Tom Fox has practiced law in Houston for 35 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This is a very special episode. This podcast comes from a webinar hosted by KonaAI on Tom Fox's latest book, Ûpping Your Game. On this webinar, Tom is joined by Vince Walden, CEO of konaAI; Hemma Lomax, Deputy General Counsel, Vice President, Global Head of Ethics and Compliance at Docusign; and Carl Hahn and Matt Galvin, both from Gentic Global Advisors PLLC. The discussion revolves around compliance, with thought leaders delving into how organizations can enhance their performance by utilizing emerging technologies and compliance strategies. The conversation begins with a focus on the transformative role of AI in compliance, highlighting its ability to support continuous monitoring, predictive analytics, and embedding compliance into day-to-day business operations. The panel emphasizes the rise of “compliance as a service” and the growing need to prioritize user experience, particularly in third-party risk management and digital transformations. The panel addresses key challenges, such as overcoming resistance from business process owners, and emphasizes the importance of using data strategically to drive better compliance outcomes. The panel introduces the concept of the “Office of Unlock” as a collaborative model to break down silos and promote agility. They also discuss change management, AI governance, and tailoring compliance communications to specific audiences. The episode concludes with practical advice for compliance officers and a forward-looking discussion on aligning compliance programs with evolving organizational and regulatory landscapes. Key highlights: Upping Your Game Embedded Compliance What's the business value? What steps should you take right now Resources Hemma Lomax on LinkedIn Vince Walden on LinkedIn Matt Galvin on LinkedIn Carl Hahn on LinkedIn KonaAI Gentic Global Advisors Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in compliance programs, see Tom Fox's new book, Upping Your Game. You can purchase a copy of the book on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This is a very special episode. Tom Fox is joined by Lisa Fine, Ellen Hunt, and Hemma Lomax from the Great Women in Compliance podcast for our annual GWIC/FCPA Compliance Report cross-post podcast. We recorded this at Compliance Week 2025. In this year of uncertainty and change in compliance, we discussed the need to revisit and emphasize foundational ethics amid the evolving compliance landscape, seeing uncertainty as a chance for professional growth and deeper ethical reflection. We also discussed integrating ethics into compliance functions and advocating for a community-oriented approach that respects diverse viewpoints and fosters global perspectives; highlighted the importance of innovative strategies and understanding human behavior, advocating for creative approaches like podcasts to foster a speak-up culture and stressing the use of technology and coaching to enhance ethical decision-making, ultimately contributing to a robust corporate culture capable of navigating international compliance challenges. Key highlights: Ethical Decision-Making in Times of Change and in a Global Business Arena Global Training Program for Anti-Corruption Enforcement Promoting Ethical Culture and Fair Treatment Harnessing Collective Energy for Compliance Excellence Resources: Lisa Fine on LinkedIn Ellen Hunt on LinkedIn Hemma Lomax on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, see my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes back Jag Lamba, CEO at Certa to discuss the use of GenAI in compliance tools. Lamba advocates for the transformative power of artificial intelligence in revolutionizing third-party risk management. By leveraging AI, particularly generative AI and natural language processing tools, Lamba believes that businesses can streamline processes, reduce friction, and enhance decision-making throughout various phases of third-party interactions. He emphasizes that AI can simplify complex tasks like analyzing extensive reports and identifying specific risks, thus improving compliance reporting and operational efficiency. Lamba envisions a future where AI seamlessly integrates into core business operations, making compliance management an inherent and valuable aspect of organizational workflows, particularly benefiting smaller and mid-sized companies. Key Highlights · Automating Third-Party Risk Management with AI · AI-powered Tools Enhancing Third Party Risk Management · AI-driven Automation for Enhanced Compliance Reporting · Automating Compliance Tasks to Boost Operational Efficiency Resources Jag Lamba on Linkedin Certa AI Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode of the Diligent Compliance Week 2025 Speaker Preview Podcasts series, Ellen Hunt discusses her two presentations at Compliance Week 2025, “Culture Effectiveness and ROI: How to Move the Needle” and “Assessing Effectiveness: Do the 30-Year-Old Federal Sentencing Guidelines Still Work? “ In her first panel presentation, they will discuss the following: Demonstrate measurable and quantifiable ROI Build psychological safety that drives ethical decision-making and engagement. Navigate matrix environments to expand the influence. Use data to tell compelling compliance success stories. Partner with the C-suite to help them navigate disruptive changes, including deregulation and major economic geopolitical shifts. In her second presentation, she and Carrie Penman, the Chief Risk and Compliance Officer at Navex, will debate whether the US Sentencing Guidelines should be updated. I hope you can join us at Compliance Week's 20th Anniversary National Conference. This year's event will be held April 28-30 at The Mayflower Hotel, Autograph Collection, Washington, D.C. The lineup is first-rate, with some top ethics and compliance practitioners around. Drop by the Diligent booth for some Compliance Podcast Network coffee to gain insights and make connections at the industry's premier cross-industry national compliance event, offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 20th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode of the Diligent Compliance Week 2025 Speaker Preview Podcasts series, Amanda Carty discusses her presentation at Compliance Week 2025, “Going Beyond Due Diligence in Risk Management.” Some of the issues she will discuss: Demonstrate measurable and quantifiable ROI Build psychological safety that drives ethical decision-making and engagement. Navigate matrix environments to expand the influence. Use data to tell compelling compliance success stories Partner with the C-suite to help them navigate disruptive changes, including deregulation and major economic geopolitical shifts. I hope you can join us at Compliance Week's 20th Anniversary National Conference. This year's event will be held April 28-30 at The Mayflower Hotel, Autograph