries as in house compliance officer Tim now consults senior managers and compliance officers globally on complex ethics and compliance matters as partner and Head of Compliance practice for ETERNA LAW.   Tim is a co-founder of Compliance Club, an international community of practitioners. You can learn more about Tim, his Compliance Manillustrated series, a YouTube channel and request advice from him by clicking at Timur Khasanov-Batirov on Linked in.  Check out his profile on the ETERNA Law page here.   In each podcast, we will take on a different issue with Tim; a hot, very often a very provocative topic from the corporate's real life agenda and find out if is it true or false. It will be a tough and very straightforward talks. We invite you to participate in these discussions by commenting each podcast and proposing topics for True or False series. The most active listeners will be invited to join us. Let's have a sincere conversation! Today, as promised we invited one of our active listeners to join us to discuss hot topics. We are Alexandra Zaytseva, LLM, EMBA, Compliance Officer at PEWETE Group, an energy company. Today we will try to find if it is any easier now to investigate harassment cases. Highlights include: Why things are very different now regarding harassment cases? How has this made investigations bore more straight forward and more difficult? Is blackmail a real threat to corporations? Join us for the next episode of Compliance Man: True or False? episode. If you disagree or wish to share your views on whistleblower topic please comment below. We will be glad to hear from you. Let's have a sincere global conversation together. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a new season of Compliance Man. This season is called True or False? In this series, I am joined by Tim Khasanov-Batirov, a compliance practitioner who focuses on compliance at international markets for over 20 years. Based on his work experience at six countries as in house compliance officer Tim now consults senior managers and compliance officers globally on complex ethics and compliance matters as partner and Head of Compliance practice for ETERNA LAW.   Tim is a co-founder of Compliance Club, an international community of practitioners. You can learn more about Tim, his Compliance Man illustrated series, a YouTube channel and request advice from him by clicking at Timur Khasanov-Batirov on Linked in.  Check out his profile on the ETERNA Law page here. In each podcast, we will take on a different issue with Tim; a hot, very often a very provocative topic from the corporate's real life agenda and find out if is it true or false. It will be a tough and very straightforward talks. We invite you to participate in these discussions by commenting each podcast and proposing topics for True or False series. The most active listeners will be invited to join us. Let's have a conversation!  Today, as promised we invited one of our active listeners to join us to discuss hot topics. We are Alexandra Zaytseva, LLM, EMBA, Compliance Officer at PEWETE Group, an energy company. Today we will try to find out the state of women in the compliance profession. Is it increasing? Are we finally moving towards full inclusion? Highlights include: Are there differences in emerging markets and the US? What has led to entry of women in the compliance profession? Did the entry from the legal profession influence a disparity? Join us for the next episode of Compliance Man: True or False? episode. If you disagree or wish to share your views on whistleblower topic please comment below. We will be glad to hear from you. Let's have a sincere global conversation together. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a new season of Compliance Man. This season is called True or False? In this series, I am joined by Tim Khasanov-Batirov, a compliance practitioner who focuses on compliance at international markets for over 20 years. Based on his work experience at six countries as in house compliance officer Tim now consults senior managers and compliance officers globally on complex ethics and compliance matters as partner and Head of Compliance practice for ETERNA LAW.   Tim is a co-founder of Compliance Club, an international community of practitioners. You can learn more about Tim, his Compliance Man illustrated series, a YouTube channel and request advice from him by clicking at Timur Khasanov-Batirov at Linked in.   In each podcast, we will take on a different issue with Tim; a hot, very often a very provocative topic from the corporate's real life agenda and find out if is it true or false. It will be a tough and very straightforward talks. We invite you to participate in these discussions by commenting each podcast and proposing topics for True or False series. The most active listeners will be invited to join us. Let's have a sincere conversation! Today we will try to find out if only a legally trained professional can be a corporate compliance officer. Highlights include: What skills does a compliance officer need? Does a legal background provide these skills? How does a compliance professional support business in emerging markets? Join us for the next episode of Compliance Man: True or False? episode. If you disagree or wish to share your views on whistleblower topic please comment below. We will be glad to hear from you. Let's have a sincere global conversation together. Resources Tim on LinkedIn Tim on Eternal Law Eterna Law Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a new season of Compliance Man. This season is called True or False? In this series, I am joined by Tim Khasanov-Batirov, a compliance practitioner who focuses on compliance at international markets for over 20 years. Based on his work experience at six countries as in house compliance officer Tim now consults senior managers and compliance officers globally on complex ethics and compliance matters as partner and Head of Compliance practice for ETERNA LAW.   Tim is a co-founder of Compliance Club, an international community of practitioners. You can learn more about Tim, his Compliance Manillustrated series, a YouTube channel and request advice from him by clicking at Timur Khasanov-Batirov at Linked in.   