FCPA Compliance Report

Follow FCPA Compliance Report
Share on
Copy link to clipboard

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.

Tom Fox


    • Jan 23, 2023 LATEST EPISODE
    • weekly NEW EPISODES
    • 20m AVG DURATION
    • 1,435 EPISODES


    More podcasts from Tom Fox

    Search for episodes from FCPA Compliance Report with a specific topic:

    Latest episodes from FCPA Compliance Report

    Tom Fox and Mike Volkov with the 2022 Year in Review for the FCPA, Part 2

    Play Episode Listen Later Jan 23, 2023 36:36


    Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special episode, I am joined by Mike Volkov, founder of the Volkov Law Group. We conclude with Part 2 looking back on the year 2022 in FCPA and Compliance. We consider the Monaco Memo, the key cases and some of the important issues which arose in 2022 and how they might impact compliance in 2023. In this episode we consider: ·      Building trust and credibility in the investigative process ·      The ABB FCPA enforcement action ·      The Honeywell FCPA enforcement action ·      Why the heat is on compliance after the Monaco Memo ·      Corporate incentives and discipline including clawbacks ·      The Glencore FCPA enforcement action and CCO Certification Resources Mike Volkov on LinkedIn The Volkov Law Group Learn more about your ad choices. Visit megaphone.fm/adchoices

    Tom Fox and Mike Volkov with the 2022 Year in Review for the FCPA, Part 1

    Play Episode Listen Later Jan 9, 2023 44:49


    Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special episode, I am joined by Mike Volkov, founder of the Volkov Law Group. We begin a two-part podcast on looking back on the year 2022 in FCPA and Compliance. We consider the Monaco Memo, the key cases and some of the important issues which arose in 2022 and how they might impact compliance in 2023. In this episode we consider: ·      The Monaco Memo ·      The Stericycle FCPA enforcement action ·      The KT FCPA enforcement action ·      The upcoming trial of Cognizant executives and internal investigations ·      Key individual prosecuted Resources Mike Volkov on LinkedIn The Volkov Law Group Learn more about your ad choices. Visit megaphone.fm/adchoices

    Eric Morehead-The US Sentencing Guidelines at 30

    Play Episode Listen Later Jan 2, 2023 27:13


    Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special episode, I visit with Eric Morehead, the Director of Advisory Services at LRN. We discuss the US Sentencing Guidelines on the 30th anniversary of their enactment and review the recent report on the history of the Sentencing Guidelines. Morehead, a former staff attorney at the US Sentencing Commissions takes a look at the numbers and considers the broader impact of the Sentencing Guidelines on compliance in the US and across the globe. Some of the highlights include: ·      What are  the US Sentencing Guidelines? ·      Why were the enacted? ·      How have they been supported by the DOJ and Courts? ·      What were the two amendments to the US Sentencing Guidelines? ·      What may be down the road for the US Sentencing Guidelines?  Resources LRN Eric Morehead on LinkedIn A Deep Dive Into Organizational Sentencing Data by Eric Morehead on Law360 Learn more about your ad choices. Visit megaphone.fm/adchoices

    Scott Garland and Zach Hafer – Practice After the DOJ

    Play Episode Listen Later Dec 19, 2022 30:50


    Welcome to the award-winning FCPA Compliance Report, the most senior podcast in compliance. In this episode, I have double trouble as I welcome Scott Garland and Zach Hafer. They worked together for many years at the US Attorney's Office for the District of Massachusetts, and both are now in private practice, Garland as a Managing Director at Affiliated Monitors, Inc. and Hafer as a Partner at Cooley LLP in Boston. Some of the highlights include: In this podcast Hafer considers DOJ corporate enforcement through the mechanisms of DPAs and NPAs based upon his tenure as the Criminal Chief. They discussed the need to balance approving prosecutions for general impact vs. based on the case's individual merits. We also consider how if at all did the Monaco Memo change DOJ focus. Garland leads us through a discussion of compliance issues within a prosecutor's office, why your compliance philosophy is so critical and some of the biggest issues and situations they both confronted while in the US Attorney's Office for the District of Massachusetts. We conclude this section with a discussion of receiving compliance advice: what worked and what did not. We conclude with a discussion of transitioning from DOJ to private practice and both Zach and Scott summarize some of the key questions they are getting from clients. Garland opines on key issues he sees for monitors after Monaco Memo and we conclude with why can proactive monitoring be such a powerful tool.  Resources Scott Garland at Affiliated Monitors Zach Hafer at  Cooley LLP Learn more about your ad choices. Visit megaphone.fm/adchoices