Collection, Washington, D.C. The lineup is first-rate, with some top ethics and compliance practitioners around. Drop by the Diligent booth for some Compliance Podcast Network coffee to gain insights and make connections at the industry's premier cross-industry national compliance event, offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 20th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode of the Diligent Compliance Week 2025 Speaker Preview Podcasts series, Kristy Grant-Hart discusses some of her panel at Compliance Week 2025, “A 360° Review of the Future of Compliance”. Some of the issues she and her panel will discuss: A comprehensive, forward-looking review of compliance across all roles within an organization. Emerging trends, critical challenges, and innovative strategies that compliance professionals need to navigate the future landscape successfully. Actionable recommendations on integrating compliance more deeply across organizational functions. I hope you can join us at Compliance Week's 20th Anniversary National Conference. This year's event will be held April 28-30 at The Mayflower Hotel, Autograph Collection, in Washington, D.C. The lineup is simply first-rate, with some of the top ethics and compliance practitioners around. Drop by the Diligent booth for some Compliance Podcast Network coffee to gain insights and make connections at the industry's premier cross-industry national compliance event, offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 20th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Andrew Hopkins, President of PrivacyChain, to discuss the critical intersection of AI, data compliance, and data ownership. Andrew brings his expertise from years of consulting, focusing on outcome-driven business support, and provides a comprehensive overview of the challenges and opportunities in managing and securing data in the age of AI. The conversation delves into the complexities of data security, the inefficiencies of traditional data management systems, and the potential of new technologies to enhance data governance and personal data ownership. Listeners will gain valuable insights into navigating the evolving landscape of data management and the importance of contextual integrity in AI processes. Key highlights: The Intersection of AI, Data Compliance, and Ownership Challenges in Data Management and Compliance Data Governance Shortcomings of Current Data Management Systems Data Integrity and Context Resources: Andrew Hopkins on LinkedIn The Privacy Chain Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Corporate Transparency Act expert and maven Jonathan Wilson for a look at how the Trump administration killed the Corporate Transparency Act (CTA). In March, the Treasury Secretary announced that all domestic reporting companies would be exempt from filing Beneficial Ownership Information (BOI) reports, with only foreign reporting companies required to file. This obviously violates both the intent of the law and its plain language. Jonathan outlines the impact of this interim final rule, noting the loss of a critical tool for federal and state law enforcement and financial institutions. The pod explores the potential for legal challenges and the possible implications for ongoing constitutional lawsuits related to the Act. Key highlights: Unexpected Regulatory Changes Implications of the New Rule Potential Legal Challenges Resources: Jonathan Wilson on LinkedIn FinCEN Report Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom is joined by Gerry Zack, CEO and Founder of RiskTrek LLC, to discuss his recent attendance at the OECD Global Anti-Corruption and Integrity Forum in Paris. Gerry provides an in-depth event recap highlighting significant presentations, panel discussions, and key takeaways. Topics covered include the current state of anti-corruption efforts, the international cooperation among governments in combating corruption, and the evolving role of compliance programs amid changes in U.S. enforcement policies. He also shares insights on applying artificial intelligence in compliance, the importance of building trust through compliance programs, and the unique challenges faced in the healthcare and private equity sectors. The episode underscores the forum's overarching theme of innovation and the proactive steps needed to navigate a turbulent compliance landscape. Key highlights: • Structure and Highlights of the OECD Conference • Key Themes: Compliance and Anti-Corruption • Global Collaboration and Government Responses • Incentives and Value of Compliance Programs • Trust and Technology in Compliance • Data Analytics and AI in Compliance Resources: Gerry Zack on LinkedIn Gerry Zack's Email: Gerry@risk-trek.com RiskTrek LLC Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Tim O'Toole and Matt Ellis from Miller & Chevalier Chartered to discuss the significant implications of President Trump's executive order designating Mexican drug cartels as foreign terrorist organizations (FTOs). Tim and Matt elaborate on the heightened compliance risks and operational challenges now faced by companies operating in these regions. The conversation delves into the legal distinctions between Specially Designated Nationals (SDNs) and FTOs, the broad-ranging impact on industries such as agriculture and logistics, and the urgent need for robust risk assessment strategies to mitigate civil and criminal liabilities under U.S. law. They also explore the broader Latin American context and potential collateral consequences for U.S. and Latin American companies amid anticipations of increased regulatory scrutiny and enforcement actions. The discussion concludes with timely observations on recent U.S. Treasury directives aimed at curbing cartel money laundering activities, showcasing the lengths the administration is willing to go to combat these criminal enterprises. Key highlights: Executive Order and FTO Designation Heightened Risks for Companies in Mexico Complexities of Cartel Influence in Mexico Risk Management Strategies for Companies Broader Implications for Latin America Potential Weaponization of FTO Designation Corporate Compliance and Human Rights Resources: Designation of Cartels as FTOs Creates Heightened Risks for Companies Operating in Latin America Miller & Chevalier Tim O'Toole Matt Ellis Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes Erica Salmon Byrne, Chief Strategy Officer at Ethisphere, on an exciting launch day for the 2025 World's Most Ethical Companies honoree list. The World's Most Ethical companies list features 136 companies from 44 industries across 19 countries, the episode delves into the significance, process, and celebration behind this prestigious designation. Byrne discusses the impressive Ethics Premium, revealing that publicly traded honorees have outperformed a comparable index by 7.8%, underscoring the profitability of ethical business practices. Listeners will gain insights into