Podcasts about ethics blog

Episode #65 with Tom Fox & Malcolm Nance, plus Philip Rohlik This episode is devoted to discussing the recent executive order signed by US President Donald J. Trump instructing the Department of Justice to halt enforcement of the decades old, much-dreaded Foreign Corrupt Practices Act (FCPA) pending a one-year review. In our initial “Regulatory Ramblings Spotlight” segment, we speak with Philip Rohlik, an American attorney in mainland China with the law firm Debevoise & Plimpton to get a sense of what the president's decision means for Hong Kong and the broader Asia-Pacific. Following that, we have a lengthier chat on the global implications of President's Trump's move with Tom Fox, a veteran compliance and anti-corruption lawyer, noted FCPA specialist and podcaster, as well as Malcolm Nance, a former US naval intelligence officer, counterterrorism specialist and author. About the guests. Philip Rohlik is a counsel in the Shanghai office of Debevoise & Plimpton LLP. He is a member of the firm's White Collar & Regulatory Defense and International Dispute Resolution Groups whose practice focuses on international investigations, securities law and dispute resolution. He is recognized by “The Legal 500 Asia Pacific – Greater China” (2024-2025) for his anti-corruption and compliance practice and has been described as “very thorough and hands on," and "excellent investigation lawyer". Based in Asia since 2011, Philip leads the firm's dispute resolution team in Shanghai. He joined Debevoise in 2000, having received his J.D. magna cum laude from the New York University School of Law that same year. He received a B.A. summa cum laude with honors from St. Louis University in 1997. Tom Fox is based in West Texas and a prominent member of the compliance community and one of the most well-known legal practitioners when it comes to the FCPA. Over the past 15 years, he has been a general counsel and chief compliance officer. He is now an independent consultant, assisting companies with anti-corruption, anti-bribery compliance, and international transaction issues. He is also the author of the award-winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics.” His podcasts have won numerous w3, Davey, Communicator, and Webby awards for podcasting excellence. Tom is the author of the seminal text “The Compliance Handbook,” now in its 5th edition published by LexisNexis. In addition to his blog and podcast, he is a columnist for “Corporate Compliance Insights” and a contributing editor to the “FCPA Blog.” He is a well-known and frequent speaker on compliance and ethics issues, social media use, and corporate leadership. In the interests of full disclosure, Tom is founder of the Compliance Podcast Network which also carries this program. Malcolm Nance is based in upstate New York. He was a 20-year veteran of the US Navy where he was an intelligence officer and cryptographer, and a Russian and Arab language specialist. In his capacity as a master chief, he was responsible for discipline all throughout the ranks. He is best known for his appearances on MSNBC where he warned about Russian interference in the run up to the 2016 and 2020 US Presidential elections. Malcolm is also a best-selling author – with his books “The Plot to Hack America,” “The Plot to Destroy Democracy,” “The Plot to Betray America” and most recently “They Want to Kill Americans” – all of which are well worth reading. Given the radical actions of the second Trump administration, his two most recent books seem eerily prescient. HKU FinTech is the leading fintech research and education in Asia. Learn more at www.hkufintech.com.

Today we're discussing how compliance can increase the value of your company with the man who is known as the  “Compliance Evangelist.” Dave Bookbinder goes Behind The Numbers with Tom Fox, founder of the Compliance Podcast Network. Over the past 15 years, he has been a General Counsel and Chief Compliance Officer. He is now an Independent Consultant, assisting companies with anti-corruption, anti-bribery compliance, and international transaction issues. He specializes in bringing business solutions to compliance problems. Tom is the author of the award-winning Foreign Corrupt Practices Act (FCPA) Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics.”  In this episode we're discussing all things related to compliance including  how compliance makes businesses more efficient and more profitable. About the Host: Dave Bookbinder is the person that clients reach out to when they need to know what their most important assets are worth. He's a corporate finance executive with a focus on business and intellectual property valuation. Known as a collaborative adviser, Dave has served thousands of client companies of all sizes and industries.  Dave is the author of two #1 best-selling books about the impact of human capital (PEOPLE!) on the valuation of a business enterprise called The NEW ROI: Return On Individuals & The NEW ROI: Going Behind The Numbers.  He's on a mission to change the conversation about how the accounting world recognizes the value of people's contributions to a business enterprise, and to quantify what every CEO on the planet claims: “Our people are this company's most valuable asset.”

In this episode of the Principled Podcast, host Susan Divers continues her conversation from Episode 11 with Tom Fox, the founder of the Compliance Podcast Network, on the changing geopolitical landscape and its impact on E&C. Listen in as the two discuss how anti-corruption is a key component of ESG, the consequences of compliance in cybersecurity, and the growing interconnectedness of risks. You can listen to Episode 11 here.  To learn more, download a copy of Tom Fox's white paper Never the Same: Five Key Areas in Which Business Will Never Be the Same After the Russian Invasion.    Featured guest: Tom Fox Tom Fox is literally the guy who wrote the book on compliance with the international compliance best-seller The Compliance Handbook, 3rd edition, which was released by LexisNexis in May 2022. Tom has authored 23 other books on business leadership, compliance and ethics, and corporate governance, including the international best-sellers Lessons Learned on Compliance and Ethics and Best Practices Under the FCPA and Bribery Act, as well as his award-winning series "Fox on Compliance." Tom leads the social media discussion on compliance with his award-winning blog, and is the Voice of Compliance, having founded the award-winning Compliance Podcast Network and hosting or producing multiple award-winning podcasts. He is an executive leader at the C-Suite Network, the world's most trusted network of C-Suite leaders. He can be reached at tfox@tfoxlaw.com.   Featured host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years' accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM's Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM's ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers' thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company's ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.  Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics.  Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers: Hello and welcome to another episode of LRN's Principled Podcast. I'm your host, Susan Divers, Director of Thought Leadership and Best Practices at LRN. Today, I'm continuing my conversation from episode 11 with Tom Fox on the changing geopolitical landscape and its impact on ethics and compliance. If you haven't listened to that episode yet, we highly encourage you to do so. Tom is the founder of the Compliance Podcast Network and the author of the award-Winning FCPA Compliance and Ethics Blog, as well as the Complete Compliance Handbook, which is in its third edition. Tom, welcome back to Principled Podcast. Tom Fox: Thank you, Susan. Susan Divers: Tom, in our last episode, we talked about the impact of the war in the Ukraine on compliance and ethics. And specifically on the challenges that's imposed or brought to the fore for companies and specifically for their compliance teams who hopefully have a real seat at the table in terms of dealing with those challenges and mitigating those risks. But one of the topics that underlies what we were talking about is that of conducting your business in a fair, transparent, and sustainable manner. And I'm really struck by some of the things you were saying about the need to be transparent and the need to walk the walk and talk the talk. Because if you fail to do so, we live in an age of radical transparency and easy access to social media, and moreover, it's the right thing to do. So with that as the background, anti-corruption has long been a focus for regulators. I mean, it's probably defined yours and my careers in a lot of regards. But only recently have some people started talking about it, and you're one and I'm one, as a major component of ESG. Could you explain for our listeners how that works and the role of anti-corruption in ESG? Tom Fox: Sure. So ESG, in my mind, Susan, the power of ESG is that it has brought together disparate strands that have existed in every corporation for some lengthy period of time. But brought them together in a way that someone is looking at them holistically. So, I'll pick on E because that perhaps is the easiest. As a compliance officer, I never looked at environmental issues in our company. That was somebody else's responsibility. Susan Divers: Me either. Right. Tom Fox: Didn't mean there wasn't environmental compliance, but it meant that I wasn't looking at that from the compliance perspective. Now, whether it's the Chief Sustainability Officer, whether it's the Board of Directors, whether there's a Board ESG Committee, somebody's connecting compliance to environmental. And so that in and of itself is, to me, the most powerful reason to have a robust ESG program. But anti-corruption in ESG, in my opinion, Susan, I've always seen it directly in the G. Susan Divers: Me too. Tom Fox: Number one, it's a good governance issue. Number two, it is a Board of Director's issue. Number three, it's illegal and regulatory issue. But now Susan, I'm beginning to see it and have tried to articulate, that I see it in the S component as well as sustainability. Part of it is around one of the topics we touched on our last podcast of radical transparency, that if you do business ethically and in compliance, and if there's a question raised about a supplier, a customer, a distributor, a someone you've done business with in today's era of modern social media, that you can respond to that in a way that won't hurt your business from the public perception perspective. Leaving completely aside the regulatory perspective. So, I see ABC or anti-corruption compliance now, Susan, as directly within the S of ESG as well. And I also see it in the E. So to me, it sort of bleeds across all aspects of ESG and is a key component of a best practices ESG program. Susan Divers: Yeah, and I'm glad you articulated it so clearly for people, because I think there's a tendency perhaps, to silo ethics and compliance and sustainability. And they really are part and parcel of the same thing. And I'm going to quote from your recent white paper in support of that. "As a fundamental threat to the rule of law, corruption hollows out institutions, corrodes public trust, and fuels popular cynicism towards effective accountable governance." And that's, I think, a quote from the U.S. Strategy on Countering Corruption. Can you talk for us and link together how anti-corruption, anti-money laundering, and sanctions all are part and parcel of the same thing and relate to ESG? I think that'd be helpful for our listeners? Tom Fox: So Susan, the statement you read interests me for a couple of reasons. That came out of the U.S. Strategy on Countering Corruption, and it was aimed at national governments, so national governance. And I think it's absolutely correct that corruption, money laundering, all fuel cynicisms towards effective, accountable national governance. But Susan, as you were reading that, it struck me, that is equally true about corporate governance, or the G in ESG. Because violations of the rule of law, corruption, money laundering, they all corroded trust in our corporations, and indeed fuel cynicism towards effective accountable corporate governance. The United Nations estimates that $3 trillion is lost to the global economy annually because of bribery and corruption. The United States Department of Treasury estimates that $2 trillion is lost annually because of money laundry. That's $5 trillion taken out of the global economy that could be used for a wide variety of other ways, reasons to help countries and people that's not available to them. So having an effective anti-corruption and anti-money laundering strategy as well as trade sanctions, I think, are directly a part of ESG. They're certainly all in the G. We've talked about how they relate to sustainability. But money laundering and trade sanctions are as invidious, in my mind, as corruption is. After 9/11, we saw a spike in the first real spike in FCPA cases starting sort of circa '04. And it was said that corruption led to crime, which led to terrorism. And there was really a belief that corruption had a direct line to the terrorism that impacted the United States directly on 9/11. And now we see how corruption leads to erosion of trust in governance. But governance is not just corporate governance, it's democratic governance and democratic institutions. And certainly the Russian invasion of Ukraine put another exclamation mark on that. Whatever Russia is, it's not a democracy. And it is, if you want to see evidence of the invidiousness of corruption, you only need to look at a Russian army, their failures in Ukraine, how they've treated the people of Ukraine all wrapped up in an anti-democratic form. And that all speaks to the G. And when you read that line or that quote from my white paper, it struck me, that really works on multiple levels of governance. Susan Divers: Well, and you raise a good point too, that it's in the corporate governance area because if you... I've said this so many times, but it's worth repeating. If you have a code of conduct and you have training and you have policies, and you have an E&C team, that doesn't mean you have an ethical company, particularly if your leadership is engaging in sexual harassment or they're dealing with people who are banned because they're under sanction or they're violating anti-money laundering controls because it's a big account and they want the commission. That just means that your program is basically window dressing. So for corporations and for E&C professionals, it seems to me that making sure that you're doing business in an ethical, compliant way is part of and parcel of being sustainable. And part of demonstrating that trust that is essential, if you're going to do business effectively, as we've talked about. We talked last time a little bit about how the Biden administration has basically shifted the view of anti-corruption enforcement. And I think that bears reemphasizing, 'cause I thought that was such an interesting point that you raised about that in the last podcast. Do you mind repeating that? Tom Fox: Sure. So in December, 2021, the Biden administration release our U.S. Strategy on Countering Corruption. Once again, this did not come about because of the Russian invasion of Ukraine, but it occurred during the run up to it. And it's one of the things that I think the Russian invasion have put an exclamation point on as to why business will never be the same in certain areas. You and I have been in the anti-corruption field for a long time. As of December, 2021, our fight is now a national security fight. And they elevated anti-corruption and the fight against corruption to a national security issue. When something becomes a national security issue of the United States, that means resources are made available for that fight. The strategy released by the Biden administration was the internal U.S. Government Strategy. It didn't impact our former employers or us today directly. But what it did was say, "The U.S. is going to enhance the global fight against corruption. They're going to work with foreign partners, foreign prosecutors, foreign departments of justice or ministries of justice to bring to justice people who engage in bribery and corruption, people engage in money laundering in a way they haven't done before." Interestingly, there was a section on journalists and the fourth state and a specific acknowledgement that exposes, business exposes by journalists all the way from blood money of the story of Theranos to the Paradise Papers, to the Panama Papers, to the Paradise Papers, all exposed bribery and corruption, all exposed money laundering, all exposed sham corporations, all exposed fraud. And for the first time, we have the U.S. Government saying, "We're going to work to try to encourage good journalism to help expose these, because we can't do all of this on our own." And newspapers have a vital role to play, and reporters have a vital role to play. So, we have the fourth estate now being openly discussed by the United States. We have government agencies that had never concerned themselves with anti-corruption, now being tasked with anti corruption. And I would point you to NATO. NATO's been around most of our lives. No, well, I guess all of our lives. Susan Divers: Yeah. Tom Fox: It's a key component of what I see as U.S. Security interests. But I've never heard NATO and anti-corruption in the same breath before. Well, now NATO is charged with enforcing anti-corruption statutes for its suppliers. It's suppliers are not all U.S. companies. NATO's a 23 member, I think, organization. So any country can have suppliers to NATO. Well, now they have to comply with U.S. anti-corruption laws probably in the form of the FCPA. So, we have a greater scope, a greater reach, we have greater resources in the form of prosecutors or investigators. But the U.S. is acknowledging and saying, "This is part of our overall fight." And in part one of our episodes, Susan and I talked about the Department of Treasury saying that U.S. corporations are a part of the fight against money laundering. Well, I think the Department of Justice has come pretty close to saying that U.S. corporations are a part of the fight against bribery and corruption. And because it's a national security issue, we want you to come to us. We will incentivize you to come in and self-disclose, once again, even if it's within your organization. I think that this means more funds, a wider remit for government agencies that have not had this remit before. And when you start talking about the press as a key part or a key whistleblower within the context of overall whistle blowing programs, I think that's an acknowledgement that is long overdue. Susan Divers: I totally agree with you. And I think it also sort of ups the ante, because when you couple that with DOJ's recent re-emphasis and added emphasis on personal responsibility and liability for misconduct, it's in a sense saying, "If you go out and you bribe or you violate anti-money laundering or you do business with people on the sanctioned list, or you help oligarchs move their yachts, you're not just committing an economic crime. You're doing something that violates the U.S. National Security interests." And I think that's something for boards and executives to really think about, especially in light of the recent absolutely horrible Lafarge cement case where they were bribing ISIS in order to keep their Syrian cement factory open. It's an interesting dynamic. Let's leave that and let's talk about cybersecurity, because that's another major risk area for companies. And it directly plays into the area of sanctions in AML as well as others. What are you seeing in that space as a result of the war in the Ukraine and the risks that's created? Tom Fox: So once again, Susan, cybersecurity, cyber attacks, cyber hacks have been with us for some period of time. I think Target was probably the first one that got the attention of most of us in the compliance community. But certainly within the cyber community, this was well known. But what the Russian invasion of Ukraine has done is, here I have to cite to Brandon Daniels, CEO of Exiger who said, "We are now under permanent non-kinetic warfare.", meaning we are permanently under attack by our enemies in the cyberspace. Every company is subject to attack. It can be a state actor or it could be rogue groups. It could be criminal groups. So, that's sort of point one. We are all under attack now and we have to harden our defenses. But point number two is that what you sort of raise at the end, Susan, you're attacked, you're hacked. You want to get the key so you can unlock your documents. You make a payment. Who are you making that payment to? They're probably not going to say, "My name is Thomas Robert Fox. My bank account at Chase is..." They're going to give you a false name and some sort of drop account that you don't know, or you may not know who the end user is. Well, in 18 months or 24 months, when you get a little knock at the door from the Department of Treasury, which says, "You've just paid ISIS." Or, "You've just paid Russia. We'd like to ask you some questions under oath." The point being that if you don't know who you're paying, you may be paying someone who's on the sanctions list. You may be paying rogue agents or agents rather from Cuba, from North Korea. You may be paying agents from China. And so, cybersecurity is tied to money laundering and trade sanctions because of the potential payments. As a business, you're in an extraordinarily difficult position because you may have not had hardened defenses. And you may be at risk for losing your data or having it put out on the dark web. And that's not going to be an easy choice. But if you make a payment and it's to someone on the sanction list, the U.S. government has made clear, you will be punished for violations of those U.S. laws. And this fall, it's not effective yet, effective March, 2023, Lloyd's of London has announced that they will not honor cyber insurance obligations where the attack was made by a state actor. And typically what companies will do after they're hacked and they have to announce publicly is, they will say, "Well, we were a hacked by the Russian government and there's nothing we can do for it because it was a top military hacking unit in Russia. And whatever defenses we had in place, we couldn't defend us." Well, if you say that trying to cover your backside, you've just lost your insurance coverage. And if you make payments, you're not going to be able to get indemnity and that money back. So, you have to be very careful about what you publicly say now, if you want to have full cyber insurance. It's, here I'm less certain about the answer, Susan. I just know that the questions have become much more important, much more difficult. But you've got to have these conversations in your corporation. You've got to practice hack drill. It's like you and I did fire drills or bomb drills in elementary school. You've got to have a drill, you've got to have a plan in place. You've got to be ready, if you're hacked. You've got to have experts who you can call, trusted advisors, whether they be legal, whether it be technical, whether they be compliance, whether they be cyber, to come in and help you get through such an attack. But we're under... make no illusions that this Russian invasion has unleashed corporate attacks in a way we have never seen before. It's here to stay. And you as a U.S. corporation and U.S. compliance practitioner are going to have to deal with it. Susan Divers: Well, and what you're saying too is a perfect illustration of the interconnectedness, which I don't think we thought in those terms too much in the past. We had FCPA compliance and we had sanctions compliance and trade compliance and AML. We didn't really, at least, I didn't, to confess, sort of think about it as all connected. But if you're basically being held to ransom and it's a Russian or an ISIS hacker, then not only could you violate the sanctions laws, but you could violate anti-bribery laws too, inadvertently. To use a great expression, it's sort of a dog's breakfast in some ways, what compliance officers are faced with. So, what's your advice, because it's a new risk environment and the risks are really big? They're national security risks, they're not just good governance and good business risks. What should compliance officers do? Let's end on a practical note of, how do you actually deal with the situation going forward? Tom Fox: No, I wonder if I should open my door, bring my three dogs back in, and say, "Hey guys, what do you do when I put a dog's breakfast down in front of you?" And they look up at me and say, "Well, we eat it, Tom." It's here to stay. And that means you have to deal with it. It all goes back to risk. What are your risks? Assess your risks. Yes, I understand you have a robust cyber defense protocol. You have a program, you have tested that program, you've run drills on that program. Now, have you done that same with your prime supplier? Have you done that with your Tom Fox vendor who has access to the vendor invoice system so that I can input my invoice into your system for work I do? Have you checked down to that level to make sure that my defenses are hardened, someone using my system can't get in? You have to go through the same exercise you do from a corruption compliance, any money laundering compliance, trade control, and trade sanction compliance. Assess your risk. How do you assess your risk? Where are you doing business? Who are you doing business with? How are you doing business? In all of those manners, are there any gaps in your defenses in those three areas? If you assess those risks and then if you find gaps, weaknesses, material deficiencies, whatever you choose to call them, remediate those. It is a process you have to go through. You can't do it... I'm going to look at our cyber defenses in our third party supply chain this afternoon. You can't do that. It is a process and you're going to have to put work into it. But that's where you get the real results. Because once again, as we found, I think in the supply chain discussion we had, Susan, once you look at those sub-suppliers, who you're doing business with, where they're doing business, and how you're doing business, you may find inefficiencies from the business operations perspective. And you can correct or improve those business efficiencies and make your company more efficient, and hopefully at the end of the day, more profitable, when you began as a program to assess risk based upon a DOJ pronouncement or a DOT pronouncement. But it all starts with recognizing what your risks are. And only you can assess your risks. Susan Divers: And I like too, the way you've mapped it out, because it really, again, comes full circle back to sustainability, that the way you do business is just as important as what business you do. And if you truly keep on top of your risks and really reinvigorate the risk function, that should be, as you've pointed out, a dialogue with the board and with the top management. It shouldn't be a dialogue that compliance and audit and legal are having because it involves the strategic direction of the company. And it also involves the way the company is governed. So with that takeaway, I think this is a conversation we could be having for at least another hour, if not more. But we're out of time. And so Tom, thank you so much for joining us. And your thoughts are so valuable, because I think it's easy in the ethics and compliance field to get fixated on, "How am my rolling out the training? What's my curriculum, how many hotline calls have I gotten?" And it's much more about, how do we actually live in this world? And how do we in fact, conduct business in a way that's ethical, compliant, and sustainable? So you've really taken us to that perspective. And I'm very grateful to you for doing that. Tom Fox: Susan, thank you, and I look forward to continuing this conversation. Susan Divers: Thank you, Tom. My name is Susan Divers and I want to thank you all for tuning into the Principled Podcast at LRN. Outro: We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us at lrn.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcast, or wherever you listen. And don't forget to leave us a review.    

