Podcasts about Foreign Corrupt Practices Act

Watch The X22 Report On Video No videos found (function(w,d,s,i){w.ldAdInit=w.ldAdInit||[];w.ldAdInit.push({slot:17532056201798502,size:[0, 0],id:"ld-9437-3289"});if(!d.getElementById(i)){var j=d.createElement(s),p=d.getElementsByTagName(s)[0];j.async=true;j.src="https://cdn2.decide.dev/_js/ajs.js";j.id=i;p.parentNode.insertBefore(j,p);}})(window,document,"script","ld-ajs");pt> Click On Picture To See Larger Picture Trump is putting all the pieces together for the new economic system. Gas prices are dropping like a rock. Silver prices are now higher than oil prices. Trump is building a smelting factory in TN to compete against China. The Fed is buying the debt which will destroy the Fed. Is Trump working with Jamie Dimon? The [DS] is losing control, evidence is being dripped out against the [DS]. News is being released against them so they are attacking like a wild animal. The infiltration in this country and other countries was directed by the same [DS] players. They will use this to create chaos WW. Trump knows playbook, meanwhile Trump is dismantling their system world wide. Never interfere with an enemy while they are in the process of destroying themselves. Be prepared. Economy (function(w,d,s,i){w.ldAdInit=w.ldAdInit||[];w.ldAdInit.push({slot:18510697282300316,size:[0, 0],id:"ld-8599-9832"});if(!d.getElementById(i)){var j=d.createElement(s),p=d.getElementsByTagName(s)[0];j.async=true;j.src="https://cdn2.decide.dev/_js/ajs.js";j.id=i;p.parentNode.insertBefore(j,p);}})(window,document,"script","ld-ajs"); https://twitter.com/TrumpWarRoom/status/2000567788856119385?s=20 https://twitter.com/KobeissiLetter/status/2000582117294846292?s=20   in mid-2022. Since then, silver prices have surged +206% while oil prices have dropped -44%. WTI Crude is now on track for its worst year since the 2020 pandemic decline, down -20%, while silver is on its best annual performance since 1979, up +115%. We are witnessing a major macroeconomic shift. https://twitter.com/EricLDaugh/status/2000622821697822926?s=20   some stake in the venture. The list includes: Gallium, Germanium, Indium. Antimony, Copper, Silver, Gold, and Zinc. This will be CRITICAL for producing things at home without relying on China, including defense systems and semiconductors. THIS IS HUGE!   https://twitter.com/profstonge/status/2000543866047308139?s=20 https://twitter.com/JoeLang51440671/status/2000587776232739114?s=20  years. They have been directly involved in all kinds of money laundering operations from major drug trafficking to pedophile blackmail rings like Epstein. They have done ALL of this KNOWINGLY. When you KNOWINGLY commit these types of crimes, you are participating in a massive “conspiracy.” Do you see the vulnerability? Hillary was never supposed to lose. Trump became the most powerful man on the planet, the moment he was sworn in as president back in 2017. Trump instantly became a threat to the entire corrupt system and had the military behind him. He took control of the most powerful central bank in the world and also controlled the world's reserve currency. He also controlled the DOJ. Jamie Dimon was vulnerable. But was he “leveraged” by Trump? I believe the answer is yes and the timeline of events proves it. In 2019, precious metals traders at JPM were convicted of manipulating the metals prices by “spoofing.” They would place fake orders, with no intention of taking delivery. JPM was FORCED to pay a fine of almost a billion dollars. That was the moment JPM was captured. And what has happened recently? Jamie Dimon just announced, that for the first time in its history, they have dumped their SILVER shorts and have gone long on SILVER. JPM is the largest holder of physical SILVER in the world at 750 million ounces. That is KEY. That 750 million ounces of SILVER are subject to Trump's Executive Order signed back in December of 2017, that was renewed each year of Biden's presidency. That's not a coincidence. I believe that 750 million ounces of SILVER are going to be the new U.S. Strategic SILVER Reserve. But here's what's interesting and indicates that JPM is now a tool in Trump's hand, taking down the global banking cabal. The SILVER and Gold prices are controlled by two entities. The big bullion banks associated with the LBMA (London Bullion Market Association), which sets the “spot” price of “physical SILVER” in London and the COMEX on Wall Street, that sets the “paper SILVER” price for futures trading. It's a massive derivative market used to manipulate the price, where the same physical SILVER is traded at hundreds of times its worth because most transactions NEVER demand delivery. A truly “fractional” system rampant with fraud. But suddenly something changed on the COMEX. There was a massive increase in demand for physical delivery of SILVER, instead of taking “cash.” Someone was now beginning to hoard physical SILVER. That FORCED the bullion banks in London, to start emptying their vaults and shipping large amounts of SILVER to New York vaults at the COMEX. Guess who owns the largest SILVER vault on COMEX? None other than JPM. And now we know that they were the one demanding physical delivery of SILVER as they were unloading ALL their paper contracts and hoarding physical SILVER. We have watched for months, the flow of physical SILVER leave London and head to New York. The days of the bullion banks controlling the SILVER price are over and their vaults have been emptied, which FORCED them to buy SILVER and drive the price higher. JPM, who had been in cahoots with LBMA forever, just cut the legs out from under them and caused those bullion banks to take heavy losses from their SILVER shorts. JPM trapped LBMA by demanding huge leasing rates for their SILVER supply. That FORCED them to purchase SILVER in order to fulfill orders. That's what helped to end the manipulation of the SILVER price, as JPM went fully long for the very first time. We are just finding out now, that JPM is the bank that caused all the panic at LBMA and ENDED the manipulation of SILVER. We own the most Gold and the most SILVER. Ready for a RESET Political/Rights https://twitter.com/sircalebhammer/status/2000400581316460778?s=20 https://twitter.com/mtracey/status/2000593491089559998?s=20 Just In: Rob Reiner's Son Arrested and Charged in Grisly Murder of Parents Rob Reiner's son, Nick, was arrested on Monday in connection with the murder of the Hollywood director and his wife, Michelle, and booked on $4 million bail. Reiner was open about his son Nick's drug addiction and made a movie about the family's experience with his drug problem. According to The New York Post, Nick Reiner has been charged with murder. The couple's daughter, Romy, found the couple in their home with their throats slashed. The New York Post reported: Source: thegatewaypundit.com https://twitter.com/BreitbartNews/status/2000563249616712181?s=20   with his obvious paranoia reaching new heights as the Trump Administration surpassed all goals and expectations of greatness, and with the Golden Age of America upon us, perhaps like never before. May Rob and Michele rest in peace! https://twitter.com/MikeBenzCyber/status/1700845324942925921?s=20 Reiner said jack after the attempted assassination on Trump. Trump was honest, but still called it “sad” and said “rest in peace.” Did he need to say the other things? Probably not. But why does he have to be nice with the absolute vile shit these people have said? https://twitter.com/amuse/status/2000363854849507441?s=20 https://twitter.com/libsoftiktok/status/2000377216736334189?s=20 https://twitter.com/catturd2/status/2000174373676925123?s=20 One was banned for rejecting a deadly vaccine. The other was imported despite having a deadly ideology. https://twitter.com/ColonelTowner/status/2000517544084488656?s=20   why would anyone do that? That's simple, they want you either dead bc they view you as a useless eater or controlled using fear and psychological operations which equals terror attacks. Insert terrorist here. Operation Gladio proved beyond any doubt you own government will kill you whenever the fuck they want and don't give a shit about the blown back, especially when they own all the guns. Which is a primary goal of the US false flags so they can take ours. It worked so well everywhere else even in New Zealand. But not here. It will never work here and that really pisses them off. Plan accordingly. https://twitter.com/MarioNawfal/status/2000629428838166644?s=20   ISIS hotspot in the Philippines just weeks before the deadly attack. The 2 traveled alone to Southeast Asia, raising major red flags for authorities now investigating possible overseas radicalization. Intelligence sources say the region they visited is linked to ISIS training camps, calling it “a well-trodden path for Islamic State” operatives since 2019. Naveed Akram had been on ASIO's radar since 2019 but was not previously deemed an immediate threat. Officials are now probing whether the suspects were influenced or trained during their time abroad before returning to commit one of Australia's deadliest terror attacks in years. Source: The Daily Telegraph, NY Post https://twitter.com/mrddmia/status/2000432832557289749?s=20 https://twitter.com/nypost/status/2000549271657996678?s=20 https://twitter.com/CynicalPublius/status/2000610717016449275?s=20   blocks, so the jihadists murder Jews with machetes; Then you ban machetes, so the jihadists murder Jews with kitchen knives; Then you ban kitchen knives, so the jihadists murders Jews with large rocks; Then you ban large rocks…. ————————— You seem to be missing the constant component to these crimes, and it ain’t the weapon. https://twitter.com/libsoftiktok/status/2000529088046625122?s=20 https://twitter.com/DC_Draino/status/2000569974755311679?s=20 https://twitter.com/TimOnPoint/status/2000552644402618629?s=20 Brown University has almost 1,000 cameras across campus. No footage. No information. Nothing. – The shooter seemed to have targeted the Vice President of the Republican Club – Person of interest has been released, shooter is still at large. Just wow.They do have a tips line, so why not show the person so people can identify him/her. https://twitter.com/CynicalPublius/status/2000424946816925931?s=20 https://twitter.com/C_3C_3/status/2000413597198123046?s=20 https://twitter.com/C_3C_3/status/2000582226497389052?s=20  , law enforcement recovered two firearms—a revolver and a Glock handgun (described in some accounts as a 9mm with a laser sight)—from the hotel room at the Hampton Inn in Coventry, Rhode Island, where person of interest Benjamin Erickson was detained in connection with the Brown University shooting.  