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What happens when the world's most influential anti-bribery law is abruptly paused? Is transparency merely a compliance box-tick—or the most powerful tool we have against global threats like kleptocracy, sanctions evasion, and illicit finance? In this eye-opening episode of Corruption, Crime, and Compliance, Michael Volkov is joined by two powerhouse experts in the global fight against corruption: Scott Greytak and Josh Birenbaum (*see ‘'About Guests below). Together, they break down the sweeping implications of the U.S. government's pause on Foreign Corrupt Practices Act (FCPA)enforcement, the gutting of the Corporate Transparency Act (CTA), and what all of this means for business leaders, policymakers, and the international community.When the United States hit pause on FCPA enforcement, the global anti-corruption landscape shifted. Scott and Josh explore how companies are reacting, how allies are stepping up enforcement, and why transparency is emerging as a national security imperative. They offer a forward-looking conversation filled with insights for compliance professionals, risk officers, and anyone committed to ethical business in a volatile world.You'll hear them discuss:Why the U.S. government's pause on FCPA enforcement shocked the global anti-corruption community—and why companies should still stay the course with compliance regardless of political signals.How the Corporate Transparency Act, once seen as the most significant U.S. anti-money laundering law in a generation, has been quietly gutted—leaving a dangerous gap in the fight against shell companies and financial crime.What it means that U.S. companies are now incentivized to form anonymously domestically to avoid ownership disclosure—inviting kleptocrats, traffickers, and foreign adversaries to hide in plain sight.Why global businesses must prepare for a sharp rise in trade compliance enforcement, as tariffs, export controls, and sanctions take center stage in economic security—and why transparency is essential to managing these risks.How foreign enforcers, especially in Europe, are beginning to step up—but why no alliance or coalition can truly fill the vacuum left by a retreating United States.What makes transparency not just a compliance tool, but a weapon against geopolitical threats—from Xinjiang's forced labor camps to Russian shadow fleets and fentanyl trafficking.How transparency can be hardwired into foreign aid policy to protect U.S. taxpayer money, prevent narco-state development, and give American businesses a fair shot abroad.Why there's still hope—from new bipartisan support for anti-corruption measures to the emergence of a national security lens on transparency across Congress, federal agencies, and the private sector.About GuestsScott Greytak is an anticorruption attorney and the Director of Advocacy for TI US. His work focuses on designing anticorruption laws and policies, organizing and leading ideologically inclusive coalitions, and lobbying the U.S. Congress and administration. Greytak was named a Top Lobbyist in 2021, 2023, and 2024 by the National Institute for Lobbying & Ethics. Josh Birenbaum is the deputy director of FDD's Center on Economic and Financial Power, focusing on illicit finance risks and global corruption. Previously, Josh was the research and policy analyst at TRACE International, producing articles, book chapters, op-eds, model policies, industry reports, and speeches on sanctions, export controls, corruption, conflict minerals, money laundering, human rights, illicit finance, and other topics. ResourcesScott Greytak on LinkedIn | Email - sgreytak@us.transparency.orgJosh Birenbaum on LinkedIn | Email - jbirenbaum@fdd.orgMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
Innovation comes in many areas, and compliance professionals must be ready for and embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. Today, we begin a 3-part podcast series sponsored by Diligent with Clint Palermo, Kristy Grant-Hart, and Stephanie Font. In Part 3, Tom is joined by Kristy Grant-Hart, Vice President and Head of Compliance Advisory Services at Spark Compliance Consulting, a Diligent brand, about the state of compliance in the wake of recent changes to FCPA enforcement. They discuss the importance of staying consistent with compliance programs, the role of regulatory bodies worldwide, and the practical implications of modern slavery and trade sanctions. Kristy emphasizes the need for a strategic focus on forward-looking risks and the benefits of combining Diligent's software capabilities with expertise in compliance services. They also underscore the importance of maintaining psychological safety and a speak-up culture within organizations. Key highlights: The Importance of Consistency in Compliance The Power of Combining Compliance Services with Technology Strategic Focus for Compliance Officers Resources: Kristy Grant-Hart on LinkedIn Spark Compliance Visit Diligent Website Tom Fox Instagram Facebook YouTube Twitter LinkedIn
When The United States has hit pause on Foreign Corrupt Practices Act (FCPA) enforcement—it left many asking whether Europe will now be stepping up to lead the global anti-corruption charge. In this episode of Corruption, Crime and Compliance, Michael Volkov explores how European prosecutors are responding to the enforcement gap, why multinational companies can't afford to slow down their compliance efforts, and how both state-level and international initiatives are reshaping the future of anti-bribery law.You'll hear him talk about:The launch of a new International Anti-Corruption Prosecutorial Task Force formed by the UK, France, and Switzerland, designed to intensify cross-border enforcement and cooperation in bribery and corruption cases.The task force's formation as a direct response to the U.S. enforcement pause, signaling that European agencies are prepared to take a more prominent role in prosecuting international corruption, especially involving multinational corporations.California's bold move to pursue foreign bribery under its Unfair Competition Law (UCL), reinforcing that FCPA violations remain prosecutable at the state level despite federal hesitation.A continued commitment by global companies to maintain strong compliance programs, reflecting awareness that international and local enforcement can still pose serious legal and financial risks.The unexpected dismissal of the long-running FCPA case against Cognizant executives, contrasted with the DOJ's decision to move forward with prosecutions in other high-profile cases, suggesting a selective enforcement pattern under current policy shifts.A landmark case by the UK Serious Fraud Office (SFO), charging a company with failure to prevent bribery—a first for the SFO to bring such a case before a jury, potentially setting a new standard for corporate liability in the UK.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
Robert shares his formative experiences, the pivotal moments that led to the founding of his company, and the tough decisions that came along the way. He delves into topics such as the importance of resilience, making quick and decisive choices, and the evolution of leadership. 05:35 The Leap into Entrepreneurship14:34 Leadership and Accountability22:51 A Life-Changing Conversation35:19 Teaching Financial Wisdom to Kids…
Host Professor J.W. Verret interviews Pete Tomczak, global head of investigations at Baker McKenzie, about the current state of Foreign Corrupt Practices Act practice in the wake of the new administration's pause. We discuss the real world FCPA case of US v. Lawrence Hoskins, a defendant who was acquitted in a case that went to trial and saw multiple appellate decisions that demonstrates a tendency for federal overreach in FCPA matters.