the rigorous application process, the importance of cross-functional relationships, and the global nature of the honoree list. Byrne also previews the upcoming Global Ethics Summit and emphasizes the critical role of talent acquisition and retention in corporate success. Key Highlights · What is Launch Day? · Ethics Premium Highlights · Overview of Honoree Companies · Global Ethics Summit Preview · Deep Dive into the Ethics Premium Resources Erica Salmon Bryne on LinkedIn Ethisphere World' Most Ethical Awards for 2025 Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running compliance podcast. In this episode, Tom welcomes Eric Morehead to discuss the role and function of the U.S. Sentencing Commission. Eric is the Director of Advisory Services Solutions at LRN and former Assistant General Counsel at the U.S. Sentencing Commission. He and Tom review the intricacies of the U.S. Sentencing Commission's role, structure, and impact. Eric walks through his professional journey and explains the Sentencing Commission's function in standardizing federal criminal sentences and promoting organizational compliance programs. He emphasizes the importance of the Sentencing Guidelines, the process for their amendment, and the challenges faced by the Commission, such as quorum issues. The discussion also touches on current topics, including the potential impact of executive orders on DEI policies and the FCPA pause, stressing the continued relevance of the Sentencing Guidelines in compliance program development. Key highlights: Eric Morehead's Background and Role at the U.S. Sentencing Commission Understanding the U.S. Sentencing Commission Process of Creating and Amending Sentencing Guidelines Impact of Sentencing Guidelines on Compliance Programs Current Issues in Compliance: DEI and FCPA Enforcement Resources: Eric Morehead on LinkedIn LRN US Sentencing Guidelines for Organizations Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running compliance podcast. In this episode, Tom welcomes Jonathan Marks, who discusses the role of internal audit in export control compliance. Jonathan starts by defining export controls and their significance: regulations governing the export, re-export, and transfer of goods, technology, and services across borders to protect national security and enforce foreign policy. As a Compliance Profession, you should recognize the severe impacts of operational disruptions, supply chain issues, and national security risks resulting from non-compliance, emphasizing the need for comprehensive compliance frameworks. Internal audit responsibilities are expanded, stressing the necessity of robust policies, clear responsibilities, consistent employee training, and thorough risk assessments. Jonathan discusses practical internal audit strategies, including evaluating high-risk transactions, identifying compliance gaps, and regularly monitoring and testing compliance controls through transaction testing, data analytics, third-party due diligence, and incident response mechanisms. Jonathan underscores the importance of collaboration between internal audit, legal, compliance, and supply chain teams to ensure an integrated and proactive compliance approach, thereby mitigating risks and strengthening corporate governance. Key highlights: Understanding Export Controls and Compliance Role of Internal Audit in Export Controls Key Areas for Internal Audit Focus Testing and Monitoring Controls Resources: Jonathan Marks on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes back Corporate Transparency Act expert and maven Jonathan Wilson for a look at judicial insights and recent developments in the Corporate Transparent Act (CTA) litigation. Tom and Jonathan discuss the recent developments, including a preliminary injunction by Judge Kernodle in the Smith v. Treasury case, and its implications on CTA enforcement. Important differences between this injunction and previous ones, such as the Texas Top Cop Shop case, are highlighted. Wilson offers insights into the constitutional debates, particularly regarding the Commerce Clause, and reviews key decisions from federal district courts, including the persuasive Boyle decision from the District of Maine. They also touch on upcoming appeals and the potential impacts on the CTA's nationwide enforcement. Key Highlights · Current Status of the Corporate Transparency Act · Judge Kernodle's Injunction and Legal Arguments · Supreme Court's Involvement and Implications · Analysis of the Boyle Decision · Procedural Updates and Future Outlook Resources Jonathan Wilson on LinkedIn FinCEN Report Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Kevin Carroll, now a partner at Fluet, to discuss national security issues to date under the Trump Administration. Kevin Carroll discusses his move to Fluet Law, a national security law firm. He delves into the ongoing chaos in national security, ranging from employees' concerns over legal processes at the Agency for International Development and the FBI to the unprecedented moves of the Trump administration in reprioritizing enforcement efforts. Kevin emphasizes the criticality of maintaining international alliances and intelligence-sharing, especially amidst controversial DOJ staffing and enforcement decisions. They also touch on the potential ramifications for U.S. companies engaged in foreign trade and anti-corruption enforcement. Don't miss Kevin's expert insights on the delicate balance of national security and legal frameworks in uncertain times. Key highlights: 00:11 Kevin's New Professional Chapter 00:35 National Security Concerns 02:11 Law Enforcement Priorities 04:52 International Relations and Security 14:04 Corporate Legal Risks Abroad 17:15 USAID and Export Control Resources: Kevin Carroll on LinkedIn Fluet Kevin Carroll on Fluet Law Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Alejandra Almonte and Ann Sultan, both Members of Miller & Chevalier, and uses the EEOC's release in 2024 of its Enforcement Guidance on Harassment in the Workplace as an introduction to considering compliance and the workplace under the new Trump Administration. Ann and Alejandra dive deep into the EEOC's 2024 enforcement guidance on harassment and explore the implications of recent Executive Orders from the Trump administration. The conversation extends to the necessity of risk assessments in the current climate, focusing on how companies can maintain safe and compliant workplaces amidst shifting policies. Ann and Alejandra share valuable perspectives on conflicts of interest, the intersection of workplace safety and emotional well-being, and strategies for fostering a positive organizational culture even in uncertain times. Do not miss this expert advice on navigating the complexities of workplace conduct and compliance in the evolving legal landscape. Key highlights: EEOC's 2024 Enforcement Guidance on Harassment Impact of Policy Changes on Workplace Conduct Ensuring a Safe and