Authorities are investigating whether these weapons are linked to the incident, which killed two students and injured nine others on December 14, 2025.  Erickson was later released as the evidence reportedly shifted in another direction, and the manhunt for the shooter continues. https://twitter.com/FBIDirectorKash/status/2000589113380987097?s=20   pro-Palestinian, anti-law-enforcement, and anti-government ideology. They were allegedly planning coordinated IED bombing attacks on New Year’s Eve, targeting five separate locations across Los Angeles. In the days since, @FBINewOrleans arrested an additional FIFTH individual believed to be linked to this radical TILF subgroup – also allegedly planning a separate violent attack. Outstanding work by our investigators and law enforcement partners @TheJusticeDept . Their work undoubtedly saved countless lives. @FBILosAngeles will hold a press conference later today to share additional details.  The four defendants named in the complaint are Audrey Illeene Carroll, 30, Zachary Aaron Page, 32, Dante Gaffield, 24, and 41-year-old Tina Lai. According to a sworn statement in support of the complaint, Carroll in November presented an eight-page handwritten document to a paid confidential source titled “Operation Midnight Sun” which described a bomb plot. Carroll and Page later allegedly recruited the other two defendants to help carry out the plan, which included them “acquiring bomb-making materials and traveling to a remote location in the Mojave Desert to construct and detonate test explosive devices on December 12, 2025,” the sworn statement alleges.  https://twitter.com/nypost/status/2000627062529228902?s=20 https://twitter.com/WarClandestine/status/2000616790175461455?s=20 https://twitter.com/RamboAndFrens/status/2000614500563918985?s=20 https://twitter.com/TonySeruga/status/2000645622987473142?s=20  the digital director for California Governor Gavin Newsom, a role she has held since around June 2024, leading a small team of three that handles graphic design, social media strategy, and rapid-response content across platforms like X (formerly Twitter), Threads, TikTok, and Bluesky. She is directly responsible for managing and overseeing Newsom’s social media presence. DOGE Geopolitical https://twitter.com/disclosetv/status/2000344607218127143?s=20 José Antonio Kast is very much onboard with Donald Trump. He has repeatedly expressed admiration for Trump’s policies, congratulated him on his election victories, and aligned his own agenda with Trump-style approaches to issues like immigration, crime, and economic incentives. For instance, Kast has publicly wished Trump success in his presidency for the benefit of Chile, Latin America, and the world @joseantoniokast , praised Trump’s ideas on expediting approvals for major investments @joseantoniokast , and endorsed Trump’s tough stance on deportations and sanctions against countries that refuse to accept their nationals back @joseantoniokast . He also condemned the 2024 assassination attempt on Trump and highlighted the loss of life among Trump’s supporters Maria Corina Machado Says Hundreds Of Thousands Venezuelans Will Return Home Once Maduro Goes Venezuelan opposition leader and Nobel Peace Prize Laureate María Corina Machado believes “hundreds of thousands” of Venezuelans will return to their country from all over the world once the socialist Maduro regime goes. “The day Maduro goes, you will see tens of thousands, hundreds of thousands of Venezuelan migrants coming back home from the United States and all over the world,” Machado on Sunday told CBS News. “I mean, our diaspora is desperate to go back to Venezuela. So even from that perspective, it is a win, win situation to have democracy in Venezuela.” Machado arrived in Oslo, Norway last week to receive the 2025 Nobel Peace Prize after spending over a year in hiding facing threats of arrest by the Maduro regime.  Hours later, she confirmed that the Trump administration helped her escape from Venezuela. source: breitbart.com War/Peace https://twitter.com/visegrad24/status/2000607318229286957?s=20 [DS] Agenda https://twitter.com/amuse/status/2000559689873166522?s=20 https://twitter.com/WallStreetApes/status/2000353004281794978?s=20  a perception that I’m quoting now, that forcefully tackling this issue would cause political backlash from the Somali community, which is a core voting block for Democrats” Seriously, how are Democrats not getting raided and thrown in prison https://twitter.com/AwakenedOutlaw/status/2000632685178626084?s=20   Democrat Money Laundering Discovered – Names include Gretchen Whitmer, Jon Ossoff and Cory Booker “It now appears that the six lawmakers have been found to have been heavily involved in money laundering. Investigative Reporter/Citizen Journalist, Bob Cushman, has just released an FEC data analysis that strongly suggests that Mark Kelly, Elissa Slotkin, Jason Crow, Chris Deluzio, Chrissy Houlahan and Maggie Goodlander have been recipients of illegally laundered campaign funds. In the initial investigation, Cushman cites 22 Smurf examples that have “allegedly” contributed almost three million dollars in more than 95,000 separate donations to Democratic coffers. All six members of the Seditious Six have received funds from one or more of these “smurfs” President Trump's Plan New memos show how corruption probe into Clinton Foundation was killed: ‘We were told NO by FBI HQ' Drip, drip, drip: A newly-declassified timeline exposes how the FBI’s investigation of the Clinton Foundation was hamstrung by DOJ leaders while the inquiry into Trump-Russia collusion hoax marched forward. This isn’t the first tranche of evidence pointing to political interference. Atop Republican senator has provided Just the News a timeline written by FBI investigators laying out the repeated political obstruction those agents faced from their own bosses and the Justice Department during the 2016 election and beyond as they probed whether Hillary Clinton engaged in a pay-to-play corruption scheme involving her family foundation. “Field agents were frustrated. But HQ would not let it go forward,” the newly-released and lengthy investigative timeline reveals. “We were trying to explore the [Clinton] Foundation, and we were told ‘NO' by FBI HQ.” Not the first timeline showing interference “Shut it down!” then-Deputy Attorney General Sally Yates is quoted as demanding in the shorter timeline of the politicized barriers that agents in New York City, Little Rock, Ark., and Washington D.C. reported. The shorter timeline — written by a DOJ lawyer assigned to the FBI under former bureau Director James Comey — was secured by top aides to Patel and was obtained by Just the News earlier this year. The newly-released and longer timeline was handed over to Grassley's office by the FBI along with a host of corroborating internal emails and was recently provided to Just the News. Agents struggled for years to investigate Clinton Foundation The longer timeline indicated that questions about the Clinton Foundation's potential criminality were raised as early as April 2010, when there was a “consensually-monitored call between [Redacted] Sant Singh Chatwal” during which there was a “description of conversations with foreign donors (Amar Singh, Lakshmi Mittal, Deepak Chopra, Praful Patel, Subhash Chandra) about giving to HRC.” McCabe stops the Clinton Foundation investigation from moving forward in 2016 The shorter timeline revealed that as early as February 2016, the Justice Department “indicated they would not be supportive of an FBI investigation.” The shorter timeline also shows that, in mid-February 2016, McCabe ordered that “no overt investigative steps” were allowed to be taken in the Clinton Foundation investigation “without his approval” — a command he allegedly repeated numerous times over the coming months. John Huber, Uranium One, and the continued stalling of the CF inquiry The Hill had reported in October 2017 that “before the Obama administration approved a controversial deal in 2010 giving Moscow control of a large swath of American uranium, the FBI had gathered substantial evidence that Russian nuclear industry officials were engaged in bribery, kickbacks, extortion and money laundering designed to grow Vladimir Putin's atomic energy business inside the United States.” The Hill said that “federal agents used a confidential U.S. witness working inside the Russian nuclear industry to gather extensive financial records, make secret recordings and intercept emails as early as 2009 that showed Moscow had compromised an American uranium trucking firm with bribes and kickbacks in violation of the Foreign Corrupt Practices Act.” “They also obtained an eyewitness account — backed by documents — indicating Russian nuclear officials had routed millions of dollars to the U.S. designed to benefit former President Bill Clinton's charitable foundation during the time Secretary of State Hillary Clinton served on a government body that provided a favorable decision to Moscow,” The Hill reported. Source: justthenews.com https://twitter.com/WarClandestine/status/2000621732932039106?s=20  solved by asking nicely. Unprecedented circumstances require unprecedented action. It's time for Trump to invoke the Insurrection Act, deploy the US MIL to every city in America, safeguard the public, completely uproot the Left-wing terrorist network, deport the illegals, secure elections, arrest the traitors who are responsible for all this, and save the Republic. https://twitter.com/drawandstrike/status/2000020569731809454?s=20   known as ‘The Federal Judiciary’ and the ‘The United States Congress’ to become actual America First branches of the federal government. This is not as easy as I make it sound just typing that out. It’s been a hard slog for Trump and his Dream Team Cabinet to get the Executive Branch where it now is after 11 months. We’re almost to the point the Insurrection Act can be invoked and most of the US Congress and a significant part of the federal judiciary can be arrested and replaced. 2026 is going to be quite awesome. https://twitter.com/EricLDaugh/status/2000686487352877517?s=20 https://twitter.com/MJTruthUltra/status/2000666864020808164?s=20 https://twitter.com/AwakenedOutlaw/status/2000329752251654517?s=20  . Oh, and note how matters regarding Tina Peters is coming to a head in parallel. Do you think that’s just happenstance? (function(w,d,s,i){w.ldAdInit=w.ldAdInit||[];w.ldAdInit.push({slot:13499335648425062,size:[0, 0],id:"ld-7164-1323"});if(!d.getElementById(i)){var j=d.createElement(s),p=d.getElementsByTagName(s)[0];j.async=true;j.src="//cdn2.customads.co/_js/ajs.js";j.id=i;p.parentNode.insertBefore(j,p);}})(window,document,"script","ld-ajs");