In each podcast, we will take on a different issue with Tim; a hot, very often a very provocative topic from the corporate's real life agenda and find out if is it true or false. It will be a tough and very straightforward talks. We invite you to participate in these discussions by commenting each podcast and proposing topics for True or False series. The most active listeners will be invited to join us. Let's have a sincere conversation! Today we will try to find out if it is a negative when compliance is a part of the corp legal function. Highlights include: What is the role of the corporate legal function in the US and emerging markets. Who should compliance report up to in an organization? What happens when compliance says NO? Resources Tim on LinkedIn Tim on Eternal Law Eterna Law Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a new season of Compliance Man. This season is called True or False? In this series, I am joined by Tim Khasanov-Batirov, a compliance practitioner who focuses on compliance at international markets for over 20 years. Based on his work experience at six countries as in house compliance officer Tim now consults senior managers and compliance officers globally on complex ethics and compliance matters. Tim is a co-founder of Compliance Club, an international community of practitioners. You can learn more about Tim, his Compliance Man illustrated series, a YouTube channel and request advice from him by clicking at Timur Khasanov-Batirov on Linked in.   In each podcast, we will take on a different issue with Tim; a hot, very often a very provocative topic from the corporate's real life agenda and find out if is it true or false. It will be a tough and very straightforward talks. We invite you to participate in these discussions by commenting each podcast and proposing topics for True or False series. The most active listeners will be invited to join us. Let's have a sincere conversation! Today we will try to find out whether companies are eager to be ethical even if they do not feel pressure of potential investigation or regulatory sanctions. Highlights include:  Enforcement practice establishes standards and principles that create a right compass, allowing not only to act ethically at person's view but also to avoid sanctions for the company. Knowledge of applicable anticorruption laws, enforcement trends and ethical behaviors of top management lead to success. Do companies act more aggressively due to low risk of enforcement. Join us for the next episode of Compliance Man: True or False? episode. If you disagree or wish to share your views on whistleblower topic please comment below. We will be glad to hear from you. Let's have a sincere global conversation together. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a new season of Compliance Man. This season is called True or False? In this series, I am joined by my colleague Tim Khasanov-Batirov, a compliance practitioner who focuses on compliance at international markets for over 20 years. Based on his work experience at six countries as in house compliance officer Tim now consults senior managers and compliance officers globally on complex ethics and compliance matters. On top of that Tim is a co-founder of Compliance Club, an international community of practitioners. You can easily learn more about Tim, his Compliance Man illustrated series, a YouTube channel and request advice from him by clicking at Timur Khasanov-Batirov at Linkedin.    In each podcast, we will take on a different issue with Tim; a hot, very often a very provocative topic from the corporate’s real life agenda and find out if is it true or false. It will be a tough and very straightforward talks. We invite you to participate in these discussions by commenting each podcast and proposing topics for True or False series. The most active listeners will be invited to join us. Let’s have a sincere conversation! Today we talk about whistleblowers. ‘Behind the scenes” corporates are confessing that: They do not like whistleblowers; Whistleblowers bring problems; They do not know how to protect whistleblowers.  Yet whistleblowers bring many pluses. Some are Whistleblowers can protect company and management from big problems; Whistleblowers signal on unethical and unlawful practices. Join us for the next episode of Compliance Man: True or False? episode. If you disagree or wish to share your views on whistleblower topic please comment below. We will be glad to hear from you. Let’s have a sincere global conversation together. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to Compliance Man Chooses the Target with Tim Khasanov-Batirov series. Today we a have a special Christmas podcast. Our goal is to highlight matters that should be on agenda of practitioners that deploy compliance programs in industries or countries of active FCPA enforcement. We target three specific matters that you might like to address in the course of implementation of your compliance program. Today we will focus on classical but evergreen topic of gifts giving.  Target #1: How to kill your corporate gifts policy? If you work at the HQ of an international corporation and believes that all questions with gifts giving in your company are already settled many years ago you might be wrong. The most unpleasant news could be that the reason of this problem are not necessarily rogue managers in the fields, who deliberately violate rules. Look at your global gifts policy and if it says something like “gifts of nominal value are allowed” there is big chance that the problem is already there. Assume that in some countries at which your company operates per local legislation (or updates in the legislation) gifts giving to state officials are prohibited as such or this process is a subject to certain limitations. In ideal case your global policy is adopted in each jurisdiction by local compliance team. We recommend checking out if it is really so as most likely you don’t have compliance folks in each jurisdiction of corporate presence. Another typical problem is when simultaneously in each respective jurisdiction there are two policies. The global one, which allows petty gifts, even if it contains clause on prevalence of local laws and a tailored gifts policy adopted by an office in the respective jurisdiction. In reality the personnel in the fields will get confused which policy to follow.       Target #2: Toxic Gifts  The FCPA enforcement practice clearly demonstrates absolute ban on entertainment of state officials and PEPs by companies. It is also clear that it is forbidden to give luxurious gifts and even sometimes small gifts if there is a corruption intent. Still there is a grey area for list of non-luxurious gifts which still might be considered as non-appropriate from my point of view even if there is no intent to influence decision taking. I mean alcohol, for instance. In some jurisdictions it is a common practice to give alcohol as Christmas gift. From my prospective it is not right but still it is just a personal view, not a law.            Target #3: Non-Toxic Gift We have touched a couple of problems related to gifts giving and now it is time to get back to talking about pleasant sides of Christmas. It is time to say that Compliance Man has launched a channel at you tube called ‘Compliance Man by Timur Khasanov-Batirov” aimed on sharing compliance tips with professional community. The first video of the series called “1001 Compliance days” is available here. Please feel free to comment and subscribe. Merry Christmas to everyone from Compliance Man!    Join us for the next episode of Compliance Man Chooses the Target with Tim Khasanov-Batirov in 2020. 

