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The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the intricate future of corporate compliance amidst changes brought by the presidential executive order suspending FCPA investigation and enforcement. Matt shares insights from a recent Compliance Week event in Boston, highlighting concerns among compliance professionals about the potential obsolescence of their roles. The discussion covers two primary scenarios: regulatory relaxation, making dedicated compliance roles redundant, and technological advancements, particularly AI, potentially replacing human compliance officers. However, both agree on the enduring importance of robust compliance functions integrated within corporate structures, emphasizing the strategic value of compliance in risk management and business operations. They explore the dual excitement and anxiety surrounding AI's role in compliance. Matt and Tom caution against shortsighted management decisions to decentralize compliance functions and highlight how AI can be harnessed to enhance rather than replace human oversight. They argue for proactive measures from compliance officers to demonstrate their value and leverage AI to improve compliance programs. As Matt eloquently puts it, this is a challenging yet opportune time for compliance professionals to up their game and secure their vital role in ensuring corporate integrity and efficiency. Key highlights: The Future of Compliance Post-Executive Order The Role of Technology in Compliance AI's Impact on Compliance Officers Strategic Imperatives for Compliance Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Hui Chen A Pause in FCPA Enforcement: Crisis or Opportunity Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast Learn more about your ad choices. Visit megaphone.fm/adchoices
Episode #65 with Tom Fox & Malcolm Nance, plus Philip Rohlik This episode is devoted to discussing the recent executive order signed by US President Donald J. Trump instructing the Department of Justice to halt enforcement of the decades old, much-dreaded Foreign Corrupt Practices Act (FCPA) pending a one-year review. In our initial “Regulatory Ramblings Spotlight” segment, we speak with Philip Rohlik, an American attorney in mainland China with the law firm Debevoise & Plimpton to get a sense of what the president's decision means for Hong Kong and the broader Asia-Pacific. Following that, we have a lengthier chat on the global implications of President's Trump's move with Tom Fox, a veteran compliance and anti-corruption lawyer, noted FCPA specialist and podcaster, as well as Malcolm Nance, a former US naval intelligence officer, counterterrorism specialist and author. About the guests. Philip Rohlik is a counsel in the Shanghai office of Debevoise & Plimpton LLP. He is a member of the firm's White Collar & Regulatory Defense and International Dispute Resolution Groups whose practice focuses on international investigations, securities law and dispute resolution. He is recognized by “The Legal 500 Asia Pacific – Greater China” (2024-2025) for his anti-corruption and compliance practice and has been described as “very thorough and hands on," and "excellent investigation lawyer". Based in Asia since 2011, Philip leads the firm's dispute resolution team in Shanghai. He joined Debevoise in 2000, having received his J.D. magna cum laude from the New York University School of Law that same year. He received a B.A. summa cum laude with honors from St. Louis University in 1997. Tom Fox is based in West Texas and a prominent member of the compliance community and one of the most well-known legal practitioners when it comes to the FCPA. Over the past 15 years, he has been a general counsel and chief compliance officer. He is now an independent consultant, assisting companies with anti-corruption, anti-bribery compliance, and international transaction issues. He is also the author of the award-winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics.” His podcasts have won numerous w3, Davey, Communicator, and Webby awards for podcasting excellence. Tom is the author of the seminal text “The Compliance Handbook,” now in its 5th edition published by LexisNexis. In addition to his blog and podcast, he is a columnist for “Corporate Compliance Insights” and a contributing editor to the “FCPA Blog.” He is a well-known and frequent speaker on compliance and ethics issues, social media use, and corporate leadership. In the interests of full disclosure, Tom is founder of the Compliance Podcast Network which also carries this program. Malcolm Nance is based in upstate New York. He was a 20-year veteran of the US Navy where he was an intelligence officer and cryptographer, and a Russian and Arab language specialist. In his capacity as a master chief, he was responsible for discipline all throughout the ranks. He is best known for his appearances on MSNBC where he warned about Russian interference in the run up to the 2016 and 2020 US Presidential elections. Malcolm is also a best-selling author – with his books “The Plot to Hack America,” “The Plot to Destroy Democracy,” “The Plot to Betray America” and most recently “They Want to Kill Americans” – all of which are well worth reading. Given the radical actions of the second Trump administration, his two most recent books seem eerily prescient. HKU FinTech is the leading fintech research and education in Asia. Learn more at www.hkufintech.com.