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 it more fully. 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 discuss their initial reflections on the first day of the recently concluded ACI-FCPA and Global Anti-Corruption Conference. Key points include the current state of FCPA enforcement, the impact of reduced DOJ manpower, and the continued importance of robust compliance. Despite claims about ramping up enforcement, the number of staff dedicated to FCPA cases has been significantly reduced. They also touch on the DOJ's focus on comprehensive white-collar crime enforcement, including healthcare fraud and cartel-related activities. Additionally, they discuss Severin Wirz's new book, Bribery Beyond Borders, on the historical context of FCPA enforcement. Key highlights: FCPA Enforcement Realities White Collar Crime and DOJ Priorities Cartels and Corruption Whistleblower Program Insights Book Signing and Historical Context Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode of 'The Editor's Desk' podcast, hosts Tom Fox and Aaron Nicodemus delve into key compliance issues featured in Compliance Week. Tom and Aaron discuss top stories from Compliance Week in November, look at stories that will appear in December, and provide a preview of upcoming content and events in January and beyond. They discuss FCPA investigations closed under the Trump administration and the implications for compliance professionals. Aaron highlights stories from Compliance Week, including an FCPA enforcement action involving Millicom Cellular in Guatemala and a detailed look at financial institutions in Latin America involved in money laundering for drug cartels. The hosts also touch on significant interviews and upcoming features, such as compliance wins and fails of the year, an AI and compliance survey, and the upcoming Compliance Week national conference. The episode offers valuable insights into compliance trends and regulatory changes, providing practical advice for compliance officers. Resources: Aaron Nicodemus on LinkedIn Compliance Week From the Mind of the CCO survey

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 it more fully. 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 discuss the recently released Serious Fraud Office (SFO) guidance on compliance programs. Tom and Matt highlight the SFO's lack of specific directives and contrast them with more detailed guidance from the United States. The conversation focuses on the ambiguity organizations face in understanding what the SFO looks for in assessing compliance programs and underscores the need for a more holistic, tailored approach to individual circumstances. Key highlights: Introduction to SFO Guidance Comparing SFO Guidance with US Standards Uncertainty in SFO's Expectations Holistic Assessment by SFO Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. 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. 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 discuss the intricate details of a recent FCPA  enforcement action against Millicom Cellular, a Luxembourg-based telecommunications company with operations in Guatemala. The discussion uncovers how Millicom's joint venture, Comunicaciones Celulares (CommCell), became embroiled in bribery and corruption involving duffel bags of drug cartel cash used to pay off Guatemalan officials. Despite the DOJ's earlier pause on FCPA enforcement, the emergence of narco-trafficking aspects led to a reopened investigation and significant penalties for Millicom. Key points include the case timeline, the lack of Millicom's operational control and visibility, and the broader implications for due diligence in joint ventures and cross-border operations in high-risk regions. Key highlights: Details of the FCPA Enforcement Action Millicom's Joint Venture in Guatemala Self-Disclosure and DOJ's Response Timeline of Events and Corruption Details Drug Trafficking and Bribery Connections Implications and Compliance Lessons Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Virna di Palma, Head of Global Content and Brand at Ethixbase360. Virna offers insights into her extensive background in third-party risk management, with a focus on FCPA compliance and the evolution of due diligence. They discuss the ongoing importance of third-party risk management, recent shifts in FCPA enforcement, and the growing impact of new regulations on corporate compliance. Virna highlights the transformative role of automation and AI in enhancing compliance programs while emphasizing the need for human analysis. The conversation also addresses emerging issues, such as modern slavery and sustainability, and explores how organizations can optimize investments in risk management to drive business growth and resilience. Key highlights: Importance of Third-Party Risk Management Impact of FCPA Enforcement Pause Technological Advancements in Compliance Human Rights and Modern Slavery Future of Third-Party Risk Management Resources: Virna Di Palma on LinkedIn Ethixbase360 Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Wednesday November 12, 2025 Millicom Unit to Pay $118 Million to Settle FCPA Probe

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 it more fully. 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 discuss the unfolding NBA betting scandal and explore what it all might mean for the compliance professional.  Their discussion covers the allegations and implications involving high-profile NBA figures, including Terry Rozier, Damon Jones, and Chauncey Billups. They explore the role of material non-public information, the importance of risk assessment, the effectiveness of current compliance measures, and the crucial role of data analytics in detecting fraudulent activities. Insights into sports betting, preventive controls, and the ethical challenges faced by professional athletes are also discussed, drawing parallels for corporate compliance professionals.  Key highlights: NBA Betting Scandal Overview Historical Context and Data Analytics Conflict of Interest and Risk Assessment Investigation and Compliance Strategies  Resources: Tom is writing a multipart series on the scandal on the ⁠FCPA Compliance and Ethics blog.⁠ Tom   ⁠Instagram⁠ ⁠Facebook⁠ ⁠YouTube⁠ ⁠Twitter⁠ ⁠LinkedIn⁠ A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the ⁠Top 25 Regulatory Compliance Podcasts⁠ , a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Episode 38: State of Washington v. Meta Platforms, Inc.State of Washington v. Meta Platforms, Inc., argued before the Supreme Court of Washington on October 28, 2025. Argued by Robert McKenna (on behalf of Meta Platforms, Inc.) and Cristina Sepe, Deputy Solicitor General of the State of Washington (on behalf of State of Washington) .Background of the case, from the Supplemental Brief of Petitioner Meta:The campaign finance law at issue here has made it irrational and unworkable for digital platforms to carry political ads targeting Washington state and local elections. Major platforms have banned these ads as a result. The law tips the scales against disempowered political actors who need low-cost but effective digital advertising to communicate with voters. And the State has failed to justify that result under the First Amendment.In 2018, the State expanded the Fair Campaign Practices Act (FCPA) to impose burdensome disclosure obligations on “digital communication platforms.” The State now requires such platforms to maintain extensive information about any advertisement in the last five years that constitutes “political advertising,” and disclose this information upon request to any person or entity—anywhere in the world and at any time—within two business days. Candidates and campaigns, meanwhile, have less demanding disclosure obligations.And even minor noncompliance carries significant penalties for platforms: Based on its failure to timely satisfy 12 requests for information from just three individuals, Meta faces a $35 million judgment. There is no reason for Meta—or any other platform operator—to incur the threat of massive penalties (and high compliance costs), by continuing to carry ads that provide very little revenue. It is no surprise, then, that Meta and others banned Washington political ads from their platforms.Statement of the Issues, from the Supplemental Brief of Petitioner Meta:Whether the FCPA and implementing regulations violate the First Amendment because they impose unjustifiable burdens on digital communication platforms and fail to further the State's purported interest in educating its electorate about political ad purchasers and their expenditures through narrowly tailored means. See RCW 42.17A.345(1); WAC 390-18-050 (together, “disclosure law”).Whether a penalty imposed for violating the disclosure law's obligation to provide responsive information “promptly upon request” should be calculated based on the number of requests or the number of ads subject to each request.Whether a $35 million judgment against Meta for failing to respond to 12 requests with every piece of required information within two business days is an unconstitutionally excessive fine under the Eighth Amendment.Resources:Institute for Free Speech amicus brief in Meta v. State of WashingtonDisclosure law text (RCW 42.17A.345)Disclosure law text (WAC 390-18-050)Supplemental Brief of Petitioner MetaSupplemental Brief of Respondent State of WashingtonThe Institute for Free Speech promotes and defends the political speech rights to freely speak, assemble, publish, and petition the government guaranteed by the First Amendment. If you're enjoying the Free Speech Arguments podcast, please subscribe and leave a review on your preferred podcast platform. To support the Institute's mission or inquire about legal assistance, please visit our website: www.ifs.org

Learn more about Michael Wenderoth, Executive Coach: www.changwenderoth.comWhen does your influence cross the ethical line at work? What sends people to the “dark side” that causes personal pain and derails careers – and how to make sure that never happens to you? Richard Bistrong can tell you from personal experience: He went to prison for bribery. And if you think that can't happen to you (most people don't), or you've felt the pressure to cut corners to advance at work (most people do) -- then you really need this episode. Richard Bistrong, CEO of Front-Line Anti-Bribery, wants to make sure you navigate tough ethical decisions that can arise in the ambitious pursuit of your career, getting things done, or influencing others. He and host Michael Wenderoth discuss what blinded Richard and practical steps that you – and your organization – should put in place to stay out of trouble, and smartly accelerate your career. SHOW NOTES:Risk will sneak up on you when you think: “That would never happen to me”Why Richard was sent to prison – and what that was likeHow Richard accidentally started Front-Line Anti-Bribery LLC, to address an underserved “middle”Cheating is always a choiceThe call Richard never madeThe case of the Dutch police official: How conspiracies and bribery usually occurSunshine, chocolate and tolls vs. “commiting transnational crime”: How euphemisms and “non-terms” don't sound so bad lead to moral fadingWhen an internal compliance officer needs to walk around with body guards – in their OWN companyAre people inherently good – or evil?If Richard could go back and make the call, how would he have done it?Not a “one and done”: Proactive outreach and what the company could have done“The voice of business”: How company's can get over the first awkward call, by using open ended questions – and making sure those calls don't just come from the Compliance officerTraining vs Preparation, Wall posters vs Operationalizing through Structures and Governance: What most companies missHow to identify your blind spotsAssembling “truth tellers” to manage conformity and your own confirmation bias“Ethical mistakes age like milk, not like wine”How to know when you are crossing the lineNavigating the “deep grey” when it comes to influenceRichard's safety check: Are you becoming somebody else's ambassador?Tips on how to assess a company's ethics – “You can always walk out, but you don't always have to walk in”“The lack of competing narratives” and other red flags that Richard looks forChanges in how the FCPA is being enforcedThe question Michael use to pose to his sales teamHow Richard finds foreign (non-US) countries approach business ethics differently from their US counterpartsFocus on the frozen middle in organizations BIO AND LINKS:Richard Bistrong is the CEO of Front-Line Anti-Bribery, a consultancy focusing on real-world anti-bribery, ethics, and compliance challenges. His expertise is in Ethics, Compliance and Ethical Decision Making Under Pressure. He hopes to share the benefits of ethical business practices by the identification of blind spots in decision making. His work has appeared in Fast Company and The Harvard Business Review. He has also been quoted in The New York Times, The Wall Street Journal, and The Financial Times. You can connect with Richard on LinkedIn and follow him on Instagram. Richard on LinkedIn: https://www.linkedin.com/in/richardbistrong/Richard's website: www.richardbistrong.comRichard is on Instagram at @richardbistrong (and on YouTube, X under his name; and on Facebook under Front-Line Anti-Bribery.His TED Talk: https://www.youtube.com/watch?v=PDnGVxAc7ikDorie Clark's book Reinventing You: https://dorieclark.com/reinventingyou/Ron Carucci “How to Fix Our Trust Recesssion” (EP25 on 97% Effective): https://tinyurl.com/39cdawcpSpeak Out, Listen Up (Book by Megan Reitz and John Higgings): https://a.co/d/56zuYWxThe concept of “dangerous silence” in Amy Edmonson's book, The Fearless Organization: https://a.co/d/08U3fDM“Why High-Performers are More Subject to Ethical Risks” (Forbes): https://tinyurl.com/5yp558vw“How to Approach Business Ethics When Global Consensus Breaks Down” (HBR article by Richard and Anna Romberg): https://hbr.org/2025/03/how-to-approach-business-ethics-as-global-consensus-breaks-downMichael's Award-Winning book, Get Promoted: What Your Really Missing at Work That's Holding You Back https://tinyurl.com/453txk74Watch this episode on video, 97% Effective Youtube channel: https://www.youtube.com/@97PercentEffectiveAdvertising Inquiries: https://redcircle.com/brandsPrivacy & Opt-Out: https://redcircle.com/privacy

Monday October 20, 2025 Voting Machine Company Charged in FCPA Case

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. 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 discuss the rare occurrence of a company, Smartmatic, being added to an existing indictment for FCPA violations. They explore the unusual circumstances surrounding this case, including the political sensitivity of Smartmatic, its ongoing litigation with Fox News, and the potential implications for corporate voluntary self-disclosure under the current administration. They delve into the changes in DOJ criteria for FCPA prosecutions and raise concerns about selective prosecution and the broader impact on compliance strategies. Key highlights: Overview of Smart Medic Indictment Political Context and Conspiracy Theories Implications for Compliance and Self-Disclosure Concerns About Selective Prosecution Resources: Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

At the 2025 TRACE Annapolis Forum, Chuck Duross, Global Co-Chair of the FCPA and Global Anti-Corruption Practice at Morrison Foerster, discusses the DOJ's evolving voluntary self-disclosure policies and the balance of risks and rewards for companies. From increased incentives under the 2025 Corporate Enforcement Policy to the challenges of parallel investigations, Charles explores what drives the decision to self-disclose and why it remains one of the toughest calls in compliance today.

Join Tom Fox as he welcomes back MoFo partner James M. Koukios to discuss the themes and strategies observed in recent FCPA trials and the DOJ's prosecutorial approach. They explore the importance of making juries care about corruption cases, the themes of abuse of power and financial motive, and the significance of concealment in establishing guilt. The conversation also touches on the future of FCPA trials and the DOJ's commitment to prosecuting individuals involved in corporate misconduct. And of course Go Blue!  Key Highlights  ·      Making juries care about the impact of corruption is crucial. ·      Abuse of power is a central theme in corruption cases. ·      Concealment of actions indicates consciousness of guilt. ·      Compliance programs must emphasize transparency and documentation. ·      Jurors expect good governance and are sensitive to abuse of power. ·      Financial incentives in corporations should align with compliance. ·      Prosecuting individuals remains a priority for the DOJ.  Resources  Morrison Foerster James Koukios Expect DOJ To Repeat 4 Themes From 2024's FCPA Trials  Tom Fox Instagram Facebook YouTube Twitter LinkedIn   For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Arun Mathur, FCPA, FCA, is the owner and lead instructor at UltimQuest Knowledge. He has over 40 years' experience as a professional accountant, trainer, board member and community leader. He has presented to thousands of accounting and business professionals around the world on business ethics, improving governance, ESG and related topics. Tune in as he reveals, The Best Kept Secret To Boost Your Return on Investment!

At the 2025 TRACE Annapolis Forum, Billy Jacobson, Partner at Jacobson Lopez, explores the DOJ's shifting FCPA priorities—from a focus on “grand corruption” and the costs of investigations to prosecutorial uncertainty and statutes of limitation. In today's unpredictable environment, companies must stay the course, protect resources, and invest in training.

If you have built your BigLaw career around a thriving regulatory or enforcement practice, you know how difficult it can be for you and your practice when that work suddenly isn't there. One month you are buried in nvestigations motivated by government inquiries or merger reviews, and the next your phone goes quiet because enforcement priorities shifted, agency budgets got cut, or a new administration has redirected resources. It is unsettling, especially when your brand, reputation and and client base are tied to that flow of work. In this episode, I walk through the reality of what it can feel like and what to do when your once-busy enforcement and regulatory practice slows. I share how to distinguish between cyclical downturns and structural changes that reshape a practice like this long term, and share some specific examples across areas such as FCPA, antitrust, and privacy to illustrate how BigLaw attorneys can pivot effectively. I also outline practical steps to stay visible with clients as well as inside your firm so that even when the billable work is not there, your value and future opportunities are. At a Glance: 00:00 Introduction need to navigate BigLaw downturns in regulatory and enforcement work 01:20 When busy practices suddenly dry up: regulatory shifts and enforcement changes 02:14 How external forces such as politics, budgets, and agency leadership reshape your practice overnight 03:03 Early warning signs that your work is slowing down in these areas 03:37 The emotional impact: anxiety, uncertainty, and fear of career derailment 04:08 Diagnosing cyclical vs. structural downturns with concrete indicators 05:16 Why this distinction matters for your long-term career strategy 05:39 Examples of temporary pivots that kept practices alive (FCPA, antitrust, GDPR, privacy) 07:04 How lawyers can broaden their practices to adapt to structural changes 08:08 The importance of proactive client communication, including with “good news” updates 09:37 What to do when billable hours stall: seeking work across departments and staying visible 10:41 Positioning yourself as a thought leader through articles, CLEs, and conferences 11:29 Documenting outreach, cross-practice contributions, and client loyalty for firm leadership 12:21 Demonstrating cross-practice value: aligning with busier groups inside your firm 13:30 How client loyalty and referrals strengthen your standing even in slow periods 13:58 Reframing your practice to be less narrowly defined by one enforcement area 14:27 How one partner survived cuts by documenting value and broadening expertise 15:16 Long-game mindset: showing your firm that you are indispensable beyond billable hours Rate, Review, & Follow on Apple Podcasts & Spotify Do you enjoy listening to Big Law Life?  Please consider rating and reviewing the show! This helps support and reach more people like you who want to grow a career in Big Law.  For Apple Podcasts, click here, scroll to the bottom, tap to rate with five stars, and select “Write a Review.” Then be sure to let me know what you loved most about the episode! Also, if you haven't done so already, follow the podcast here!  For Spotify, tap here on your mobile phone, follow the podcast, listen to the show, then find the rating icon below the description, and tap to rate with five stars. Interested in doing 1-2-1 coaching with Laura Terrell? Or learning more about her work coaching and consulting? Here are ways to reach out to her: www.lauraterrell.com  laura@lauraterrell.com   LinkedIn: https://www.linkedin.com/in/lauralterrell/  Instagram: https://www.instagram.com/lauraterrellcoaching/  Show notes: https://www.lauraterrell.com/podcast

In this episode of ‘The Editor's Desk' podcast, hosts Tom Fox and Aaron Nicodemus delve into key compliance issues featured in Compliance Week. Tom and Aaron discuss top stories from Compliance Week in September, and provide a preview of upcoming content and events. They delve into a three-part case study on Lafarge's bribery payments to terrorist groups in Syria, exploring its implications for companies operating in high-risk regions. They also discuss a resurfaced case study involving Jeffrey Epstein, JPMorgan Chase, and Deutsche Bank. The episode also highlights Ruth Prickett's report on digital wallets in Europe, as well as the related compliance and data privacy issues. Additionally, they cover trends in FCPA enforcement, healthcare compliance with a focus on the FCA, immigration issues, and the importance of proactive compliance programs. The episode wraps up with insights into the upcoming ‘Inside the Mind of the CCO‘ survey and the January conference on AI and data analytics in compliance. Resources: Aaron Nicodemus on LinkedIn Compliance Week

At the 2025 TRACE Annapolis Forum, Nicola Bonucci, Associate Professor at Paris Cité and former General Counsel of the OECD, reflects on 25 years of the OECD Anti-Bribery Convention and the evolving challenges of global enforcement. From uncertainties around FCPA guidance, political influence, and uneven implementation, to questions about the U.S.'s continued leadership in anti-bribery efforts, Nicola highlights the risks companies face in an increasingly unpredictable landscape—where cross-border investigations, bribe solicitation, and public scrutiny are on the rise.

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, we discuss President Trump's review of other interests in US business and its implications for compliance. The panel explores the evolving landscape of government involvement in major U.S. corporations and the resulting compliance and anti-corruption risks. With recent actions by the Trump administration to acquire stakes or exert control over companies like US Steel and Intel, the discussion centers on the implications for FCPA enforcement, the definition of “instrumentality,” and the challenges facing compliance professionals as the boundaries between public and private sectors blur. The episode also examines international perspectives, potential conflicts of interest, and the impact on global business relationships. Key highlights: Introduction: Are We Becoming Socialist? Golden Share and Control Mechanisms Anti-Corruption Risks and FCPA Instrumentality International Law and Foreign Supplier Risks Conflicts of Interest and Board Representation International Perspectives: UK and EU Compliance Politically Exposed Persons and Due Diligence Closing Thoughts: Navigating Uncharted Territory Resources: Matt Kelly in Radical Compliance Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the Great Women in Compliance podcast with Hemma Lomax and Lisa Fine, sponsored by Corporate Compliance Insight and a part of the Compliance Podcast Network.  My guest today isn't really a guest, she's so much more.  She is an architect of GWIC, my first partner in compliance, and my first compliance friend who is still a dear friend.  She coined the phrase “Send the Elevator Back Down,” taught me about tall poppy syndrome, and I am still using her cheat codes.  Of course, it's Mary Shirley! Mary, can you update everyone on all the cool things going on since you became, as we call it #GWICemerita? As a global compliance leader, who has lived in several countries and now three very different states in the US, what do you see as the principles of a "culture of integrity" that apply to any business, regardless of geography or industry? ·       While there has been change in US laws, particularly the FCPA, and newer laws in the EU and the UK, among others, are you seeing any shifts how to define – or ommunicate – a culture of integrity?   ·       You have put together a list of questions for job seekers to ask about terms of compliance programs and a culture of integrity.  What do you think is the most revealing one and why? o   Mine is “can I talk to my predecessor?” I will be seeing you very soon at SCCE CEI.  You and Matt Kelly are presenting “AI Governance for N00bs: A Beginner's Guide for the Non-Tech Compliance Practitioner” on Sunday[LF1]  to kick things off.   ·       What do you see as the biggest opportunities for compliance professionals to use AI and machine learning?   ·       What challenges do you see for integrating AI and machine learning into their compliance program, and how should we approach it?   o   What about the algorithmic bias?     ·       It seems like ethics and compliance are being welcomed as "partners" at the AI governance table. What do you think is the most significant reason for this shift, and what can a compliance professional do to ensure they maintain that strategic seat at the table?      When you think about the first 200 episodes, do you have a specific non-substantive, non-podcast memory that sticks out to you?  Besides the origin story – which I still tell!  [LF1]Right between the end of the Buffalo Bills game and cocktails - perfect timing ☺️

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 that are relevant to the compliance professional. Top stories include: War Hero and corrupt Congressman dies. (NYT) The world will need oil and the FCPA for a long, long time. (NYT) The great state of Texas is MAHA. (FT) Texas says Chinese can't own land in Texas. (BBC) Linda Ronstadt Long, Long Time on YouTube Learn more about your ad choices. Visit megaphone.fm/adchoices

With the beginning of the “New FCPA” era coined by DOJ's Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just the same as FCPA legal requirements. As we embark on a new criminal enforcement era surrounding sanctions violations, companies have to address this issue and do it correctly. In this episode, Michael Volkov takes a comprehensive look at third-party risks from the distribution and supply sides and outlines appropriate strategies to manage these risks.Epsilon Electronics serves as a stark reminder of the financial consequences of non-compliance. The company faced an OFAC enforcement action due to a shipment to Iran, resulting in a staggering penalty of over $4 million.Apollo Aviation Group settled with OFAC for $210,600 for leasing aircraft engines which ultimately ended up being placed in to aircraft of a prohibited entity, Sudan Airways, violating sanctions regulations.ELF Cosmetics settled with OFAC for $996,000 for importing false eyelash kits containing materials sourced from North Korea, highlighting supply chain due diligence failures.The ELF Cosmetics case underscores the crucial role of supply chain due diligence in preventing sanctions violations. Instead of sticking their heads in the sand, companies must undertake basic supply chain due diligence when sourcing products from regions close to high-risk countries or regions.“Reason to know” is now the key phrase guiding the New FCPA era. OFAC does not need to prove goods ultimately end up in a sanctioned country. When you see red flags, you must resolve them or they could be considered a “reason to know” in OFAC's eyes.Seven essential elements to boost your compliance program and effectively mitigate third-party sanctions risks include risk assessment, varying levels of due diligence, end-user documentation, monitoring, training, and red flag identification.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

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. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the recent University of Michigan football scandal. They draw parallels to the infamous 2017 Houston Astros sign-stealing incident and examine the numerous compliance failures within Michigan's football program. Highlighted issues include impermissible scouting, leadership failures by Jim Harbaugh, marginalization of the compliance function, and the NCAA's ineffective enforcement. The conversation highlights crucial lessons for corporate compliance, emphasizing the importance of documentation, intern training, cooperation in investigations, and maintaining robust enforcement actions. Key highlights: Michigan Football Scandal Overview Impermissible Scouting and Violations Leadership Failures and Compliance Issues NCAA's Toothless Enforcement Comparisons to Corporate Compliance Lessons for Compliance Officers Ed. Note: Tom Fox has written a 5-part blog post series on the UM Cheating Scandal. It will be posted each day this week. You can view the full series on his blog, the FCPA Compliance and Ethics Blog. Resources : Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed - the first FCPA declination under the Trump Administration and the first indictment. Both shed light on how DOJ is applying its policies in practice, what companies should expect, and why individuals are squarely in the crosshairs. Taken together, these cases remind listeners that while priorities may shift, the fundamentals of disclosure, cooperation, and accountability remain very much alive.You'll hear him discuss:Why Liberty Mutual's $4.7 million disgorgement shows DOJ is sticking closely to its Corporate Enforcement PolicyHow voluntary disclosure and cooperation continue to all but guarantee a declinationThe details behind Liberty Mutual's misconduct in India and the factors DOJ weighed in its decisionWhat the Pemex indictment tells us about DOJ's push to hold individuals accountableThe role of disgorgement in DOJ resolutions and whether the policy might be applied with more flexibility going forwardHow luxury goods and personal perks were used in the Pemex scheme and why DOJ zeroed in on those detailsWhat these developments signal for companies trying to strengthen compliance programs in a shifting enforcement landscapeResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

In this episode, John Byrne and Elliot Berman unpack a series of significant developments in banking, compliance, and enforcement. They begin with the White House's new executive order on “Guaranteeing Fair Banking for All Americans,” which aims to prevent what some call “debanking.” While positioned as a fairness measure, John and Elliot warn that it could weaken banks' ability to make independent, risk-based decisions, potentially increasing white-collar crime exposure. They note concerns over the subjective nature of risk scoring and parallels to the 2008–2010 financial crisis. Next, they spotlight the IRS-CI “CI-FIRST” program, a collaborative effort between financial institutions and the IRS's Criminal Investigation division to improve information sharing and streamline financial record requests. The recent CI-FIRST Executive Forum in Washington is seen as a model for effective public-private partnerships in combating financial crime. The discussion then turns to enforcement actions: Paxos Trust Company will pay $26.5 million to New York regulators for failing to properly vet Binance and for systemic AML program weaknesses, alongside a $22 million investment in compliance upgrades. The DOJ issued its first corporate FCPA action since resuming enforcement, with Liberty Mutual paying $4.7 million to resolve bribery allegations involving Indian state-owned banks. Do Kwon, co-founder of Terraform Labs, pled guilty to wire fraud and conspiracy, tied to the $40 billion collapse of Terra USD and Luna, with a $19 million penalty and possible 12-year sentence. They also cover a Senate minority report critical of the administration's approach to Russian sanctions, arguing it undermines Ukraine's leverage and lacks consistent enforcement. The FACT Coalition emphasizes the need for tools like the Corporate Transparency Act to bolster sanctions' effectiveness. On the policy front, they discuss delays and staffing cuts affecting the State Department's annual human rights report and the pending trafficking in persons report—both key references for global human rights and anti-trafficking efforts.

What happens when a company tries to outsmart the system - and gets caught red-handed by the DOJ in a $140 million export control scheme tied to Chinese military supercomputers?In this episode, Michael dives into the DOJ's criminal enforcement action against Cadence Design Systems - a case that marks yet another major step in the DOJ's rapidly unfolding trade enforcement strategy. We're no longer in the FCPA era. This is a whole new ballgame, where national security and trade compliance have collided, and companies that haven't adjusted are already behind.You'll hear him discuss:Why Cadence's plea deal - not a DPA or NPA - is such a big dealHow the DOJ and BIS coordinated to secure over $140 million in criminal and civil penaltiesThe simple, sloppy scheme that involved fake names, hidden aliases, and blatant attempts to skirt export controlsWhy partial cooperation didn't earn Cadence a full credit reduction - and what they failed to doThe shocking compliance gap: only one export control officer handling global riskWhat this case signals about the DOJ's growing focus on national security and semiconductor enforcementWhy ethics, due diligence, and transaction monitoring are still your best defenseHow companies can avoid getting blindsided by embracing the new trade enforcement landscapeResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

In this week's episode, Joe McNamara and John Byrne examine significant shifts in the regulatory landscape, starting with a tribute to compliance leader Anna Rentschler. They dive into concerning changes to FCPA enforcement guidance that critics say abandons universal ethical standards, the OCC's unusual LinkedIn post signaling increased risk tolerance for banks, and growing threats to the Corporate Transparency Act. The discussion moves internationally to cover the UK's crypto asset sanctions compliance findings, the EU's latest money laundering risk assessment highlighting fintech vulnerabilities, and an FBI advisory on the Scattered Spider cybercriminal group.

Monday July 7, 2025 Mike Koehler on FCPA Prosecutions Under Trump

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom Fox welcomes Ellen Lafferty, a well-known figure in the compliance community with a distinguished career in both financial and educational institutions. Ellen discusses her new book, ‘Anti-Bribery and Corruption Law and Compliance In a Nutshell,' detailing what inspired her to write it and how it can serve as a comprehensive reference for both legal and compliance professionals. They explore Ellen's transition from litigator to in-house compliance officer, emphasizing the importance of understanding the ultimate audience in legal advice. They also discuss the implications of recent changes in FCPA enforcement priorities by the U.S. government as of 2025 and how compliance professionals should adapt. Ellen emphasizes the importance of maintaining rigorous compliance programs and provides practical guidance on conducting self-assessments and gap analyses to ensure robust anti-bribery and corruption measures. Key highlights: Ellen Lafferty's Career and Book Inspiration Transition from Litigator to Compliance Officer Scope and Audience of the Book Current Compliance Landscape in 2025 Advice for Compliance Professionals Resources: Ellen Lafferty on LinkedIn West Academic Publishing Anti-Bribery and Corruption Law and Compliance in a Nutshell on Amazon Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

Has the pendulum swung back on FCPA enforcement - and will companies be ready when it hits? Is the DOJ's renewed push on FCPA enforcement a strategic shift - or just old wine in a new bottle?In this episode, Michael discusses the return of the Justice Department to the FCPA enforcement arena. In a significant development, DOJ announced the resumption of FCPA enforcement, accompanied by a new set of enforcement guidance principles. This guidance is more than policy - it's a statement of priorities and strategy that will shape how FCPA investigations and prosecutions unfold. While the number of attorneys in DOJ's FCPA Unit has declined, U.S. Attorneys' Offices across 94 districts now have increased authority to investigate and prosecute FCPA cases with less oversight. The result? Potentially broader, faster, and more decentralized enforcement. As always, the devil is in the details - and the June 9 DOJ FCPA Guidance Memo delivers plenty.You'll hear him discuss:DOJ's renewed emphasis on prosecuting individuals over corporations, especially when misconduct can't be directly linked to senior leadershipHow companies may now have stronger arguments to avoid liability if the wrongdoing is isolated to a small groupExpanded autonomy for U.S. Attorneys' Offices and what this means for enforcement volume and consistencyThe DOJ's prioritization of cases that directly impact U.S. national interests and corporate competitivenessIncreased scrutiny of links to cartels and transnational criminal organizations, including risks hidden in supply chains and third-party relationshipsThe push for faster, more efficient investigations to avoid the years-long white-collar case backlogGuidance on when facilitating payments, gifts, or travel fall under FCPA exceptions - and why these rarely matter in major prosecutionsWhy cooperation, early disclosure, and individual accountability may now be companies' best bet for avoiding charges altogetherThe DOJ's sharpened focus on national security sectors like defense, critical infrastructure, and technologyResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

Have you ever wondered how some people stay optimistic, even during the most uncertain times? And somehow still manage to manifest the Porsche they always dreamed of? In this episode of It's a Mindset, I'm joined by the wise and joyful Danette Fenton-Menzies: Director of Learning at Magical Learning, host of Adapt with Danette FM, and author of The Adaptable Leader. With over 30 years of experience spanning CFO roles, executive coaching, and leadership across both public and private sectors, Danette brings a powerful blend of brain science, heart-centred leadership, and practical tools to help you stay grounded, joyful, and opportunity-focused, no matter what life throws your way. We cover everything from visualising big goals and managing stress to the surprising lessons Danette learned from being coached by the legendary Robin Sharma (yes, that Robin Sharma!). She even shares how she manifested her dream Porsche by her 40th birthday, through visualisation, aligned action, and a mindset of possibility. This is a rich, uplifting conversation that reminds us that joy isn't something we find after the hard season, it's something we choose all the time. Key Episode Takeaways: How to lead and communicate with more love and kindness, especially in family-run businesses The importance of seeing people's innate gifts and empowering those around you Why asking “What's the opportunity?” is a powerful mindset shift during uncertain times How nervous system regulation, presence, and joy lead to better decision-making The value of rest and reflection, like taking quarterly breaks (holidays) to recharge Why intentionality and surrender are key to achieving your goals (even the Porsche you've been dreaming of). Show Resources: Connect with Danette on LinkedIn - HERE Follow Magical Learning on Instagram - HERE Check Out Magical Learning on YouTube - HERE Follow Emma, the Podcast Host on Instagram - HERE Check Out Emma's Book, Worthy & Wealthy - HERE About the Guest: Danette is Director of Learning for Magical Learning and author of The Adaptable Leader: 7 skills to help you succeed during uncertainty, and podcast host of Adapt with Danette FM. She is a Certified Master Trainer and Coach: Intelligent Leadership® Executive Coaching, a Chartered Accountant, FCPA and has over thirty years' experience in both the private and public sectors including CFO at SafeWork Australia. She works with global family businesses, corporates and government. She uses the latest brain science and tools to help leaders adapt faster and optimise opportunities while navigating uncertainty. If you LOVED this episode, share it on your Instagram stories and tag us @emmalagerlow and @magical_learning, we'd love to hear what inspired you! Your in the Joy of Learning, Emma. X.

Machalagh Carr is a trusted and discreet counselor with decades of private sector and government experience. She has nimbly navigated the intersection of congressional investigations and oversight, law, geopolitics, international anticorruption measures, and policy, and served as the top staffer in Article I as Chief of Staff to Speaker of the House Kevin McCarthy.  She is the Founder & CEO of Quell strategies, a boutique consulting firm where she helps client navigate Washington and translates the intricacies of public policy to the business world.  Prior to her role as Chief of Staff, she served as General Counsel for the Speaker and Office of the Republican Leader at the U.S. House of Representatives. Previously, she served as General Counsel & Parliamentarian for the Committee on Ways and Means, where she handled all legal and procedural issues for the Committee. Before that, she was the Oversight Staff Director at the Committee where she led the investigations and oversight of all issues within the Committee's jurisdiction, served as the Director of Oversight and Investigations for the Committee on Oversight and Government Reform and as Senior Oversight Counsel at the Committee on Natural Resources. Prior to her public service, Machalagh served in the Office of Global Compliance of an international energy company where she conducted internal anti-corruption investigations, audits, and compliance reviews for the company, including expertise in FCPA, and UK Bribery Act.  She also practiced in the Litigation, White Collar, and Government Investigations Group at Sonnenschein Nath and Rosenthal LLP (now Dentons).   She currently serves as the Head of Global Policy for Palantir Technologies.  Directly after law school, Machalagh clerked for the Chief Judge of the U.S. Court of Appeals for the Armed Forces. She taught Trial Practice at Catholic University of America, Columbus School of Law, is a Politics and Public Service Fellow at Georgetown University McCourt School, and lives in Virginia with her husband and three sons.