    FTX and Risk: Part 2 - Risk Management and Due Diligence

    Play Episode Listen Later Dec 12, 2022 30:18


    Welcome to the award-winning FCPA Compliance Report, the most senior podcast in compliance. In this episode, I conclude a 2-part series on the subjects of FTX and risk. I am joined by Gilbert Paiz and Andrew Gay, principals in the Texas Hill Country Advisors. In our previous Part 1, we considered risk and risk management through the lens of US domiciled financial institutions and how their risk management protocols help to not only assess risk, but manage throughout the life cycle of a banking-customer relationship. In this Part 2, we consider individual risk in investing and what type of background information, questions and due diligence individual should engage in and how thes questions and background investigations apply equally to larger investments made by sophisticated investors, hedge funds  and institutional investors; who should have made them before investing in FTX but they all failed to do so.   Some of the highlights include:  ·      What due diligence should an individual perform? ·      What should an individual look for in financial statement? ·      Why is the physical location of businesses and where it might be incorporated such an important piece of information? ·      What are backstops, guarantees or other mechanisms to retrieve investments? ·      What Due Diligence mistakes did you see in FTX? ·      What are related party transactions and why are they problematic? ·      Why are audited financials critical?  Resources Texas Hill Country Advisors Learn more about your ad choices. Visit megaphone.fm/adchoices

    FTX and Risk: Part 1 - Financial Institutions

    Play Episode Listen Later Dec 5, 2022 23:46


    Welcome to the award-winning FCPA Compliance Report, the most senior podcast in compliance. In this episode, I begin a 2-part series on the subjects of FTX and risk. I am joined by Gilbert Paiz and Andrew Gay, principals in the Texas Hill Country Advisors. In Part 1, we consider risk and risk management through the lens of US domiciled financial institutions and how their risk management protocols help to not only assess risk, but manage risk throughout the life cycle of a banking customer relationship. In Part 2, we will consider individual risk in investing and what type of background information, questions and due diligence individual should engage in and how this questions and background investigations apply equally to larger investments made by sophisticated investors, hedge funds  and institutional investors; who should have made them before investing in FTX but they all failed to do so.  Some of the highlights include:  ·      How do banks think of risk? ·      What internal processes or controls are in place to help a bank manage its risks? ·      What types of oversight do banks and financial institutions use to help manage risk? ·      Why are levels of review so critical? ·      How do banks think about customers in terms of risk? ·      Who decides how much risk to allow a customer to engage in with a banks money, whether through loans or other capital? ·      Do bank employees receive ongoing training on risk management issues? ·      What tech is in place to facilitate the management of risk?  Resources Texas Hill Country Advisors Learn more about your ad choices. Visit megaphone.fm/adchoices

    Ty Francis on LRN Acquisition of Compliance Learning Solutions

    Play Episode Listen Later Dec 2, 2022 19:17


    Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special episode, I visit with Ty Francis, the Chief Advisory Officer at LRN. We discuss the just-announced LRN acquisition of the Compliance Learning business unit from Thomson Reuters. The acquisition will further establish LRN's position as the largest global provider of E&C program management and learning solutions serving over 2,500 companies and tens of millions of learners. It will place LRN literally across every continent, including a larger strategic presence in Asia-Pacific markets. This acquisition also enhances LRN's capabilities and expertise in the financial services marketplace and will help accelerate several of its vertical market product strategies. Some of the highlights include: ·      How this acquisition allows LNR to bring compliance training to where a customer's employees are located. ·      How this acquisition will facilitate data-driven compliance.  ·      Why a holistic, worldwide scope for compliance learning will be a business positive.  ·      How this acquisition will meet the continued growth in the regulatory landscape on a global basis.  Resources LRN Learn more about your ad choices. Visit megaphone.fm/adchoices

    Investigative Protocols After the Monaco Memo

    Play Episode Listen Later Nov 28, 2022 48:38


    In this episode, I take things in a different direction today as I post the recording of a webinar I recently put on for i-Sight Software Solutions. In this presentation, I detail what the Monaco Memo means your corporate investigative protocol.  Some of the highlights include:  ·      What changes did the Monaco Memo portend for corporate investigative protocols? ·      What unintended consequence did the Russian invasion of Ukraine bring to the public view of whistleblowers?  ·      Why is triage a key aspect of your investigative protocol? ·      Why should you create an investigative protocol long before an investigation becomes needed? ·      How do you create an investigative protocol to keep key decision makers in the loop?  Resources For a White Paper on these issues, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices

    David Simon and Mike Walsh on Global Supply Chain Disruption and Compliance, Part 2

    Play Episode Listen Later Nov 21, 2022 25:00


    In this episode, I visit with Foley & Lardner partners David Simon and Mike Walsh on the disruption to the global supply chain, which I focused on in the podcast series, Never the Same. They have co-authored an article entitled,  Managing Supply Chain Disruption in an Era of Geopolitical Risk on the topic. In this Part 2 of a two-series, we continue our exploration of the current global supply chain and focus on issues relating to China.  Some of the highlights include:  ·      Why ever company should prepare for a China confrontation over Taiwan. ·      Is the UFLPA a true game changer for supply chains and compliance?  ·      What is the impact of China's Belt and Road program? It's debt financing? ·      Why is the global supply chain and indeed the global economy of the past 30 years now dead? ·      What steps compliance functions should take now around the global supply chain of the future.  Resources David Simon Mike Walsh Managing Supply Chain Disruption in an Era of Geopolitical Risk by Mike Walsh and David Simon Why Supply Chain Will Never Be the Same After the Russian Invasion by Tom Fox Learn more about your ad choices. Visit megaphone.fm/adchoices