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the TD Bank BSA and AML enforcement action which led to $3bn in fines and penalties. In this episode, Tom and Matt discuss TD Bank's conscious strategy of not raising the budget, known as the Flat Cost Paradigm or Zero Expense Growth Paradigm and how this completely strangled the Bank's compliance and AML functions. This tactic aimed to increase profits by keeping expenditures flat year after year. The impact of this strategy is particularly evident in the global AML team's expenditures on the U.S. anti-money laundering program, which decreased by 2021 compared to 2018. Despite significantly growing U.S. assets and net income, the bank refrained from increasing its budget for essential programs, a fact highlighted in the Justice Department indictment. The Bank's strategy is a clear warning when a business puts profits over compliance. Key Highlights · Introduction to the Flat Cost Paradigm · Details of the Budget Strategy · Impact on Anti-Money Laundering Efforts · Financial Growth Amidst Budget Constraints Resources 1. Blogs Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog 2. Tom Instagram Facebook YouTube Twitter LinkedIn 3. Enforcement Related Material A. OCC OCC Press Release Consent Order Civil Money Penalty B. DOJ TD Bank US Holding Company Information TD Bank N.A. Information TD Bank US Holding Company Plea Agreement and Attachments TD Bank N.A. Plea Agreement and Attachments Merrick Garland Remarks Nicole Argentieri Remarks Learn more about your ad choices. Visit megaphone.fm/adchoices
Tom Fox is passionate about podcasting and compliance. He is the Leading Voice in Compliance, having founded the only podcast network in compliance, the award-winning Compliance Podcast Network. Tom is also a co-founder of the award-winning Texas Hill Country Podcast Network, which focuses on a rural area of Texas. Tom has won 33 awards for podcast hosting and producing podcasts. He is also an award-winning blogger, having posted the FCPA Compliance and Ethics Report daily since 2010.Tom is also a best-selling author, having written 30 books in the areas of compliance, business ethics and leadership. He is the author of the seminal compliance work, The Compliance Handbook, now in its 4th edition. He is author of two other international best-sellers on compliance; Lessons Learned on Compliance and Ethics and Best Practices Under the FCPA and Bribery Act. He is most proud of his 3 best-selling children's books on compliance Being a Compliance Officer is Awesome, Speaking Up is Awesome and Compliance Saves the Galaxy. All 3 were published by Dinosaur House and are available at Amazon.com.Become a supporter of this podcast: https://www.spreaker.com/podcast/inspiring-stories--2917948/support.