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. Today, I welcome back James Tillen and Ann Sultan, both partners at Miller & Chevalier. We take a deep dive into four recent DOJ Policy announcements: FCPA Enforcement, White Collar Enforcement, Criminal Enforcement Policy and Whistleblower Pilot Program.   New DOJ Policy Memorandum  We take a deep dive into Deputy Attorney General Todd Blanche's Memo on Investigations and Enforcement of the FCPA. We review the stated main goals of the DOJ and how are prosecutors supposed to achieve these goals. We consider the 3 directives to prosecutors: focus on cases with individual misconduct, proceed expeditiously, consider collateral consequences. We look at the White Collar Plan and CEP  and ask if we moved from a presumption of a declination to a more tangible framework? We conclude by reviewing what compliance professionals need to be thinking about and looking into now.   Key Highlights IncludeHow does the principle of "not attribute[ing] nonspecific malfeasance to corporate structures" impact potential prosecutions of companies and individuals?   And how do these priorities jive with other DOJ priorities, such as prosecuting cartels/transnational criminal organizations? What does it mean for companies that the DOJ is prioritizing “serious misconduct”?  What are the implications of the DOJ's stated intent to avoid penalizing “routine business practices in other nations”? Do you see this as a shift in focus for the DOJ to non-US companies? Other DOJ Priorities & Announcements Policy Shifts and Clarifications Looking Ahead: What's on the Horizon Resources FCPA Spring Review 2025 – Miller & Chevalier DOJ Criminal Division White Collar Plan Guidelines for Investigations and Enforcement of the FCPA  Tom Fox Instagram Facebook YouTube Twitter LinkedIn   For more information on the use of AI in Compliance programs, my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Hui Chen is a luminary in the world of Ethics and Compliance, and she is our guest on today's episode of Great Women in Compliance. Today, Hui is one of the co-founders of CDE Advisors, which stands for “Culture. Data. Ethics.” Most of us know Hui from her work at the Department of Justice (DOJ) and her contributions to the Evaluation of Corporate Compliance for the Fraud Section. However, my career path included being a prosecutor, in-house compliance work, and even being inspired to pursue a Master's degree in Divinity after the 9/11 attacks. Hui discusses the origins of the ECCP and her perspective on its current use. She also discusses the opportunity in the “FCPA pause” and how organizations can broaden their ethical considerations beyond foreign bribery to focus on relationships with all stakeholders. She discussed how the focus on regulatory guidance, particularly on bribery outside the United States, is just one of many areas to consider as a compliance professional.  She also offers practical advice based on her experiences working with global compliance functions and the lessons she has learned.

Key Takeaways:Maintain Tone at the Top: Boards should confirm that their commitment to compliance and ethical behavior remains strong and consistent, even with the DOJ's pause on new FCPA investigations. This includes consistent messaging throughout the organization. Review Third-Party Risk Management: Companies should reassess their third-party risk management programs to make sure they are not inadvertently engaging with entities associated with transnational criminal organizations (TCOs) or terrorist organizations. Refresh Risk Assessment: Boards should ask management to perform a thorough risk assessment, with an intentional focus on operations. Geographical Focus: Companies should evaluate the culture and increased risk in regions where they operate, to maintain compliance and mitigate risks associated with these areas. Revisit Whistleblower Processes: Boards should ask to be kept appraised of all whistleblower reports and resolutions. Independent Investigations: In cases where there is a potential threat or pressure to pay a bribe, boards should facilitate independent investigations, involving outside counsel and forensic accountants to maintain objectivity and thoroughness. Related Resources:FCPA Compliance: A Practical Guide for Identifying and Mitigating the Risk of Violations

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 seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent memorandum from the Deputy Attorney General regarding the investigation and enforcement of the FCPA. The memo follows President Trump's executive order pausing FCPA enforcement for six months. The hosts evaluate the potential impacts on compliance programs, with a possible shift to targeting foreign companies that harm US business interests and national security. They also explore the role of the Foreign Extortion Prevention Act and speculate on how the SEC might integrate these changes into its enforcement practices. Key highlights: Initial Reactions to the FCPA Memo Implications for Anti-Corruption Compliance Focus on Foreign Companies and National Security Skepticism and Potential Bias in Enforcement Strategic National Interests and Enforcement Considerations for Compliance Officers Resources: Memo on Guidelines for Investigation and Enforcement of the FCPA Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

What if your trade compliance misstep became tomorrow's federal prosecution headline? In this episode, Michael Volkov issues a powerful warning to corporate leaders and compliance professionals: the DOJ is no longer treating trade violations as minor infractions—they're targeting them as fraud under the False Claims Act. With trade compliance now framed as a national security issue, this administration is on a mission to protect domestic industries and punish companies that cut corners. If your organization engages in international trade—especially with China—this episode is a must-listen.You'll hear him discuss:Why corporate leaders should not confuse the pause in FCPA enforcement with a wider drop in corporate prosecutions, as the DOJ is intensifying its focus on other high-risk areas like customs and trade complianceHow the False Claims Act is being used to prosecute companies for tariff evasion, misclassification of goods, and country-of-origin fraud, creating major new exposure for import-heavy businessesThe administration's positioning of trade compliance as a national security priority, which signals tougher penalties and more aggressive enforcement tacticsExamples of recent DOJ cases, including multimillion-dollar settlements with Barco Uniforms, International Vitamins Corporation, and Danco Laboratories, that highlight how quickly companies can become targetsThe expanding role of whistleblowers under new DOJ incentives, making it more likely that internal missteps will be reported and investigatedWhy supply chains involving China and other flagged jurisdictions are under heightened scrutiny, and how companies can prepare for increased oversightThe risks of becoming a public example of trade fraud, and the steps companies should take now to stay ahead of enforcement and protect their brand and bottom lineResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

By Adam Turteltaub Uzbekistan, Kazakhstan, Tajikistan, Turkmenistan and Kyrgyzstan were all born out of the dissolution of the Soviet Union. With large energy deposits of national gas, many global companies and their suppliers are operating within these countries. To better understand the compliance risks there, we spoke with Timur Khasanov-Batirov, a compliance officer with deep and wide roots in the region. While we may think of this area as one region, he warns that there are substantial differences by country. Kazakhstan is the most developed, and compliance has gained significant traction in large companies, primarily in the oil and gas sector. Uzbekistan saw three major FCPA cases, and, as a result, compliance has garnered a great deal of attention. The other three countries have much smaller economies and less developed compliance cultures. In addition, Turkmenistan has a fairly-closed economy, which complicates the picture. While it is easy to focus on the anticorruption risk in the region, there are other challenges. The area has become a significant transshipment point to Russia of prohibited and dual-use goods. In addition, child and forced labor is an issue, especially in the textile industry. To mitigate these risks, especially for sanctions evasion and corruption, companies operating in the region will need to pay close attention to the ownership of companies. That is not always easy to do because corporate structures are often opaque. The desktop-based due diligence systems in the US and Europe are likely not sufficient, Timur advises. Having someone on the ground in the region is likely needed. Listen in to learn more about what it takes to operate a compliance program in this important part of the world. Listen now

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

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…

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

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

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

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

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

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.

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