Ever wondered what really happens when corporate crime hits the courts in India? In this week's episode, Dr. Rosinus and his guest Mr. Varshney take you inside the fascinating world of white-collar crime and economic criminal law in India. They break down the mechanics of India's civil and criminal courts, comparing the Indian system to the UK's, and give you an insider's look at how key laws like those addressing corruption, money laundering, and internal investigations shape the landscape. Furthermore, India's response to global enforcement crackdowns like the FCPA also comes under the spotlight, revealing how Indian companies are adapting to new compliance challenges. And just when you think it's all wrapped up, they dive into India's evolving sanctions regime and what it means for doing business in the country. Whether you're in compliance, law or international business, this episode is packed with expert insights, real-world implications, and a few surprises. Dr. Rosinus in conversation with: Nikhil Varshney is partner at Cyril Amarchand Mangaldas, a leading Indian law firm. Mr. Varshney has over 11 years of experience and focuses on Disputes, White-Collar Crimes, Investigations and Sanctions practice area. He handles general commercial litigation and sensitive criminal matters and investigations for domestic and international clients. He also has an expertise in handling internal investigations regarding a wide range of issues relating to bribery, ethics and integrity, misconduct, financial irregularities and fraud. Mr Varshney also advises on sanctions related issues. He can be reached by email at nikh-il.varshney@cyrilshroff.com or by phone at +91 8587074934 https://www.rosinus-on-air.com https://rosinus-partner.com
Welcome to this edition of the award-winning Everything Compliance. In this episode, Matt Kelly, Jonathan Armstrong, Karen Moore, and Tom Fox, the Compliance Evangelist, will appear as panelists. 1. Karen Moore examines EU changes in reporting on ESG and CCCD and rants about the anxiety caused by the Trump Administration. 2. Matt Kelly reviews the off-channel messaging scandal. He rants about the Trevor Milton pardon. 3. Jonathan Armstrong takes a deep dive into Agentic AI and its implications for compliance. He shouts out to Russell Brand for unmasking British actor Penelope Keith as JFK's assassin. 4. Tom Fox examines the world's response to Trump's suspension of FCPA enforcement. He shouts out to Opening Day of the 2025 MLB season and highlights his hometown heroes, the Houston Astros. The members of Everything Compliance are: Karen Woody – is one of the top academic experts at the SEC. Woody can be reached at kwoody@wlu.edu Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong – is an experienced compliance & technology lawyer based at Punter Southall Law in London (https://puntersouthall.law/). He adds an international focus and can be reached at Jonathan.Armstrong@puntersouthall.law. Jonathan Marks – can be reached at jtmarks@gmail.com Karen Moore – is a principal at Sounding Board Compliance and can be reached at karen.moore@soundingboardcompliance.com The host and producer, rantor (and sometime panelist) of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the award-winning Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional. Top stories include: End of SEC FCPA bribery unit. (Reuters) Ex-Shell boss tasked with cleaning up Nigerian National Petroleum Company (NNPC). (BBC) The judge dismisses Adams's case with prejudice. (NYT) DOJ moves to dismiss FCPA trial of former Cognizant execs. (Law360) sub req'd Learn more about your ad choices. Visit megaphone.fm/adchoices
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the intricate future of corporate compliance amidst changes brought by the presidential executive order suspending FCPA investigation and enforcement. Matt shares insights from a recent Compliance Week event in Boston, highlighting concerns among compliance professionals about the potential obsolescence of their roles. The discussion covers two primary scenarios: regulatory relaxation, making dedicated compliance roles redundant, and technological advancements, particularly AI, potentially replacing human compliance officers. However, both agree on the enduring importance of robust compliance functions integrated within corporate structures, emphasizing the strategic value of compliance in risk management and business operations. They explore the dual excitement and anxiety surrounding AI's role in compliance. Matt and Tom caution against shortsighted management decisions to decentralize compliance functions and highlight how AI can be harnessed to enhance rather than replace human oversight. They argue for proactive measures from compliance officers to demonstrate their value and leverage AI to improve compliance programs. As Matt eloquently puts it, this is a challenging yet opportune time for compliance professionals to up their game and secure their vital role in ensuring corporate integrity and efficiency. Key highlights: The Future of Compliance Post-Executive Order The Role of Technology in Compliance AI's Impact on Compliance Officers Strategic Imperatives for Compliance Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Hui Chen A Pause in FCPA Enforcement: Crisis or Opportunity Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group's podcast, All Things Investigation. In this podcast, host Tom Fox is joined by HHR partner Mike DeBernardis on the considerations of trying an FCPA case. Tom and Mike deeply dive into the complexities of preparing for and trying an FCPA case. It includes negotiating with corporate and individual clients involved in criminal cases. It is often easier to convince corporate clients to cooperate with government entities and engage in negotiation processes. Conversely, individual clients, driven by strong convictions of their innocence, can be resistant unless negotiation results in a non-prosecution decision. We highlight the challenging conversations defense counsels must have with individual clients regarding realistic outcomes, including discussing the strengths of the prosecution's case and potential plea deals. Establishing early discussions about acceptable outcomes and strategies is vital to navigating these difficult negotiations. Key highlights: Corporate vs. Individual Clients Challenges in Defense Counsel Discussing Plea Deals Importance of Early Negotiation Resources: Mike DeBernardis Hughes Hubbard & Reed Website
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional. Top stories include: Who is going to get your 23andMe data? (WSJ) Even Bloomberg says to enforce the FCPA. (Bloomberg) The House speaker says Congress can eliminate district courts. (Reuters) What is the fire risk for your business? (NYT) Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode of Great Women in Compliance, Hemma hosts Jennifer Lee, a partner at Jenner & Block LLP and former Assistant Director at the SEC. The discussion covers Jennifer's work in SEC investigations, the importance of integrity in legal practice, and key challenges faced by compliance professionals, including evolving cybersecurity obligations and the future of FCPA enforcement. Tune in today to hear Jennifer share her insights on maintaining ethical standards, managing client expectations during investigations, and the value of community and mentorship in the legal profession. Highlights include: - How to avoid the slippery slope to enforcement - Insights on values-based decision-making from Jennifer's reading list - What our clients need most from legal and compliance counsel - Perspectives from a former federal prosecutor at the SEC - What compliance officers should be thinking about today
The Foreign Corrupt Practices Act goes back decades. It prohibits U.S. companies from bribing officials of other countries for contracts. Even if corruption is the norm in that country. Now the Trump administration says it's not enforcing the FCPA. For what this means, we turn to an attorney who's an expert in this law, Cadwalader partner Martin Weinstein. Learn more about your ad choices. Visit podcastchoices.com/adchoicesSee Privacy Policy at https://art19.com/privacy and California Privacy Notice at https://art19.com/privacy#do-not-sell-my-info.
The Foreign Corrupt Practices Act goes back decades. It prohibits U.S. companies from bribing officials of other countries for contracts. Even if corruption is the norm in that country. Now the Trump administration says it's not enforcing the FCPA. For what this means, we turn to an attorney who's an expert in this law, Cadwalader partner Martin Weinstein. Learn more about your ad choices. Visit podcastchoices.com/adchoices
In this episode of Whistleblower of the Week, host Jane Turner speaks with Stephen M. Kohn, co-Founder and Board Chairman of National Whistleblower Center and leading whistleblower attorney. On February 10th, President Trump halted enforcement of the Foreign Corrupt Practices Act (“FCPA”) in an Executive Order, arguing the move would aid American business abroad. Listen to Kohn and Turner discuss how this decision will impact American business and whistleblowers reporting bribery, corruption, and collusion. On March 13th, Kohn published an article, “Crippling the FCPA is Bad Business for the U.S” in the NYU Compliance and Enforcement Blog. He highlights his recent research which illustrates how FCPA enforcement primarily targets foreign companies, with monetary sanctions against foreign companies far outpacing sanctions against U.S-based companies. National Whistleblower Center has launched a campaign to call for the resuming of FCPA enforcements. Take action today by contacting your Representatives and Senators. Listen to the podcast on WNN or on Spotify, Apple Podcasts, Google Podcasts, or Amazon. Subscribe on your favorite platform!
This episode features a discussion between regular KB host Liz David-Barrett, and Kevin E. Davis, the Beller Family Professor of Business Law at NYU School of Law. Their conversation centres on the international regulation of bribery and corruption, specifically focusing on the U.S. Foreign Corrupt Practices Act (FCPA), following President Trump's recent suspension of its enforcement. The episode explores the potential implications for U.S. companies, foreign entities, and international anti-corruption efforts. Read Kevin's recent blog post on this issue here: https://wp.nyu.edu/compliance_enforcement/2025/02/21/implications-of-pausing-fcpa-enforcement/ And his paper on international regulation here: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4506000
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss additional compliance issues raised by the current administration. The first involves the Trump Administration investigating environmental groups receiving EPA grants. While both believe the investigations are politically motivated, they highlight the need for a robust compliance program, documentation of that program in practice, and transparency with stakeholders. The second example is the Democratic Republic of Congo's offer to the Trump administration for mineral extraction rights, raising concerns about navigating FCPA compliance amid high corruption risks. The episode underscores the importance of robust compliance capabilities to handle unpredictable regulatory environments and emerging risks. Key highlights: Compliance Issues under the Trump Administration Environmental Groups Under Investigation The Democratic Republic of the Congo Deal Compliance is the Answer Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the award-winning FCPA Compliance Report, the longest-running compliance podcast. In this episode, Tom welcomes Eric Morehead to discuss the role and function of the U.S. Sentencing Commission. Eric is the Director of Advisory Services Solutions at LRN and former Assistant General Counsel at the U.S. Sentencing Commission. He and Tom review the intricacies of the U.S. Sentencing Commission's role, structure, and impact. Eric walks through his professional journey and explains the Sentencing Commission's function in standardizing federal criminal sentences and promoting organizational compliance programs. He emphasizes the importance of the Sentencing Guidelines, the process for their amendment, and the challenges faced by the Commission, such as quorum issues. The discussion also touches on current topics, including the potential impact of executive orders on DEI policies and the FCPA pause, stressing the continued relevance of the Sentencing Guidelines in compliance program development. Key highlights: Eric Morehead's Background and Role at the U.S. Sentencing Commission Understanding the U.S. Sentencing Commission Process of Creating and Amending Sentencing Guidelines Impact of Sentencing Guidelines on Compliance Programs Current Issues in Compliance: DEI and FCPA Enforcement Resources: Eric Morehead on LinkedIn LRN US Sentencing Guidelines for Organizations Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
The Foreign Corrupt Practices Act has been a mainstay of corporate culture for the last quarter-century, and has cost companies millions, sometimes even billions, of dollars in fines. And that's before you start counting the lawyers' fees. This law, used to prevent US businesses from engaging in bribery to win foreign business, has seen a major uptick in enforcement over the last 25 years. And, over that period, it has become a major revenue driver for elite law firms. Some say that the law keeps companies honest, and actually benefits corporations by providing them a shield for responding to requests for bribes. But last month President Donald Trump said the law “sounds good on paper but in practicality, it's a disaster.” Trump signed an executive order pausing the initiation of new investigations for 180 days and meanwhile ordering the AG to issue updated guidelines. On the latest episode of On The Merits, leading FCPA practitioner, Martin Weinstein, the chair of Cadwalader's compliance, investigations & enforcement practice, talks about the impacts of a law he calls the “greatest tariff in the US Code” and what it could mean for business if enforcement winds down. And Bloomberg Law reporter Roy Strom discusses the impact on large law firms, which have built premier practices focusing on this law. Do you have feedback on this episode of On The Merits? Give us a call and leave a voicemail at 703-341-3690.