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the speech by Principal Deputy Assistant Attorney General Nicole M. Argentieri at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. Argentieri, revealed substantial updates to the department's Evaluation guidelines for effective compliance programs, focusing on whistleblower protections and the effectiveness of reporting mechanisms. Matt, reporting live from Dallas, discussed the implications of these updates, especially regarding the DOJ's increased scrutiny on companies speak-up cultures and the protection of whistleblowers. Tom and Matt explored the practical steps compliance officers need to take to meet these new DOJ expectations, including ensuring anonymous reporting mechanisms are well-publicized and effectively utilized, fostering a culture that encourages reporting without fear of retaliation, and aligning company policies with the latest external whistleblower protection laws. They also touched on the potential challenges of balancing AI risks with these new guidelines and the broader impact on compliance programs. Key Highlights · Key focus on enhancing whistleblower protections. · Compliance officers must ensure that reporting mechanisms are well-publicized. · Importance of aligning internal policies with external whistleblower protection laws to ensure comprehensive employee training. · The balancing the challenges of AI risks with the need to adhere to new DOJ guidelines. · The practical steps for compliance professionals to align their programs with DOJ's evolving expectations. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you compliance related stories to start your day. Sit back, enjoy a cup of morning coffee and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership or general interest for the compliance professional. · DOJ releases 2024 Update to the Evaluation of Corporate Compliance Programs. (FCPA Compliance & Ethics Blog) · Jackson Walker referred for disciplinary proceedings. (Reuters) · Singapore gears up for huge corruption trial. (Al Jazeera) · UK government says flexible work better for companies. (BBC) For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here. Check out the full 3-book series, The Compliance Kids on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the recent Department of Justice (DOJ) declination for the Boston Consulting Group (BCG). They highlight why this case garnered significant attention and dissect the substantive actions BCG took to avoid prosecution, including firing implicated employees and forcing equity forfeiture. The duo also explores the seven factors that led to the declination, such as timely self-reporting, full cooperation, and improved compliance measures. The episode provides a comprehensive analysis of the BCG case, offering crucial takeaways for compliance officers on how to handle potential corruption issues and DOJ expectations. Key Highlights: Overview of the Boston Consulting Group Declination DOJ's Factors for Declination Full Cooperation, Timely Self-Disclosure and Employee Consequences Remediation Efforts and Compliance Improvements Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the Plea Agreement filed by the DOJ in the Boeing criminal case. Today we delve into the proposed plea agreement between the Department of Justice and Boeing, following violations of the company's 2021 Deferred Prosecution Agreement (DPA). We discuss the detailed aspects of the plea, including a $243 million criminal penalty, a $455 million compliance investment plan, a three-year prosecutor probation with a compliance monitor, and a unique interaction between Boeing's board and the families of crash victims. Matt and Tom also explore Boeing's obligations to integrate safety and quality programs with its ethics and compliance initiatives, and the implications of these stringent new requirements. Key Highlights: Boeing's Compliance and Safety Issues Expansion of Corporate Compliance Role Implications for Boeing's Compliance Culture Monitor, Oversight, and Victim's Families Role of the Board and Compliance Spending Future Considerations and CCO Certification Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn 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 Jay Rosen who discusses the recent FCPA enforcement action involving the software giant SAP. Jay Rosen is a seasoned compliance professional with a deep understanding of the SAP FCPA enforcement case. His perspective on the topic of SAP's FCPA enforcement case and the importance of cooperation and self-disclosure is shaped by his belief that self-disclosure is paramount in any FCPA investigation or enforcement action. He points out that SAP did not initially self-disclose, but began to cooperate only after investigative reports were made public in South Africa. Despite this, Rosen acknowledges SAP's commendable efforts in providing regular, prompt, and detailed updates to the fraud section, producing relevant documents, and undertaking extensive remediation actions. He underscores the importance of conducting a root cause analysis, implementing data analytics, and enhancing compliance programs and internal controls, asserting that companies can recover if they follow these steps and use data-driven analytics to counterbalance any negative facts. Join Tom Fox and Jay Rosen as they delve deeper into this topic on this episode of the FCPA Compliance Report. Key Highlights: The facts and underlying bribery schemes Lack of self-disclosure and what it means Extensive cooperation Extensive remediation A superior result achieved Resources Jay Rosen on LinkedIn Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on Ethico and