    David Simon and Mike Walsh on Supply Global Chain Disruption and Compliance, Part 1

    Play Episode Listen Later Nov 14, 2022 21:56


    In this episode, I visit with Foley & Lardner partners David Simon and Mike Walsh on the disruption to the global supply, which I explored in the podcast series, Never the Same. They have co-authored an article entitled,  Managing Supply Chain Disruption in an Era of Geopolitical Risk on the topic. In this Part 1 of a two-series, we begin to explore the topic of the events which have led to the disruption of the global supply chain and the impact on compliance functions. Some of the highlights include:  ·      What led to the disruption in the global supply chain?  ·      Will this continue for the foreseeable future? ·      Why is the global supply chain and indeed the global economy of the past 30 years or so now dead? ·      Why the impact of this supply chain disruption is greater in the EU than US.  Resources David Simon Mike Walsh Managing Supply Chain Disruption in an Era of Geopolitical Risk by Mike Walsh and David Simon Why Supply Chain Will Never Be the Same After the Russian Invasion by Tom Fox Learn more about your ad choices. Visit megaphone.fm/adchoices

    Shannon Martin on Internal Podcasts for the Corporate Compliance Function

    Play Episode Listen Later Nov 7, 2022 19:44


    In this episode, I visit Shannon Martin, Director of Communications and Corporate Podcasting Specialist at Podbean, a podcast hosting platform. We discuss how companies and, more specifically, corporate compliance functions can use internal podcasts to communicate compliance and ethics concepts using storytelling and other informative techniques. Some of the highlights include: Why storytelling works in the corporate world. Why the power of voice works so well. How internal podcasts can help a compliance function avoid compliance communication fatigue. Why your imagination only limits you.  Resources Shannon Martin on LinkedIn Podbean Learn more about your ad choices. Visit megaphone.fm/adchoices

    James Koukios on MoFo's April 2022 Top 10 International Anti-Corruption Developments

    Play Episode Listen Later Oct 31, 2022 25:27


    In this episode, I visit with fan fav James Koukios, partner at Morrison & Foerster on the firm's always great monthly Top 10 International Developments newsletter for the month of April 2022. Some of the highlights include: Key areas we discuss on this podcast are: ·      The Stericycle FCPA enforcement action. ·      The Roger Ng conviction. ·      Limits of prosecution on FCPA accounting provisions? ·      US government using corporations in the ABC, AML and trade control fight.  James Koukios on MoFo.com MoFo Top 10 International Anti-Corruption Developments for April 2022 Learn more about your ad choices. Visit megaphone.fm/adchoices

    A Dark Day for Dechert

    Play Episode Listen Later Oct 24, 2022 23:16


    In this episode, I visit with Jonathan Armstrong, partner at Cordery Compliance in London. We consider the recent payment by the international law firm Dechert of £20 million for its conduct and that of its former partner Neil Gerrard in the ENCR affair. The matter was certainly a dark day for Dechert and a black eye on the legal profession. Some of the highlights include:  Key areas we discuss on this podcast are: ·      What were the failures of the law firm?  ·      What led to the £20 million interim payment? ·      Will there be discipline against the law firm? ·      What is the role of a law firm to oversee investigations? ·      How are the implications of holding investigative data under GDPR going forward? ·      Who watches the watchers (and investigators)?  Resources Jonathan Armstrong on Cordery Compliance Hannah Walker in Law.com on the scandal Learn more about your ad choices. Visit megaphone.fm/adchoices

    Erica Salmon Byrne on Ethisphere Partnership with Alpine Investors

    Play Episode Listen Later Oct 17, 2022 20:13


    In this episode, I visit with Erica Salmon Byrne, now CEO at Ethisphere. We review the firm's recent acquisition by Alpine Investors, a B-Corp. Key areas we discuss on this podcast are: What does this new partnership mean for Ethisphere? Who is Alpine Investors, and what is a B Corp. What is People Focused Private Equity, and why was this a good fit for Ethisphere? What will be Erica's role going forward? How this move will refocus Ethisphere's efforts in ESG.  Resources Ethisphere Press Release Ethisphere Alpine Investors Learn more about your ad choices. Visit megaphone.fm/adchoices

    Oracle FCPA Enforcement Action

    Play Episode Listen Later Oct 10, 2022 25:46


    In this episode, I take on a solo pod to discuss and consider the Oracle FCPA enforcement action brought by the Securities and Exchange Commission. Key areas for discussion on this podcast are: ·      Background facts. ·      Same facts in same country? ·      Failure of a paper program. ·      The need for data analytics.  ·      Where is the DOJ? ·      What are the lesson learned going forward? Resources For a White Paper on the Oracle FCPE enforcement action, email tfox@tfoxlaw.com Learn more about your ad choices. Visit megaphone.fm/adchoices