Inclusive Workplace Risk Assessments and Workplace Misconduct Conflicts of Interest in the Workplace Resources: Miller & Chevalier Ann Sultan Ann Sultan on LinkedIn Alejandra Almonte Alejandra Almonte on LinkedIn Culture@Work: Fall 2024 Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes back Mike Huneke and Brent Carlson for a special 2-part podcast series on the bombshell AI advancements announced by DeepSeek on President Trump's inauguration day. In Part 1, we reviewed the business and compliance implications and in this Part 2, they consider the Sputnik Moment which has occurred. In this episode, we delve into the concept of the 'Sputnik moment' as it relates to the global race to dominate artificial intelligence (AI) technology in the 21st century. Our discussion highlights the economic and military applications of AI and its significance for the United States. The conversation touches on the role of compliance, enforcement, and the evolving regulatory landscape, including recent developments like the AI diffusion framework. The episode also explores the increasing responsibilities placed on U.S. companies and their compliance teams, especially concerning export controls and national security standards. Key Highlights · Economic and Military Implications of AI · Compliance and Enforcement Challenges · The Role of Compliance Teams · Board of Directors' Responsibilities Resources Mike Huneke Hughes Hubbard & Reed website Brent Carlson on Linkedin A Fresh Look at US Export Controls and Sanctions DeepSeek Finds US Export Controls at a New ‘Sputnik Moment' in Bloomberg.Law Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Mike Huneke and Brent Carlson for a special two-part podcast series on DeepSeek's bombshell AI advancements announced on President Trump's inauguration day. In Part 1, they review the business and compliance implications, and in Part 2, they consider the Sputnik Moment that has occurred. In Part 1, they consider the immediate and significant repercussions in both the business and compliance landscapes. Key topics include the economic and geopolitical ramifications of DeepSeek's innovations, changes in export control policies, and the unique compliance challenges AI technology poses. The discussion also examines how corporations can recalibrate their risk frameworks, integrate high-probability standards, and leverage data analytics to handle millions of transactions in a global economy. Emphasizing the importance of comprehensive compliance programs, the episode provides actionable insights for compliance professionals navigating this evolving landscape. Key highlights: DeepSeek's AI Breakthrough Economic and Compliance Implications Export Controls and Legal Concerns Compliance Strategies and Risk Management Training and Organizational Culture Resources Mike Huneke Hughes Hubbard & Reed website Brent Carlson on LinkedIn A Fresh Look at US Export Controls and Sanctions DeepSeek Finds US Export Controls at a New ‘Sputnik Moment' in Bloomberg.Law Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Jag Lamba, CEO of Certa.AI, the podcast's sponsor. We look at the recent events involving economic and trade sanctions levied on Colombia (now withdrawn) and the announcement of DeepSeek as a cost-effective competitor to ChatGPT in the AI space to discuss how quickly your risks can change. We overlay this discussion through the lens of the DOJ's 2024 Update on the Evaluation of Corporate Compliance Programs (2024 ECCP). Jag provides insights on how compliance officers can proactively manage risk amidst rapidly changing global landscapes by ensuring their programs are well-designed, adequately resourced, and effective. Key takeaways include the importance of data, controls, and technology in building robust compliance frameworks and using business impact and ROI to secure necessary resources. Key highlights: Current Events Impacting Compliance 2024 ECCP-Designing a Well-Structured Compliance Program 2024 ECCP-Adequate Resourcing for Compliance Programs 2024 ECCP: Effectiveness of Compliance Programs in Practice Proactive Risk Management Strategies Export Controls and Compliance Challenges Resources: Jag Lamba on LinkedIn Certa.ai Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Jonathan Wilson to discuss recent turbulent developments regarding the Corporate Transparency Act (CTA) at the Supreme Court. The conversation includes key legal battles in Texas involving injunctions against the CTA. They explore the Supreme Court's recent stay on a previous injunction, the new Smith v. Treasury case, and its implications. The hosts analyze the confusion and uncertainty surrounding compliance with the CTA and offer strategic advice to businesses during this chaotic period. They conclude with insights on the political and judicial landscape, potential future rulings, and the importance of the CTA in combating money laundering. Key highlights: Supreme Court's Recent Actions Smith v. Treasury Case Overview Discussion on Universal Injunctions Future Implications and Legal Advice Political Landscape and CTA Support Resources: Jonathan Wilson on LinkedIn FinCEN Report Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running compliance podcast. In this episode, Tom welcomes back Brent Carlson and Mike Huneke to discuss a crucial topic in corporate compliance: the return on investment (ROI) in export controls compliance. This pod reviews the challenges compliance professionals face in articulating the value proposition for investments in compliance programs. Brent and Mike highlight the misconceptions about compliance being merely a cost center and explore various ways to demonstrate its tangible benefits to executive teams and boards. The discussion also covers the impact of recent regulatory changes and geopolitical tensions and how companies can proactively address these shifts to ensure robust compliance and leverage new opportunities. By looking at past enforcement actions and drawing parallels with the evolution of the FCPA, the episode provides listeners with critical insights into the practical steps for enhancing compliance programs and the importance of staying ahead of regulatory expectations in a rapidly changing global trade environment. Key highlights: Setting the Stage for Compliance ROI Challenges in Export Controls Compliance Geopolitical Influences on Export Controls Comparing Export Controls to FCPA National Security and Economic Security Solutions and Strategies for Compliance Resources: Hughes Hubbard & Reed website Brent Carlson on Linkedin Mike Huneke on LinkedIn A Fresh Look at US Export Controls and Sanctions Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In the first episode of the 2025 FCPA Compliance Report, Tom welcomes back Jonathan Wilson, founder and CEO of the FinCEN Report, to discuss recent legal machinations surrounding the Corporate Transparency Act (CTA). They delve into a December court ruling by the Eastern