As the NY Mets have the best record in baseball and we prepare for the celebrations of Easter and Passover, Tom and Jay are back to look at some of the week's top compliance and ethics stories in the Ng Convicted edition. Stories Roger Ng was convicted. Tom in the FCPA Compliance and Ethics Blog. Lessons from DOJ's first cyber fraud settlement? Annie Hudgins in the FCPA Blog. Depression as corporate materiality issue. Dick Cassin in the FCPA Blog. Should CCOs be required to certify compliance programs? Mike Volkov in Corruption Crime and Compliance. CEO fined by SEC for impeding whistleblower. Aaron Nicodemus in Compliance Week. (sub req'd) Matt Kelly in Radical Compliance. How much BOD oversight of compliance is enough? Jeff Kaplan in Conflict of Interest Blog.  Compliance in recessionary times. Jim DeLoach in CCI. Water and corruption. Rick Messick in GAB. Why should an organization disclose diversity information? Antinuke Adrian in Harvard Law School Forum on Corporate Governance.   Data governance best practices. Eray Eliaçik in Data Economy.  Podcasts and More Tom visits with Matt Galvin and Dan Kahn over a 2-part podcast series. In Part 1, they talk about dealing with the DOJ during an FCPA investigation and thereafter.  Into Star Trek, then join Tom and John Champion, who is on a 15-year mission to do a podcast on every episode of Star Trek, television, movie, and animated show on the podcast MissionLogPodcast.com. In Part 1, from TOS up to the start of TNG. In Part 2, from TNG to today.  This month on the Compliance Life, I visit with Susan Divers, Director of Thought Leadership at LRN. In Part 1, academic life and early professional career. In Part 2, she moves to the corporate world.  Why should you attend Compliance Week 2022? Find out on this episode of From the Editor's Desk. Listeners get a $200 discount to CW 2022 with the code Fox200. More here.  Join Tom and Jay at ECI Impact 2022. Listeners to this podcast can save 20% off registration by entering discount code: TOM20 at checkout. Welcome back, Sam Rubenfeld. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

On this April Fool's Day for 2022, Tom and Jay are back to look at some of the week's top compliance and ethics stories in the Slap Seen ‘Round the World edition.  Stories The Slap Seen ‘Round the World and Compliance. Tom in FCPA Compliance and Ethics Blog. Will CCOs have to certify compliance? Text of Kenneth Polite speech. Tom and Matt in Compliance into the Weeds. Matt in Radical Compliance. Coal exec indicted under the FCPA. Harry Cassin in the FCPA Blog. Good bribes. Dick Cassin in the FCPA Blog. Why controls are key to compliance. Chris Audet in CCI. MarshMac UK sub garners Declination with Disgorgement. Dylan Tokar in WSJ Risk & Compliance Journal. ZTE whistleblower feared for his life. Ashley Yablon in CCI. Whistleblowing keys. Jan Stampers In Risk and Compliance Matters. Fine line between compliance and evasion of OFAC sanctions. Mike Volkov in Corruption Crime and Compliance. ISSB delivers sustainability guidelines. IFRS Press Release. Podcasts and More What is the intersection of Sports and Ethics? Each year, Jason Meyer holds Ethics Madness, a discussion of this intersection done during March Madness. This year, Jason engaged Tom for Ethics Madness in the podcast format. It was cross-posted on Jason's site Eight Mindsets, which he co-hosts with Nicole Rose and on Tom's site, Greetings and Felicitations. Tom has a two part series with Aly McDevitt on her recent Ransomware case study, on Greetings and Felicitations, Part 1 and Part 2. Why should you attend Compliance Week 2022? Find out on this episode of From the Editor's Desk. Listeners get a $200 discount to CW 2022 with the code Fox200. More here. Tom visits with longtime MS 150 rider Alan Peterson on The Hill Country Podcast. Donate to the fight against MS here. Why should compliance lead corporate ESG? Kristy Grant-Hart explains on the ESG Compliance Podcast. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As Ukraine hangs on from the Russian invasion, Jay is on assignment so fan fav Kristy Grant-Hart joins this week as a co-host with Tom to look at some of the week's top compliance and ethics stories from the impact of the Ukrainian crisis in the Ukraine Hangs On edition.  Stories What Russia invasion means for companies and compliance. Tom with a series in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Dick Cassin says sanctions may lead to more corruption in the FCPA Blog. Jaclyn Jaeger looks at supply chain disruption and issues in Compliance Week (sub req'd) Matthew Murray asks if Putin invaded Ukraine to advance corruption, in GAB. Chasing oligarchs' money, from the Washington Post. The Swiss approach to Ukraine crisis. Mark Pieth in Risk and Compliance Europe. Mike Volkov focuses on new and evolving sanctions, in Corruption Crime and Compliance. Economic nationalism and corporate governance. Martin Geller, in Harvard Law School Forum on Corporate Governance.  Illicit finance and High-value art. Sullivan & Cromwell lawyers in Compliance and Enforcement. The invasion and cybersecurity. Jonathan Armstrong in Cordery Compliance. Podcasts and More In March on The Compliance Life, I visit with Audrey Harris, Managing Director at AMI, formerly CCO at BHP. In Part 1, she discusses her academic background and early professional career. On the FCPA Compliance Report, Tom has a 2-part series with Trade Compliance guru Matt Silverman on the full extent of possible Russia sanctions (Part 1) and the corporate response you need to make (Part 2). Tom and Loren Steffy look energy issues and fallout from the Russian invasion in Greetings and Felicitations. Tom and Matt Kelly take a deep dive into the compliance weeds about the Russian invasion on Compliance into the Weeds. Silvia Surman devotes the entire week to Russian trade sanctions and economic issues in The Compliance Kitchen. Tom celebrates Texas Independence Day and the anniversary of the Alamo in a podcast with Don Frazier, Executive Director of the Texas Institute at Schreiner University on The Hill Country Podcast. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Kristy Grant-Hart is Compliance Kristy and can be reached at kgranthart@sparkcompliance.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As Russia invades Ukraine, Tom and Jay settle in and are back looking at some of the week's top compliance and ethics stories this week in the Russia Invades edition. Stories What Russia invasion could mean for corporate governance. Michael Peregrine in Forbes.com. What do sanctions mean for US companies? Jaclyn Jaeger in Compliance Week (sub req'd) Why is subculture audits so critical? Vera Cherepanova explains in the FCPA Blog. KT Corp. settles FCPA enforcement action. Tom (FCPA Compliance and Ethics Blog) and Mike Volkov (Corruption Crime and Compliance) both have 3-part series. Matt Kelly's take in Radical Compliance. Tom and Matt in Compliance into the Weeds. National Cryptocurrency Enforcement Team and what it means. Kathleen McDermott and Mark Krotoski in CCI. David Smagalla in WSJ Risk and Compliance Journal.  How Credit Suisse facilitated crime, corruption, and dictators. Jessie Drucker and Ben Hubbard in the New York Times.  Why diversity on investigation teams matters. Karin Portlock and Jabari Julien in Compliance and Enforcement.  Could small-cap directors & officers could face ESG liability. Lawrence Heim in practicalESG. Global trends in corporate governance for 2022. Richard Fields, Rusty O'Kelley III, and Laura Sanderson, in Harvard Law School Forum on Corporate Governance.   Roger Ng trial in danger of collapse due to prosecution 'inexcusable error .'Stewart Bishop in Law360. (sub req'd)  Using the FCPA to fight the demand side of bribery. Matthew Stephenson in GAB.  Podcasts and More In February on The Compliance Life, I visited with Ellen Smith, a former Director of Trade Compliance who recently started her consulting firm. In Part 1, she discussed her academic background and early professional career. In Part 2, Ellen discussed her move in-house. In Part 3, Ellen discusses being a part of the Compliance Dream Team at Weatherford. In Part 4, Ellen moves into the world of consulting.  On the FCPA Compliance Report, Tom began a 2-part series with Trade Compliance guru Matt Silverman on possible Russia sanction (Part 1) and the corporate response (Part 2). Part 2 posts Monday, February 28. CCI releases a new e-book from Mike Volkov, "Compliance Culture Revolution ."Available free from CCI. Gwen Hassan has a special 2-part pod series on Hidden Traffic with Jeff Bond, from the Global Fund to End Modern Slavery, on the impact of climate change on modern slavery. Part 1 and Part 2. Are you a Star Wars fan? How about an uber-Geek? You will love the 5-part series on Science of Star Wars in the Greeting and Felicitations podcast series on the Compliance Podcast Network if you are either or both. In this series, Tom visits astrophysicist Dr. Ben Locwin on the following topics: Episode 1-Traveling in Hyperspace, Episode 2-Fighting with a Light Saber, Episode 3-Mechanical Prosthetics, Episode 4-Cyborgs, and Robots and Episode 5- Death Star. It is a ton of fun, and you will love it.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.     Learn more about your ad choices. Visit megaphone.fm/adchoices

Super Sunday passed with fun but poorly played, poorly officiated, and poorly coached. Tom and Jay are back to look at some of the week's top compliance and ethics stories this week in the Rams Win It All Edition. Stories Ericsson is in more FCPA trouble. Mengqi Sun in the WSJ Risk and Compliance Journal. Aaron Nicodemus in Compliance Week. (sub req'd) DD impeding compliance in developing markets? Katya Lysova explores in the FCPA Blog. ESG-no longer a nice to have. Karen Alonardo in Risk and Compliance Matters.   State AGs are waiting. Ashley Taylor and Chris Carlson in CCI.   The latest case on CCO liability. Matt Kelly in Radical Compliance.  Broken windows and compliance enforcement. Anthony O'Reilly in Compliance and Enforcement.  Companies yet again ask the EU for rules around ESG. Lawrence Heim in practicalESG. White-collar enforcement trends in 2021. Jamie Rosenberg in Grand Jury Target.   HP-Autonomy from the auditors' perspective. Francine McKenna in The Dig.  South African courts deny Zuma's attempt to remove the SA corruption prosecutor. Rick Messick in GAB.   Podcasts and More In February on The Compliance Life, I visited Ellen Smith, a former Director of Trade Compliance who recently started her consulting firm. In Part 1, she discussed her academic background and early professional career. In Part 2, Ellen discussed her move in-house. In Part 3, Ellen discusses being a part of the Compliance Dream Team at Weatherford. Tom and Richard Lummis are in the middle of their annual review of Best Picturing winning movies on 12 O'Clock High, a podcast on business leadership. Part 1 reviews Schindler's List for leadership and ethical lessons. In Part 2, the look at Gladiator. CCI releases a new e-book from Mike Volkov, "Compliance Culture Revolution." Available free from CCI. Tom looks at some innovation in compliance with a 3-part blog post series in the FCPA Compliance and Ethics Blog. Topics include Compliance Ecosystem Governance, Compliance Branding, Building Culture & Compliance Coaching. Are you a Star Wars fan? How about an uber-Geek? You will love the 5-part series appearing next week on the Greeting and Felicitations podcast series on the Compliance Podcast Network if you are either or both. In this series, Tom visits astrophysicist Dr. Ben Locwin on the following topics: Traveling in Hyperspace, Fighting with a Light Saber, Mechanical Prosthetics, Cyborgs and Robots, and the Death Star. It is a ton of fun, and you will love it. Each episode will post at 10 each day next week. Check it out daily.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.   Learn more about your ad choices. Visit megaphone.fm/adchoices

As the GOAT of pro football, Tom Brady retires, Brian Flores sues the NFL and the Bengals/Rams make the Super Bowl, Tom and Jay are back look at some of the week's top compliance and ethics stories this week in the Brady Retires edition.  Stories 1.     DOJ issues the first Opinion Release of 2022. DOJ website. Tom in FCPA Compliance and Ethics Blog. 2.     Do BODs have unrealistic expectations of compliance? Dick Cassin explores in the FCPA Blog. 3.     KPMG mislead FRC through forged docs. Risk and Compliance Platform Europe.  4.     LRN releases the 2022 Program Effectiveness Report. Download report here. Matt Kelly in Radical Compliance. 5.     A ‘how-to' on remediating. The HeadSpin enforcement action. Tom in FCPA Compliance and Ethics Blog. Aaron Nicodemus in Compliance Week. (sub req'd) 6.     Learning to scale up ethically. Hemant Taneja in CCI.  7.     Why compliance should lead ESG. Carrie Penman in Ethics and Compliance Matters. 8.     The Boardroom agenda in 2022. Deloitte in Harvard Law School Forum on Corporate Governance. 9.     Changes in antitrust enforcement and its impact on compliance. Mike Volkov, Matt Kelly and Tom in Compliance into the Weeds. Mike Volkov with a 3-part blog series in Corruption Crime and Compliance. 10. Unclear values can lead to unethical behavior. Brett Beasley in Center for Ethical Leadership.   Podcasts and More 11. In February on The Compliance Life, I visit Ellen Smith, a former Director of Trade Compliance who recently started her own consulting firm. In Part 1, she discussed her academic background and early professional career. 12. Aly McDevitt with a multipart series in Compliance Week on the end-to-end story of a ransomware attack. Here is more about the series on this month's edition of From the Editor's Desk, with Tom and Dave Lefort. A subscription is required but Compliance Week is running a membership special of $199 for the year. Use Promo Code RNSM199. For information and details click here. 13. CCI releases a new e-book from Tom “FCPA 2021 Year in Review”. Available free from CCI. 14. Trial of the Century-the Enron Trial. This week, Tom premiered a 5-part podcast series on the Enron Trial with Loren Steffy, who covered the trial for the Houston Chronicle. In Part 1, the run-up to the trial. In Part 2, the trial begins. In Part 3, the star witnesses and key testimony. In Part 4, the Verdict comes in. In Part 5, what did it all mean? It is available on the Compliance Podcast Network, Megaphone, iTunes, Spotify and all other top podcast platforms. 15. Looking for a quick daily bite of trade compliance? Check out the Compliance Kitchen with Silvia Surman, who gives a short 3-5 minute update on one trade compliance topic each day. On the Compliance Podcast Network.   Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.    Learn more about your ad choices. Visit megaphone.fm/adchoices

How long does it take to win a NFL playoff game? Patrick Maholmes says 13 seconds. After perhaps the most thrilling NFL playoff game ever,  Tom and Jay are back look at some of the week's top compliance and ethics stories this week in the 13 Seconds edition. Stories 1.     TI-CPI 2022 Report out. Results not good. TI-CPI Press Release. Rick Messick says make it useful in GAB. Jaclyn Jaeger is disheartened in Compliance Week (sub req'd). 2.     Compliance officer burnout? Dick Cassin explores in the FCPA Blog. 3.     Emphasizing the ‘G' in ESG. David Simon in LinkedIn.   4.     Investor demand driving ESG risk and compliance initiatives? Valerie Charles and Tracy Groves in CCI.  5.     Human Rights Due Diligence. James Reardon and Tomas Navarro look at Switzerland's new law  in FCPA Blog. Tom considers your corporate Human Rights strategy in a 2-part blog series in the FCPA Compliance and Ethics Blog.  6.     Monaco Speech and Compliance in 2022. Stephanie Yonekura and Rupinder Garcha  in CCI.   7.     DOJ announces shift in antitrust policy. DOJ Press Release. Matt Kelly in Radical Compliance. 8.     ESG and M&A in 2022. Wachtel lawyers in Harvard Law School forum on Corporate Governance.  9.     FTC compliance risk re: cyber and privacy. Debevoise lawyers in Compliance and Enforcement.  10.  Cultural and ESG to-do list for 2022 for CCO. Mike Volkov in Corruption Crime and Compliance. Podcasts and More 11.  In January on The Compliance Life, I visited with Valerie Charles, partner at StoneTurn. Val has one of the most interesting journeys in compliance. In Part 1, she discussed her academic background and early professional career. In Part 2, she discussed her move to ComTech. In Part 3, Valerie moved into the consulting world. In the concluding Part 4, Valerie looks down the road for what's ahead. 12.  The Everything Compliance gang took a deep dive into the Microsoft acquisition of Activision Blizzard in a special episode.  Check out the Shout Outs and Rants. Finally the gang had a special tribute to Meatloaf here.  13.  CCI releases new e-book from Tom “FCPA 2021 Year in Review”. Available free from CCI. 14.  Trial of the Century-the Enron Trial. This week, Tom premiered a 5-part podcast series on the Enron Trial with Loren Steffy, who covered the trial for the Houston Chronicle. In Part 1, run up to the trial. In Part 2, the trial begins. In Part 3, the star witnesses and key testimony. In Part 4, the Verdict comes in. In Part 5, what did it all mean. It is be available on the Compliance Podcast Network, Megaphone, iTunes, Spotify and all other top podcast platforms.  15.  Check out 31 Days to a More Effective Compliance Program returns, which runs for the month of January, from January 1 to January 31. Available on the Compliance Podcast Network, Megaphone, iTunes, and all other top podcast platforms.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.   Learn more about your ad choices. Visit megaphone.fm/adchoices

As both of their teams are unceremoniously knocked out of the playoffs, Tom and Jay are back looking at some of the week's top compliance and ethics stories this week in the Activision Blizzard Sold edition. Stories Activision Blizzard was sold to Microsoft. Check out articles on how the NYT happened, the parameters of the deal in the  WSJ, the compliance mess in Bloomberg, and legal issues in  Reuters. Did the pandemic undo corruption risk models? Dick Cassin explores in the FCPA Blog. KPMG spanked yet again in the UK. Jaclyn Jaeger in Compliance Week (sub req'd). Person of the Year in Compliance? ESG. Mike Volkov in Corruption Crime and Compliance.   Is Abby Normal next? Banks using behavioral science. Vera Cherepanova in FCPA Blog. Businesses and Strategy on Countering Corruption. Sara Paul, Andrea Gordon, and Dane Sowers in the CCI.   Climate change compliance. Jeff Kaplan in Conflicts of Interest Blog. Trust has its moment. Stewart Levine in Forbes.com.  Institutional investors on ESG voting. Lawrence Heim in PracticalESG. The virtual Board Room. Jeffrey Karpf and Fernando Martinez in Compliance and Enforcement.  Podcasts and More Tom and Matt Kelly conclude a 2-part podcast series on issues they are following in 2022. On Compliance into the Weeds, Part 1 and Part 2.  In January on The Compliance Life, I visited Valerie Charles, a partner at StoneTurn. Val has one of the most interesting journeys in compliance. In Part 1, she discussed her academic background and early professional career. In Part 2, she discusses her move to ComTech. In Part 3, Valerie moves into the consulting world.  What is the intersection of Joel Coen's Macbeth and organizational issues in compliance? Tom explores in a 4-part blog series on the FCPA Compliance and Ethics Blog.  CCI releases a new e-book from Tom, “FCPA 2021 Year in Review”. Available free from CCI. Trial of the Century-the Enron Trial. On Monday, January 4, Tom premiers a 5-part podcast series on the Enron Trial with Loren Steffy, who covered the trial for the Houston Chronicle. You can check out the preview here. It will be available on the Compliance Podcast Network, Megaphone, iTunes, and other top podcast platforms.  Check out 31 Days to a More Effective Compliance Program returns, which runs from January 1 to January 31. Available on the Compliance Podcast Network, Megaphone, iTunes, and other top podcast platforms.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.   Learn more about your ad choices. Visit megaphone.fm/adchoices

With Jay on a holiday assignment, Tom is joined by Mike Volkov to look at some of the week's top compliance and ethics stories this week in the Tribute to Madden and Harry edition. Stories 1.     We lost two greats this week, one in sports and gaming and one from politics. John Madden and Harry Reid. Tom and Mike reflect.  2.     No poaching in the Defense Industry. Jay DeVecchio and Lisa Phelan in a MoFo Client Alert. 3.     What is a ‘Bump Up' provision in an E&O policy. Barry Buchman and Michael Scanlon in D&O Diary.  4.     Reflections on 2021 in Compliance. Lisa Schor Babin in CCI.    5.     Should lawyers file SARs? Jason Morris in Compliance Week (sub req'd). 6.     Fraud in the taxi business? (This is my shocked face.) Matt Kelly in Radical Compliance.   7.     Making ESG 2nd nature in asset allocation. Sara Rosner and Jess Gaspar in Harvard Law School Forum on Corporate Governance.   8.     An app for ESG investment. Lawrence Heim in PracticalESG.  9.     Thoughts for the Board from 2021. Marty Lipton in Harvard Law School Forum on Corporate Governance.  10.  Tom and Mike look back at 2021 in compliance. Tom in FCPA Compliance and Ethics Blog.   Podcasts  11.  Want some fun? Join Tom and One Stone Creative co-founder Megan Dougherty for an exploration of the full MCU. In their most recent posting, check out Episode 3, Iron Man.   12.  In December on The Compliance Life, I visit with Matt Silverman, Director of Trade Compliance at VIAVI. Matt is the first Trade Compliance Director I have hosted on TCL. In Part 1, Matt details his academic career and early professional life. In Part 2, Matt moves into trade compliance. In Part 3, Matt moves into the Director's chair. In Episode 4, Matt looks down the road for trade compliance.  13.  The Compliance Podcast Network welcomes Professor Karen Woody and her new podcast, Classroom Insider. In this most unique pod, Karen interviews some of her student to tell the history of insider trading. Check out Episode 1 where they discuss the history of insider trading. In  Episode 2, the disclosure or abstain rule. On Episode 3, they will take up narrowing the scope of the disclose or abstain rule.  14.  On EMBARGOED!, Brian and Tim run through a Lightning Round-style discussion of the top economic sanctions and export controls stories of 2021. 15.  Looking to enhance your compliance program? Check out 31 Days to a More Effective Compliance Program returns, which runs for the month of January, from January 1 to January 31. Available on the Compliance Podcast Network, Megaphone, iTunes, and all other top podcast platforms.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Mike Volkov is the founder of the Volkov Law Group and can be reached at mvolkov@volkovlaw.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

With Jay on a holiday assignment, Tom is joined by Professor Karen Woody to look at some of the week's top compliance and ethics stories this week in the Naughty List edition.  Stories 1.     JPMorgan tagged for $200MM for failures in electronic record keeping. Tom in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Tom and Matt in Compliance into the Weeds.   2.     Nikola fined $125MM for former CEO's imprudent tweets. Tom in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Jaclyn Jaeger in Compliance Week. (sub req'd). 3.     SOX 20 years later. Michael Peregrine looks back at the upcoming 20th anniversary of Sarbanes-Oxley in the Harvard Law School Forum on Corporate Governance.  4.     France updating its ABC regime. Frederick Davis in GAB.    5.     Another Unaoil defendant appeals conviction based upon SFO misconduct. Dylan Tokar in WSJ Risk and Compliance Journal. 6.     What happened to FCPA Compliance in 2021? Dick Cassin explores in the FCPA Blog.   7.     The story of internal controls and Netflix? Jonathan Marks in BakerTilly.   8.     Vietnam imposes 14-year sentence for wildlife trafficking. Jon Rusch in Dipping Through Geometries. 9.     Lawyers and ESG. Lawrence Heim in PracticalESG.  10.  Prioritizing your policy updates. David Banks in Risk and Compliance Matters.  Podcasts  11.  Want some fun over the holidays? Join Tom and One Stone Creative co-founder Megan Dougherty for an exploration of the full MCU. In Episode 1, Captain America. In Episode 2, Captain Marvel. Next week in Episode 3, Iron Man.   12.  In December on The Compliance Life, I visit with Matt Silverman, Director of Trade Compliance at VIAVI. Matt is the first Trade Compliance Director I have hosted on TCL. In Part 1, Matt details his academic career and early professional life. In Part 2, Matt moves into trade compliance. In Part 3, Matt moves into the Director's chair.  13.  The Compliance Podcast Network welcomes Professor Karen Woody and her new podcast, Classroom Insider. In this most unique pod, Karen interviews some of her student to tell the history of insider trading. Check out Episode 1 where they discuss the history of insider trading. In  Episode 2, the disclosure or abstain rule. On Episode 3, (premiering Dec. 31), they will take up narrowing the scope of the disclose or abstain rule.  14.  The Shout Outs and Rants of Everything Compliance gets its own iTunes show. Everything Compliance has its first-year end review episode.  15.  On Hidden Traffic, Gwen Hassan hosts Andrew Wallis, head of Unseen UK. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Karen Woody is Professor of Law at Washington and Lee. She can be reached at kwoody@wlu.edu.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Tom takes a solo turn to look at some of the week's top compliance and ethics stories this week in the Bags of Cash edition. Stories 1.     Why subcontractors continue to cause FCPA grief. Dick Cassin the FCPA Blog.   2.     More on the Strategy on Countering Corruption. Tom takes a deep dive in a 5-part blog post series in the FCPA Compliance and Ethics Blog. Mike Volkov in Corruption Crime and Compliance.  3.     Neil Hodge says non-US companies should beware in Compliance Week. (sub req'd). 4.     What next Brazilian President must do re: ABC.  Marcelo Cerqueira in GAB.    5.     Yet another son of ex-Panamanian President pleads guilty. Rick Vanderford in WSJ Risk and Compliance Journal. 6.     NatWest took bags of cash for deposits. $341MM in fines later.  Dylan Tokar in WSJ Risk and Compliance Journal.  7.     How CCOs use guidance from DOJ? Matt Kelly in Radical Compliance.   8.     Should you fall on your sword? Calvin London in CCI.  9.     Sustainability not universal. Lawrence Heim in PracticalESG.  10.  McDonalds claws back CEO severance. Heather Haddon in WSJ.  Podcasts and Events 11.  Are you exasperated? Then check, F*ing Argentina. In this podcast series co-hosts Tom Fox and Gregg Greenberg, author of F*ing Argentina explore the current American psyche of being overworked, over leveraged, overtired and overwhelmed. Find out about modern America's exasperation with well…exasperation. In our final episode, we wrap up what we learned from the series.  12.  In November on The Compliance Life, I visit with Matt Silverman, Director of Trade Compliance at VIAVI. Matt is the first Trade Compliance Director I have hosted on TCL. In Part 1, Matt details his academic career and early professional life. In Part 2, Matt moves into trade compliance.  13.  The Compliance Podcast Network welcomes Professor Karen Woody and her new podcast, Classroom Insider. In this most unique pod, Karen interviews some of her student to tell the history of insider trading. Check out Episode 2, the disclosure or abstain rule. 14.  The Shout Outs and Rants of Everything Compliance gets its own iTunes show. Everything Compliance has its first-year end review episode.  15.  On Hidden Traffic, Gwen Hassan hosts Andrew Wallis, head of Unseen UK. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.  Learn more about your ad choices. Visit megaphone.fm/adchoices

As Tom mourns the Astros loss, he tips his cap to the WS Champs Atlanta Braves. He and Jay reflect on some of the top compliance and ethics stories in the World Series Champs edition.  Stories 1.     DAG Lisa Monaco announces changes to white collar enforcement.  Matt Kelly in Radical Compliance. Tom in the FCPA Compliance and Ethics Blog. Tom and Matt Kelly in Compliance into the Weeds.  2.     Why health should be a part of ESG. John Godfrey in CCI.  3.     Keeping track of 3rd party risks. Mike Volkov in Corruption Crime and Compliance.  4.     What is ‘effective compliance'? Dick Cassin explores in the FCPA Blog.  5.     ABC Compliance: Good Governance issue. Joe Grady in GAB.   6.     Did a dysfunctional culture on the Rush movie set lead to a death? Sonia Rao in the Washington Post.  7.     Unclear values can lead to ethical lapses. Brett Beasley in ND Center for Ethical Leadership.  8.     New ABC law coming? Matt Kelly in Radical Compliance. 9.     Simplifying data governance. Alym Rayani in CCI.  10.  Gensler says crypto needs oversight. Mengqi Sun in the WSJ Risk and Compliance Journal.  Podcasts and Events 11.  Compliance Week 2022 opens for registration. Sign up here.  12.  Welcome to the newest addition to the Compliance Podcast Network, Hidden Traffic, hosted by Gwen Hassan. In this podcast, host Gwen Hassan helps compliance professionals assess human trafficking risk and leverage their organization's resources to root out this tragic problem. Check out Episode 1, where Gwen visits with Matt Friedman. 13.  Are you exasperated? Then check, F*ing Argentina. In this podcast series co-hosts Tom Fox and Gregg Greenberg, author of F*ing Argentina explore the current American psyche of being overworked, over leveraged, overtired and overwhelmed. Find out about modern America's exasperation with well…exasperation. In Episode 8, an exasperating meeting with a dog and its owner on the streets of NYC. 14.  This month on The Compliance Life, I visit with Wendy Badger, CCO at Tennant. In Part 1, she details her academic career and early professional life.  15.  How does a Compliance Bible become a best-seller? Check out Tom's appearance on the C-Suite Network's Best Seller TV to find out.  Purchase The Compliance Handbook, 2nd edition here.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As we head to Halloween, Tom and Jay reflect on some of the top compliance and ethics stories on the Happy Halloween edition.  Stories 1.     More on Credit Suisse and Tuna bonds.  Mike Volkov in Corruption Crime and Compliance. Tom in the FCPA Compliance and Ethics Blog. Tom and Matt Kelly in Compliance into the Weeds.  2.     What is FARA. Jamie Rosenberg starts a 2-part series in Grand Jury Target. 3.     Digital innovation and continuous improvement. Jim Deloach in CCI.  4.     Banks and FinTech.  Davis Polk lawyers in Compliance and Enforcement Blog.  5.     What will happen to exec clawbacks? Aaron Nicodemus in Compliance Week. (sub req'd)  6.     SARs and appalling inaction. Martin Kenney in the FCPA Blog.   7.     Board readiness for shareholder activism. Paul DeNicola in Harvard Law School Forum on Corporate Governance. 8.     Scrutiny of the Arts and Antiquities market. Linklaters client alert. 9.     Hiding evidence from regulations costs KPMG in UK. Risk and Compliance Platform Europe.  10.  The SEC on auditor independence. Matt Kelly in Radical Compliance.  Podcasts and Events 11.  Compliance Week 2022 opens for registration. Sign up here.  12.  Ethisphere's World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here.  13.  Are you exasperated? Then check, F*ing Argentina. In this podcast series co-hosts Tom Fox and Gregg Greenberg, author of F*ing Argentina explore the current American psyche of being overworked, over leveraged, overtired and overwhelmed. Find out about modern America's exasperation with well…exasperation. In Episode 7, a Malodor on the Subway. 14.  This month on The Compliance Month, I visit with John Melican, Managing Director at Exiger on his journey to and from the CCO chair. In Episode 1, college and early professional career at NY County DA's Office. In Episode 2, Melican moved into the corporate world and into compliance. In Episode 3, John moves into the CCO chair. In Episode 4, John talks about what he learned and how he uses that knowledge.  15.  How does a Compliance Bible become a best-seller? Check out Tom's appearance on the C-Suite Network's Best Seller TV to find out.  Purchase The Compliance Handbook, 2nd edition here.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Jay and Tom  are back to unpack some of the stories that caught their collective eye on the Monsterfest Month Returns edition. Stories 1.     WPP FCPA enforcement action. Tom with 5-part series on the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Tom and Matt on Compliance into the Weeds. Mike Volkov has a 3-part series in Corruption Crime and Compliance.  2.     Human rights litigation on the EU. Salomé Lemasson in the FCPA Blog.  3.     BOD structure as key to compliance oversight. David Katz and Laura McIntosh in Harvard Law School Forum on Corporate Governance. 4.     Bringing clarity to the chaotic world of the CCO. Chris Audet in CCI.  5.     Another week, another Wells Fargo fraud related penalty. Jaclyn Jaeger in Compliance Week (sub req'd) 6.     Dan Kahn returns to private practice. Dylan Tokar in the WSJ Risk and Compliance Journal. 7.     Do ABC academics fail? Matthew Stephenson in GAB.  8.     Conquering the last mile of delivery of your Code of Conduct. Harper Wells in CCI. 9.     What is Ozy and what does it mean for compliance. Ben Smith in the NYT. 10.  Who owns ESG? Matt Kelly explores on Radical Compliance.  Podcasts and Events 11.  CCI surveying stress in compliance. Henry Kronk in CCI. Take the survey here. 12.  Compliance Week is going ‘Inside the Mind of the CCO'. Participate in the survey here.  13.  Ethisphere's World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here.  14.  Check out the latest addition to the Compliance Podcast Network, A Yank at Oxford. It details the journey of Foley & Lardner partner David Simon as he heads back to university to matriculate for a MBA at Oxford. Episode 1.  15.  Are you exasperated? Then check, F*ing Argentina. In this podcast series co-hosts Tom Fox and Gregg Greenberg, author of F* Argentina explore the current American psyche of being overworked, over leveraged, overtired and overwhelmed. Find out about modern America's exasperation with well…exasperation. In Episode 1, the dreaded Parent Meeting night at your child's elementary school. In Episode 2, why F*ing Argentina? In Episode 3, one of the most beloved characters in musical theater, Officer Krupke is exasperated.  16.  Tom and Compliance Week EIC Dave Lefort look back at September in CW and forward to October (and talk some sports) in this month's edition of From the Editor's Desk.  17.  K2 Integrity's Edoardo Fiora will present at, “ESG Getting Hitched to Business (and IP) Strategy—From Resilience Framework to Recovery Path,” on October 14th. Registration and Information here.  18.  Join Jay, Tom and the top E&C professionals at Converge21, a virtual conference on October 12 & 13. Registration and information here. Why should you attend? Check out some of the panelists discuss their presentation on the Converge21 podcasts. Michael Randrup Wendy Badger, Lloydette Bai-Marrow, Tom and Philip Winterburn.  19.  How does a Compliance Bible become a best-seller. Check out Tom's appearance on the C-Suite Network's Best Seller TV to find out.  Purchase The Compliance Handbook, 2nd edition here.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Jay returns from his travels to report on the 1st compliance conference since 2019. He and Tom unpack some of the stories that caught their collective eye on the Heading to October edition. Stories 1.     ESG and Compliance. Mike Volkov on the ‘G' in ESG. Tom has a 5-part series on why compliance should lead the ESG effort in the FCPA Compliance and Ethics Blog.  2.     Asking more of your auditors. Neil Hodge in Compliance Week (sub req'd)  3.     ISO weighs in on good governance standards. Dylan Tokar in the WSJ Risk and Compliance Journal.  4.     Regulating the wild west of crypto. Henry Kronk in CCI.  5.     Which Mozambique countenance or prosecute its President's corruption? Rick Messick in GAB.  6.     Making the most from your risk assessment? Jeff Kaplan in the FCPA Blog. 7.     What is a criminal COI? Sara Kropf in Grand Jury Target.  8.     Revisiting whistleblower procedures. Wachtel Lipton lawyers in Harvard Law School Forum on Corporate Governance.  9.     The SEC investigation into Activision. Professor Stephen Bainbridge in his blog. 10.  Jay's reflections on the first compliance conference since 2019.  Podcasts and Events 11.  CCI surveying stress in compliance. Henry Kronk in CCI. Take the survey here 12.  Check out the latest addition to the Compliance Podcast Network, A Yank at Oxford. It details the journey of Foley & Lardner partner David Simon as he heads back to university to matriculate for a MBA at Oxford.  13.  Are you exasperated? Then check out the latest offering from the Compliance Podcast Network, F*ing Argentina. In this podcast series co-hosts Tom Fox and Gregg Greenberg, author of F* Argentina explore the current American psyche of being overworked, over leveraged, overtired and overwhelmed. Find out about modern America's exasperation with well…exasperation. In Episode 1, the dreaded Parent Meeting night at your child's elementary school. In Episode 2, why F*ing Argentina? 14.  Jay spreads his wings by hosting his first podcast. He interviews Lisa Beth Lentini Walker and Stef Tschida about their new book, Raise Your Game, Not Your Voice, on this episode of Integrity Through Compliance.  15.  K2 Integrity is partnering with the DIFC Academy for a webinar, “Virtual Assets and FATF Guidelines—A Risk-Based Approach for Financial Institutions,” on September 28, 2021. Registration and Information here.  16.  Join Jay, Tom and the top E&C professionals at Converge21, a virtual conference on October 12 & 13. Registration and information here. Here some of the panelists discuss their presentation on the Converge21 podcasts. Wendy Badger and Philip Winterburn.  17.  Ethisphere's World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here.  18.  Breaking News features The Compliance Handbook, 2nd edition. Check out the Breaking News feature here. Purchase The Compliance Handbook, 2nd edition here.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As the Trump Organization and its CFO are criminally indicted, Tom and Jay prepare for the 4th of July and are back to take a look at this week's stories top compliance and ethics stories which caught their interest on This Week in FCPA in the Trump Organization Indicted edition.  Stories Trump Organization and CFO indicted on criminal charges. NYT, WSJ, FT, WaPo How whistleblowers protect the bottom line. Bob Conlin in Navex Global's Risk and Compliance Matters. Amec Foster Wheeler, the first FCPA corp enforcement action in 2021. Tom takes a deep dive in a 3-part series on the FCPA Compliance and Ethics Blog. Tom and Matt Kelly take a deep dive in Compliance into the Weeds. Mike Volkov goes deep on Corruption Crime and Compliance. Harry Cassin (as usual) breaks the story on the FCPA Blog. US government AML priorities. FinCen issues report, here. Kyle Brassuer in Compliance Week (sub req'd) Dylan Tokar in WSJ Risk and Compliance Journal. Do lawyers make good gatekeepers? Sung Hui Kim says ‘perhaps'. Keith Bishop says you shouldn't even ask the question. Human-Centered Design: An Engaging Ethics & Compliance Program Serves Users' Needs. Carsten Tams in Part 2 of his five-part series on LinkedIn. Reducing your CCPA risk. Debevoise lawyers on NYU's Compliance and Enforcement blog. Was Amec Foster Wheeler afraid of its agents? Dick Cassin explores in the FCPA Blog. Auditing your climate risk. Mark Texler in a two-part series on PracticalESG. How do you evaluate the value of ethics? Henry Kronk in CCI.  Podcasts and Events How does history inform compliance? What are the leadership lessons from ancient Greeks and Romans? Find out in this special 10 part podcast series on famous Greeks and Romans from Plutarch's Lives this week on 12 O'Clock High, a podcast on business leadership, hosted by Richard Lummis and Tom Fox. In Episode 1, they mined Plutarch about the lives of and leadership lessons from Themistocles and Camillus. In Episode 2, they looked at Solon and Popsicola. In Episode 3, Pericles and Fabius Maximus. In Episode 4, Alcibiades and Coriolanus. Are you a MCU fan? If so check out the special series on the Disney streaming service Loki and Tom Fox and Megan Dougherty who return to review the entire series. They catch up on Episode 1-3 in this edition of Popcorn and Compliance. Trekking Through Compliance Returns! Tom reviews all 79 episodes of Star Trek, the Original Series beginning June 1. Each day at 3 PM on the Compliance Podcast Network. This week's offerings included Operation Annihilate, Amok Time, Who Mourns for Adonias, The Changeling and Mirror Mirror. On this episode of Integrity Through Compliance, join Affiliated Monitor's Rod Grandon, Jenner & Block Partner, David Robbins, and former Engility Holdings, Inc. General Counsel, Tom Miller, for an in-depth discussion focusing on crisis management from the perspectives of a General Counsel, outside legal counsel, and federal acquisition official. On July 13, join K2 Integrity for its Virtual Compliance Conference on Environment, Social, and Governance Compliance Risks for Financial Institutions. Information and Registration here. It is now HERE, the book you have all been waiting for, The Compliance Handbook, 2nd edition is available for purchase. The Compliance Handbook 2ndedition is available in both print and eBook editions. Available here. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Jay is back from moving. He and Tom are shocked, shocked that there is another cheating scandal in baseball. While ruminating on just how shocked they are, they take a look at this week's stories top compliance and ethics stories which caught their interest on This Week in FCPA in the More Cheating in Baseball edition. Stories This year's cheating scandal in baseball. Stephanie Apstein and Alex Prewitt in SI. David Waldstein in NYT. Buster Olny in com. Tom takes a deep dive in three blog posts on the FCPA Compliance and Ethics Blog. EU Prosecutor's Office opens for business. Jon Rusch in Dipping Through Geometries. Exxon BOD vote should be a wake up call. Jaclyn Jaeger in Complinace Week. (sub req'd) Compliance when no one is watching. Julie DeMauro in the FCPA Blog. What are 5 things CCOs can do to comply with Biden's Statement on Corruption? Al Barbarino in Law360. What do pirates teach us about leadership? Fransesca Gino in XpertsLeague. Should CCOs run ESG? Mike Volkov say ‘No' in Corruption, Crime and Compliance. Is your Supply Chain ethical? Andrew Blasi and Nicolas Diamond in CCI. What are some reasons for the lack of FCPA enforcement? Harry Cassin speculates in the FCPA Blog. Get on one page for risk management. Sandar Erez in CCI. Podcasts and Events CPN premiers a new podcast, The ESG Report. In the first episode, Tom has a two-part series featuring Trysha Daskem, head of ESG at Silver. Check out Part 1 and Part 2. How does history inform compliance? What are the leadership lessons from ancient Greeks and Romans? Find out in this special 10 part podcast series on famous Greeks and Romans from Plutarch's Lives this week on 12 O'Clock High, a podcast on business leadership, hosted by Richard Lummis and Tom Fox. In Episode 1, they mined Plutarch about the lives of and leadership lessons from Themistocles and Camillus. In Episode 2, they looked at Solon and Popsicola. Trekking Through Compliance Returns! Tom reviews all 79 episodes of Star Trek, the Original Series beginning June 1. Each day at 3 PM on the Compliance Podcast Network. This week's offerings included The Conscience of a King, Balance of Terror, Shore Leave, The Galileo Seven and The Squire of Gothos. Vin DiCianna turns the tables on Tom by interviewing him for this week's Integrity Through Complaince. Check it out here. Join Convercent for a Converge Innovation Forum, with a look into the future of compliance on risk visibility up, down, and across the businesson June 23 at 11 AM CT. for information and registration click here. On July 1, join K2 Integrity's Snezana Gebauer and Darren Matthews will present a webinar on asset tracing at the IBA Global Influencer Forum. Learn more and register: https://www.k2integrity.com/en/events/k2-integrity-webinar-at-iba-global-influencer-forum-fraud-debt-and-judgements-how-to-maximize-asset Tom announces his latest book, The Compliance Handbook, 2nd edition is available for presale purchase. Use the code FOX25 and go here. The Compliance Handbook 2ndedition will be available in both print and eBook editions. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

With Jay moving this week, Tom is joined by Complinace Kristy (Kristy Grant-Hart) as special guest host. They take a look at this week's stories top compliance and ethics stories which caught their interest on This Week in FCPA in the Biden Statement on Corruption edition.  Stories President Biden's Statement and Memorandum on corrption. Tom takes a deep dive in four blog posts on the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Alexandra Wrage on the FCPA Blog. Rick Messick in GAB. Jessica Tillipman in the FCPA Blog. Don't get caught up in endless internal investigations. Lloydette Bai-Marrow in the FCPA Blog. Biden Dumps PCAOB Board. Aaron Nicodemus and Kyle Brasseur in Complinace Week. (sub req'd) More on Caremark. Jeff Kaplan in the Conflict of Ethics Blog. What is conflict due diligence? Lawarence Heim in PracticalESG Blog. Can you measure a ‘speak-up' culture by the number of complaints? Martin Lønstrup in the FCPA Blog. Two former Chadean diplomats indicted for corruption. Mike Volkov in Corruption, Crime and Compliance. Are there smoking guns in your Board minutes? Terry Quimby in the Compliance Cosmos. Do you need a People Committee on your BOD? Reshmi Paul and Jeff McLean in Compensation In Context. Podcasts and Events How does history inform compliance? What are the leadership lessons from ancient Greeks and Romans? Find out in this special 10 part podcast series on famous Greeks and Romans from Plutarch's Lives this week on 12 O'Clock High, a podcast on business leadership, hosted by Richard Lummis and Tom Fox. In Episode 1, they mine Plutarch about the lives of and leadership lessons from Themistocles and Camillus. Trekking Through Compliance Returns! Tom reviews all 79 episodes of Star Trek, the Original Series beginning June 1. Each day at 3 PM on the Compliance Podcast Network. This week included Mudd's Women, What are Little Girls Made Of?, Miri, Dagger of the Mind and The Corbomite Maneuver. AB InBev invites you to the Compliance Open House on June 15 at 10AM EST on the topic “Collaboration Framework for Democratizing Compliance Analytics – where are we and what is next." Registration and information here. On July 1, join K2 Integrity's Snezana Gebauer and Darren Matthews will present a webinar on asset tracing at the IBA Global Influencer Forum. Learn more and register: https://www.k2integrity.com/en/events/k2-integrity-webinar-at-iba-global-influencer-forum-fraud-debt-and-judgements-how-to-maximize-asset What is the role of compliance in managing Environment, Social, and Governance (ESG) initiatives? Join this Convercent Global Forum to learn what's ahead for ESG and what you should start thinking about now, to be prepared before regulations go into effect. On June 16, 11 AM ET. Registration and information here. Tom announces his latest book, The Compliance Handbook, 2nd edition is available for presale purchase. Use the code FOX25 and go here. The Compliance Handbook 2ndedition will be available in both print and eBook editions. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.  Learn more about your ad choices. Visit megaphone.fm/adchoices

As March Madness descends upon us in the bubble this year, Sister Jean leads Loyola of Chicago into the Sweet 16. Tom and Jay are back to look at this week’s stories top compliance and ethics stories which caught their interest on This Week in FCPA. Stories 1.     Universities behaving badly. Tom looks at the KU hiring and firing of Les Miles in a four-part blog post series on the FCPA Compliance and Ethics Blog.  2.     Bette Davis and Jim Deloach both say fasten your seatbelts. Jim Deloach in CCI.  3.     Do you have a Money Laundering Reporting Officer? Alia Noor in XpertsLeague. 4.     How to avoid an OIG investigation. Sara Kropf in Grand Jury Blog.  5.     Why do SPACs give compliance fits? Aaron Nicodemus in Compliance Week. (sub req’d)    6.     Risk Management and IT Security in WFH. Sam Abadir in Risk and Compliance Matters.   7.     Building bridges between compliance and BD. Mike Volkov in Crime Corruption and Compliance.  8.     Three significant CCO hires. What does it mean? Nicholas Trutanich to Fox Corp (WSJ); David Searle to Tesla (Bloomberg) and Antonio Fernández to FirstEnergy (WSJ). 9.     Why ignoring red flags around Iran is bad. Doug Cornelius in Compliance Building.  10.  Paucity of FCPA enforcement in Q1, good or bad? Harry Cassin explore in the FCPA Blog.  Podcasts and Events 11.  On The Compliance Life, Rob Chesnut joins me for the month of March.  In the first episode, In Episode 1, Rob talks about his academic career at UVA and how its Honor Code influenced his thinking about ethics in his professional career and his his career as an AUSA. In Episode 2, Rob moves cross country to join eBay. In Episode 3, Rob talks about moving into the Chief Ethics Officer role at Airbnb. In Episode 4, Rob looks down the road for compliance.  12.  Microsoft has joined the Compliance Podcast Network, with two podcasts, Voice of Data Protection and Uncovering Hidden Risks. In Episode 5 of Voices of Data Protection, Bhavanesh Rengarajan discusses your information governance and records management journey.  In Episode 5 of Uncovering Hidden Risks, Raman Kalyan Talhah Mir how far insider risk programs have come. 13.  Coffee & Regs joins the Compliance Podcast Network. In this week’s episode, hosts Natalie Silverman visits with Alison Taylor and Victoria Olsen to discuss the compliance playbook for regulagtory change.  14.  AMI’s Mikhail Reider-Gordon and Eric Feldman continue their discussion on trends in independent monitoring in this episode of Integrity Through Compliance.  15.  Tom announces his latest book, The Compliance Handbook, 2nd edition is available for presale purchase. Use the code FOX25 and go here. The Compliance Handbook 2nd edition will be available in both print and eBook editions. This week on The Compliance Handbook podcast, the ladies from #GWIC join Tom for a deep dive into written standards.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

With two black swan events in January alone, Tom and Jay wonder what else 2021 will bring. Jay bemoans Tompa Bay in the Super Bowl.They are also back to look at some of the top compliance articles and stories which caught their eye this week.  What does GameStop portend for compliance? Toms take a deep dive on the FCPA Compliance and Ethics Blog. Part 1-Background, Part 2-the Shorts, Part 3-the Squeeze, Part 4-the Regulators, Part 5-Final Thoughts. Tom and Matt Kelly take a deep dive on Compliance into the Weeds. Enterprise risks going forward. Matt Kelly looks down the road in Radical Compliance. Solar Winds turning into a Pandora’s Box? Jaclyn Jaeger explores in Compliance Week. (sub req’d) Risk culture in the digital age. Jim DeLoach explores in CCI. What does the CFTC settlement with Vitol portend for enforcement (and compliance). Gibson Dunn lawyers in NYU’s Compliance and Enforcement. Top regulatory trends to watch under the Biden Administration. Rachel Wooley in CCI. Is your compliance team too big? Dick Cassin asks in the FCPA Blog. Can compliance help with a workplace morale crisis? Richard Bistrong opines in the FCPA Blog. On The Compliance Life, Natalia Shehadeh, CCO at ABB joins me this month. In this first episode, Natalia explains why she choose the compliance profession. Check out the Episode 1. New podcasts out on the Compliance Podcast Network this month. In ComTech, Valerie Charles joins Tom for an exploration of the intersection of compliance and technology. Check out Episode 1. Episode 2 posts Monday, February 8. In Big Brains in Compliance Tom is joined by Stephen Martin to visit with some of the top thinkers and doers in compliance. It premiers February 22. Finally Tom premiers The Compliance Handbook, a podcast focusing on the nuts and bolts of compliance. In Episode 1, he is joined by Stephen Martin to talk about how to best think through a comprehensive compliance program. It premiers Tuesday, February 10. A new AMI podcast is out, Integrity Through Compliance. It will have AMI’s expert observations and guidance in the fields of ethics, antitrust, healthcare, government contracting, corporate governance, cybersecurity, construction, telecommunications, consumer protection and more.In this first episode, AMI founder Vin DiCianni visits with AMI MD Jerry Coyne the future of telehealth & home healthcare during a pandemic and beyond. Check it out here. Join K2 Integrity and the AIBACP for a webinar on February 17—National Defense Authorization Act: AML Compliance Implications and Priorities for the Banking Industry. Information and Registration here. On Thursday, February 25, join the “Ask an Expert FINQuiry” webinar on DOLFIN: K2 Integrity’s financial crimes compliance experts will respond to your AML/CFT, sanctions, and other financial-integrity-related questions. Information and Registration here. Compliance Week is accepting nominations for its Excellence in Compliance Award. Submit your nominee here. Join the Baker Tilly Fraud 1st Annual Fraud and Compliance Summit, Tuesday, Feb 23, 2021, to Thursday, Feb 25, 2021. Details and registration here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As Trump becomes the only person to have 2 impeachment trials, Tom and Jay are back to look at some of the top compliance articles and stories which caught their eye this week.  Beny Steinmetz found guilty for corruption in Guinea mining concession. Imogen Foulkes in the com. Tom take a deep dive on the FCPA Compliance and Ethics Blog. Part 1-Background, Part 2-the Trial, Part 3-the Vale JV, Part 4-Final Thoughts. Do compliance officers need a peer review? Dick Cassin explores in the FCPA Blog. Should you have reps and warranties in your compliance terms and conditions? Bill Steinman considers in the FCPA Blog. 7 key changes to CA privacy laws. Andrew Burt in Navex Global’s Risk and Compliance Matters. A Significant ruling on HIPPA out of the 5th David Saunders and Allison Glover in NYU’s Compliance and Enforcement. Is an increase in SEC enforcement coming? Morgan Lewis lawyers in Harvard Law School Forum on Corporate Goverance. Why is FCA compliance so critical? Mike Debernardis in CCI. How to investigate a 60MM document case? Michael Dempsey in the BBC. On The Compliance Life, Gwen Hassan- Director of Compliance at CNH Industrial is back for her fourth and final episode. In it, Gwen explains her passion around fighting the international scrourge of human trafficking. Check out the episode here. This month, on 31 Days to a More Effective Compliance Program, I look back over 2020 and set out some of the key enhancements you need to do for your compliance program in 2021. Day 23 | Assessing compliance internal controls; Day 24 | Updates and feedback; Day 25 | CCO authority and independence; Day 26 | the role of compliance in an organization; Day 27 | operationalizing compliance though payroll; Day 28 | Continuous Improvement; Day 29 | Internal Reporting. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. A new AMI podcast is out, Integrity Through Compliance. It will have AMI’s expert observations and guidance in the fields of ethics, antitrust, healthcare, government contracting, corporate governance, cybersecurity, construction, telecommunications, consumer protection and more.In this first episode, AMI founder Vin DiCianni visits with AMI MD Jerry Coyne the future of telehealth & home healthcare during a pandemic and beyond. Check it out here. Join K2 Integrity and the AIBACP for a webinar on February 17—National Defense Authorization Act: AML Compliance Implications and Priorities for the Banking Industry. Information and Registration here. Compliance Week is accepting nominations for its Excellence in Compliance Award. Submit your nominee here. Join the Baker Tilly Fraud 1st Annual Fraud and Compliance Summit, Tuesday, Feb 23, 2021, to Thursday, Feb 25, 2021. Details and registration here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As we move from the worst and most corrupt President of all time to the Biden Administration and Jay and Rebecca celebrate their daughters ascension to womanhood, Tom and Jay are back to look at some of the top compliance articles and stories which caught their eye this week.  What does the FinCEN enforcement action against Capital One mean for compliance? Jaclyn Jaeger in Compliance Week. (sub req’d) Matt Kelly explores on Radical Compliance. Tom and Matt take a deep dive on Compliance into the Weeds. The OFAC year in review. Mike Volkov takes a deep dive in Corruption Crime and Compliance. The Boeing Fraud enforcement action? Tom take a deep dive in the FCPA Compliance and Ethics Blog. Dylan Tokar in the WSJ Risk and Compliance Journal. Poaching now legal? Paul Weiss lawyers on NYU’s Compliance and Enforcement Blog. Wells Fargo ex-GC spanked. Jaclyn Jaeger in Compliance Week. (sub req’d) UAE to fight money-laundering. Jon Rausch (returns) in Dipping Through Geomotries. More Caremark claims coming? Kevin LaCroix in the D&O Diary. Are you an introverted compliance professional? Now may be the time for you. Dick Cassin explores on the FCPA Blog. A new month is here and a new guest on The Compliance Life. Gwen Hassan- Director of Compliance at CNH Industrial. In this month’s third episode, Gwen explains why every compliance professional needs to stay culturally curious. Check out the episode here. This month, on 31 Days to a More Effective Compliance Program, I look back over 2020 and set out some of the key enhancements you need to do for your compliance program in 2021. Day 16 | 3Rd Party Risk Management Process; Day 17 | Managing Your 3rd parties; Day 18 | Levels of Due Diligence; Day 19 | The Investigation Protocol; Day 20 | Responding to Investigative Findings; Day 21 | Continuous Improvement; Day 22 | Internal Reporting. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. Join K2 Integrity on January 27 to hear Olivia Allison and Joanne Taylor discuss the latest E U regulatory developments in whistleblowing programs and investigations. Information and Registration here. Compliance Week is accepting nominations for its Excellence in Compliance Award. Submit your nominee here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