In this episode of The Ethics Experts, Nick and Gio welcome Andrew McBride. Andrew McBride is the CEO of Integrity Bridge LLC, a consulting practice offering strategic & operational compliance support for companies. Andrew has over 25 years of compliance experience, at an international law firm and several multinational companies in the Americas, Europe and Australasia. In his most recent role as Chief Risk & Compliance Officer at Albemarle Corporation, he built a new ethics and compliance program, and recruited a new team, against the backdrop of an FCPA investigation. The investigation was resolved by way of a Non-Prosecution Agreement with the U.S. Department of Justice and Cease & Desist Order with the U.S. Securities and Exchange Commission. As part of the resolution, Albemarle secured a 45% reduction in penalty due to its co-operation with the investigation and the compliance program that was built, the largest FCPA % penalty reduction to date. In recognition of these efforts Albemarle was awarded Compliance Program of the Year by Compliance Week in May 2024. In parallel to the FCPA investigation and business ethics efforts, Andrew played a key role supporting Albemarle's commitment to sustainability including UN Global Compact membership, management of the company's human rights framework and support for the company's successful efforts to achieve certification against the Initiative of Responsible Mining Assurance (IRMA)'s Mining Standard. Prior to Albemarle, Andrew was Associate General Counsel Compliance at BHP, Senior Antitrust Counsel at BP and Managing Associate at Linklaters. Andrew is admitted to practice law in England, Western Australia & California. He is also a Certified Fraud Examiner.
Is your company prepared for the compliance storm ahead? With tariffs shaking global trade, aggressive sanctions enforcement, and new risks from AI, businesses must rethink their strategies. Can your compliance program keep up, or will it be left scrambling?In this episode of Corruption, Crime, and Compliance, Michael Volkov unpacks the rapidly shifting risk landscape facing businesses today. From trade compliance and supply chain disruptions to cybersecurity and government enforcement, he highlights the top legal and compliance challenges of the year and offers practical guidance on how companies can stay ahead. While the regulatory world is in flux, one thing remains certain—organizations that fail to adapt will face significant financial, legal, and reputational consequences.You'll hear him discuss:The evolving trade landscape, including tariff enforcement, import risks, and the potential economic fallout of aggressive trade policiesWhy supply chain mapping is no longer optional, with companies needing to identify vulnerabilities, alternative sourcing strategies, and compliance risks to avoid costly disruptionsHow businesses should approach the FCPA enforcement pause, what it signals about the government's priorities, and why global companies remain committed to anti-corruption programsWhy compliance teams must elevate import control and export control programs, particularly as the US expands restrictions on advanced computing, AI, and semiconductor exportsHow transnational criminal organizations are infiltrating legitimate supply chains for money laundering, and what companies must do to strengthen their due diligence effortsThe importance of a strong compliance culture in a time of regulatory uncertainty—how companies can remain flexible, proactive, and aligned with their core values despite the shifting landscapeResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
India's complex regulatory landscape presents significant challenges for businesses navigating anti-bribery enforcement, compliance frameworks, and evolving data privacy concerns. With shifts in global regulatory priorities — such as changes in US FCPA enforcement and the growing influence of the UK Bribery Act — companies must stay proactive in risk management. As technology, including AI and machine learning, reshapes investigations, organisations need robust compliance programmes to mitigate fraud, money laundering, and corruption risks in an evolving enforcement environment. Join host Brian Mich as he speaks with forensic expert Sushmit Bhattacharya about the intricacies of compliance and investigations in India. They discuss the impact of shifting global anti-corruption policies, the role of AI in forensic analysis, and how businesses can strengthen governance in the face of increasing regulatory scrutiny. From navigating FCPA and UK Bribery Act enforcement to handling emerging risks in data collection and privacy, this episode offers valuable insights for legal and compliance professionals operating in India. Find out more.
In today's episode, Lisa speaks with a Great Gentleman in Compliance, Andrew McBride, the CEO and founder of Integrity Bridge. Andrew shares his journey in the compliance field from private practice, to becoming Chief Compliance Officer at Albemarle, to starting Integrity Bridge. At Albemarle, Andrew built a new ethics and compliance program against the backdrop of an FCPA investigation. The work of Andrew and his team and their cooperation with the US Department of Justice, led to a decrease of 45% penalty reduction. The program was also awarded Compliance Week's “Program of the Year” award. He highlights the importance of having a multifunctional approach to building compliance programs, working closely with various departments such as sales, procurement, and finance. He also emphasizes how ethics and compliance teams are best positioned to succeed if they have different backgrounds and skill sets. Andrew shares his experience in building Integrity Bridge, a consultancy focused on helping companies design and implement holistic compliance programs to proactively use technology and address risks which are constantly evolving.
Are You Ready for the Next Wave of Corporate Risk? Corporate risks are shifting, and every board, C-suite, and compliance team must take a fresh look at their risk landscape. While some risks like cybersecurity, data privacy, and artificial intelligence remain high priorities, others—such as anti-corruption and antitrust enforcement—are evolving in unexpected ways. With regulatory changes and new enforcement priorities emerging, businesses must stay ahead of the curve to avoid costly missteps. In this episode of Corruption, Crime & Compliance, Michael Volkov unpacks the latest updates in FCPA enforcement, antitrust scrutiny, and trade compliance. With the DOJ shifting its focus, companies need to prepare for the new compliance reality.You'll Hear Him Discuss:Why companies must reassess their risk priorities in today's unpredictable business environment, as corporate risks continue to shift in response to new regulatory and enforcement trends.The impact of the FCPA enforcement pause, what it really means for global businesses, and why companies cannot afford to dismantle their anti-corruption programs despite the temporary halt in enforcement.How the DOJ is shifting its focus toward prosecuting criminal cartels and transnational organizations, and what that means for businesses operating in high-risk regions or industries.The evolving landscape of antitrust enforcement, including key takeaways from Gail Slater's confirmation hearing and how the administration's new approach may impact high-tech competition cases.How businesses should prepare for heightened tariffs, trade compliance risks, and increased customs enforcement, particularly as the U.S. targets imports from China, Southeast Asia, Mexico, and Canada.Why workplace immigration enforcement is becoming a bigger concern, with the government ramping up workplace raids, audits, and compliance checks for companies employing immigrant workers.The growing scrutiny around government grants, the potential for fraud investigations, and how businesses receiving federal funds must ensure strict compliance with evolving regulatory requirements.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection—they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network. Ronnie's company, Learnings and Entertainment, utilizes the entertainment devices people use to consume information in their everyday, non-work lives and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies, and resources more accessible. In this episode of Creativity and Compliance, Tom Fox and Ronnie Feldman take up the challenge handed down by Hui Chen in light of the administration's suspension of FCPA enforcement to up their compliance game. Ronnie begins by advocating for a transformation in compliance training, suggesting a shift from traditional e-learning methods to engaging communication campaigns emphasizing a Speak Up Culture and seamlessly integrating compliance into daily business operations. He believes that by using short, entertaining formats and training leaders to present content playfully, compliance can become more interesting and effective, positioning compliance professionals as valuable assets through proactive engagement and collaboration. Tom underscores the importance of compliance professionals being approachable and communicative, serving as problem solvers who collaborate with business units to achieve unexpected, beneficial outcomes. Both experts agree that by humanizing the compliance function and focusing on values and behaviors, compliance professionals can enhance their programs and contribute significantly to organizational success. Key highlights: Engaging Communication Campaigns for Compliance Training Strategic Communication for Compliance Professionals Cultivating Proactive Compliance Culture through Training Programs Strategic Engagement for Compliance Professionals Resources: Ronnie Ronnie Feldman (LinkedIn) Learnings & Entertainments (LinkedIn) Ronnie Feldman (Twitter) Learnings & Entertainments (Website) Compliance Confessions – inspired by “Mean Tweets” these 90-second commercials address misconceptions and excuses to promote speak up culture and the E&C team as positive and helpful. E&C Training Jams – a soulful singer banters with ethics & compliance explaining policies, sharing examples and debunking excuses. Tales from the Hotline – Real speak up-themed stories about workplace behavior gone wrong. Workplace Tonight Show! – E&C meets SNL Weekend Update explaining corporate risk topics and why employees should care. 60-Second Communication & Awareness Shorts – A variety of short, customizable, music and multimedia, quick-hitter “commercials” promoting integrity, compliance, speaking up and the E&C team as helpful advisors and coaches. Custom Live & Digital Programing – Custom creative programming that balances the seriousness of the subject matter with a more engaging delivery. After all, you can't bore people into learning. Tom Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here. Creativity and Compliance was recently honored as one of the Top 35 Podcasts on Creativity by Feedspot. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group's podcast, All Things Investigation. In this podcast, host Tom Fox is joined by HHR Partner Mike DeBernardis to discuss the recent executive order by the Trump administration to pause the enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days. They take a deep dive into the potential implications for compliance programs, the continuing relevance of the FCPA, and the broader legal and business effects of this temporary halt. The conversation also explores how companies might navigate this hiatus, consider the long-term implications, and maintain robust compliance standards despite the pause in enforcement. Highlights include Mike's insights on the intersection of compliance and business efficiency and the potential for non-US authorities to fill any enforcement void created by the U.S. Department of Justice's pause. Key highlights: Executive Order on FCPA Enforcement Implications for FCPA Compliance SEC and Business Implications Compliance Programs and Business Practices Future of FCPA Guidance Opportunities for Compliance Officers Resources: Hughes Hubbard & Reed website
What happens when an entire era of anti-corruption enforcement is put on pause? Is this a strategic move to bolster American businesses or a dangerous rollback of corporate accountability? In an unprecedented move, the Trump administration has hit the brakes on FCPA enforcement for at least 180 days, citing concerns over U.S. economic competitiveness and national security. In this episode of Corruption, Crime, and Compliance, Michael Volkov breaks down the implications of this game-changing executive order. The executive order claims that FCPA enforcement has been stretched beyond its original intent, harming American businesses while benefiting foreign competitors. With the Department of Justice now ordered to reassess its approach to anti-bribery enforcement, the business and legal communities are left wondering—what happens next? Will companies adjust their compliance strategies, or will global enforcement trends keep them in check?You'll hear him discuss:The Trump administration's rationale for halting FCPA enforcement and why the decision was both surprising and expectedThe executive order's directive to the Attorney General to reassess FCPA investigations and enforcement prioritiesThe shift in DOJ focus from corporate bribery cases to prosecuting cartels and transnational criminal organizationsThe potential impact on global anti-corruption efforts, as countries like the UK, France, and Brazil continue enforcing their own bribery lawsThe uncertainty surrounding DOJ's forthcoming guidance and what companies should anticipate in the next 180 daysThe broader implications for corporate compliance programs, risk assessments, and international business strategyThe historical context of past efforts to reform the FCPA and why similar arguments were made over a decade agoThe potential for companies to seek remedial measures for past FCPA enforcement actions and the challenges in implementing such a policyHow this shift in enforcement priorities may affect corporate ethics, internal investigations, and global compliance expectationsResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
The zealously anti-regulatory Trump is back and anti-corruption activist Frank Vogl is very worried. Vogl warns that MAGA's increasingly deregulated America financial landscape could make the 2008 crash look like a minor bump in the economic road. With Trump putting the Foreign Corrupt Practices Act on "pause" and DOGE kingpin Elon Musk openly dreaming of turning X into a bank, we're watching traditional financial regulation shrivel to the minimal levels of Calvin Coolidge's 1920's. Meanwhile, Melania is launching crypto tokens, Putin's kleptocracy has been legitimized by the Ukraine “peace” negotiations, and the increasingly unaccountable banks are begging to gamble with our money again. What could possibly go wrong? Here are the five KEEN ON takeaways from this conversation with Frank Vogl:* Financial Deregulation Concerns - Frank Vogl warns that Trump's administration is actively dismantling financial regulations, including pausing the Foreign Corrupt Practices Act and weakening the Consumer Financial Protection Bureau. He fears this deregulation could lead to a financial crisis potentially worse than 2008.* Three-Pronged Financial Risk - Vogl identifies three interconnected areas of concern:* Traditional banks seeking reduced capital requirements and fewer restrictions* Unregulated expansion of Silicon Valley firms (like X/Twitter) into banking* The growing crypto market and its potential for money laundering and speculation* Regulatory Enforcement Weakening - The Trump administration is systematically weakening regulatory agencies by appointing anti-regulation leaders and reducing staff (e.g., the Federal Deposit Insurance Corporation lost 500 staff). This reduction in oversight capacity could enable financial abuse and fraud.* International Corruption Implications - The suspension of the Foreign Corrupt Practices Act and potential lifting of Russian sanctions could create a vacuum in global anti-corruption enforcement, as no other country (including the UK or Switzerland) is positioned to take over America's leadership role in fighting international financial crime.* Big Tech and Government Contracts - There's growing concern about the relationship between the Trump administration and tech leaders, not just for potential government contracts but also for their control of media platforms. Vogl argues this could be problematic for democracy if proper procurement and transparency processes aren't followed.FULL TRANSCRIPT: Frank Vogl Warns of a New Financial Crisis Under Trump 2.0Interview with Frank Vogl February 16, 2025Two months into Donald Trump's second presidency, financial corruption expert Frank Vogl returns to Keen On to discuss the dismantling of America's financial regulatory system and its potential consequences. Vogl, co-founder of Transparency International and author of "The Enablers: How the West Supports Kleptocrats and Corruption, Endangering Our Democracy," warns of parallels to both the 1920s and 2008 financial crisis, but with new digital-age complications.Andrew Keen: Hello, everybody. It is Sunday, February 16th, 2025. A couple of years ago, we did a show with my old friend Frank Vogl on the global fight against corruption. He is the author of "The Enablers: How the West Supports Kleptocrats and Corruption, Endangering Our Democracy" and co-founder of Transparency International, a nonprofit focused on exposing financial corruption. Last year, we had Frank back to discuss whether Donald Trump 2.0 would be what we called a semi-legal repeat of the Sam Bankman-Fried FTX debacle. Now, almost two months into the Trump regime, I'd like to revisit this question. Frank, you have an interesting new piece out in The Globalist about Trump-style U.S. financial deregulation and its global ramifications. Is it as bad as we feared?Frank Vogl: Yes, it's good to be with you, Andrew. We are in danger of developments that could lead to a financial crisis in a few years' time, potentially worse than the 2008 financial crisis. That crisis led to massive unemployment and economic hardship, not just in the U.S. but across the world. It was caused by wild speculation, greed, and mismanagement by fewer than two dozen financial institutions, many of which were bailed out. Now, thanks to what Trump and Elon Musk are doing, we're setting the stage for a new era of financial deregulation with all the risks that involves.Andrew Keen: It's chilling. Frank, I wonder about the historical parallels. Some people have made much of Trump's interest in McKinley's presidency, colonialism, and Latin America. But I wonder whether we're really returning to the 1920s and the unconstrained speculative capitalism of the Coolidge, Harding, and Hoover era. Are there historical analogies here? The teapot scandal and unregulated capitalism of the '20s resulted in the great crash.Frank Vogl: Yes, that's true. But we should remember it led to a new era of regulation - the establishment of the Securities and Exchange Commission and other regulatory bodies focused on ensuring financial institutions didn't have excessive power. What we're facing now is not only the prospect of excessive power by financial institutions but a much more complicated array of financial institutions. Take Elon Musk, who unquestionably wants to enter the financial arena by operating his own quasi-bank.Andrew Keen: He's always been clear about that - he's said X will ultimately be a bank among other things.Frank Vogl: What we're seeing now is not only the possibility of bank deregulation, but also the emergence of a whole new unregulated system of finance from Silicon Valley. Add to that the complete mayhem of gambling, greed, corruption, and money laundering associated with crypto tokens. Put all of that together and you have a dangerous situation that could affect the global economy.Andrew Keen: Some might say you're overreacting. A Silicon Valley entrepreneur friend who was on the show yesterday argued that the Biden administration, particularly figures like Lina Khan, was stifling innovation. They'd say Trump's people are just letting innovators innovate, with Musk as a prime example. How would you respond to that?Frank Vogl: I disagree when it comes to finance. Let me explain. Our government essentially has two components: the administrative state, where government departments monitor and implement programs and projects, and the regulatory state, where agencies protect American citizens in health, consumer safety, and finance. First and foremost, we need a safe and sound financial system. Everyone benefits from that. We have a healthy financial system right now - just look at the stock market. It could be improved, but let's not demolish it. The profits of the biggest banks in 2024 were at record levels. Jamie Dimon, head of JP Morgan Chase, took home a record $39 million in compensation. The head of Goldman Sachs got an $80 million bonus.Andrew Keen: Which in Silicon Valley terms isn't that much money, certainly compared to the Musks and others of this world.Frank Vogl: My point is that banks are the bedrock of our financial system. The people at the top are being compensated better than ever before. So what are they campaigning for? What are they supporting Trump on? They're arguing for the kind of deregulation that Paul Volcker, the former Federal Reserve Board president, warned would be dangerous.Andrew Keen: My understanding of the 2008 crash was that banks took advantage of vulnerable consumers and lent them money they shouldn't have borrowed, creating the subprime mortgage crisis that crashed the economy. What do bankers want to do in 2025 that, in your view, they shouldn't be allowed to do?Frank Vogl: You're right about what happened, but also many financial institutions borrowed enormous sums. They leveraged their basic resources to speculate on complicated derivative financial instruments. They were essentially gambling. As Chuck Prince, who ran Citigroup, said, "We have to keep dancing as long as the music is playing."Andrew Keen: Capitalism is about dancing, Frank. It's about taking risk, isn't it?Frank Vogl: To some degree, but when you have an institution like JPMorgan Chase with over $4 trillion in assets, you have to think hard about its mission. That mission fundamentally is to serve customers, not just the top executives. Let them get rich at the top, but let them be prudent and maintain integrity. Trump and Musk have no time for that. Let me give you one example: Trump recently announced we're no longer going to investigate international and corporate corruption. He put the Foreign Corrupt Practices Act on pause.Andrew Keen: Yes, that was February 10th. Quoting from whitehouse.gov: "Pausing Foreign Corrupt Practices Act enforcement to further American economic and national security," whatever that means.Frank Vogl: The act was signed by Jimmy Carter in 1977. The largest single fines ever paid for foreign bribery were by Goldman Sachs - nearly $4 billion globally, with $1.6 billion to the U.S. alone. Now we're ending investigations of exactly the kind of activity that made Goldman Sachs very profitable. We're ending all manner of fraud investigation in finance. Take another example: last week, the Consumer Financial Protection Bureau was essentially shuttered. A judge ruled it should continue, but Trump's appointees ensure it has minimal resources to investigate. The CFPB investigates banks that commit fraud against regular customers. Remember what Wells Fargo did? The CFPB caught them, and they paid major fines.Andrew Keen: How does all this add up to a financial crisis? The CFPB situation is troubling, but why should this cause the whole system to collapse?Frank Vogl: Let's look at this in three components: banks, digital finance, and crypto. Starting with banks - they're lobbying hard for reduced capital requirements, meaning less money in reserve for crises. They want fewer regulations on how they use their money so they can speculate on their own account. Why? Because banks' short-term profits determine the bankers' compensation. Their bonuses are tied to those profits.Andrew Keen: So if banks are allowed to gamble aggressively, that's great if they win, but if they lose, we all lose. Is that the argument? Then we have to bail them out again?Frank Vogl: That's part of it. The other concern is that as some banks lose, they may get merged into other banks until you have just a handful of enormous banks that can never fail. If they were to fail, our economy would fail. The moral hazard is that banks know when they take huge risks, they'll be bailed out. Now add to this all these quasi-banking systems from Silicon Valley - PayPal, Venmo, Apple Pay. And X recently announced a deal with Visa on payment systems, just the first step to creating X Financial.Andrew Keen: You're sounding a bit reactionary, maybe alarmist. What's wrong with PayPal? It's simply a digital system for people to buy stuff.Frank Vogl: You're right, it's fine the way it is today. But what if these entities are allowed to take deposits and make loans, doing everything banks do, all online? Who's regulating that? Where's the safety?Andrew Keen: But where's the evidence that the Trump administration will allow PayPal or X or Apple Pay to become banks without traditional regulations? From a traditional banking perspective, I'd assume Jamie Dimon and his peers would fight this because it undermines them.Frank Vogl: We're seeing an administration tearing the system apart. Look at each regulatory agency - Trump has put people in charge with long histories of opposing regulation. The Federal Deposit Insurance Corporation just lost 500 staff through "voluntary resignations." When you reduce regulatory enforcement and investigation, you open the door to abuse. History shows that when there's opportunity for abuse, abuse happens. I hope your optimism about Silicon Valley's ability to manage complicated finance is justified, but I'm skeptical.Andrew Keen: So you're saying Apple or X or PayPal shouldn't be able to be banks, even with traditional banking regulations?Frank Vogl: No, that would be fine. But who's going to regulate it? Do you see Trump proposing to Congress that a brand new regulatory agency be established for this kind of finance? That's not how the Trump team thinks. Just look at crypto.Andrew Keen: Yes, let's look at crypto. Melania Trump launched her own cryptocurrency - it's an enormous speculative bubble, like the tulip speculation. Last week, both Donald and Melania Trump's crypto tokens plummeted. Someone's profiting, someone's losing. How important is this to the broader economy? Is it just another sideshow, another way for the Trump family to get rich while we lose?Frank Vogl: It's contained at the moment. The whole crypto token business is perhaps $3-4 trillion in size - very small in terms of global finance. But I worry about an administration with strong conflicts of interest developing this kind of rapid gambling speculation. Most people invested in crypto are young, between 18 and 35. Many don't have experience with past financial crises.Andrew Keen: And there's a clear difference between using PayPal to buy something online and investing in crypto. One is entirely speculative, one is just a financial transaction.Frank Vogl: Do you really think Elon Musk's X Financial will be satisfied just being a rival to PayPal's payment system? Or does he have bigger ambitions to turn X Financial into something much more like a bank?Andrew Keen: I think he does, but...Frank Vogl: And then comes the question: who is going to regulate this?Andrew Keen: Musk himself? That's a joke. Although at the moment, there's no concrete evidence. X is still struggling for survival as just a social media platform.Frank Vogl: Look, I may sound pessimistic, but I'm only talking about the potential. There's very little public attention on what's happening with financial deregulation, as I wrote in The Globalist. The impact could be substantial. When you have this complete dismantling of the FCPA, other fraud investigations, the removal of inspectors general - the whole dismantling of the government's apparatus for accountability and transparency - then you have to worry about mounting financial risk in our system.Andrew Keen: Let's return to crypto. When does crypto become dangerous? If it becomes a rival to the dollar? At what point do we start worrying that a crypto crisis could become a broader financial crisis?Frank Vogl: I don't worry about that actually. I worry about the conflicts of interest - Trump and his children and cronies all making money from deregulating crypto. I think crypto will remain a sideshow for a long time. But I'm considerably worried about money laundering. With a Justice Department that's stopped investigating financial crimes, and a cryptocurrency system free of regulation - something Trump has promised - organized crime and kleptocrats worldwide will be able to hide their ill-gotten gains and transfer them between countries. That's worrying in itself, even if it doesn't cause a global financial meltdown.Andrew Keen: I wonder if there's another dimension to Trump's upcoming meeting with Putin in Saudi Arabia to discuss Ukraine. There's what one author called "KGB-style capitalism" - the mass laundering of illegal wealth. How much does Trump's eagerness to bring Putin back into the international system have financial ramifications?Frank Vogl: Putin and the oligarchs, Lukashenko in Belarus and his cronies, the former oligarchs of Ukraine who made their money with Russia - all these people have been sanctioned since the war started in February 2022. We're approaching the third anniversary. Putin really wants those sanctions lifted to restore global money laundering and financial crime opportunities. This might be leverage in a deal.Andrew Keen: Can Trump get away with that politically in D.C.? If he pulls the sanctions card to establish what he'd call a Ukrainian peace - really a peace imposed by America on Ukraine - will mainstream Republicans accept that?Frank Vogl: They seem to accept everything today. Trump seems to get away with an awful lot. But I'd like to return to something earlier - there needs to be more public attention on the dismantling of the Consumer Financial Protection Bureau. To use a new word in the vocabulary, it has been "Musked." The CFPB, like USA Today, has been Musked. Musk and Trump have weaponized their authority to dismantle these institutions. We'll see it at the SEC and the Commodity Futures Trading Commission. When you weaponize authority, you monetize power. This is where the conflict of interest comes in. Unfortunately, Congress isn't alert to these developments.Andrew Keen: In a broader international sense, I've always understood that American law is more aggressive than the UK's. Oliver Pollock, who's been on the show, wrote "Butler to the World" about the corrupt British system that invites dirty money from overseas, particularly Russia. Given that Trump is demanding half of Ukraine's mineral resources, could this Trump revolution undermine America's role in standing up to dirty money, both domestically and overseas?Frank Vogl: It might undermine it, but there's no authority anywhere to replace it. The U.S. Justice Department did a fantastic job investigating cryptocurrencies, crypto finance, and bribery of foreign government officials - not just by U.S. companies but by many companies worldwide with U.S. listings, like Airbus Industries. There's no authority in Europe willing to take on that task. So we leave a vacuum. And who fills the vacuum? Kleptocrats, organized crime, and corrupt businesses. A Nigerian paper recently headlined that Nigerian politicians are now open to American bribes. We're being seen as permitting corruption - a terrible reputation. The Swiss or British won't suddenly become super-active in filling the roles the U.S. Justice Department has played.Andrew Keen: As The Guardian headlined today, "Elon Musk's mass government cuts could make private companies millions." We all know the famous photo from the inauguration with Zuckerberg, Bezos, Google's CEO, and Musk. Some might say, what's wrong with that? These companies are the engine of the American economy. Why shouldn't the Trump administration focus on making big American companies more profitable? Won't that make Americans wealthier too?Frank Vogl: There are two answers. First, I agree - if standard public procurement, accountability, and transparency procedures are in place, then companies winning competitive bidding should win. If these happen to be the companies you mentioned, good for them. But if contracts are given without proper bidding processes and transparency, the public loses. Second, Trump didn't embrace these people primarily for their business power - they control media. Autocrats worldwide, from Orbán to Netanyahu, ensure they have media-controlling business tycoons on their side. Trump is incredibly sensitive to publicity and has attracted these powerful media tycoons. I worry about how this media power will be used to undermine democracy and freedom of speech.Andrew Keen: What's the headline for today? Last time, we discussed whether Trump 2.0 would be a semi-legal repeat of the Sam Bankman-Fried debacle. What's the worst that can happen in this new regime?Frank Vogl: Actions are being taken, sometimes inadvertently, that undermine the safety and soundness of our financial system. If that happens, everyone - not just here at home but internationally - will suffer.Andrew Keen: So we'll get 2008 again, or 1930?Frank Vogl: I hope we get neither. But we must be acutely aware of the risks and call out all deregulatory measures if we believe they risk our system, especially when prompted by corruption and greed rather than public interest.Andrew Keen: Well, Frank Vogl, I hope you're wrong, but I suspect you may be right. This won't be the last time you appear on the show. There will be many twists and turns in the financial history of the Trump regime. Thank you so much, Frank. Keep watching in D.C. - we need eyes and ears like yours to make sense of what's happening.Frank Vogl: Andrew, it was once again a great pleasure. Thank you.Frank Vogl is the co-founder of two leading international non-governmental organizations fighting corruption -- Transparency International and the Partnership for Transparency Fund (Frank is the Chair of the PTF Board). He teaches at Georgetown University, writes regular "blog" articles on corruption for theGlobalist.com and lectures extensively. Frank is also a specialist in international economics and finance with more than 50 years of experience in these fields - first as an international journalist, then as the Director of Information & Public Affairs at the World Bank official and, from 1990 to 2017, as the president and CEO of a consulting firm, Vogl Communications Inc.Keen On is a reader-supported publication. To receive new posts and support my work, consider becoming a free or paid subscriber.Named as one of the "100 most connected men" by GQ magazine, Andrew Keen is amongst the world's best known broadcasters and commentators. In addition to presenting the daily KEEN ON show, he is the host of the long-running How To Fix Democracy interview series. He is also the author of four prescient books about digital technology: CULT OF THE AMATEUR, DIGITAL VERTIGO, THE INTERNET IS NOT THE ANSWER and HOW TO FIX THE FUTURE. Andrew lives in San Francisco, is married to Cassandra Knight, Google's VP of Litigation & Discovery, and has two grown children.Keen On is a reader-supported publication. To receive new posts and support my work, consider becoming a free or paid subscriber. This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit keenon.substack.com/subscribe
This week: Trump has signed an order suspending the enforcement of the Foreign Corrupt Practices Act. Felix Salmon, Emily Peck, and Elizabeth Spiers speculate on his motives and on how likely it actually is that this will shield anyone from the FCPA. Then, Elon Musk has taken $80 million that was sent to New York City by FEMA directly out of the city's account. The hosts discuss the legality and worrisome precedent of the move. Finally, inflation is still a thing. They go over the latest inflation report which of course leads to another Egg Watch 2025. In the Slate Plus episode: Japanese 7Elevens Want to hear that discussion and hear more Slate Money? Join Slate Plus to unlock weekly bonus episodes. Plus, you'll access ad-free listening across all your favorite Slate podcasts. You can subscribe directly from the Slate Money show page on Apple Podcasts and Spotify. Or, visit slate.com/moneyplus to get access wherever you listen. Podcast production by Jessamine Molli. Learn more about your ad choices. Visit megaphone.fm/adchoices
This week: Trump has signed an order suspending the enforcement of the Foreign Corrupt Practices Act. Felix Salmon, Emily Peck, and Elizabeth Spiers speculate on his motives and on how likely it actually is that this will shield anyone from the FCPA. Then, Elon Musk has taken $80 million that was sent to New York City by FEMA directly out of the city's account. The hosts discuss the legality and worrisome precedent of the move. Finally, inflation is still a thing. They go over the latest inflation report which of course leads to another Egg Watch 2025. In the Slate Plus episode: Japanese 7Elevens Want to hear that discussion and hear more Slate Money? Join Slate Plus to unlock weekly bonus episodes. Plus, you'll access ad-free listening across all your favorite Slate podcasts. You can subscribe directly from the Slate Money show page on Apple Podcasts and Spotify. Or, visit slate.com/moneyplus to get access wherever you listen. Podcast production by Jessamine Molli. Learn more about your ad choices. Visit megaphone.fm/adchoices
This week: Trump has signed an order suspending the enforcement of the Foreign Corrupt Practices Act. Felix Salmon, Emily Peck, and Elizabeth Spiers speculate on his motives and on how likely it actually is that this will shield anyone from the FCPA. Then, Elon Musk has taken $80 million that was sent to New York City by FEMA directly out of the city's account. The hosts discuss the legality and worrisome precedent of the move. Finally, inflation is still a thing. They go over the latest inflation report which of course leads to another Egg Watch 2025. In the Slate Plus episode: Japanese 7Elevens Want to hear that discussion and hear more Slate Money? Join Slate Plus to unlock weekly bonus episodes. Plus, you'll access ad-free listening across all your favorite Slate podcasts. You can subscribe directly from the Slate Money show page on Apple Podcasts and Spotify. Or, visit slate.com/moneyplus to get access wherever you listen. Podcast production by Jessamine Molli. Learn more about your ad choices. Visit megaphone.fm/adchoices
This week: Trump has signed an order suspending the enforcement of the Foreign Corrupt Practices Act. Felix Salmon, Emily Peck, and Elizabeth Spiers speculate on his motives and on how likely it actually is that this will shield anyone from the FCPA. Then, Elon Musk has taken $80 million that was sent to New York City by FEMA directly out of the city's account. The hosts discuss the legality and worrisome precedent of the move. Finally, inflation is still a thing. They go over the latest inflation report which of course leads to another Egg Watch 2025. In the Slate Plus episode: Japanese 7Elevens Want to hear that discussion and hear more Slate Money? Join Slate Plus to unlock weekly bonus episodes. Plus, you'll access ad-free listening across all your favorite Slate podcasts. You can subscribe directly from the Slate Money show page on Apple Podcasts and Spotify. Or, visit slate.com/moneyplus to get access wherever you listen. Podcast production by Jessamine Molli. Learn more about your ad choices. Visit megaphone.fm/adchoices
John Maytham is joined by Karam Singh, Executive Director at Corruption Watch, to analyze Donald Trump’s executive order halting FCPA prosecutions. Singh expressed concern that this move could weaken global anti-corruption efforts, as the FCPA has long been a cornerstone of corporate accountability. See omnystudio.com/listener for privacy information.
This podcast is based on TRACE's recent Year in Review webinar with Kate Atkinson. Kate is a Member and the Chair of Miller & Chevalier, based in their DC office, and she reviews for us the FCPA highlights for 2024.
Friday February 15, 2025 Trump Pauses FCPA Enforcement
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the Trump Administration's attempts to end enforcement by the CFPB and corruption under the FCPA. Last week, significant alterations were made to enforcement policies related to the Foreign Corrupt Practices Act (FCPA) and the Consumer Financial Protection Bureau (CFPB), resulting in a noticeable reduction in enforcement efforts and a shift in focus towards issues like corporate bribery associated with drug cartels and human trafficking. These actions will create risks for U.S. businessmen in countries like China, who might face false charges due to the de-emphasis on traditional FCPA enforcement, and these policy shifts might expose U.S. companies to anti-corruption investigations leveraged by other countries in retaliation to Trump's trade policies. Matt Kelly emphasizes the need for businesses to maintain robust compliance programs despite the enforcement rollback, warning that legal risks remain due to the statute of limitations, and stresses the importance of upholding corporate compliance and ethical standards to prevent corruption. Through their extensive experiences in compliance and corporate governance, both Tom and Matt highlight the complexities and potential repercussions of these enforcement changes on global business operations. Key highlights: Introduction: Unpacking the Current Situation Emphasis on Corporate Bribery in Enforcement Changes Upholding Compliance Duties Amid Enforcement Changes FCPA and CFPB Statute of Limitations Global Business Impact of Trump's Trade Policies Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional. Top stories include: Trump orders pause in FCPA enforcement. (WSJ) What is illegal DEI? (NYT) AI washing for lawyers. (Reuters) US companies whine about EU and ESG rules. (Bloomberg) For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Check out the FCPA Survival Guide on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional. Top stories include: New AG signals FCPA retreat. (Radical Compliance) With apologies to Madonna, it's a transactional world. (FT) Shein, forced labor, and the EU DSA. (TechCrunch) Is the Rooney Rule still legal? (Bloomberg) For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Check out The FCPA Survival Guide on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News—all from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional. Top stories include: Did the Chinese steal IP from ChatGPT? (WSJ) Trump Administration complains that agencies are following its mandates. (The Atlantic) Joe Wilson wants more FCPA and FEPA enforcement. (Newsweek) Serbian PM resigns amid corruption probe. (ABC) For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Check out The FCPA Survival Guide on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Can the DOJ's commitment to holding individuals and corporations accountable under the FCPA survive the changing political climate in 2025? Will the push for innovation in corporate compliance programs be enough to maintain momentum, especially with emerging technologies like artificial intelligence? In this episode of Corruption, Crime and Compliance, Michael Volkov dives deep into the FCPA enforcement landscape of 2024, outlining key cases, changes in DOJ policies, and the evolving role of compliance programs. He highlights the significant rise in penalties and individual criminal prosecutions, as well as the continuation of major corporate settlements such as Raytheon, Trafigura, Gunvor, and SAP. The episode also explores DOJ's new whistleblower program and its continued push for companies to enhance their compliance frameworks.You'll hear him discuss:Key FCPA enforcement matters in 2024 including the Raytheon, Trafigura, Gunvor, and SAP cases.The shift in DOJ's approach, where individual prosecutions now play a larger role than ever before.The rise in penalties: 2024 saw a significant jump, with a total of $1.7 billion in fines.The return of travel, hospitality, and gifts as common bribery techniques, despite increased focus on compliance.DOJ's major industry sweeps, particularly targeting the energy commodity trading industry.The emergence of new compliance challenges with a focus on artificial intelligence and emerging technologies in corporate settings.The controversial SAP settlement and the DOJ's approach to a lack of voluntary disclosure.The impact of mergers and acquisitions on compliance processes and the integration of acquired companies.DOJ's new whistleblower program designed to incentivize individuals to report misconduct.How companies should approach merger and acquisition integration to ensure compliance and prevent risks.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
In this week's episode, Hemma visits Catherine Razzano, a veteran legal and compliance expert and Head of Global Legal Compliance at social media giant TikTok. Learn about Catherine's transition from private practice to in-house compliance work as she shares her journey from a prestigious clerkship and partnership track in Big Law with an FCPA and white-collar practice to leading in-house compliance teams at General Dynamics, Panasonic, and TikTok. Hemma asked Catherine about the challenges and benefits of working under a monitorship, with Catherine emphasizing the importance of relationship building and trust. Catherine also shared her experiences leading teams under scrutiny and pressure, including during the pandemic and at TikTok. Catherine discusses the source of her firm commitment to mentoring and sponsoring the next generation of ethics and compliance leaders. Tune in to hear inspiring insights on the importance of intentionality and finding your passion when navigating transitions as we enter the second quarter of the century in 2025. Highlights include: Managing compliance teams under scrutiny and pressure Culture-building in global organizations Navigating different industries as a compliance professional Following your passion for career growth and transitions The importance of mentoring and sponsorship Biography: Catherine Razzano is the Head of Legal Compliance at TikTok, the social media giant where she leads a global team of compliance professionals. She joined TikTok from Panasonic Avionics Corp., where she was hired in 2018 to help the company strengthen its compliance systems while under independent oversight following an investigation into violations of U.S. antibribery law. Before Panasonic, Catherine was an Associate General Counsel and Director of International Law & Compliance at General Dynamics after leaving her white-collar criminal practice at prestigious law firms, Cadwalader Wickersham and Taft and Clifford Chance, LLP, and serving as Judicial Law Clerk to the Honorable John M. Facciola in the United States District Court for the District of Columbia Thanks, as always, to our sponsor, Corporate Compliance Insights, and our wonderful #GWIC community. You can join the Great Women in Compliance community on LinkedIn here.
How did a high-stakes bribery scheme involving insider deals, Airbus planes, and secret payments bring down a global aviation giant? In this episode, Michael Volkov dives deep into the AAR Corporation FCPA case—a cautionary tale of bribery, insider deals, and compliance failures in high-risk sectors. The DOJ and the Securities and Exchange Commission (SEC) closed 2024 with a major coordinated settlement with AAR Corporation, a provider of aviation products and services. The case involved criminal and civil FCPA charges related to bribery schemes in Nepal and South Africa. Deepak Sharma, the CEO of an AAR subsidiary, orchestrated the schemes, securing insider information and paying bribes to government officials to win lucrative contracts. Despite AAR's late self-reporting, the DOJ credited the company for its cooperation and remediation efforts. The case highlights ongoing corruption risks in the aviation industry, especially where state-owned enterprises and third-party agents are involved.You'll hear him discuss:The details of the Illinois-based provider of aviation products AAR Corporation FCPA settlement with the DOJ and SEC.How Deepak Sharma orchestrated bribery schemes in Nepal and South Africa.The separate civil resolution with Deepak Sharma under which Sharma agreed to pay a disgorgement of $130,835 plus prejudgment interest of $53,762.The role of third-party agents in facilitating corrupt practices.Julian Aires, a former third-party agent of AAR, pleaded guilty in the District of Columbia on July 15, 2024 to a conspiracy to violate the FCPA for his role in the South Africa scheme.Why insider information from government officials is a "kiss of death" in compliance.How bribes were disguised through sham invoices and shell companies.The importance of robust compliance programs in high-risk industries like aviation.Red flags to watch for in industries dealing with state-owned enterprises.How the DOJ and SEC weigh cooperation and remediation in enforcement actions.Key takeaways for compliance professionals from the AAR case.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
Welcome to the award-winning FCPA Compliance Report, the longest-running compliance podcast. In this episode, Tom welcomes back Brent Carlson and Mike Huneke to discuss a crucial topic in corporate compliance: the return on investment (ROI) in export controls compliance. This pod reviews the challenges compliance professionals face in articulating the value proposition for investments in compliance programs. Brent and Mike highlight the misconceptions about compliance being merely a cost center and explore various ways to demonstrate its tangible benefits to executive teams and boards. The discussion also covers the impact of recent regulatory changes and geopolitical tensions and how companies can proactively address these shifts to ensure robust compliance and leverage new opportunities. By looking at past enforcement actions and drawing parallels with the evolution of the FCPA, the episode provides listeners with critical insights into the practical steps for enhancing compliance programs and the importance of staying ahead of regulatory expectations in a rapidly changing global trade environment. Key highlights: Setting the Stage for Compliance ROI Challenges in Export Controls Compliance Geopolitical Influences on Export Controls Comparing Export Controls to FCPA National Security and Economic Security Solutions and Strategies for Compliance Resources: Hughes Hubbard & Reed website Brent Carlson on Linkedin Mike Huneke on LinkedIn A Fresh Look at US Export Controls and Sanctions Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
What went wrong when McKinsey paid bribes to secure consulting contracts with South Africa's state-owned enterprises? In this episode, Michael Volkov dives into the December 2024 DOJ settlement with McKinsey & Company, which paid $122 million after being found guilty of paying bribes to officials at Transnet and Eskom to secure valuable consulting contracts. The case involved significant violations of the Foreign Corrupt Practices Act (FCPA) and highlights the risks companies face when failing to implement effective compliance programs.You'll hear him discuss:The details of McKinsey's settlement with the DOJ for $122 million, including the 35% discount and the cooperation credits granted by the government.The role of Vikas Sagar, McKinsey's former senior partner, and his guilty plea in 2022 for orchestrating bribery payments.How McKinsey Africa used sensitive, non-public information obtained through bribes to secure multi-million dollar contracts with Transnet and Eskom.The ongoing issue of engaging third-party intermediaries and the importance of conducting thorough due diligence before entering into business relationships.The lessons learned from McKinsey's lack of proper oversight and controls that allowed a small group of corrupt executives to facilitate bribery schemes.The broader impact of local content requirements in international business and the associated risks of partnering with unqualified entities that have ties to corrupt government officials.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
Thursday December 26, 2024 Global Aerospace Company to Pay $30 Million to Settle FCPA Charges
Morrison Foerster partners Kate Driscoll and Nate Mendell, both former federal prosecutors and members of the firm's Investigations + White Collar Defense Group, hosted the seventh episode of When Your Life Sciences Are on the Line, where leading practitioners and thought leaders share the insights and advice needed to manage business and legal risk in the life sciences sector. In this episode, Kate and Nate spoke with Chen Zhu, a partner in Morrison Foerster's Investigations + White Collar Defense and FCPA + Global Anti-Corruption Groups, and James Koukios, co-head of Morrison Foerster's FCPA + Global Anti-Corruption Group and former senior deputy chief of the Fraud Section at the U.S. Department of Justice (DOJ). Together, they discussed anti-corruption and Foreign Corrupt Practices Act (FCPA) considerations and enforcement concerns for life sciences companies, especially those operating in both the U.S. and China.
What happens when a Chief Executive Officer becomes the architect of a global bribery scheme? In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case — a landmark matter that underscores the severe consequences of C-suite misconduct. With CEO Zhengmin Pan at the center of the conspiracy, BIT Mining's efforts to infiltrate Japan's emerging casino market were built on fraudulent payments, sham contracts, and falsified financial records.Michael examines the tactics used to conceal illicit payments, the role of Japanese authorities in uncovering the misconduct, and the broader implications for corporate compliance and executive accountability.You'll hear him discuss:How BIT Mining's former CEO, Zhengming Pan, supervised a $2 million bribery scheme targeting Japanese government officials to secure entry into Japan's integrated resort (IR) market.The specific tactics used to launder bribe payments, including the use of sham consulting agreements, inflated lecture fees, and misclassification of bribes as "management advisory fees" and "travel expenses" in company records.The DOJ's charges against Pan, which included conspiracy to violate the anti-bribery and books-and-records provisions of the FCPA, as well as multiple counts of books-and-records violations and substantive anti-bribery offenses.The terms of Bit Mining's three-year Deferred Prosecution Agreement (DPA) with the DOJ, which included an agreed-upon $10 million criminal penalty, reduced from an initial $54 million based on the company's inability to pay.The SEC's parallel enforcement action, which resulted in a $4 million civil penalty, later credited against the DOJ's settlement amount.How Japanese enforcement authorities played a crucial role in uncovering the scheme and what ultimately led to Bit Mining's failure to win the integrated resort bid.Practical compliance takeaways for corporate boards and executive teams, including the importance of strong third-party due diligence, financial control safeguards, and executive oversight to prevent and detect misconduct at the top.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
What does it take for a global telecom giant to get caught up in a bribery scheme involving over $85 million—and what can we learn from their mistakes? How do companies like Telefónica Venezolana manage to conceal millions in bribes through inflated contracts and shell companies, and why do these schemes so often fly under the radar?This episode dives into Telefónica Venezolana's $85.2 million settlement with the DOJ for bribery violations under the FCPA. Michael Volkov unpacks how the Venezuelan subsidiary exploited a government-controlled currency auction system, paid nearly $29 million in bribes, and concealed it through inflated equipment purchases. The case reveals systemic flaws and offers essential lessons on preventing corporate misconduct.You'll hear him discuss:How Telefónica Venezuela used inflated supplier contracts to fund $28.9 million in bribesThe role of shell companies and intermediaries in concealing bribery schemesHow bribery enabled access to $110 million in undervalued U.S. currencyDOJ's assessment of cooperation, compliance efforts, and penalty reductionsTelefónica's failure to address red flags in its financial controls and due diligence processesThe importance of vetting third parties and managing high-risk transactionsHow Telefónica implemented compliance reforms, including anti-corruption measures and internal auditsLessons for compliance professionals on detecting and preventing similar schemesResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group
In this episode with Vancouver Mayor Ken Sim, we discuss: Will Vancouver become a Bitcoin city and adopt a strategic reserve? Ken's Bitcoin journey involving Jeff Booth Home affordability for young people Will Canada be pro-Bitcoin? Why everyone should take Bitcoin seriously ---- Bio: Ken Sim has been Vancouver's mayor since 2022. He is an accomplished entrepreneur and the co-founder of two successful companies: Rosemary Rocksalt and Nurse Next Door. Ken holds an FCPA designation, and is a two-time recipient of the Ernst and Young Entrepreneur of the Year Award (Pacific Region) in the Emerging Entrepreneur category (2006) and Healthcare Services category (2016). Follow Ken on X https://x.com/KenSimCity ---- Coin Stories is powered by Bitdeer Technologies Group (NASDAQ: BTDR), a publicly-traded leader in Bitcoin mining that stands alone as the only vertically-integrated, technology-focused Bitcoin mining company. Learn more at www.bitdeer.com. ---- Natalie's Promotional Links: Secure your Bitcoin with collaborative custody and set up your inheritance plan with Casa: https://www.casa.io/natalie For easy, low-cost, instant Bitcoin payments, I use Speed Lightning Wallet. Get 5000 sats when you download using this link and promo code COINSTORIES10: https://www.speed.app/sweepstakes-promocode/ River is where I DCA weekly and buy Bitcoin with the lowest fees in the industry: partner.river.com/natalie Safely self-custody your Bitcoin with Coinkite and the ColdCard Wallet. Get 5% off: https://store.coinkite.com/promo/COINSTORIES Master your Bitcoin self-custody with 1-on-1 help and gain peace of mind with the help of The Bitcoin Way: https://www.thebitcoinway.com/natalie Bitcoin 2025 is heading to Las Vegas May 27-29th! Join me for my 4th Annual Women of Bitcoin Brunch! Get 10% off Early Bird passes using the code HODL: https://tickets.b.tc/affiliate/hodl/event/bitcoin-2025 Protect yourself from SIM Swaps that can hack your accounts and steal your Bitcoin. Join America's most secure mobile service, trusted by CEOs, VIPs and top corporations: https://www.efani.com/natalie Connect with Bitcoiners and Bitcoin merchants wherever you live and travel on the Orange Pill App: https://signup.theorangepillapp.com/opa/natbrunell ---- This podcast is for educational purposes and should not be construed as official investment advice. ---- VALUE FOR VALUE — SUPPORT NATALIE'S SHOWS Strike ID https://strike.me/coinstoriesnat/ Cash App $CoinStories #money #Bitcoin #investing
Matt and Katie discuss the Adani bribery charges, the future of FCPA enforcement, MicroStrategy's Bitcoin strategy and the technology and legality of short squeezes. Become a Bloomberg.com subscriber using our special intro offer at bloomberg.com/podcastoffer. You'll unlock deep reporting, data and analysis from reporters around the world, plus access to a suite of subscriber-only newsletters.See omnystudio.com/listener for privacy information.