District of Texas, which issued a universal injunction against the CTA, claiming it oversteps Congress's authority under the Commerce Clause. The Fifth Circuit stay panel initially stayed this ruling but was later reinstated by the merits panel, leading the government to appeal to the Supreme Court. The episode also covers historical context, potential impacts on businesses, and predictions for future court actions regarding the CTA. Key highlights: Texas Top Cop Shop Case Overview Court Rulings and Injunctions Supreme Court Involvement Government Response and Filing Process Implications of Administration Change Resources: Jonathan Wilson on LinkedIn FinCEN Report Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes Jennifer B. Gardner, a seasoned trial lawyer and expert in leadership and influence. She shares her unique professional journey, from running her law practice to becoming a master storyteller in the courtroom. Jennifer delves into the importance of emotional intelligence, right-brain communication in influencing and persuading, and the necessity of understanding human psychology to lead and connect with diverse audiences effectively. Jennifer also sheds light on how these skills translate into the corporate compliance world, emphasizing the power of crafting messages that resonate emotionally and using simple, compelling language. She offers practical tips on combining data with storytelling, understanding one's audience, and developing resilience in high-pressure situations. Whether you are a compliance officer, lawyer, or business leader, Jennifer's insights provide valuable strategies for becoming more influential and effective in your professional role. Highlights in this episode: Jennifer's Journey into Law and Leadership The Power of Influence in Law Applying Influence in the Corporate World The Art of Storytelling in Legal Cases Somatics and Leadership The Importance of Self-Awareness and Mindfulness Exploring the Art of Influence Program Resources: Jennifer B. Gardner on LinkedIn Gardner and Associates Law Firm The Art of Influence Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom engages in a comprehensive discussion with Bruna Veiga about the evolution and significance of the compliance department in the financial markets in Brazil and globally. Bruna describes her journey, starting as a trainee and advancing to her current role as a Legal and Compliance Officer in fund management. She highlights the crucial role of combining regulations from different regions, particularly the rigorous frameworks in Brazil and the United States, to manage compliance effectively. The conversation delves into the historical development of compliance programs in Brazil, the challenges faced, and the similarities with the U.S. regulatory landscape. Bruna provides insights on managing compliance amidst evolving regulations, the importance of continuous learning, and establishing a culture that values ethical compliance. Key topics such as money laundering, AI governance, and compliance considerations in marketing are also explored, offering valuable strategies for compliance professionals to navigate these complex areas. Highlights in this episode: Development of Compliance in Brazil Navigating Multiple Regulations Hot Topics in Compliance: AI and Money Laundering Compliance Communication and Engagement Career Advice for Aspiring Compliance Professionals Resources: Bruna Veiga on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Check out the entire 3-book series, The Compliance Kids, on Amazon.com. For an audio/video version of the Compliance Kids book, Speaking Up is AWESOME, contact Tom Fox. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this edition, Tom Fox welcomes Adrian Roux, a senior associate at Edward Nathan Sonnenberg, to discuss recent legislative changes in South Africa's anti-corruption efforts and their global relevance. Adrian highlights the introduction of a new offense in South Africa akin to the UK's Bribery Act's ‘failure to prevent bribery' offense and discusses a new policy directive for non-trial resolutions for companies facing corruption charges. Both initiatives aim to mitigate extensive corruption exposed during the Zuma era's state capture saga, which involved high-profile public and private sector corruption cases investigated by the Zondo Commission. Adrian explains the challenges and implications of these legislative changes for compliance professionals globally, emphasizing the importance of understanding new compliance obligations and developing adequate procedural defenses. Additionally, the episode touches on increased international cooperation between South African and U.S. authorities in white-collar enforcement. This collaboration, noted in recent FCPA enforcement actions, signifies a growing trend towards global enforcement in corporate compliance and anti-corruption matters. Highlights in this episode: New Legislative Changes in South Africa Failure to Prevent Offense Adequate Procedures and Compliance Programs Corporate Alternative Dispute Resolution Directive International Cooperation in White Collar Enforcement Resources: Arian Roux on LinkedIn ENS Law Firm Zondo Commission Report on State Capture Article on 34A of the Prevention and Combating of Corrupt Activities Act Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Check out the full 3-book series, The Compliance Kids, on Amazon.com. For an audio/video version of the Compliance Kids book, Speaking Up is AWESOME, contact Tom Fox. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This edition delves into the implications of Donald Trump's presidency for corporate compliance and ethics. We share some initial thoughts from compliance officers and industry experts, exploring the widespread concern over Trump's controversial character and potential impact on businesses' ethical cultures. Key discussion points include the existential angst among compliance professionals, the future of FCPA enforcement, and the role of influential figures like Elon Musk in the Trump administration. The episode underscores the importance of maintaining robust compliance programs despite political uncertainties and the potential for increased regulatory challenges and internal corporate risks. Highlights in this episode: Compliance in the Trump Era Existential Angst in Compliance FCPA Enforcement Under Trump Elon Musk's Role in the Administration The Future of Compliance and Governance Conclusion: The Risks of Relaxed Controls For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Check out the full 3-book series, The Compliance Kids, on Amazon.com. For an audio/video version of the Compliance Kids book, Speaking Up is AWESOME, contact Tom Fox. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this edition, Tom Fox welcomes Frank Tumminello for an in-depth discussion on the Corporate Transparency Act (CTA) and its business implications. They delve into the reasons behind the CTA, a law established under the Anti-Money Laundering Act of 2020, and its importance in enhancing transparency and preventing criminal activities like tax evasion and money laundering. Despite being in effect for nearly a year, there needs to be more awareness, with only 15% of the 40 million affected companies having complied. Frank explains the Beneficial Ownership Information (BOI) report, its requirements, and the challenges businesses might face in staying compliant. They also touch upon the misconceptions and legal difficulties surrounding the CTA, as well as the efforts of FinCEN to facilitate compliance, including the potential for extended deadlines in hurricane-affected FEMA zones. Lastly, Frank introduces ‘File Forms,' a platform designed to streamline BOI reporting, highlighting its features, success stories, and support to businesses navigating these new requirements. Highlights in this episode: Overview of the Corporate Transparency Act Purpose and Misconceptions of the CTA Beneficial Ownership Information Reporting Constitutionality and Legal Challenges FinCEN Updates and Compliance Efforts File Forms: Features and Benefits Resources: Frank Tumminello on LinkedIn FileForms Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this edition, Tom Fox welcomes back Alexander Cotoia to discuss the intricate and profoundly impactful topic of anti-boycott compliance related to U.S. companies involved in international trade. They delve into the specifics of the EAR's anti-boycott provisions, a framework designed to prohibit U.S. companies from participating in or supporting foreign-imposed boycotts not endorsed by the U.S. government. The conversation highlights the strict reporting requirements enforced by BIS and IRS to ensure transparency and adherence to U.S. trade compliance interests. Alexander explains the details of Quantum Corporation's recent settlement over violations, emphasizing the importance of active reporting to maintain U.S. trade relationships. The discussion also touches on potential compliance challenges, particularly regarding China and Taiwan. Tune in for best practices in anti-boycott compliance and learn how to navigate this complex regulatory landscape. Highlights in this episode: Understanding Anti-Boycott Law Deep Dive into EAR's Anti-Boycott Provisions Enforcement and Compliance Case Study: Quantum Corporation Best Practices for Compliance Global Implications and Future Concerns Resources: Alexander Cotoia on LinkedIn Volkov Law Group Alexander Cotoia's article on BIS – Quantum Corp Enforcement Action Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this edition, Tom Fox visits with Sam Silverstein on how compliance professionals should view the new DOJ mandate on using data to assess, manage, and improve corporate culture through data-driven compliance. The Culture Audit sponsors this podcast. In this comprehensive discussion, Tom Fox and Sam Silverstein delve into the 2024 Update to the Evaluation of Corporate Compliance Programs (ECCP) by the DOJ. Released in September, this latest update emphasizes the importance of data analytics, culture, engagement, and trust in compliance programs. With a detailed breakdown of over 250 questions posed by the ECCP, Tom and Sam provide valuable insights on how companies can benchmark their compliance programs and prepare for potential investigations. They highlight the role of a culture audit in addressing the DOJ's requirements, offering a detailed look into how organizations can measure and improve their compliance culture. This webinar educates compliance professionals on the latest DOJ expectations and provides practical tools and methodologies to enhance corporate compliance efforts. Highlights in this episode: Importance of Culture and Data Analytics Leveraging Data for Compliance Measuring and Improving Culture Data-Driven Culture of Compliance Understanding and Utilizing Culture Audit Data Forward Steps for a Stronger Culture Resources: Culture Audit Set up a call to discuss the Culture Audit. Click here Sam Silverstein and the Accountability Institute Sam Silverstein on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Registration and information for the Compliance Podcast Network First Annual Agora Awards are here. This event is free. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox visits with Dr. Ian Oxnevad and Chris Mason from Infortal Worldwide about the Israeli attack on Hezbollah through its pagers and explores what all of this means for the compliance professional. The podcast explores the compliance and supply chain ramifications stemming from pagers licensed by a Taiwanese company to a Hungarian firm which were subsequently used to disrupt Hezbollah's operations. This incident serves as a springboard for discussing the broader implications for global businesses, emphasizing the essential role of due diligence in complex supply chains. The episode offers insightful commentary on how Hezbollah's lack of scrutiny over their suppliers led to vulnerabilities that were exploited by Israel, acting as a cautionary tale for organizations everywhere. Key topics include the unexpected ways legitimate companies can be compromised, the pervasive nature of risk management, and the importance of vetting and verifying partners across all industries to maintain business integrity and reputation. Highlights in this Episode: Attack on Hezbollah Compliance and Supply Chain Issues Payment Anomalies and Red Flags Lessons Learned and Risk Management The Importance of Knowing Your Risk Profile Unintended Consequences and Risk Management Final Thoughts on Supply Chain Vulnerabilities Resources Infortal Worldwide Dr. Ian Oxnevad on LinkedIn Chris Mason on LinkedIn Tom Fox Instagram Facebook YouTube Twitter Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox cross post the first episode of a new podcast series from Nicolas Tollet, partner at Hughes, Hubbard and Reed In this episode, Tollet delves into the substantial financial benefits stemming from robust compliance measures. Tollet recounts a company's journey through two deferred prosecution agreements (DPAs) related to bribery and corruption allegations in Africa and Brazil, detailing how proactive compliance actions saved the company approximately $100 million. He emphasizes the crucial role of an independent monitor and in-depth compliance reviews in identifying and mitigating misconduct. Tollet explores the implementation of compliance policies and training programs, drawing comparisons with high-profile cases like Walmart's FCPA settlement, to illustrate the long-term financial stability and operational integrity gained through early compliance investment. Highlights in this Episode: The First Deferred Prosecution Agreement (DPA) The Second DPA and Lava Jato Investigation Compliance as a Competitive Advantage Detecting and Addressing Misconduct Remediation and Strengthening Compliance Financial Benefits of Compliance Comparing with Walmart FCPA Case Resources: Nicolas Tollet at Hughes Hubbard & Reed Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Check out the full 3-book series, The Compliance Kids on Amazon.com. For an audio/video version of the Compliance Kids book, Speaking Up is AWESOME, contact Tom Fox. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, in this episode, host Tom Fox is joined by Roxanne Petraeus and Susan Divers from Ethena to discuss innovative perspectives on compliance training, specifically focusing on the 2024 update to the Evaluation of Corporate Compliance Programs. Roxanne, drawing from her military background, emphasizes the importance of practical and effective compliance training that resonates with employees rather than traditional 'check-the-box' methods. Susan highlights the shift towards emphasizing outputs over inputs, urging for compliance programs that are not just on paper but practiced and understood by all employees. The discussion delves into the new expectations from the DOJ regarding the use of AI and data analytics in compliance, positioning compliance officers as pivotal to maintaining organizational justice and fairness. They also explore strategies for persuading senior management to prioritize compliance through emphasizing organizational culture and reputation. The conversation concludes with the role of leadership in fostering a compliant culture and practical steps for reaching out to Ethena for further insights. Highlights in this Episode · Deep Dive into the 2024 Compliance Program Update · Roxanne's Journey and Ethena's Mission · Susan's Transition to Athena · Outputs Over Inputs: A New Compliance Focus · The Role of AI in Compliance · Leadership and Compliance Strategy Resources Roxanne Petraeus on LinkedIn Susan Divers on LinkedIn Ethena Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here. Check out the full 3-book series, The Compliance Kids on Amazon.com. For an audio/video version of the Compliance Kids book, Speaking Up is AWESOME, contact Tom Fox. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, I welcome back Jag Lamba from Certa AI, the sponsor of this podcast to consider the integration of AI into your overall compliance framework. Our discussion emphasizes the importance of using great software to effectively integrate AI into existing processes, systems, and teams. For successful implementation, the software should be both flexible and scalable to suit different organizational needs and volumes. Moreover, the incorporation of guardrails is crucial in areas like third-party compliance due to AI being a relatively new technology. These guardrails function as a framework to prevent excessive autonomy similar to the limitations set on a new coworker. It is fascinating look at the cutting edge use of AI in compliance. Highlights in this Episode · Integrating AI with Existing Systems · The Human in the Loop · Flexibility and Scalability in Software · Key Elements: Guardrails in AI Resources Jag Lamba on LinkedIn Certa AI Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox welcomes back Vince Walden, founder of KonaAI. Vince reports on the 2024 Update to the Evaluation of Corporate Compliance Programs. (Today's episode is a cross-posting from Data Driven Compliance.) Walden, a distinguished expert in compliance data analytics, actively participates in industry forums such as the Society of Corporate Compliance and Ethics annual summit in Grapevine, Texas. He advocates for compliance professionals to have ample access to relevant data sources, enabling them to monitor and test policies, controls, and transactions effectively. Walden stresses the importance of AI developers being vigilant about potential biases and public harm, aligning with the Department of Justice's stance on accountability. He advises compliance practitioners to collaborate with internal audit and finance teams to ensure they have the necessary transactional data for comprehensive risk assessments, highlighting successful, cost-effective implementations like those at Albemarle as models for gradual, data-driven compliance program adoption. Highlights in this Episode Data-Driven Compliance for Cost Savings Enhancing Compliance through Advanced Data Analysis Identifying High-Risk Areas for Data Analytics Proactive Risk Mitigation through Real-Time Monitoring ROI-driven Compliance Programs with Data Analytics Resources: Vince Walden on LinkedIn KonaAI Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, I welcome back the well known white collar defense practitioner and contrarian, Jon May as we take a deep dive into May's concerns with the new DOJ Whistleblower Financial Incentive Program. Jon May is a renowned legal expert known for assisting fellow attorneys in developing innovative solutions for complex cases. With extensive experience, May has authored papers critiquing the Department of Justice's Corporate Whistleblower Program, arguing that it is fatally flawed due to the DOJ's inherent hostility towards whistleblowers and lack of enforceable rights for them. He highlights significant practical issues within the program, such as the stringent requirement for complete cooperation and the misconception that whistleblowers are solely motivated by monetary rewards. By drawing attention to these critical flaws, May advocates for necessary reforms to make the program more effective and fairer. Highlights in this Episode · Flaws in DOJ's Whistleblower Reward System · Unfair Reward System for Whistleblowers · Financial Hurdles in SEC Whistleblower Program · Risk and challenges of DOJ whistleblower cooperation · Whistleblower rewards in corporate enforcement policies Resources Jon May Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, I welcome back Kevin Carroll to discuss the latest developments in the Trump Jan 6th case, including the Special Prosecutor's Superseding Indictment. In this week's episode, Tom Fox is joined by Kevin Carroll to discuss the latest developments in one of the Trump trials. Jack Smith's Superseding Indictment in the January 6th case in Washington, D.C., is dissected. Carroll explains the concept of a superseding indictment and its implications for the charges and defendants involved. The conversation also covers the impact of the Supreme Court's decision on official acts and how it intersects with Trump's legal strategies. Carroll provides insights into the procedural aspects of the case, potential trial timelines, and the broader ramifications of the court's rulings on other ongoing cases involving Trump. Highlights in this Episode · The Superseding Indictment · Supreme Court's Impact on the Indictment · Trump's Conversations with Pence · Trial Within a Trial Concept · Impact on Other Trump Trials · Election Proximity and Legal Actions Resources Kevin Carroll on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom welcomes back Miller & Chevalier attorneys Executives