    Mike Huneke on the General Counsel Role in CCO Certification

    Play Episode Listen Later Oct 3, 2022 28:57


    In this episode, I visit with Mike Huneke, partner at Hughes Hubbard. We look at the role of the GC in the CCO certification requirement as first announced by Assistant Attorney General Kenneth Polite and confirmed by Deputy Attorney General Lisa Monaco. Some of the highlights include: Key areas we discuss on this podcast are: What is the new CCO certification policy? Why did the DOJ create the policy? How has the DOJ thinking around recidivists evolved? Reasonableness is not a factual basis. Companies with full transparency are unlikely to have conflicts due to the recent changes in CCO certification. What is the role of the monitor going forward? Resources Mike Huneke on Hughes Hubbard What is the General Counsel's role in CEO and CCO compliance certifications? On the FCPA Blog Learn more about your ad choices. Visit megaphone.fm/adchoices

    The EC Gang on the Monaco Doctrine

    Play Episode Listen Later Sep 30, 2022 56:31


    In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, we have the Award-Winning Everything Compliance quartet of Jonathan Marks, Jonathan Armstrong, Karen Woody, and Tom Fox on the Monaco Memo. 1. Tom Fox looks at the Monaco Memo through the monitorship language and answers a listener's questions about compliance programs under the Monaco Memo. 2. Karen Woody reviews the Monaco Memo, the self-disclosure angle, and investigatory considerations and ponders the role of defense counsel going forward. 3. Jonathan Marks also looks at investigatory issues under the Monaco Memo, the role of the Board of Directors, and the role of the forensic auditor under the Monaco Memo. 4. Jonathan Armstrong's self-disclosure from a UK angle joins Karen Woody in questioning how defense counsel should move forward. Resources Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog 1.     A Jolt for Compliance 2.     Timely Self-Disclosure 3.     Corporate Compliance Programs 4.     Monitors 5.     The Heat is On Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices

    Laura Perkins on the Monaco Memo

    Play Episode Listen Later Sep 29, 2022 21:44


    In this special 5 part podcast series, I am taking a deep five into the Monaco Memo and analyzing it from a variety of angles. In this episode of the FCPA Compliance Report, I am joined by Hughes Hubbard partner Laura Perkins to take a deep dive into the Monaco Memo. Some of the highlights include: 1.     Determination of Monitor Need.  2.     Roadmap to proa-active compliance.  3.     Timely self-disclosure as criteria for monitorship? 4.     Monitor selection criteria. 5.    Monitor review and oversight. Resources Laura Perkins on HughesHubbard.com Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog 1.     A Jolt for Compliance 2.     Timely Self-Disclosure 3.     Corporate Compliance Programs 4.     Monitors 5.     Polite Speech Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices

    Matt Kelly on the Monaco Memo

    Play Episode Listen Later Sep 28, 2022 36:40


    In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, I am joined by my Compliance into the Weeds co-host Matt Kelly for a deep dive into the weeds of the Monaco Memo. Some of the highlights include: Corporate accountability. Timeliness in turning over evidence of wrongdoing. Baby Carrots in evaluating the corporate history of misconduct. Additions to Evaluation of Corporate Compliance Programs. Tweaks to the Yates Memo formulation. Monitors and Monitorships.  Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Introduction Self-Disclosure Corporate Compliance Programs Monitors What it all means Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices

    Vin DiCianni on the Monaco Memo

    Play Episode Listen Later Sep 27, 2022 36:03


    In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, I am joined by my Affiliated Monitors founder Vin DiCianni to take a deep dive into the monitors and monitorship portions of the Monaco Memo. Some of the highlights include: Determination of Monitor Need. Roadmap to proa-active compliance. Timely self-disclosure as criteria for monitorship? Monitor selection criteria. Monitor review and oversight.  Resources Vin DiCianni on Affiliated Monitors Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog A Jolt for Compliance Timely Self-Disclosure Corporate Compliance Programs Monitors Polite Speech Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices

    James Koukios on the Monaco Memo

    Play Episode Listen Later Sep 26, 2022 36:31


    In this special 5 part podcast series, I am taking a deep five into the Monaco Memo and analyzing it from a variety of angles. In this episode of the FCPA Compliance Report, I am joined by fan fav James Koukios, partner at MoFo. James is a former member of the FCPA Unit and in this podcast we take a deep dive into the Monaco Memo. Some of the highlights include: 1.     Issues involving individual accountability.  2.     Burden shifting on communications devices and timeliness of self-disclosing and reporting.  3.     How the Monaco Memo lays out DOJ expectations? 4.     Monaco Memo at 30,000 ft and ground level. . 5.    Tweaks to the Yates Memo formulation. 6.    New requirements to the FCPA Corporate Enforcement Policy  7.    Will the incentives be enough? Resources James Koukios on MoFo Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog 1.     A Jolt for Compliance 2.     Timely Self-Disclosure 3.     Corporate Compliance Programs 4.     Monitors 5.     Polite Speech Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices

    Tomell Ceasar and the Middle East and Africa Compliance Association

    Play Episode Listen Later Sep 19, 2022 29:01


    In this episode of the FCPA Compliance Report, I am joined by Tomell Ceasar. He is the Group Head of Ethics and Compliance at Careem (An Uber Company). He is one of the founders of the Middle East and Africa Compliance Association (MEACA). Some of the highlights include: 1.     What is it like practicing compliance in EAME?  2.     EAME is a huge amount of territory to cover with many different countries and cultures?  3.     How does that play into compliance for the region? 4.     Training in EAME. 5.    Genesis of MEACA. 6.    What do you and the other founders hope to accomplish through MEACA?  7.    What are the requirements for membership? Resources Tomell Ceasar on LinkedIn Middle East and Africa Compliance Association Learn more about your ad choices. Visit megaphone.fm/adchoices

    2023 World's Most Ethical Companies Applications Open

    Play Episode Listen Later Sep 12, 2022 17:12


    In this episode of the FCPA Compliance Report, I am joined by Erica Salmon Byrne, President of Ethisphere and Chair of the Ethisphere's Business Ethics Leadership Alliance. Some of the highlights include: 1.     Ethisphere announces the 2023 World's Most Ethical application process.  2.     What is the application process? 3.     What is the Ethics Quotient and why is it such a useful measure?  4.     What are the 5 categories of evaluation? 5.     Why is going through the application process itself so useful? 6.     How can a company use it as a benchmarking exercise? 7.     How does the Ethisphere “The Sphere” interact with the application process? 8.     What are the 6 archetypes of value creation? Resources Erica Salmon Byrne Ethisphere World's Most Ethical Companies application process, here Learn more about your ad choices. Visit megaphone.fm/adchoices

    Professor George Serafeim on Purpose + Profits

    Play Episode Listen Later Aug 29, 2022 32:52


    In this episode of the FCPA Compliance Report, I am joined by Harvard Business School Professor, author of the book Purpose + Profits, How Business Can Lift Up the World. Some of the highlights include: 1.     Why this book and why now? 2.     His personal journey to ‘purpose'. 3.     Is this book an extension of his earlier work around white-collar crime and anti-corruption compliance.  4.     What trends bring together both business goals and broader societal goals? 5.     How did technology and social media help this change? 6.     What is the role of Gen Xers and Millennials? 7.     How can or should a company data analytics into this change? 8.     What are the 6 archetypes of value creation? 9.     What is the Southwire “12 for Life” story?  10.  Why did your student's attempt to replicate it fail and what lessons did you draw from that failure.  Resources George Serafeim at the Harvard School of Business George Serafeim on Linkedin Purpose + Profits on Amazon.com Learn more about your ad choices. Visit megaphone.fm/adchoices

    Susannah Hammond on Thomson Reuters 2022 Cost of Compliance Report

    Play Episode Listen Later Aug 22, 2022 33:34


    In this episode of the FCPA Compliance Report, I am joined by Susannah Hammond, Senior Regulatory Intelligence Expert at Thomson Reuters, on the firm's 2022 Cost of Compliance Report. Some of the highlights include: The genesis of this report. Why can this Report be seen as cathartic? What was the genesis of this report? What areas have the greatest need for compliance functionality? What are the top 3 challenges for compliance functions and compliance professionals over the next 12 months? Why is culture still such a challenge? Where does the Report see compliance down the road Why will changes in regulations continue to be a key challenge? How concerned are compliance professionals about CCO and compliance personnel liability? Resources Susannah Hammond on LinkedIn 2022 Cost of Compliance Report, here Thomson Reuters Regulatory Intelligence website The Compliance Clarified podcast series Learn more about your ad choices. Visit megaphone.fm/adchoices

    Susannah Hammond on Thompson Reuters 2022 Cost of Compliance Report

    Play Episode Listen Later Aug 19, 2022 31:05


    In this episode of the FCPA Compliance Report, I am joined by Susannah Hammond, Senior Regulatory Intelligence Expert at Thompson Reuters on the firm's 2022 Cost of Compliance Report. Some of the highlights include: The genesis of this report. Why can this Report be seen as cathartic. What was the genesis of this report?  What areas have the greatest need for compliance functionality? What are the top 3 challenges for compliance functions and compliance professionals over the next 12 months? Why is culture still such a challenge? Where does the Report see compliance down the road Why will changes in regulations continue to be a key challenge? How concerned are compliance professionals about CCO and compliance personnel liability? Resources Susannah Hammond on LinkedIn 2022 Cost of Compliance Report, here Learn more about your ad choices. Visit megaphone.fm/adchoices