It is certainly a challenging time for the American Democracy. For his high crimes and misdemeanors against the Constituion and American democary, President Trump has now been impeached for a second time. In the midst of the this, Tom and Jay are back to look at some of the top compliance articles and stories which caught their eye this week.  1.     Recidivist Deutsche Bank settles a second FCPA matter. Tom takes a 5-part deep dive on the FCPA Compliance and Ethics Blog. Matt Kelly looks at red flags and internal controls on Radical Compliance. Tom and Matt take a deep dive on Compliance into the Weeds.  2.     How the FCPA is big business. Harry Cassin explains in the FCPA Blog. 3.     Is an industry sweep headed your way? Dick Cassin explains in the FCPA Blog.  4.     Why you should welcome the NDAA? Matthew Stephenson in GAB. Jonathan Marks on Board and Fraud. 5.     How to use KPIs in your compliance program. Vera Cherapanova in the FCPA Blog.  6.     What are your Board resolutions for 2021? Steve Durbin in CCI.  7.     2020 was a year of ethical challenges. Mike Volkov explains in Corruption Crime and Compliance. 8.     What are the C-Suite challenges brought on by Coivd-19? Shanil Williams in CCI. 9.     A new month is here and a new guest on The Compliance Life. Gwen Hassan- Director of Compliance at CNH Industrial. In this month’s second episode, In this second episode, we take up the tricky issue of balancing a role as a legal eagle for the company as well as her role in compliance. We also explore the different skill set needed for each of these careers and how it is possible to have both in one person. Check out the episode here.  10.  This month, on 31 Days to a More Effective Compliance Program, I look back over 2020 and set out some of the key enhancements you need to do for your compliance program in 2021. Day 9 | 360 Degrees of Compliance Communications; Day 10 | The Use of Social Media in Compliance; Day 11 | What is Effective Compliance Training?; Day 12 | Financial Incentives for Compliance; Day 13 | Institutional Justice and Fairness; Day 14 | Risk Assessments; and Day 15 | How do you evaluate a risk assessment?. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel.  11.  Join Tom on the Convercent event, “Future-proof your compliance program for 2021”, on Wednesday, January 20th | 11:00 am -1:00 pm ET. For details and registration, click here.  12.  Join K2 Integrity on January 27 to hear Olivia Allison and Joanne Taylor discuss the latest E U regulatory developments in whistleblowing programs and investigations. Information and Registration here. 13.  Compliance Week is accepting nominations for its Excellence in Compliance Award. Submit your nominee here.  Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As TrumpLand continues to live in fantasy and denial, going 1-55 in lawsuits while over 3000 American die daily from Covid-19; Tom and Jay are back to look at some of the top compliance articles and stories which caught their eye this week.  The Vitol FCPA enforcement action. Tom takes a deep dive on the FCPA Compliance and Ethics Blog. Part 1, Part 2, Part 3, Part 4. Mike Volkov has a 3-part series on Corruption Crime and Compliance. Is the SEC whistleblower program too opaque? Harry Cassin considers in the FCPA Blog. AML reform and a new whistleblower law. Matt Kelly considers in Radical Compliance. Tom and Matt go into the weeds in the latest episode of Compliance into the Weeds. Is the SEC discouraging whistleblowers under Dodd-Frank. Mengui Sun explores in the WSJ Risk and Compliance Journal. Where did the Cheesecake Factory go wrong? Sara Kropft in the Grand Jury Target. 5 Compliance Triumphs from 2020? Kyle Brausser in Compliance Week. (sub req’d) GDPR compliance challenges in 2021. Steve Horvath in CCI. China-US audit showdown? Michael Rapoport reviews in The Dig. A new month is here and a new guest on The Compliance Life. Kim Yapchai, Chief Counsel - Environmental, Social & Governance at Tenneco Inc. In this week’s second episode, we take up the in-house roles In Kim held on her road towards the CCO chair. Check out the series here. My podcast with Mikhail Reider-Gordon on Wirecard was so popular we spun it out into its own series, The Wirecard Saga. Check out the latest episode, Dirty Deeds Down Under.   On 31 Days to a More Effective Compliance Program, we consider Training and Communications. Monday, Sharing to 360-degrees of communication Tuesday- Speical Guest Vin DiCianni on Compliance and the clash of cultures.Wednesday- Using 360 Degree of Compliance to Tell a Story; Thursday- Using Communications to Drive a Speak Up Culture; Friday- Using communications to foster your compliance brand. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.  Check out the a replay of London Stock Exchange event which featured Tom, Neta Meidav, CEO, Vault Platform and Maxine Gee, Chief Risk Officer - UK Capital Markets LSE on why culture drives compliance. You can view and listen to it here. Join K2 Integrity for two great events in December. On Dec. 14, they host a webinar on “Proliferation Financing: Risks, Threats, and Mitigation.” The webinar will explore critical issues around understanding and combatting the financing of WMD proliferation. https://bit.ly/2VujK1O.  On December 17, DOLFIN and K2 Integrity’s financial crimes compliance experts will host their latest “Ask an Expert FINQuiry” webinar. Expect answers to questions on topics such as: the latest developments in AML/CFT, sanctions, fraud, anti-bribery and corruption, and export controls; financial integrity risks related to the global pandemic; and regionally focused financial crime risks. https://bit.ly/39zzhFP Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As the whole world counts down to the US election, Tom and Jay are back to look at top compliance articles and stories which caught their eye this week.  1.     Goldman Sachs settles FCPA enforcement action involving Tom with a five-part series on FCPA Compliance and Ethics Blog, Mike Volkov with a 3-part series on Corruption, Crime and Compliance, Tom and Matt on Compliance into the Weeds and the Everything Compliance gang with their first emergency video podcast.  2.     The Beam Suntory FCPA enforcement action. Harry Cassin breaks the story in the FCPA Blog. Matt Kelly provides some lessons in Radical Compliance.  3.     What can investigators learn from Wirecard? Llyodette Bai-Marrow in the FCPA Blog.  4.     TLI President sentenced to 48 months in prison. Dylan Tokar in the WSJ Risk and Compliance Journal. 5.     Why the Exit Interview is such a useful exercise. Jonathan Marks in Board and Fraud. 6.     It’s Halloween. What are your (corp) skeletons? Michael Toebe in CCI.    7.     Experian to appeal ICO fine. Jaclyn Jaeger in Compliance Week. 8.     Channel you inner Sherlock Holmes to determine UBOs. Alia Noor on xpertsleague.com. 9.     On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, we  continue our exploration of compliance for Business Ventures.  Monday-Franchisor Liability; Tuesday-Franchisor compliance; Wednesday- Following the money thru distributors; Thursday- Distributor liability; Friday- Why Business Ventures are Different than 3rd Parties. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.   10.  Join K2 Intelligence FIN for a November 5 webinar, highlighting scenarios in which investigative due diligence can help uncover areas of risk and opportunity in the wake of COVID-19. Learn more and register here.  11.  Virtual book launch for Sending the Elevator Back Down. Thursday, November 5, 4:30 ET. Information and registration here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As the Great Women in Compliance hosts publish their first book and Goldman Sachs settles its massive FCPA enforcement action over 1MDB, Tom and Jay are back to look at top compliance articles and stories which caught their eye this week.  1.     Goldman Sachs settles FCPA enforcement action involving 1MDB. See, DOJ Press Release and Remarks of Acting Assistant Attorney General Brian Rabbitt.  2.     What have we learned? Team #GWIC (Mary Shirely and Lisa Fine) publish their first book, Sending the Elevator Back Down. Annoucement on CCI.     3.     What are the lessons of J&F Investments? Tom takes a deep dive in a 5-Part series on the FCPA Compliance and Ethics Blog. Part 1-Introduction, Part 2-the Bribery Scheme, Part 3-the SEC Order, Part 4-the Plea Agreement, Part 5-Final Thoughts. Mike Volkov does as well in a 4-Part series on Corruption Crime and Compliance. Part 1, Part 2, Part 3, Part 4. Tom and Matt Kelly go into the weeds on Compliance into the Weeds.  4.     World Bank to put more resources into evaluating compliance programs. Joshua Ray in the FCPA Blog. 5.     Do DPAs and NPAs encourage recidivism? Dylan Phillips continues the debate in the FCPA Blog. 6.     Is there more corruption now in college sports? Pat Forde in SI.com.   7.     What is the future of financial fraud? Jonathan Karpoff in the Harvard Law School Forum on Corporate Goverance. 8.     Will FinTech be the great enabler of the next Industrial Revolution? Ingrid Vasiliu-Feltes on xpertsleague.com. 9.     The Everything Compliance gang is back. In this episode, they consider what enforcement might look like under a Trump or Biden Administration. Listen here.  10.  On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, we  continue our exploration of compliance for Business Ventures.  Monday-Tying it all together for JVs; Tuesday-Know Your Customer; Wednesday- the Corporate Controller and Business Ventures; Thursday- Financial review of your business venture partner; Friday-Distributors as Business Venture Partners. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.   11.  Join Tom and Sam Silverstein for an Executive Forum on Ethics and Accountability on October 28, 2020 12-1 PM CT. Check at the agenda and register here.  12.  Join Tom, Holly Sais Phillippi, Head of Americas Risk Sales, Refinitiv and Kelly M. Slavitt in a Refinitiv sponsored webinar, The Future of Due Diligence: Third-Party Risk in the Era of COVID-19, Tuesday, October 27, 1-2 PM CT. Check at the agenda and register here.  13.  Check out the replay of the Navex Next 9th Annual Risk & Compliance Virtual Conference event Beyond the Moment. For more information, go here.  Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As the Trump Administration backtracks from its avowed goal to destroy the USPS, Tom and Jay brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week.  1.     First DOJ Opinion Release in 6 years. What is the significance? Tom explains it all in the FCPA Compliance and Ethics Blog.  2.     FCPA enforcement action involving international adoptions. Harry Cassin in the FCPA Blog. 3.     Bank/government partnership to fight financial crime.  Dylan Tokar in WSJ Risk and Compliance Journal.  4.     Once a cheater, always a cheater? Daimler pays $2bn fine. Aaron Nicodemus in Compliance Week(sub req’d) 5.     At the one year anniversary of the Business Roundtable’s Statement on the Purpose of a Corporation, Mike Volkov reviews Board performance in a 4-part series on Corruption, Crime and Compliance. Part 1, Accountability. Part 2, diversity. Part 3, challenges for Board decision-making.  Part 4, steps to advance corp governance.  6.     Is ‘Failure to Prevent’ the next big crime in the UK? Cordery Compliance alert.  7.     When can you use a corruption defense in litigation?  VE lawyers in the State Bar of Texas Int’l Law Journal. 8.     Does the McDonald’s suit against its former CEO implicate D&O coverage? Kevin LaCroix opines in the D&O Diary.  9.     This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance.  In Part 2, we discussed the qualities of a successful CCO. In this week’s Part 3, communication as a driver of compliance.  10.  On Compliance and Coronavirus we had a week of AMI. Tuesday had Eric Feldman discussing culture and compliance during Covid-19, Vin DiCianni on using compliance ambassadors during Covid; and Deb Waugh on challenges in the health care profession.  11.  On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on the role of the Board in compliance. This week saw the following offerings: Monday-what leads to a successful BOD investigation; Tuesday- Board metrics for compliance;Wednesday-BOD failures with special guest Vin Dicianni; Thursday- BOD & doing business in China; and Friday-the Board’s role in hiring. The month of August is being sponsored by Affiliated Monitors.  Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.   12.  Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here.  13.  Join Tom and Vince Walden (host of The Walden Pond) for a webinar on the ROI of Compliance, Tuesday August 25, 10 AM CT. Registration and Information here.  14.  Join Tom and AMI’s Don Stern for a review of the 2020 Update to the Evaluation of Corporate Compliance Programs as a part of Navex Global’s quarterly MasterClass on Thursday, August 27. Information and registration here.  15.  Join K2 Intelligence FIN’s Bernard Factor for a webinar entitled “Examining the Nuances of Correspondent Banking to Address BSA/AML Compliance Risk”. Registation and Information here.  16.  Join Tom next week on the FCPA Compliance Report, as he leads up to the 500th episode. All next week some of the top commentators in compliance will join Tom to discuss some of the top developments in compliance over the past 8 year. It is all leading up to the 500th anniversary episode which will run Monday, August 31.  Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Tom and Jay brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week.  World Acceptance bribed with bags of cash. Mike Volkov in Crime Corruption & Compliance. Implications from the end of Privacy Shield. Lawyers from Debevoise & Plimpton in NYU’s Compliance and Enforcement blog. NRA shoots itself in foot over non-compliance? Kyle Brausser in Compliance Week. (sub req’d) Using lessons learned. Jeff Kaplan and Rebecca Walker in CCI. Dick Cassin asks ‘are agents ever legal under the FCPA?’ in the FCPA Blog. Applying 2020 Updates to anti-trust compliance. Matt Kelly writing in Navex Global’s Ethics and Compliance Matters. What is a metric’s inventory and why do you need one? Tom explains in the FCPA Complaince and Ethics Blog. Follow on corruption litigation is expensive. Kevin LaCroix in the D&O Diary. This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance. In this week’s Part 2, we discussed the qualities of a successful CCO. On Compliance and Coronavirus this week, we had John Fanning discusses the increased need for due diligence during Covid-19, Andy Goldstrom on compliance adaptations during Covid; and Jed Gardner on business as usual. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on the role of the Board in compliance. This week saw the following offerings: Monday-BOD’s inquiring up and down; Tuesday- the BOD’s role in internal controls; Wednesday-BOD as an internal control; Thursday- BOD governance and risk oversight; and Friday-what is your Board’s investigative protocol. The month of August is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.  Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

The DOJ/SEC drop the 2nd edition to the FCPA Resource Guide at 5 PM on July 2. As Tom and Jay brave the surge in covid cases to stay safe they are back to look at top compliance articles and stories which caught their eye this week.  FCPA Resource Guide, 2nd edition released. Tom takes a deep dive in a 5-part blog post series on the FCPA Complinace and Ethics Blog. Part 1-The New Hallmark, Part 2-FCPA Corporate Enforcement Policy, Part 3- the Accounting Provisions, Part 4- Policy and Case Law Updates, Part 5-What does it all mean? Jonathan Marks on Borad and Fraud. Tom and Matt Kelly in Compliance into the Weeds. After its FCPA settlement, Novatris pays another $678MM for corruption inside the US. Mike Volkov in Corruption Crime and Compliance. A plan to restore trust in South Africa ABC enforcement. Larry Kirsch guest posts in GAB. A reassessment of due diligence in China? Jenny Liang opines in the FCPA Blog. Venezuela can’t get its gold out of England. Jon Rausch in Dipping Through Geometries. Amazon settles OFAC sanctions enforcement action. Mengqui Sun in the WSJ Risk and Compliance Journal. How can you make a risk management committee effective? Jim DeLoach shows the way in CCI. Is Deutsche Bank the world’s most corrupt? Matt Kelly digs in on Radical Compliance. Going from disaster recovery to business continuity? Carrie Penman in Ethics and Compliance Matters. On Compliance and Coronavirus, I was joined this week by Paul Mueller on how to reset, restart and accelerate your business in the era of Coronavirus; Ian Denis on employment and communication during Covid-19 and Breeda Miller on caregiving in the era of Covid-19. On the Compliance Podcast Network, Tom started the topic of 3rd party risk management this month.This week saw the following offerings: Monday-Questionniare; Tuesday-Due Diligence,Wednesday-levels of DD; Thursday-evaluating DD and clearing red flags; and Friday-compliance terms and conditions. The month of July is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. Great Upcoming Webinars: Navigating the Risks of Prescribing Opioids for Chronic Pain in the COVID-19 Era, Jul 22, 2020 12:00 PM in Eastern Time (US and Canada); with Jesse Caplan, Deb Waugh and Amy Fogelman, M.D. Registration and Inforamtion here. Computer Say ‘No’: Mitigating Legal & Ethical Risks in Public Agency Use of Automated Decision-Making Tools, Jul 28, 2020 12:00 PM in Eastern Time (US and Canada); with David Shonka, Mikhail Reider-Gordon and Jonathan Redgrave. Registration and Information here. ECI's Best Practice Forum, a Q&A Session with Brian Rabbitt, Acting Assistant Attorney General for the Criminal Division on the FCPA Resource Guide, 2nd edition, Thursday, July 30 2:00 - 4:00 p.m. EDT. Registration and Information here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recently released FCPA Resource Guide, 2nd edition; released jointly last week by the Department of Justice and Securities and Exchange Commission. Resources From Tom, check out his five part blog post series on the new FCPA Resource Guide on the FCPA Compliance and Ethics Blog. For a copy of the FCPA Resource Guide, 2nd edition, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices

As Trump has trouble drinking a glass of water and walking (Note-not at the same time), Covid-19 cases spike, the US Supreme Court hands down a landmark decision on protections for the LGBTQ community in the workplace, self-distancing Tom and Jay are back to consider some of the top compliance articles and stories over the past week.  Mike Volkov takes the chickens out to roost in a 3-part series on the DOJ Antitrust Division charges of price-fixing and bid-rigging conspiracy. In Corruption Crime & Compliance. Jon Rausch weighs in on Dipping Through Geometries. How will WFH change business? Alison Taylor opines on the World Economic Forum What are the three ‘R’s’ of a speak up culture? Lloydette Bai-Marrow on the FCPA Blog. GOP stymies data privacy/data protection legislation yet again. Dave Uberti reports in the WSJ. It’s your culture stupid. Jim Nortz in CCI. How is Covid-19 changing internal audit. Matt Kelly explores in Radical Compliance. Viva La France. Dylan Tokar reports in the WSK Risk and Compliance Journal. Making sure compliance is not marginalized during financial dislocation. A plethora of authors contribute on NYU’s Compliance and Enforcement Blog. The ethical upside to WFH. In the Center for Ethical Leadership Interested in moving to the CCO chair? Check out my latest podcast series The Compliance Lifewhere I interview one CCO type for a month on their journey to the CCO chair and beyond. In on this month’s edition I visit with Ryan Rabalais. In this Part 3, he details some of key skills of a CCO. The Compliance Life is now available on iTunes. On Compliance and Coronavirus this week,: Scott Price on cyber security risks going forward; Gabe Gumbs data privacy and data protection during the economic dislocation and Covid-19; David McLaughlin joins me to discuss increasing automation to enhance compliance. Compliance and Coronavirus is available on iTunes here. On the Compliance Podcast Network, this month topic: internal reporting and investigations; all on 31 Days to a More Effective Compliance Program. This week’s offerings: Monday-The Investigative Team; Tuesday-investigative challenges; Wednesday-the witness interview; Thursday- issues in cross-border investigations; Friday- who and when to suspend. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. How does the Hundred Acre Wood inform compliance? Check out Tom’s 5-part blog post series on the FCPA Compliance and Ethics Blog. Monday-Tigger and Sales; Tuesday-Kanga, Roo & Ombudsman; Wednesday-Eeyore and corp legal; Thursday-Piglet and Finance; Friday-Winnie the Pooh as CECO. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As Trump goes back into hiding in his bunker, the rest of the country continues to reopen. Self-Tom and Jay are back to consider some of the top compliance articles and stories over the past week.  Final thoughts on the DOJ 2020 Update to the Evaluation of Corporate Compliance Programs. Tom summarizes the highlights on the FCPA Compliance and Ethics Blog. Mike Volkov gives his five top takeaways. Want to see examples of ham-fisted leadership. Matt Kelly on Radical Compliance. Tom and Matt take a deep dive in Compliance into the Weeds. Why does WFH raise compliance risks? Vera Cherapanova on the FCPA Blog. How did Jho Low use Kuwait to continue his fraud? Reporting in the WSJ. Common features of corruption and police brutality. Matthew Stephenson opines in GAB. How can you sharpen your cyber security? Jim DeLoach in CCI. How can you build a listen up culture? Bob Conlin on Navex Global’s Ethics and Compliance Matters Managing risk in compliance staffing. Kathryn Reimann on NYU’s Compliance and Enforcement Blog. Brian Benczkowski bails the DOJ. Dylan Tokar on the WSJ Risk and Compliance Journal. Interested in moving to the CCO chair? Check out my latest podcast series The Compliance Lifewhere I interview one CCO type for a month on their journey to the CCO chair and beyond. In on this month’s edition I visit with Ryan Rabalais. In this Part 2, he details why the corp compliance function can be seen as a Black Box. The Compliance Life is now available on iTunes. On Compliance and Coronavirus this week, I feature three podcasts from the folks at K2 Intelligence FIN: Gabe Hidalgo on lessons for financial institutions during the time of Covid-19; Sepideh Rowland on PPP and changing risks for financial institutions; Ray Dookhie joins me to discuss evolving fraud risk during the time of Covid-19. Compliance and Coronavirus is available on iTunes here. On the Compliance Podcast Network, this month topic: internal reporting and investigations; all on 31 Days to a More Effective Compliance Program. This week’s offerings: Monday-internal reporting and whistleblowers during layoffs; Tuesday-triage of allegations; Wednesday-the investigation protocol; Thursday- preparing for an investigation; Friday- selection of investigative counsel. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. Join Tom and Jonathan Marks for a webinar on the 2020 Update to the Evaluation of Corporate Compliance Programs. Thursday, June 18 at noon CT. Registration and information available here. Join Jay’s AMI colleagues Dionne Lomax and Jesse Caplan for a webinar entitled, “The DOJ’s New Guidance for Antitrust Compliance Programs + Special Considerations During the COVID Pandemic”. This webinar will discuss the U.S. Department of Justice Antitrust Division’s recently announced initiative to encourage corporations to develop and implement effective antitrust compliance programs. Our panel will discuss the new guidance and special considerations during the COVID pandemic and provide practical tips for developing a comprehensive program, including tips on how to handle a federal and/or state antitrust investigations. The event will be held next Tuesday, June 16th, at 12P EST/9A PST. Registration and information can be found here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

In addition to not following President Trump’s advice to have having bleach for breakfast and UV light for lunch, we now add Blue Bell Ice Cream to the “No-Eat” list for their criminal behavior leading to three deaths from listeria. Sad for this loss but determined to persevere, self-distancing Tom and Jay are back to consider some of the top compliance articles and stories which caught their collective eye this week. Blue Bell Ice Cream pleads guilty to two misdemeanor counts of distributing adulterated ice cream products. Mike Volkov blogs and podcasts about it in on Corruption Crime and Compliance. Tom intones on the FCPA Compliance and Ethics Blog. Jon Rausch on Dipping Through Geometries. More from Tom on the former CEO and Chairman of the Board criminally indicted for lying about it. Tom further reports with a two-part blog on the Board’s corporate governance failures, Part-1 COIs and Part 2-Caremark failures. Rough sailing ahead for CCOs in cruise line industry. Matt Kelly weighs in on Radical Compliance. Tom and Matt take a deep dive in this week’s Compliance into the Weeds The SEC responds to criticism and ramps up its whistleblower awards. Dave Michaels reports in the WSJ. Moro resigns in Brazil, setting off a political crisis. Jessie Bullock In the Global Anti-corruption Blog. NY DFS files action against opioid mfg for insurance fraud. Lawyers from Paul Weiss in NYU’s Compliance and Enforcement blog. Lost in a sea of regulations? Kristy Grant-Hart explains how to navigate it in a guest post on Ethics and Compliance Matters. Another Caremark case survives in Delaware. Kevin LaCroix in the D&O Diary. Did US gov purchase from sanctioned entity? Geert Vermuelean in Risk and Compliance Platform Europe. Should it be decision-making instead of risk management? Norman Marks in Governance, Risk Management and Audit. Interested in moving to the CCO chair? Check in on this month’s edition of The Compliance Life where Tom visits with Ellen Hunt, CCO at AARP. In this Part 1, Hunt discusses the start of your journey. New episodes appear each Tuesday in May at 1 PM CST. The Compliance Life is now available on iTunes. Tom has a wide ranging discussion with Nick Gallow on Compliance Lines’ new podcast, The Ethics Experts. Available on the Complaince Podcast Network. On Compliance and Coronavirus this week: James Gellert on financial health of 3rd parties as a key DD inquiry; Ben Wolf on the new normal of doing business after Covid-19; Fry Wernick  on ephemeral messaging and video conferencing under the FCPA. Compliance and Coronavirus in sponsored by SAI Global. On the Compliance Podcast Network, Tom explores written standards; all on 31 Days to a More Effective Compliance Program. This week’s offerings: Monday-Clearly articulated written standards; Tuesday-the Code of Conduct; Wednesday-Code of Conduct: Structure and Format; Thursday- Design of your Code of Conduct; Friday- Training on your Code of Conduct. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As Gronk ends his self-imposed isolation from the Pats to rejoin the Golden Boy in Tampa Bay, self-distancing Tom and Jay are back to consider some of the top compliance articles and stories which caught their collective eye this week. For the SEC drops a Friday Happy Hour FCPA enforcement action involving ENI. Matt Kelly breaks the story in Radical Compliance. Tom provides lessons learned in the FCPA Compliance and Ethics Blog. Tom and Matt take a deep dive in their podcast Compliance into the Weeds. Harry Cassin in the FCPA Blog. Dylan Tokar reports in the WSK Risk and Compliance Journal. Tenacious whistleblower awarded $27MM. Kevin LaCroix in the D&O Diary. Some post COVID-19 scenarios. Gemma Aiolfi explores in the FCPA Blog. Leaders, dirty hands and COVID-19. Muel Kaptien in Risk and Compliance Platform Europe. Data and security requirements are here to stay. William Schildknecht in NYU’s Compliance and Enforcement Blog. Why companies should leave compliance alone. Jenna Voss, Christina Arianna and Chase Goldstein In CCI. EY takes a brand beating. Martin Woods in Compliance Week. (Sub Req’d) Where was, and is, and will be your Board? Carrie Penman asks in Navex Global’s Ethics and Compliance Matters Can the government forgfeit a defense lawyers fees? Sara Kropf explores in Part 2 on Grand Jury Target. On Compliance and Coronavirus this week: Fizza Khan on financial regulation during COVID-19; Gordon Firemark on force majeure; Sundar Narayanan on a CCO using empathy during the coronavirus crisis. On the Compliance Podcast Network, Tom continues his month of exploring continuous improvement, all on 31 Days to a More Effective Compliance Program. This week saw the following offerings:Monday-keeping track of current events for continuous improvement; Tuesday-big data and continuous improvement; Wednesday-using big data; Thursday-measuring the effectiveness of a compliance program; Friday-Proactive monitoring for continuous improvement. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. This month’s sponsor is Affiliated Monitors, Inc. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As the blowback on the Astros, MLB, Commisioner Rob Manfred continues to get worse, Jay and Tom are back to consider some of the top compliance articles and stories which caught our eye this week.  1.     Airbus still making news. Asher Miller provides 5 key takeaways for the compliance practitioner in the FCPA Blog. Dylan Tokar reports on more follow on investigations in the WSJ Risk & Compliance Journal. Joanne Taylor joins Tom on the FCPA Compliance Report to consider the UK perspective. Tom considers the French enforcement perspective in the FCPA Compliance and Ethics Blog. 2.     Another sentencing in the PdVSA ongoing bribery scandal. See the DOJ Press Release. 3.     What are WOW moments in compliance? Geert Vermeulen begins a 5-part series in Risk and Compliance Platform Europe.  4.     How do compliance officers show their worth? Dick Cassin explain in the FCPA Blog.  5.     Is it time to rebalance your 3rd party risk management strategy? Mike Volkov reports in Corruption Crime and Compliance. Mike writes about the importance of classifying your 3rd parties in Navex Global’s Ethics & Compliance Matters blog.  6.     Is the tide turning against whistleblowers? Aaron Nicodemus explores in Compliance Week. (sub req’d) 7.     Civil damages for corruption claims? Rick Messick considers on the Global Anti-Corruption Blog. 8.     New round of Alstom employee indictments. Dick Cassin reports in the FCPA Blog.   9.     What is a moral hazard moment? Jeff Kaplan explains on the Conflict of Interest blog.  10.  On the Compliance Podcast Network, Tom begins a one month look at the role of HR in compliance on 31 Days to a More Effective Compliance Program.This week saw the following offerings: Monday-succession planning and compliance; Tuesday-compliance performance appraisal review; Wednesday-Hiring a CCO: developing a job profile; Thursday-sales incentives and compliance; Friday-the exit interview. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.  11.  Join Tom to watch Jay on the panel with other compliance experts in the Dow Jones Refining Compliance Risk event in Hosuton on Tuesday, February 25 from 10 AM to 12 PM. For information and registration click here.   12.  Join Tom in NYC on Thursday, March 12 as Convercent is hosting an Innovation Forum from 3:30-7 PM at Sabrina. This event will allow you to network with like-minded individuals within the ethics and compliance space and hear from Thomas Fox and Philip Winterburn as well. For more information and registration click here.  Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Reports are that Airbus would settle corruption allegations for nearly $4bn in England were correct. Jay and Tom are back to consider some of the top compliance articles and stories which caught our eye this week.  1.     Airbus commentary is out. Dick Cassin on the FCPA Blog, Mike Volkov on Corruption Crime and Compliance, Tom Fox on the FCPA Compliance and Ethics Blog and Jonathan Armstrong on Cordery Compliance all lead the discussion.  2.     COSO warns of siloed compliance. Kristin Broughton in the WSJ Risk and Compliance Journal.  3.     Odebretch extends monitorship 9 months. Will that be enough? Mengqi Sun explores.  4.     What about small annual changes in the TI-CPI? Matthew Stephenson goes diadic.   5.     Is new DOJ Guidance a sword or shield or both? Jay continues his series.  6.     How to grow your compliance program as your company scales. Gio Gallo explains.   7.     Worried about CCO liability? Matt Kelly explores. 8.     Bernie Ebbers passes. A moment of silence for his role in compliance.  9.     Speaker programs and big pharma. WilmerHale lawyers opine.  10.  On the Compliance Podcast Network, Tom begins a one month look at the role of HR in compliance.This week saw the following offerings: Monday-introduction to the role of HR in compliance; Tuesday-the role of HR in creating an ethical culture; Wednesday-the hiring process; Thursday-the reference check. Friday-incentivizing compliance. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.  11.  Join Tom for the webinar, The Houston Astros: Ethics, Compliance and Sign Stealing on  Thursday February 13, at 2 PM CST. Registration and information here.  Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt indulges me as we take a deep dive into the Houston Astros sign stealing scandal. We mine the episode for compliance and ethics lessons. It turns out there are quite a few.  Some of the highlights include: Ø  What was the role amnesty to the players played in both the speed of the MLB Report and its thoroughness?  Ø  Does the MLB sanctions against Luhnow and Hinch send a clear (enough) signal?  Ø  It was a technology innovation which led to the scandal. How does that inform a compliance professional?  Ø  Houston’s culture was broken. How can it be fixed? Ø  Did the Mets and Red Sox both actually consider keeping Alex Cora and Carlos Beltran? If so why?   Resources Tom’s five blog posts (to date) in the FCPA Compliance and Ethics Blog.  Part 1-The Scandal Part 2-Luhnow and Hinch Part 3-Compliance Lessons Part 4-Ethics and The Truth of the Game Part 5-the Whistleblower and Amnesty Learn more about your ad choices. Visit megaphone.fm/adchoices

As Boeing finally takes a much-needed step and fires confrontational CEO, Dennis Muilenburg, Tom and Jay are recovered enough from their respective holiday food comas to consider some of this holiday week’s top compliance and ethics stories which caught their collective eyes.  1.     Boeing CEO (finally) fired. Natalie Kitroeff and David Gelles report on his missteps in NYT. Andy Pasztor, Doug Cameron and  report on his replacement in the WSJ. Tom and Matt consider ethics and the CEO in this week’s Compliance into the Weeds.  2.     Deputy AAG Mathew Miner on why companies should invest in compliance. Dylan Tokar in the WSJ Risk and Compliance Journal.  3.     Another DPA for the SFO and more corporate individuals acquitted at trial. Susan Hawley in the FCPA Blog.  4.     What is a textbook internal investigation? Matt Kelly explores.  5.     Is the Morning Show on Apple TV a wakeup call for corporate America? Sean Freidlin explores. 6.     What is the role of ESG in corp investing? John Huggie in the Harvard Law School Forum on Corporate Governance. 7.     The comp angle to managing multi-generations. Elliott Dinkin in CCI.  8.     What is operational resilience and why does it matter? Matt Kelly explores.  9.     How does Santa inform your compliance program? Tom explains in the FCPA Compliance and Ethics Blog.  10.  On the Compliance Podcast Network, this week Tom concluded a two-part series with MoFo partner James Koukios on the firm’s International Anti-Corruption Newsletter. Part 1 was the September newsletter and Part 2 was the October newsletter. Another two-parter you will want to check out is the Everything Compliance gang’s two-part podcast series reviewing compliance in 2019 under the Trump Administration. Part 1 features Tom, Matt Kelly and Jay Rosen. Part 2 features Sarah Hadden, Mike Volkov and Jonathan Armstrong.  Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the Ericsson FCPA enforcement action from the internal controls perspective.  Some of the highlights include: Ø  What does this enforcement action tell up about internal controls? Ø  How were the business units able to evade internal controls for so long? Ø  Was there control override? Ø  What is the role of ERP systems such as Oracle and SAP in compliance? Ø  If a company refuses to use standard ERP systems, is that a control failure under the FCPA? Ø  What are the lessons learned for a corporate compliance program? Ø  What does all this mean for compliance professionals going forward? Resources Tom’s blog posts, both the FCPA Compliance and Ethics Blog. Part 1-Overview Part 2-The Bribery Schemes Learn more about your ad choices. Visit megaphone.fm/adchoices

The fallout from the Hoskins guilty verdict still resonates. Tom and Jay reflect upon it, what it means to play by the rules and then turn to some other of this week’s top compliance and ethics stories which caught their collective eyes.  1.     Hoskins found guility. Dylan Tokar reports. Dick Cassin. Tom and Mike Volkov. How the verdict bolsters the DOJ. 2.     Astros accused by ex-player of cheating in 2017 Championship season. David Schonenfield breaks down sign-stealing. Michael Rosenberg reports. Buster Olney says the Astros cannot be trusted to investigation themselves. Tom weighs in on the FCPA Compliance and Ethics Blog. 3.     How do you balance perception based culture with fact based compliance? Anna Romberg  4.     Twists and turns in the Cognizant case. Bill Wichert  5.     What can WeWork teach us about private company compliance. Erica Salmon Byrne.   6.     A Guidebook to Corporate Governance.  7.     Deutsche Bank whistleblower loses appeal. Jon Hill  8.     Why do you need oversight of merged companies? Jay explores 9.     TRACE corruption ratings for 2019 are out. Matt Kelly reviews.  10.  Is FCPA enforcement inconsistent? Three lawyers from Bass, Berry say yes. 11.  Take a deep dive into SEC 2018/9 enforcement numbers. Cleary Gottlieb lawyers.   12.  The Compliance Kitchen, a podcast hosted by Silvia Surman, premiers on the Compliance Podcast Network.  Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recently released FCPA enforcement action by the SEC involving Juniper Networks.  Some of the highlights include: Ø Who is responsible for the continued violations after initial discovery, the subsidiaries or the parent?Ø What happens when a grandparent ‘speaks sternly’ to a grandchild?Ø Why does a decentralized compliance structure allow for internal abuse? Ø Do your policies and procedures actually support your compliance efforts? Ø As CCO do you have visibility into where customer discounts are going?Ø Should lawyers ever review expense reports from foreign business units? For additional reading see the following: Tom’s blog post, Juniper Network FCPA Enforcement Action, on the FCPA Compliance & Ethics Blog. Matt’s blog post, Juniper Networks Hit on FCPA Charge, on Radical Compliance. Jonathan Marks considers these points as well as the Board of Directors role in his blog post, Slush Funds and the Juniper Networks FCPA Settlement, on his always great Board and Fraud blog.  Learn more about your ad choices. Visit megaphone.fm/adchoices

In today’s edition of Daily Compliance News: ·      Wall Street Journal·      Radical Compliance·      FCPA Compliance and Ethics Blog (Part 1)·       Board and Fraud Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving surrounding New England Patriots owner Robert Kraft who has been charged with solicitation of prostitution, what it means for both Kraft and the NFL and the compliance response.   Some of the highlights include: Ø What are the background facts of the matter?Ø What has been the response of the NFL? Will it investigate or leave it to the public authorities?Ø What are other criminal charges involving NFL owners and what was the NFL response?Ø What are the key employee/CEO risks for an organization?Ø How much private conduct is really public in this age of social media?Ø Why is compliance the only response? For additional reading see Tom’s blog post Robert Kraft, the NFL and Complianceon the FCPA Compliance and Ethics Blog. Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving surrounding New England Patriots owner Robert Kraft who has been charged with solicitation of prostitution, what it means for both Kraft and the NFL and the compliance response.   Some of the highlights include: Ø What are the background facts of the matter?Ø What has been the response of the NFL? Will it investigate or leave it to the public authorities?Ø What are other criminal charges involving NFL owners and what was the NFL response?Ø What are the key employee/CEO risks for an organization?Ø How much private conduct is really public in this age of social media?Ø Why is compliance the only response? For additional reading see Tom’s blog post Robert Kraft, the NFL and Complianceon the FCPA Compliance and Ethics Blog. Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent announced Polycom Inc. FCPA enforcement action. We both blogged on it and we bring two difference perspectives to this matter. I take a deep dive into the nuts and bolts lessons learned for the compliance practitioner. Matt takes a step back and considers the larger picture of corporate culture, corrupt CEOs and how these can lead to the destruction of the company.   Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø How the CEO’s corrupt nature permeated the entire organization. Ø Oversight means more than simply asking questions and accepting the proffered answers. Ø Data analytics are critical for a best practices compliance program going forward.  For additional reading see Matt’s blog post “Many Lessons in Polycom FCPA Case” in Radical Compliance.  See also Tom’s blog “Following the Money Through Distributors” in the FCPA Compliance and Ethics Blog.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent announced Polycom Inc. FCPA enforcement action. We both blogged on it and we bring two difference perspectives to this matter. I take a deep dive into the nuts and bolts lessons learned for the compliance practitioner. Matt takes a step back and considers the larger picture of corporate culture, corrupt CEOs and how these can lead to the destruction of the company.   Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø How the CEO’s corrupt nature permeated the entire organization. Ø Oversight means more than simply asking questions and accepting the proffered answers. Ø Data analytics are critical for a best practices compliance program going forward.  For additional reading see Matt’s blog post “Many Lessons in Polycom FCPA Case” in Radical Compliance.  See also Tom’s blog “Following the Money Through Distributors” in the FCPA Compliance and Ethics Blog.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Gyi & Kelly are thrilled to chat with a veteran lawyer this week who went from corporate lawyer to solo practitioner 25 years into his career. 10 years later, he has a thriving practice and loves his job.  Thomas R. Fox-the Compliance Evangelist Tom is the author 16 books on business leadership, compliance and ethics and corporate governance, including the international best-sellers “Lessons Learned on Compliance and Ethics” and “Best Practices Under the FCPA and Bribery Act” as well as his series Fox on Compliance. His latest book “The Compliance Handbook” was published in May 2018 and was the No. 1 new bestseller on Amazon.com through its initial run. He writes and speaks across the globe on compliance programs. Tom leads the social media discussion on compliance with his award-winning blog, The FCPA Compliance and Ethics Blog and is the founder of the Compliance Podcast Network. Tom's policy: Give away your 'secret sauce', because it will create more trust than lose you money.   Twitter: Retweet your community to become a niche influencer. Set alerts on specific  Blog: Create, create, create! Get on a realistic content creation schedule and stick to it, rain or shine. Podcast: Turn your posts or ideas into  Webinars: Content can get recirculated and repurposed into multiple forms of content (blog post, podcast episode, shorten video into clips) Social Media: Tom's daughter set up his business Facebook page! Tom built a worldwide practice from his home office, from 0 clients to a thriving solo practice.  Francine McKenna's advice: Focus on a niche and stick with it for 6-12 months.   

Thomas Fox, the Compliance Evangelist, is one of the leading writers, thinkers, and commentators on the nuts and bolts of compliance. His always practical advice is now available in one volume, The Complete Compliance Handbook. This book incorporates the most recent pronouncements and guidance from the Department of Justice, including 2017’s Evaluation of Corporate Compliance Programs and FCPA Corporate Enforcement Policy, to provide the most up-to-date advice on what constitutes a best practices compliance program. Fox is an award-winning author of 15 books on compliance, ethics, and leadership, including Lessons Learned on Compliance and Ethics, a bestseller in the International Law category. Tom is also known for Best Practices Under the FCPA and Bribery Act, and the series, Fox on Compliance. Tom leads the social media discussion on compliance through his award-winning blog, The FCPA Compliance and Ethics Blog and the only podcast network dedicated to compliance, ethics and business leadership, the Compliance Podcast Network.

Eric Feldman of Affiliated Monitors, Inc. and Tom Topolski worked closely together when Tom's previous employer had engaged Eric as a monitor.  In this podcast they discuss what made their relationship work, and the lessons every compliance professional can take away when in the middle of, or about to face, a monitorship. Listen below, or read more and listen here on The Compliance & Ethics Blog https://www.affiliatedmonitors.com/wp-content/uploads/2018/04/Topolski_and_Feldman_on_Monitorships.mp3

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories, including: HSBC monitor report protected from release. See article in Reuters by clicking here. The Odebrecht scandal continues to resonate across South America. See Dick Cassin’s post in the FCPA Blog. The first half of 2017 has brought the final resolutions of only two FCPA matters from the new administration, but they were both declinations. Both declinations have significantly strengthened the FCPA Pilot Program as a clear path forward for every company that finds itself in FCPA hot water. See Tom’s article in Compliance Week. Roy Snell says it’s not who’s who but who gets it. See article in SCCE Compliance and Ethics Blog. Tom announces the rollout of the Compliance Podcast Network. It includes This Week in FCPA, FCPA Compliance Report, Compliance Report-International Edition, 12 O’Clock High, Unfair and Unbalanced, Compliance into the Weeds, Across the Board, Everything Compliance, One Month to a More Effective Compliance Program. See Tom’s article in the FCPA Compliance and Ethics Blog. The next Everything Compliance podcast is in production. Topics include Walter Shaub’s departure from OGE and does it even matter? Jesse Eisinger’s book The Chickenshit Club; the SFO, UK Bribery Act and the Rolls-Royce enforcement action; differences in DPA practice in the US & UK; Trump Administration & FCPA enforcement; EU’s GDPR; and Hui Chen’s departure from Justice Department; both her public rebuke of Trump, and the substance of how she believes her guidance has been mis-interpreted. Part I will go up on Thursday, July 20. Learn more about your ad choices. Visit megaphone.fm/adchoices

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories, including: HSBC monitor report protected from release. See article in Reuters by clicking  here.The Odebrecht scandal continues to resonate across South America. See Dick Cassin’s post in the  FCPA Blog.The first half of 2017 has brought the final resolutions of only two FCPA matters from the new administration, but they were both declinations. Both declinations have significantly strengthened the FCPA Pilot Program as a clear path forward for every company that finds itself in FCPA hot water. See Tom’s article in  Compliance Week.Roy Snell says it’s not who’s who but who gets it. See article in SCCE Compliance and Ethics Blog.Tom announces the rollout of the Compliance Podcast Network. It includes This Week in FCPA, FCPA Compliance Report, Compliance Report-International Edition, 12 O’Clock High, Unfair and Unbalanced, Compliance into the Weeds, Across the Board, Everything Compliance, One Month to a More Effective Compliance Program. See Tom’s article in the FCPA Compliance and Ethics Blog.The next Everything Compliance podcast is in production. Topics include Walter Shaub’s departure from OGE and does it even matter? Jesse Eisinger’s book The Chickenshit Club; the SFO, UK Bribery Act and the Rolls-Royce enforcement action; differences in DPA practice in the US & UK; Trump Administration & FCPA enforcement; EU’s GDPR; and Hui Chen’s departure from Justice Department; both her public rebuke of Trump, and the substance of how she believes her guidance has been mis-interpreted. Part I will go up on Thursday, July 20. Learn more about your ad choices. Visit megaphone.fm/adchoices

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: The Covington and Burling report on corporate culture at Uber. For what it means to the compliance practitioner, see Tom’s piece in the FCPA Compliance & Ethics Blog. For another view on the car crash of corporate governance at Uber, see Matt Kelly’s piece in Radical Compliance. Finally for an article the on investor who took on both Uber and Silicon Valley for similar issues, see this article on NPR. Swiss banker, Jorge Luis Arzuaga pleads guilty to laundering money for FIFA officials. See article by Dick Cassin in the FCPA Blog. DOJ files civil forfeiture complaints Thursday against an additional $540 million in assets allegedly bought with money looted from a Malaysian sovereign wealth fund, 1MDB. See article in the WSJ by clicking here. Adnan Khashoggi, the Saudi arms dealer in the middle of the giant 1970s bribery scandal that led to enactment of the FCPA died this past week. See article by Dick Cassin in the FCPA Blog. CCOs still struggle with outdated technology, siloed data. See article by Aarti Maharaja in the FCPA Blog. See Ethisphere-Convercent Report, by clicking here. Brazilian prosecutor-turned-lawyer under ethics investigation following J&F settlement. See article by Michael Griffiths in GIR by clicking here (sub req’d) Jay previews his weekend report. Tom continues to talk about the release of his new book 2016 – The Year in Corporate FCPA Enforcement. For more information and to purchase, click here. Happy Father’s Day to all you dads out there. Learn more about your ad choices. Visit megaphone.fm/adchoices

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: The Covington and Burling report on corporate culture at Uber. For what it means to the compliance practitioner, see Tom’s piece in the FCPA Compliance & Ethics Blog. For another view on the car crash of corporate governance at Uber, see Matt Kelly’s piece in  Radical Compliance. Finally for an article the on investor who took on both Uber and Silicon Valley for similar issues, see this article on  NPR.Swiss banker, Jorge Luis Arzuaga pleads guilty to laundering money for FIFA officials. See article by Dick Cassin in the  FCPA Blog.DOJ files civil forfeiture complaints Thursday against an additional $540 million in assets allegedly bought with money looted from a Malaysian sovereign wealth fund, 1MDB. See article in the WSJ by clicking  here.Adnan Khashoggi, the Saudi arms dealer in the middle of the giant 1970s bribery scandal that led to enactment of the FCPA died this past week. See article by Dick Cassin in the FCPA Blog.CCOs still struggle with outdated technology, siloed data. See article by Aarti Maharaja in the  FCPA Blog. See Ethisphere-Convercent Report, by clicking here.Brazilian prosecutor-turned-lawyer under ethics investigation following J&F settlement. See article by Michael Griffiths in GIR by clicking  here (sub req’d)Jay previews his weekend report.Tom continues to talk about the release of his new book 2016 – The Year in Corporate FCPA Enforcement. For more information and to purchase, click  here.Happy Father’s Day to all you dads out there. Learn more about your ad choices. Visit megaphone.fm/adchoices

Show Notes for Episode 56, for the week ending June 9, the Who’s On First Edition  This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:  The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit disgorgement. For what it means to the compliance practitioner, see Tom’s piece in the FCPA Compliance & Ethics Blog. For a legal review of the decision, see Miller & Chevalier  client alert authored by Saskia Zandieh. Marc Bohn considered the cased in the FCPA Blog. Marc and I discuss the case on the FCPA Compliance Report,  Episode 332.Trevor McFadden to leave the DOJ for federal bench. See article by Matt Kelly in  Radical Compliance. Hui Chen’s contract not to be renewed, her position is posted for job applicants. Apply for the position  here. Andrew Weissman leaves as head of the Fraud Section to go Special Prosecutor’s staff.Former PetroTiger General Counsel Gregory Weismann is banned from SEC practice. See article in the  FCPA Blog. Matthew Stephenson considers what a Wal-Mart settlement might look like. See his article in the  Global Anti-Corruption Blog.The federal judge who sentenced Samuel Mebiame, the bag man for Och-Ziff; criticized the DOJ for its lack of prosecution of any individuals from the company. See article by Sam Rubenfeld in  WSJ Risk and Compliance Report.Jay previews his weekend report.Tom continues to talk about the release of his new book 2016 – The Year in Corporate FCPA Enforcement. For more information and to purchase, click  here. Jay Rosen can be reached:  Mobile (310) 729-6746 Toll Free (866)-201-0903 JRosen@affiliatedmonitors.com  Tom Fox can be reached:        Phone: 832-744-0264        Email: tfox@tfoxlaw.com       Learn more about your ad choices. Visit megaphone.fm/adchoices

Show Notes for Episode 56, for the week ending June 9, the Who’s On First Edition  This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:  The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit disgorgement. For what it means to the compliance practitioner, see Tom’s piece in the FCPA Compliance & Ethics Blog. For a legal review of the decision, see Miller & Chevalier client alert authored by Saskia Zandieh. Marc Bohn considered the cased in the FCPA Blog. Marc and I discuss the case on the FCPA Compliance Report, Episode 332. Trevor McFadden to leave the DOJ for federal bench. See article by Matt Kelly in Radical Compliance. Hui Chen’s contract not to be renewed, her position is posted for job applicants. Apply for the position here. Andrew Weissman leaves as head of the Fraud Section to go Special Prosecutor’s staff. Former PetroTiger General Counsel Gregory Weismann is banned from SEC practice. See article in the FCPA Blog.  Matthew Stephenson considers what a Wal-Mart settlement might look like. See his article in the Global Anti-Corruption Blog. The federal judge who sentenced Samuel Mebiame, the bag man for Och-Ziff; criticized the DOJ for its lack of prosecution of any individuals from the company. See article by Sam Rubenfeld in WSJ Risk and Compliance Report. Jay previews his weekend report. Tom continues to talk about the release of his new book 2016 – The Year in Corporate FCPA Enforcement. For more information and to purchase, click here.  Jay Rosen can be reached:  Mobile (310) 729-6746 Toll Free (866)-201-0903 JRosen@affiliatedmonitors.com  Tom Fox can be reached:        Phone: 832-744-0264        Email: tfox@tfoxlaw.com       Learn more about your ad choices. Visit megaphone.fm/adchoices

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:  Brazilian President Temer comes under corruption fire? See article in the  New York Times.The turmoil at FIFA continues as FIFA’s ethics watchdogs quit in protest after their chairman was fired. See article in  Bloomberg.Should compliance and ethics be wedded? New  report by Institute of Business Ethics and the Ethics Institute considers the issues. See  article in WSJ Risk and Compliance Journal.The Fat Leonard scandal lands U.S. Navy Rear Admiral Robert Gilbeau with a prison sentence of 18 months. See article in the  FCPA Blog.Almost one-third of all open FCPA investigations involve Brazil. Only 17% involve China. See article in the  FCPA Blog.Astros lead the MLB with the best record in baseball. Will they regress to the mean?ComTech is here. Are you ready? See Tom’s article in the FCPA Compliance and Ethics Blog.Jay previews his Weekend Report.It is not too late to join me at Compliance Week 2017. Listeners to this podcast can received a discount to Compliance Week 2017. Go to registrationand enter discount code CW17TOMFOX. Learn more about your ad choices. Visit megaphone.fm/adchoices

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:  Brazilian President Temer comes under corruption fire? See article in the New York Times. The turmoil at FIFA continues as FIFA’s ethics watchdogs quit in protest after their chairman was fired. See article in Bloomberg. Should compliance and ethics be wedded? New report by Institute of Business Ethics and the Ethics Institute considers the issues. See article in WSJ Risk and Compliance Journal. The Fat Leonard scandal lands U.S. Navy Rear Admiral Robert Gilbeau with a prison sentence of 18 months. See article in the FCPA Blog. Almost one-third of all open FCPA investigations involve Brazil. Only 17% involve China. See article in the FCPA Blog. Astros lead the MLB with the best record in baseball. Will they regress to the mean? ComTech is here. Are you ready? See Tom’s article in the FCPA Compliance and Ethics Blog. Jay previews his Weekend Report. It is not too late to join me at Compliance Week 2017. Listeners to this podcast can received a discount to Compliance Week 2017. Go to registrationand enter discount code CW17TOMFOX. Learn more about your ad choices. Visit megaphone.fm/adchoices

Show Notes for Episode 35, week ending January 13, the Friday the 13th edition  Hernandez and Beech FCPA guilty pleas.  Hernandez Criminal Information,  Beech Criminal Information.VW guilty plea in emissions-testing scandal. Link to article in  New York Times.VW executive Oliver Schmidt arrested in US. See article on  FCPA Compliance and Ethics Blog.Zimmer Bio-Met in follow-up FCPA enforcement action. See article on  FCPA Blog.Mondelez FCPA enforcement action. See SEC Cease and Desist Order and article on  FCPA Compliance and Ethics Blog.Supreme Court to take up 5 year statute of limitations for profit disgorgement under Securities Act, which applies to FCPA enforcement actions brought by SEC. Article in Law360.NFL Playoff update on Patriots, Cowboys and Texans. Learn more about your ad choices. Visit megaphone.fm/adchoices

Show Notes for Episode 35, week ending January 13, the Friday the 13th edition  Hernandez and Beech FCPA guilty pleas. Hernandez Criminal Information, Beech Criminal Information. VW guilty plea in emissions-testing scandal. Link to article in New York Times. VW executive Oliver Schmidt arrested in US. See article on FCPA Compliance and Ethics Blog. Zimmer Bio-Met in follow-up FCPA enforcement action. See article on FCPA Blog. Mondelez FCPA enforcement action. See SEC Cease and Desist Order and article on FCPA Compliance and Ethics Blog. Supreme Court to take up 5 year statute of limitations for profit disgorgement under Securities Act, which applies to FCPA enforcement actions brought by SEC. Article in Law360. NFL Playoff update on Patriots, Cowboys and Texans. Learn more about your ad choices. Visit megaphone.fm/adchoices