at Risk team, including Lauren Briggerman, Katherine Pappas, Ian Herbert, and their newest colleague Laura Deegan. We dive into key compliance and enforcement topics such as the new DOJ whistleblower initiative, recent OFAC sanctions and export controls, key FCPA enforcement actions focusing on individual liability, and notable AML developments, particularly within the cryptocurrency sector. The discussion highlights the evolving landscape of corporate compliance and the increased need for robust internal reporting and proactive compliance measures. Resources: Miller & Chevalier Chartered Lauren Briggerman Katherine Pappas Ian Herbert Laura Deegan Executives at Risk, Summer 2024 Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, I welcome back Mary Inman, Partner at Whistleblower Partners LLC to discuss the new DOJ Whistleblower Incentive Program. Tom and Mary discuss the DOJ's New Whistleblower Incentive Program's aim to fill gaps in existing reward programs and its focus areas, including financial institution violations, foreign and domestic corruption, and healthcare offenses. Mary highlights some criticisms of the program, such as lack of a reward floor and the cap on rewards, and the potential challenges and impacts on corporate compliance. They also talk about the interplay between whistleblowers, DOJ, and corporate investigations, and the potential for adaptation of the program based on stakeholder feedback. Highlights in this Episode · DOJ Whistleblower Incentive Program Overview · Four Focus Areas of the New Program · Challenges and Criticisms of the Program · Concerns About Reward Mechanisms · Race to DOJ: Whistleblowers vs. Corporations · Implications for Corporate Compliance Resources Mary Inman on LinkedIn Whistleblower Partners Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. We take things in a different direction today as Tom Fox reposts the recent webinar with Sam Silverstein and Mike Volkov, where we took a deep dive into the Boeing Plea Agreement, the Monitorship, and why culture is the key to a Boeing turnaround. We explore the recent plea agreement filed by Boeing, the outrage among victims' families over the proposed penalties, and the appointment of an independent compliance monitor. Key issues discussed include the necessity of a culture overhaul at Boeing, the implications of excluding court jurisdiction over the monitorship, and the role of the board in fostering a culture of compliance and safety. The discussion highlights the critical need to focus on values, accountability, and transparent processes to rebuild trust and ensure long-term organizational integrity. Highlights of this episode: Details of the Plea Agreement Compliance Monitor Appointment and Transparency The Importance of Culture The Role of Compliance Monitors Board Involvement and Accountability Victims' Families and Organizational Accountability Resources: Sam Silverstein Mike Volkov The Culture Audit Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, I conclude this two-part episode with Bob Tarun and Peter Tomczak from Baker & McKenzie who discuss the latest edition of their book the Foreign Corrupt Practices Act Resource Handbook. This episode provides an in-depth exploration of Delaware law's Caremark duties and their evolution, particularly in anti-corruption compliance. The discussion highlights the challenges boards face in implementing and overseeing compliance programs. Additionally, it delves into the intricacies of defending FCPA investigations, with insights into recent high-profile cases such as those involving Walmart, Glencore, and Goldman Sachs. The conversation also covers the international trends in anti-bribery and corruption enforcement, particularly focusing on regions like China, Southeast Asia, and the Middle East. Key compliance strategies and the importance of cross-border data privacy considerations in investigations are discussed, along with a critical look at the DOJ's sophistication in evaluating corporate compliance programs. Highlights in this Episode · Introduction to Caremark and Delaware Law · Key Strategies for FCPA Investigations · Challenges in FCPA Trials and Compliance · International Anti-Corruption Trends · Future of FCPA Enforcement Resources Foreign Corrupt Practices Act Handbook Bob Tarun Email: RobertWTuran@gmail.com Phone: 312-714-0225 Peter Tomczak LinkedIn Baker & McKenzie Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox welcomes Bob Tarun and Peter Tomczak from Baker & McKenzie in Part 1 of a two-part podcast series to discuss the latest edition of their book, The Foreign Corrupt Practices Act Handbook. The conversation covers their professional backgrounds, motivations for updating the book, and significant changes in FCPA enforcement and compliance practices. Bob and Peter provide detailed insights into their writing process and some of the key defenses for FCPA investigations. Key trends in international anti-bribery and corruption enforcement, the evolving role of corporate compliance programs, and strategies for dealing with DOJ expectations are also addressed. The episode concludes with discussions on future prognostications for FCPA enforcement and how listeners can connect with the authors. Highlights in this Episode Meet the Authors: Bob Tarun and Peter Tomczak Updating the FCPA Handbook: New Challenges and Insights Key Chapters and Practical Advice in the FCPA Handbook DOJ Policies and Corporate Compliance For the Board: The Pitch Count Policy Caremark Duties Defending FCPA Investigations: Strategies and Trials International Anti-Bribery and Corruption Trends Resources: Foreign Corrupt Practices Act Handbook Bob Tarun Email: RobertWTarun@gmail.com Phone: 312-714-0225 Peter Tomczak LinkedIn Baker & McKenzie Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox welcomes back Erica Salmon Byrne to discuss the recently released Ethisphere 2024 Ethical Culture Report: Closing the Speak Up Gap. They explore the genesis and findings of the report, focusing on the eight pillars of ethical culture and significant insights derived from data collected since 2020. Key topics include the importance of equipping managers to handle employee concerns, generational and tenure-based discrepancies in reporting misconduct, and the persistent issues of retaliation and employee dissatisfaction with the current reporting mechanisms. Additionally, Erica shares practical strategies for compliance teams to address these challenges and enhance their ethical culture. Highlights in this Episode Genesis of the 2024 Ethical Culture Report The Eight Pillars of Ethical Culture Key Insights: Closing the Speak Up Gap The Role of Managers in Compliance The Tenure Smile: Willingness to Speak Up Strategies for Improving Reporting Ethisphere's Future Plans and Masterclass Resources: Erica Salmon Bryne on LinkedIn 2024 Ethical Culture Report: Closing the Speak Up Gap Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices