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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
Everything You Need to Know About Independent MonitoringHave you ever wondered who makes sure a company holds up their end of a court ordered agreement? On this episode of The Inside BS Show, Dave Lorenzo interviews Vin DiCianni, the Founder of Affiliated Monitors Inc. It is their job to oversee compliance in a variety of circumstances.Join us for this show to discover the value of independent monitoring and much more. 00:00 Everything You Need to Know About Independent Monitoring01:49 Why did Vin start Affiliated Monitors?03:16 The Process of Settling with the Government as a Whistleblower06:13 What is a Private Monitoring?08:34 How can an Independent Monitor Help with a Licensing Agreement?11:08 How Do Independent Monitors Handle Advertising and Affiliation with The Legal Community?14:58 Is it a Good Idea to Bring in the Monitors as an Attorney representing a Firm that has no other choice than to close down?17:40 A Deep Understanding of a “Third Party Management” in an Independent Monitor Involving Transnational Issue.25:02 What is a Competitive Advantage in Marketing Strategy that is Verified by an Independent Monitor? 27:40 When Management Changes During an Inquiry, how Monitors handle the Issue?31:05 A Case Scenario: What Would Happen if Monitors Intervened in a National Labor Relations Board?34:12 Who to Educate about The Advantages of Monitoring?Vin DiCianniPresident and FounderAffiliated Monitors(617) 519-3899vdicianni@affiliatedmonitors.comVincent DiCianni is President and founder of Affiliated Monitors Inc. “AMI”, an independent monitoring and compliance and ethical culture assessment firm that evaluates businesses for compliance with law, regulations and best compliance practices. Before starting Affiliated Monitors in 2004, Mr. DiCianni served as an Assistant Attorney General for the Commonwealth of Massachusetts and in private practice representing businesses and professionals. In addition to overseeing Affiliated Monitors, and serving as an independent integrity monitor, Mr. DiCianni regularly conducts ethics and compliance assessments for clients in diverse fields, such as not-for profit entities, construction, antitrust, healthcare corrections, financial services, education, and government contracting. AMI works with clients to craft appropriate compliance measurement tools and to implement long-term strategies for supporting a culture of compliance within organizations. AMI provides independent integrity monitoring services for the United States Department of Justice, the United States Department of Defense, Health and Human Services, U.S.A.I.D., the U.S. Department of Transportation and many other federal agencies, state and municipal agencies. AMI also handles many Suspension and Debarment matters with U.S. Agencies such as the U.S. Navy, Air Force, Army and Environmental Protection Agency, as well as the World Bank. In addition to AMI's monitoring and consulting engagements, AMI works with multi-national companies in designing, implementing, and strengthening their programs and ethical cultures.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Audrey Harris, who handled FCPA cases prior the explosion of FCPA enforcement actions in the early 2000's, sat in the CCO Chair, led compliance program work back in private practice and now is Managing Director for Global Anti-corruption, Compliance, Ethics & Non-Financial Risk at Affiliated Monitors Inc. In this concluding episode, Audrey reflects on a key lesson which led her to join AMI. It is that an external monitor can be a Value-Add proposition for all-sides, Company Business, Company Compliance, External Counsel, Enforcement/Regulators and other Stakeholders. It is not a second investigation, nor should it be seen as a “gotcha”. Rather a monitor can present a path that can protect stakeholder and grow business, especially in this time of heightened awareness to social license and reputational risk. Audrey concludes that she loves the concept of turning a challenge into an opportunity and working at AMI on a monitorship team provides that opportunity. Resources Audrey Harris on LinkedIn Audrey Harris on Affiliated Monitors, Inc. Learn more about your ad choices. Visit megaphone.fm/adchoices
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Audrey Harris, who handled FCPA cases prior the explosion of FCPA enforcement actions in the early 2000's, sat in the CCO Chair, led compliance program work back in private practice and now is Managing Director for Global Anti-corruption, Compliance, Ethics & Non-Financial Risk at Affiliated Monitors Inc. In 2018, Audrey moved back into private practice, utilizing many of the skill sets she learned in the CCO chair. She understood that the business folks in any company needed answers not legal Memos so she worked to create compliance programs tailored to how business works. She helped to identify emerging risks company's did not see and helped not simply solve compliance issues but also solve business problems with the same or similar solutions. Resources Audrey Harris on LinkedIn Audrey Harris on Affiliated Monitors, Inc. Learn more about your ad choices. Visit megaphone.fm/adchoices
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Audrey Harris, who handled FCPA cases prior the explosion of FCPA enforcement actions in the early 2000's, sat in the CCO Chair, led compliance program work back in private practice and now is Managing Director for Global Anti-corruption, Compliance, Ethics & Non-Financial Risk at Affiliated Monitors Inc. Even though Audrey had seen numerous CCOs ‘die painful professional deaths' in 2015, Audrey moved into the CCO Chairs at BHP. She gave the Top 10 CCO lessons she learned in that role. When asked what her top accomplishment was, she answered that it was seeing the professional growth in her team and how this compliance team grew and led a compliance reset for the company. She also learned to make the commercial case for compliance. Resources Audrey Harris on LinkedIn Audrey Harris on Affiliated Monitors, Inc. Learn more about your ad choices. Visit megaphone.fm/adchoices
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to navigate the compliance waters in any company successfully? What are some of the top challenges CCOs have faced, and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Audrey Harris, who handled FCPA cases before the explosion of FCPA enforcement actions in the early 2000s, sat in the CCO Chair, led compliance program work back in private practice, and now as Managing Director for Global Anti-corruption, Compliance, Ethics & Non-Financial Risk at Affiliated Monitors Inc. Audrey graduated from Central Florida with a BA, got a MA at the University of Miami, and her law degree from Georgetown. A question about whether she wanted to go to South Beach when she was a summer clerk at Kirkland & Ellis led to FCPA work and eventual partnership at Kirkland. When she began, it was a different time in FCPA enforcement, pre-2004, and the explosion in FCPA growth. In this role, she loved problem-solving and seeing patterns, and asking why (and why and why). Resources Audrey Harris on LinkedIn Audrey Harris on Affiliated Monitors, Inc. Learn more about your ad choices. Visit megaphone.fm/adchoices
Jay Rosen of Affiliated Monitors, inc comes armed with a colorful career ranging from entertainment to business development, discussing the multi-faceted world of ethics. Joel Volk of Hot Dog Business Growth builds a rapport focusing on the common theme of finding what you value most from work and personal life. ----------------- GUEST: Jay Rosen | www.AffiliatedMonitors.com ----------------- We'd like to thank our sponsors: Hot Dog Business Growth Miller Haga Law Group Fit4TheCause Jorgensen HR ----------------- Produced by Mr. Thrive Media | Chaz@MrThrive.com
Another great woman in Fraud today is Cristina Revelo. We “met” through Jay Rosen. What a small world we live in. I love Cristina's story because she has done so much in her career already but she is not afraid to try new things. What is a monitorship, you ask? I like to call it time out for corporations. Listen to a much better definition of it from Cristina. The thing is that monitorships will be increasing. That just came out of the White Collar Crime Conference in Miami in October. I have included the link in the shownotes. From Deputy Attorney General Lisa Monaco: Of course, the decision to use monitors must also include consideration of how the monitorship is administered and the standards by which monitors are expected to do their work. And the selection of monitors will continue to be accomplished in a fashion that eliminates even the perception of favoritism. The department will study how we select corporate monitors, including whether to standardize our selection process across the divisions and offices.” As to what I listened to last week it was a lot but one podcast really stood out to me. Hidden Brain Work 2.0 The Obstacles You Don't See. Organizational Psychologist Loran Nordgren was a guest. When the last time you bought a new sofa did it take you longer to buy it because you didn't know what or how you were going to get rid of your old sofa. This is a real problem. The story of Beach House was fascinating. Fuel and Friction got me thinking about why so many victims don't go to law enforcement. We need to remove the friction for our clients. Take a listen. And I ordered Nordgren's new book, The Human Element: Overcoming the Resistance That Awaits New Ideas. Podcasts cost me money. So many books to read after listening to guests. Let's get listening to Cristina. https://www.linkedin.com/in/cristinarevelo/https://www.affiliatedmonitors.com/cristina-revelo/https://www.justice.gov/opa/speech/deputy-attorney-general-lisa-o-monaco-gives-keynote-address-abas-36th-national-institute
What is organizational culture? Eric R. Feldman, SVP at Affiliated Monitors Inc. (AMI), has said it comprises the mission, vision and values of an organization. A similar way to consider it might be as a company’s values, visions, norms and beliefs. Whichever way you define it or look at it, corporate culture affects how groups within a company interact with each other. A key inquiry is whether the corporate incentive structure supports the articulated beliefs of a company. How does one measure or audit these articulations? Companies must have a high-performance corporate culture for doing business ethically. One of the ways to do so is through the culture audit. It can also be a powerful tool for continuous improvement going forward. Find out what your employees are saying about your corporate mission, vision and values and most importantly remediate if those mission, vision and values are found wanting. Three key takeaways: What are the mission, vision and values of a company? What are the compensation and promotion incentives in the culture? Is your motto “Always be closing” or closer to “doing business ethically and in compliance”?
Given the paucity of leadership coming out of Washington during this crisis, I thought it would be a ripe time to consider some innovations in compliance leadership. While many compliance departments may have begun more as a command and control function, set up by lawyers to comply with anti-bribery laws such as the Foreign Corrupt Practices Act (FCPA), this type of leadership model is now becoming outmoded in today’s world. It is not that employees are interested in the ‘why’ they should do business ethically and in compliance with such laws but it is more that power is shifting inside corporations. Given the paucity of leadership coming out of Washington during this crisis, I thought it would be a ripe time to consider some innovations in compliance leadership. While many compliance departments may have begun more as a command and control function, set up by lawyers to comply with anti-bribery laws such as the Foreign Corrupt Practices Act (FCPA), this type of leadership model is now becoming outmoded in today’s world. It is not that employees are interested in the ‘why’ they should do business ethically and in compliance with such laws but it is more that power is shifting inside corporations. As the compliance profession matures, it will become more a component of a company’s business function. This means less of a lawyer’s top down mentality of do it because I said to do it, to more collaboration. Three key takeaways: The lawyer-driven command and control method for compliance is outmoded and outdated. Innovation in compliance leadership is recognizing the bi-lateral nature of power and communications in an organization. A feedback loop can be used in the leadership function as well. For more information on our sponsor, Affiliated Monitors Inc. check out their website, by clicking here.
In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I have been joined by AMI Managing Director Stern. We have considered how defense counsel can work proactively with independent monitors to help clients who may have sustained an ethical or compliance violation or are under government scrutiny for allegations of illegal misconduct in a wide variety of industries, disciplines and corporate settings. In this concluding episode, we look at a third-party independent in non-profit setting and how it could help universities survive Varsity Blues. Find out more about Affiliated Monitors Inc. by checking out their website here. Learn more about your ad choices. Visit megaphone.fm/adchoices
In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent monitors to help clients who may have sustained an ethical or compliance violation or are under government scrutiny for allegations of illegal misconduct in a wide variety of industries, disciplines and corporate settings. In this fourth episode, we look at a third-party independent in the health care setting. Join us in our concluding episode in which we consider working with independent third-party monitor in the non-profit setting and the Varsity Blues scandal. Find out more about Affiliated Monitors Inc. by checking out their website here. Learn more about your ad choices. Visit megaphone.fm/adchoices
In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent monitors to help clients who may have sustained an ethical or compliance violation or are under government scrutiny for allegations of illegal misconduct in a wide variety of industries, disciplines and corporate settings. In this second episode, take a deep dive into the nuts and bolts of defense counsel working with a third-part independent monitor. Join us in our next episode in which we consider case studies where an independent third-party monitor was used successfully by defense counsel. Find out more about Affiliated Monitors Inc. by checking out their website here. Learn more about your ad choices. Visit megaphone.fm/adchoices
In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent monitors to help clients who may have sustained an ethical or compliance violation or are under government scrutiny for allegations of illegal misconduct in a wide variety of industries, disciplines and corporate settings. In this first episode, we introduce the concept of defense counsel working with independent monitors. Join us in our next episode where we dive into the weeds by looking at the nuts and bolts of working with a third-party independent monitor. Find out more about Affiliated Monitors Inc. by checking out their website here. Learn more about your ad choices. Visit megaphone.fm/adchoices