Welcome to the special 10th anniversary celebration of Compliance Man Chooses the Target. In honor of this celebration with take things in a different direction today as Tim Khasanov-Batirov and myself are joined by Irfan Ahmen. Irfan is a Chief Compliance Officer at Dr. Reddy’s ( https://www.drreddys.com/ ) an international pharmaceutical company headquartered in India. He is also Tim's boss. Irfan leads the Dr. Reddy's compliance team globally, driving compliance across the organization at a global level thereby protecting company from any financial and reputational risks arising out of non-compliance and ensuring a culture of compliance and ethics in the organization. I know you will enjoy hearing about Irfan's journey in compliance, the realities of doing compliance in India and where compliance may be headed in the world's largest democracy. 

Welcome to Episode 9 of Compliance Man Chooses the Target with Tim Khasanov-Batirov.The goal is to highlight matters that should be on agenda of practitioners that deploy compliance programs in industries or countries of active anticorruption enforcement. In this podcast series, Compliance Man will target three specific matters that you might like to address in the course of implementation of your compliance program. Today we will focus on improvement of daily compliance activities.   Target #1: Communications with Colleagues It is about trust. Success of your corporate compliance program depends on whether your colleagues feel comfortable to approach you without fear. You might have a pile of policies but in the reality of any company, specifically when we talk about emerging markets personal trust to Compliance officer is essential. On practice, this allows to implement proactive rather than reactive approach, when personnel approaches compliance officer with their ethical dilemmas prior to acting.       Target #2: Generation Y Recently I was teaching Compliance class at the Summer School at Baltic Federal University. I have noticed that for generation Y and specifically for those who were born in 1990-s methods of teaching/training compliance should differ from techniques used for people of older age. The main difference is that youngsters are able and used to deploy internet search much more actively comparing to older folks. In addition generation Y feels comfortable to self-educate themselves due to availability of gadgets using which they can google virtually any compliance related information. I would suggest having in mind the above mentioned in the course of preparation of compliance trainings to young personnel.           Target #3: Keep your Compliance Eyes Open The biggest mistake compliance officer could make is to limit himself to a couple of areas, which historically are associated with compliance department’s area of responsibility as drafting anticorruption policies for instance without paying attention to business processes, projects, corporate initiatives which might also contain FCPA risk but needs analytical efforts from Compliance officer to be spotted.  It is much easier in daily routine to look solely on gifts practices as it contains a compliance associated ‘hashtag’ GIFT than to mitigate risks integrated in business processes.  Such situation is depicted in one of the releases of Compliance Man illustrated series   http://complianceinpostussr.com/compliance-man-of-integrity-corp-episode-7-mistakes/#comment-19 The best way to manage the ‘hashtag’ approach is a compliance risk register. Just go to the process, project or corporate initiative where the FCPA risk might take place. Keep your compliance eyes open to evolving corporate reality.      Join me for the next episode of Compliance Man Chooses the Target with Tim Khasanov-Batirov. Learn more compliance tips from Tim Khasanov-Batirov at: http://complianceinpostussr.com/& http://complianceinpostussr.com/blog/