    Ty Francis on Assessing Corporate Culture: A Practical Guide to Improving Board

    Play Episode Listen Later Aug 15, 2022 29:05


    In this episode of the FCPA Compliance Report, I am joined by Ty Francis, Chief Advisory Officer at LRN. We dive deeply into a recently released LNR/Tapestry Networks Report on Assessing Corporate Culture: A Practical Guide to Improving Board Oversight. Some of the highlights include: The genesis of this report. How does the Report serve as a roadmap to a clearer picture of the company's ethical culture? How can the Report help determine how to improve culture throughout the enterprise? Who should a Board collaborate with, and how? How does the work LRN conducts help organizations foster more effective collaborative cultures? How do you prioritize culture on the board agenda? What is the challenge to the board's culture? How does a Board measure and monitor? How does a Board articulate the desired culture?  How can a Board establish clear communication? Resources Ty Francis on LinkedIn LRN Assessing Corporate Culture: A Practical Guide to Improving Board Oversight Tapestry Networks Learn more about your ad choices. Visit megaphone.fm/adchoices

    James Koukios on the MoFo February Int'l Anti-Corruption Newsletter

    Play Episode Listen Later Aug 8, 2022 33:34


    In this episode of the FCPA Compliance Report, I am joined by fan favorite James Koukios, a partner at Morrison and Foerster. This episode considers some of the key ABC issues in the always great MoFo Monthly Top 10 International Anti-Corruption Developments for February 2022. Highlights of this podcast include: KT FCPA Resolution Roger Ng was convicted at the FCPA trial. Resources James Koukios on the MoFo website February International Anti-Corruption Newsletter here Learn more about your ad choices. Visit megaphone.fm/adchoices

    Mary Inman on the Current State of Whistleblowing

    Play Episode Listen Later Aug 1, 2022 30:36


    In this episode of the FCPA Compliance Report, I am joined by Mary Inman, partner at Constatine Cannon. We look at recent developments in whistleblowing and how the Ukraine War has increased the visibility of whistleblowers. Highlights of this podcast include: Whistleblower Reward Program at the US Treasury Department/FinCEN – what is its relevance to corruption, anti-money laundering and the Ukraine conflict. The House Committee on Financial Services voted to strengthen the U.S. Treasury's Anti-Money Laundering (AML) whistleblower program. What does this mean for this nascent program? How does a minimum whistleblower reward threshold, whistleblower incentives and injects more certainty into the Anti-Money Laundering whistleblower program. How has expanding AML whistleblower rewards to cover laws applicable to Russian sanctions, Congress enlisted the help of the private citizenry. Lisa Monaco recently spoke about the government relying on corporations to ID instances of money-laundering and other activities to help enforcement Russia economic sanctions and broader trade sanctions. Are private citizen or other whistleblowers as a key component of this fight? How has the Ukraine War raised the profile of whistleblowers and whistleblowing? Starting with SOX, then Dodd-Frank and the AML Law of 2020 has the US government began to understand whistleblowers as a key component in the fight against fraud, waste and abuse. Has the government embraced these same strategies and tactics in the wider fight against corruption? Tribute to Chuck Grassley for his advocacy of whistleblowers.  Resources Mary Inman on Constantine Cannon website Learn more about your ad choices. Visit megaphone.fm/adchoices

    Alvarez & Marsal Threatscape 2022 Report

    Play Episode Listen Later Jul 25, 2022 37:16


    In this episode of the FCPA Compliance Report, I am joined by Keith Williamson and Henry Chambers, Managing Directors at Alvarez and Marsal. We look at the firm's Threatscape Report. Highlights of this podcast include: A.    Threat 1-ABC Threats Why do you see a potential increase in anti-corruption investigations? In addition to the US under the FCPA, do you see other countries actively assisting US authorities in ABC investigations? The new DOJ Monaco Doctrine reinstates the Yates Memo, and the DOJ focuses on individuals. What does this mean for ABC investigations? What are some of the key challenges in handling investigations in China? How does this increase in ABC enforcement impact M&A? B.     Threat 2-Fraud and Digital Asset Fraud Threats What are digit assets and digit asset fraud? The US has not yet released many regulations regarding cryptocurrency. What is the role of other countries in such regulation, if any? Why is the Ukraine war the first ‘digital asset war'? How have the worldwide sanctions against Russia impacted the growth and use of digit assets? What key controls and screen tools for digital assets that you advocate a company employ? C.     Threat 3-Data Privacy and Data Protection What is the Personal Information Protection Law, and how does it relate to the Chinese State Secrets and Data Security Laws? How can a non-Chinese company get data out of China? What are some key components of a compliance program for this new law? How does this new law impact investigations in China? Resources Threatscape 2022 report. Keith Williamson, MD, and Head of Disputes and Investigations in Asia. Henry Chambers, Senior Director, Disputes and Investigations. Learn more about your ad choices. Visit megaphone.fm/adchoices

    Scott Garland on Sanctions, Cyber, Fraud, and Ethics Compliance & Monitoring at AMI

    Play Episode Listen Later Jul 18, 2022 24:23


    In this episode of the FCPA Compliance Report, I am joined by Scott Garland, Managing Director, Sanctions, Cyber, Fraud, and Ethics Compliance & Monitoring at Affiliated Monitors, Inc. Some of the areas we discuss include Garland's professional background and current role. We look at some of his work at the DOJ including his role as the Deputy Chief, National Security Cyber Specialist and his work as Office's Professional Responsibility Officer. We discuss his move to AMI and the types of monitorships Garland hopes to work on, as well as his thoughts on the role of a monitor. We conclude with some of Garland's top recollections from UM Law School.  Resources  Scott Garland bio on AMI. Affiliated Monitors Inc. Learn more about your ad choices. Visit megaphone.fm/adchoices

    James Koukios on the MoFo January Int'l Anti-Corruption Newsletter

    Play Episode Listen Later Jul 11, 2022 27:47


    In this episode of the FCPA Compliance Report, I am joined by fan favorite James Koukios, partner at Morrison and Foerster. In this episode we consider some of the key ABC issues in the always great MoFo Monthly Top 10 International Anti-Corruption Developments for January 2022. Highlights of this podcast include: Opinion Release 22-01. Summary Judgment granted in bribery related breach of contract case-use of bribery allegations to get out of contract. FIFA defendants raise local law defense. What is it and how is it raised and why it has never been successful in a FCPA context Former CEO of Pemex charged. Is Mexico finally stepping up to ABC enforcement? South African anti-corruption commission. Will this finally help SA move past capture and a culture of corruption. Resources James Koukios on the MoFo website January International Anti-Corruption Newsletter here Learn more about your ad choices. Visit megaphone.fm/adchoices

    Josh Fitzhugh on Trade Compliance Since the Russian Invasion of Ukraine

    Play Episode Listen Later Jun 27, 2022 22:46


    In this episode of the FCPA Compliance Report I welcome back Flex Vice President of Global Trade, Josh Fitzhugh, who visits about the challenges in economic and trade compliance since the Russian invasion of Ukraine. Topics include Current role Pre-conflict preparation How were you able to mobilize for such robust economic and trade sanctions? Some of the biggest challenges early in the conflict? What are some of the biggest challenges your team currently faces? What new challenges do you see in Q3 or further down the road? Resources Josh Fitzhugh on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

    Erica Salmon Byrne on The Sphere

    Play Episode Listen Later Jun 24, 2022 14:05


    In this episode of the FCPA Compliance Report I welcome back Ethisphere President and Chair of the Business Ethics Leadership Alliance, Erica Salmon Byrne, who talks about an exciting new innovation and service offering called The Sphere. Through this offering and for the first time, Compliance  Professionals can easily benchmark against the practices of companies with exceptional programs, to identify gaps, benchmark and access a wealth of insights and resources to guide improvements. Key areas we discuss on this podcast are:  What is The Sphere?  The data and resources built into it. The ease of access. Where can listeners find this podcast. Resources Ethisphere The Sphere Erica Salmon Byrne on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

    Loren Steffy on Putin's Oil Heist Podcast

    Play Episode Listen Later Jun 20, 2022 21:51


    In this episode of the FCPA Compliance Report I welcome Loren Steffy, now podcast host. Steffy is in the middle of a limited series on the theft by Russian President Putin on the publicly traded Yukos Oil Company back in 2007.  Key areas we discuss on this podcast are:  Why this series and why now.  What is the genesis of this story? Who is Bruce Misamore and what was his role in Yukos. Where can listeners find this podcast.  Resources Putin's Oil Heist on Stoney Creek Publishing Loren Steffy on LinkedIn Putin's Oil Heist on the Compliance Podcast Network Learn more about your ad choices. Visit megaphone.fm/adchoices

    Mike DeBernardis on Compliance Developments from Q1 2022

    Play Episode Listen Later Jun 13, 2022 31:16


    In this episode of the FCPA Compliance Report I welcome back Mike DeBernardis, a partner at Hughes Hubbard, about some of the key developments in ethics compliance and FCPA from Q1 2022. Key areas we discuss on this podcast are:  Q1 brought resolutions that were excellent examples for training and increasing understanding of compliance issues.  One of the more difficult aspects of compliance is scoping investigations. View input from your monitor as an opportunity to truly improve your processes, procedures, and controls. Having a positive relationship with them is hugely valuable. Developing an investigation plan and protocols is an iterative process. Changes to the SEC Whistleblower program. Anti-corruption implications of the Russian invasion of Ukraine.   Resources Hughes Hubbard & Reed website Mike DeBernardis  Coburn and the Attorney/Client Privilege Learn more about your ad choices. Visit megaphone.fm/adchoices

    Scott Schneider on Your Code of Conduct

    Play Episode Listen Later Jun 6, 2022 28:14


    In this episode of the FCPA Compliance Report I visit with Scott Schneider, Head of Content Development at Traliant. Scott has been in the compliance space for over 15 years and is passionate about the building blocks of a best practices compliance program, including Codes of Conduct. This week we take a deep dive into the foundational backbone of every compliance program, the Code of Conduct.  Some of the highlights include: ·      Importance of  Code of Conduct training. ·      Types of Code training. ·      Why have a Code of Conduct? ·      How does a Code of Conduct help establish culture? ·      Key areas the Code should cover? ·      How should a company develop its Code of Conduct? ·      When should a Code be revisited or reassessed? ·      The roles of Codes of Conduct and training down the road into 2025 and beyond?         Resources Scott Schneider on LinkedIn Traliant website Learn more about your ad choices. Visit megaphone.fm/adchoices

    John Warren on 2022 ACFE Report to the Nations

    Play Episode Listen Later May 23, 2022 35:11


    In the Episode, I am joined by John Warren Vice President and General Counsel at the Association of Certified Fraud Examiners. We discuss the 2022 ACFE Report to the Nations, which is the most comprehensive report on the global scourge of fraud. It is a fascinating look of how fraud occurs, where is occurs and the steps you can take to prevent it. Some of the highlights include:  What is the ACFE Report to the Nations? How often is it released? What are you trying to capture? What are some of the big picture findings of the Report? What is the annual cost of global fraud? Why are hotlines so critical to fraud detection? What is the fraud tree? What are the 5 critical areas of occupational fraud reviewed? What does the Report to the Nations tell us about corruption? What detection/prevention areas are the most effective for corruption? You can download a copy of the ACFE 2022 Report to the Nations by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices

    Claire Worledge on Data Analytic Secrets

    Play Episode Listen Later May 16, 2022 38:42


    In this episode of the FCPA Compliance Report I visit with Claire Worledge. Claire is an internal auditor by professional training. She is the author of Data Analytic Secrets. We visit about her book and her work to bring greater visibility to data analytics to the internal audit profession and the wider compliance profession. Some of the highlights include: What is data visualization? What do you see as the role of data analytics in internal audit? Why Claire wrote Data Analytic Secrets  and the audience for the book. How can data analytics and visualization be used in fraud prevention?  How about anti-corruption/anti-bribery programs?  How can internal audit be best used in an anti-corruption/anti-bribery program? What is the intersection of internal audit and internal control?         Resources Claire Worledge on LinkedIn  Aufinia website Learn more about your ad choices. Visit megaphone.fm/adchoices

    Dave Lefort on Compliance Week 2022

    Play Episode Listen Later May 9, 2022 28:46


    In this episode of the FCPA Compliance Report I visit with Dave Lefort, Managing Director at Compliance Week. We take a deep dive into the upcoming Compliance Week 2022 National Conference, detailing the Keynote speakers, panels, conversations and breakout sessions. If there is one compliance conference, you should attend Compliance Week 2022 is it. Listeners to the podcast can get a special discount to the conference of $200 with the discount code TFLAW $200 OFF. Registration and agenda here. If you want more details on why should you attend Compliance Week 2022? Find out in this podcast series featuring speakers at CW 2022. Learn more about your ad choices. Visit megaphone.fm/adchoices

    Mike Volkov on DOJ Trial Record

    Play Episode Listen Later May 2, 2022 34:41


    In this episode of the FCPA Compliance Report I visit with Mike Volkov. Mike recently did a three-part blog post series reviewing the DOJ trial strategy, successes and failures and approach of the antitrust division. In this podcast we take a deep dive into FCPA trials, other white collar fraud trials and antitrust trials the DOJ has had over the past few years. We assess the key approaches, discuss some important wins and unfortunate stumbles.     Resources Mike Volkov on Corruption Crime & Compliance Part 1 - A Mixed Bag Part 2 – Big Victories and Misguided Targets Part 3 – Antitrust Division Stumbles Learn more about your ad choices. Visit megaphone.fm/adchoices

    Gordon Graham - A Whistleblower's Story

    Play Episode Listen Later Apr 25, 2022 40:53


    In this episode of the FCPA Compliance Report I visit with Gordon Graham. Gordon is a successful whistleblower who told his tale in the book The Intrepid Brotherhood. In this book, Graham discusses how corruption threatened to ruin jobs and harm lives. The leadership at the top of the organization used intimidation, distrust, and secrecy to control the Chelan County Public Utility District showing that control and power can corrupt even the most ethical organization's integrity—unless someone speaks up. Which Gordon Graham did. In this podcast, he tells his story.  Resources website: www.intrepidbrotherhood.com LinkedIn: linkedin.com/in/gordon-graham-57385319a Facebook Author Page: In Search Of Aristotle | Facebook Learn more about your ad choices. Visit megaphone.fm/adchoices

    Claim FCPA Compliance Report

    In order to claim this podcast we'll send an email to with a verification link. Simply click the link and you will be able to edit tags, request a refresh, and other features to take control of your podcast page!

    Claim Cancel