Welcome to Episode 8 of Compliance Man Chooses the Target with Tim Khasanov-Batirov. The goal is to highlight matters that should be on agenda of practitioners that deploy compliance programs in industries or countries of active anticorruption enforcement. Today we will focus on future of compliance in the reality of emerging markets. Target #1: What is Compliance? During last ten years, Compliance Man has been witnessing interesting phenomena. Compliance became a popular concept in business and legal communities. Many countries have adopted laws, which deploy compliance philosophy. Many corporations have huge compliance departments. In the very same time, there is no universally acknowledged methodology what to consider compliance system or compliance as such. This problem extends far beyond borders of emerging markets being a global challenge for professional community. Compliance as professional occupation has to pass certain stages of development like internal audit did in early 2000s in order to form universally recognized standards. Target #2: Next Generation of Compliance Professionals Based on what we have discussed earlier on we came to another challenge, which is preparation of new generation of compliance professionals. Let’s take the following example. When employer hires a graduate from a law or medical school, he/she has a clue what knowledge and skills a graduate has. In case of hiring a young compliance professional, it is impossible to evaluate his/her academic proficiency as there are so many courses, trainings, academic programs which might not share even very basic compliance methodical approaches.      Target #3: Think Globally Act Locally? Implementation of corporate anticorruption program in the reality of emerging markets requires necessity to address both local legislation and extraterritorial laws as for instance UKBA and FCPA. Big multinationals also have piles of internal ethical rules to be deployed at their subsidiaries internationally. In addition, as previously mentioned we have been witnessing a boom of local compliance initiatives and sometimes new laws which companies have to follow as well. As a result, compliance officer faces the necessity to implement many requirements, which sometime might contradict to each other. This situation is depicted in one of the releases of Compliance Man illustrated series http://complianceinpostussr.com/compliance-man-of-integrity-corp-episode-4-it-is-about-tailoring/ To be effective and in order not to get lost in various laws, ethical concepts and compliance philosophies it is right time for professional community to agree on basic principles of corporate compliance system, which will be acknowledged as minimal standards by practitioners worldwide.        Join me for the next episode of Compliance Man Chooses the Target with Tim Khasanov-Batirov. Learn more compliance tips from Tim Khasanov-Batirov at: http://complianceinpostussr.com/& http://complianceinpostussr.com/blog/

Welcome to Episode 7 of Compliance Man Chooses the Target with Tim Khasanov-Batirov. The goal is to highlight matters that should be on agenda of practitioners that deploy compliance programs in industries or countries of active FCPA enforcement. In next three minutes, we will target three specific matters that you might like to address in the course of implementation of your compliance program. Today we will focus on teamwork. Target #1: Who is Your Team? While this question might sounds straightforward when we refer to organizational chart, the answer is not that obvious when we talk about the whole organization. Do you have supporters of Compliance movement among top managers? Do middle management and junior staff help you in promotion ethics? Do you have influencers among respected middle-level managers in your Compliance team now? Who should be in your Compliance dream team? If you have answers on these questions, it is much easier to plan efforts and evaluate rate of success of your ethics’ efforts in each department. Based on my experience even single individual who heads business function in the organization can block or in contrary stimulate efficient collaboration between all his subordinates and Compliance department.    Target #2: Engagement of Personnel from Various Hierarchy Levels. Based on my experience it is essential to raise awareness and engage in respective ways personnel from all hierarchy levels. There are at least two reasons do that. The first one is that personnel tend to raise in the organization so your efforts in engagement each individual will be bringing positive impact on each stage of his or her career. The second reason is that managers (primarily at the senior level) from time to time are assigned with new areas of responsibility. Thus, if such a senior manager is your Compliance ambassador he will expand or strengthen Compliance philosophy at his new area of responsibility as well.          Target #3: Why Things Might Not Work Well? Three killers of teamwork within Compliance department: Absence of goals based on Key Performance Indicators for each individual;Duplication of functions among compliance folks;Absence of devotion to Ethics&Compliance in the team.Learn more compliance tips from Tim Khasanov-Batirov at: http://complianceinpostussr.com/& http://complianceinpostussr.com/blog/

Welcome to Episode 6 of Compliance Man Chooses the Target with Tim Khasanov-Batirovseries of podcasts. Our goal is to highlight matters that should be on agenda of practitioners that deploy compliance programs in industries or countries of active FCPA enforcement. In this episode, we will target three specific matters that you might like to address in the course of implementation of your compliance program. Today we will focus on Due Diligence in high risk markets. Learn more compliance tips from Tim Khasanov-Batirov at:  http://complianceinpostussr.com/&http://complianceinpostussr.com/blog/

Welcome to Episode 5 of Compliance Man Chooses the Target with Tim Khasanov-Batirov.My goal is to highlight matters that should be on agenda of practitioners that deploy compliance programs in industries or countries of active FCPA enforcement. In each episode, I target three specific matters that you might like to address in the course of implementation of your compliance program. Today we will focus on compliance risks in Russia.  Target #1: Compliance Program. Russia is number six in FCPA countdown of all times. In practice it means that, this jurisdiction should get your special attention in the course of deploying corporate compliance program. Your company could face risks in many business areas. What would be the best way to find out if you are on the safe side?  I suggest you to do assessment of the corporate compliance program in Russia based on the DOJ’s guidance called Evaluation of Corporate Compliance Programs.  The most effective way to do this exercise would be engagement of the outside counsel. While this tip might look obvious, I want to specifically mention the test, which should be addressed in order to get a full picture: vThe international team from counsel side should consist of both US lawyers who have practical experience in FCPA matter along with Russian attorneys who would be able to tailor the US recommendations in accordance with Russian legislation.   I will elaborate on importance of this test when we discuss the Target #3.  Target #2: Risk Assessment & Risk Appetite. The vital part of your efforts on global arena is FCPA risk assessment. There is no chance that any company would be able to spend millions of dollars spreading compliance resources on unnecessary or minor issues.    In the very same time on practice, I have seen that sometimes company were not clear on particular risks they were trying to mitigate. In plain language, they were just wasting compliance resources by doing something for the sake of doing something. To be effective on a high-risk market you should define priorities, the most risky areas that you would like to address. As a second step, the company should define the risk appetite, or so to say, the internal standard on risk acceptance, that company agrees to take.                                 Target #3: Legislation. While deploying international antibribery standards in the branch of your organization in Moscow do not ignore local laws.  The reasons are the following: 1. Sometimes Russian anticorruption legislation might contain provisions that in some instances are more restrictive than FCPA (for example, local requirement in certain cases to notify the former employer of your newly hired ex-governmental official); 2. Certain FCPA principles might collude local laws (for example, due diligence of your business partner should be construed not to breach Russian antitrust legislation); 3. Some pieces of legislation should be reviewed carefully prior to deployment of the compliance instruments (for example, Russian data privacy laws should be analyzed prior to launch of whistleblower line).              Join us for the next episode of Compliance Man Chooses the Target with Tim Khasanov-Batirov.  Learn more compliance tips from Tim Khasanov-Batirov at:  http://complianceinpostussr.com/&http://complianceinpostussr.com/blog/

Welcome to Episode 4 of Compliance Man Chooses the Target with Tim Khasanov-Batirov. My goal is to highlight matters that should be on agenda of practitioners that deploy compliance programs in industries or countries of active FCPA enforcement. I target three specific matters that you might like to address in the course of implementation of your compliance program. Today we will focus on Industrial & Consumer Goods industry. Target #1: Politically Exposed Persons The interpretation of the term politically exposed person is a tricky thing. For instance, you want to engage a law firm, which is owned by a sibling of a governmental official, let say, in Kazakhstan.  If you do business in the country where culturally strong family ties extends beyond immediate family members it could be a challenge to define whether a person among many siblings of a particular PEP de-factocould act as a shadow representative so to say of that PEP.  How to decrease compliance risks in this situation? The best way would be to the following: To find out if your company really needs offered legal services;To conduct fair market value estimation of fees to be paid;Talk to business people and folks in the professional community (or even better to do detailed background check in addition to due diligence) to find out if your potential business partner enjoys preferential regime before local state bodies being sibling of the governmental official. Target #2: Construction of Plants If your company decides to expand, its business by constructing a plant overseas we would recommend accessing the following three areas, which might encompass corruptions risks: Approvals of design of your plant by respective foreign regulators;Permissions on land allocation and construction permits to be obtained overseas;Taxation, which might vary subject to interpretation of the vague tax rules regarding construction works by overseas tax authority.       Target #3: Local Team Bribes are paid by people. Thus, the most important assurance you want to get is adherence to ethical culture by your team in the fields. How to access whether your FCPA/Ethics program really works even on distance of thousands miles from the HQ? You may want to do self evaluation of your FCPA program using guidance called Evaluation of Corporate Compliance Programsby DOJ: https://www.justice.gov/criminal-fraud/page/file/937501/download I will give you some practical insights regarding this tip in the next episode of the show. Join us for the next episode of Compliance Man Chooses the Target with Tim Khasanov-Batirov. Learn more compliance tips from Tim Khasanov-Batirov at: http://complianceinpostussr.com/& http://complianceinpostussr.com/blog/

In this episode of Compliance Man Chooses the Target, we’re talking about oil and gas. Target 1: Joint ventures. As a standard practice in emerging nations, a joint venture could be formed between a foreign investor and a local state company. What are the risks involved in this? Target 2: Request for donations. It is common to get various requests for donations from authorities in the region. You might want to check out local laws on the legality of making such donations. If it isn’t clear, you can use this argument to deny such requests.  Target 3: Consultants. If business people want to hire consultants in a high-risk country, it is more than a red flag. It doesn’t matter whether the company intends to enter the market or expand its local presence, your scrutiny over such engagements should be extremely high. Be ready to justify the amount of money to be paid to consultants as remuneration.

In this episode of Compliance Man Chooses the Target, we’re talking about the healthcare industry. Target 1: Interactions with healthcare professionals. Is it acceptable to give souvenirs or flowers to doctors? What is the best way to find out?  Target 2: Clinical trials and research. Clinical trials are an integral part of the official approval process required for the marketing of medicines. Consequently, scenarios might be linked to government officials responsible for the issuance of these licenses. Target 3: In many nations, your sales to state-owned hospitals are conducted through local distributors, and the participation of these distributors might pose an FCP risk. What can you do to ensure transparency? 

Welcome to Compliance Man Chooses the Target, hosted by Tim Khasanov-Batirov. Tim has been working in the former Soviet Union for the last 20 years as a lawyer and compliance person, and the challenges in that region differ from the issues compliance practitioners face in the US.  Compliance Man Chooses the Target is a podcast series aimed at sharing insights from the region to a global audience, highlighting practical matters you will need to look at if you work in a risky country or industry.

In this episode of Compliance Man Chooses the Target, we’re exploring communications services.  Target 1: Permissions and permits. Should a telecom company decide to operate in a higher risk market, it will need to obtain various permissions. Tentatively, look at all processes and related issues regarding governmental permits in these jurisdictions. Target 2: Underdeveloped judicial systems. Investors are becoming hostages, and you will likely spend a lot of money for a low chance to win a court case. So what can you do instead? Target 3: Participation in business associations. You may want to find out which association or Chamber of Commerce has a reputation for developing compliance practices. In many countries, the ethics movement is needed by companies from the communications services industry.