a free White Paper on top compliance issues in 2024, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the ERP software giant SAP. The recent $220 million fine imposed on German software giant, SAP, for violations of the FCPA underscores the critical role of internal audits in maintaining corporate compliance. Despite having a comprehensive FCPA compliance program, SAP's lack of control over its subsidiaries led to bribery activities, a situation that Tom and Matt believe could have been prevented with a robust internal audit function. Fox emphasized the need for strong internal audits to identify and address issues within different parts of an organization. Similarly, Kelly, underscored the importance of internal audits in identifying and rectifying control lapses. To delve deeper into this topic and understand the implications of the SAP case, join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds. Key Highlights · The bribery schemes and geographic scope · What is culture? · Third parties and corruption risks · The fine and penalty · The comeback · Lessons learned for the compliance professional Resources Matt on Radical Compliance Tom Tom on the FCPA Compliance and Ethics Blog Instagram Facebook YouTube Twitter LinkedIn For more information on Ethico and a free White Paper on top compliance issues in 2024, click here. 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 Ryan Lougheed, Director, of Product Management at Onspring. Ryan Lougheed has over twelve years of experience in the Governance, Risk, and Compliance (GRC) field, currently serving as the director of a platform at Onspring, a SaaS GRC platform and business process automation platform. Drawing from his background in esports, Lougheed believes that teamwork and communication are crucial in both the GRC space and the world of esports. He emphasizes the importance of effective and efficient communication, especially in high-stress situations, and believes that these skills can be carried over to a compliance-focused career. In the context of esports, Lougheed explains that communication is vital in a team of five players and that professional esports organizations provide resources such as physical trainers and sports psychologists to support their players' communication skills. He also notes that the esports industry is evolving, with larger companies creating brands around individual streamers and organizations acting as agents to help grow the streaming culture. Join Tom Fox and Ryan Lougheed on this episode of the FCPA Compliance Report podcast to delve deeper into the importance of teamwork and communication in GRC. Key Highlights GRC Collaboration and Communication Streamlining compliance with Onspring's centralized platform Streamlining Communication in High-Stress Compliance Situations Leveraging Esports Skills for GRC Success Resources Ryan Lougheed on LinkedIn Onspring Tom Fox Instagram Facebook YouTube Twitter Learn more about your ad choices. Visit megaphone.fm/adchoices
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I dive into the hot topic of clawbacks, with a focus on Deputy Attorney General, Lisa Monaco's new pilot program and Kenneth Polite's take on the use of prosecutorial discretion for organizations. Our hosts explore the opportunities for corporate compliance and HR personnel for clawback solutions and the use of the Federation Corrupt Practices Act (FCPA). They also discuss the need for thorough documentation of personnel involved with and/or accused of illegal conduct, as well as the potential costs to shareholders. Bottom line: Tom Fox and Matt Kelly are here to take you on a deep dive into the complexities of clawbacks and help organizations get compliant and stay compliant. Key Highlights Prosecutorial Discretion and Credit [00:05:24] Implications of the Foreign Corrupt Practices Act on Corporate Compliance and HR [00:09:41] The Mathematics of Corporate Policy Development and Management [00:13:59] Corporate Compliance and the Foreign Corrupt Practices Act [00:17:47] Balancing Compliance and Risk in Business Practices [00:21:49] Notable Quotes: 1. "It is part of the department's larger effort to hold individuals more accountable and to have companies basically be participants in that project and to have companies embrace the culture of compliance, how would you hold individuals accountable if you're the company, you'd have that clawback clause over their head, and then you would now have more incentive to actually use it, which is not necessarily an easy thing." 2. "What we expect companies that use programs to address not only employees who engaged and wrongdoing a connection with conduct under investigation, but also those who had supervisory authority over the employees or business area engaged in in the misconduct and knew of or were willfully blind to the misconduct." 3. "You must have the clawback policies in place, at the time of resolution, then get a reserve credit for those clawback compensation moneys that you must successively claw it back within the term of the resolution." 4. "If you do try to recoup the compensation and you fail, you'll still be eligible for up to 25 percent of whatever you were trying to recoup."" Resources Matt in Radical Compliance Tom in FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into recent decision by the Delaware Court of Chancery in the McDonald's case creating a duty of oversight for corporate officers. Some of the highlights include: · Why bad facts can make bad law? · The sordid facts of David Fairhurst during his tenure at McDonald's. · The legal rationale. · What is Caremark and how did it influence this decision? · What does it mean for CCOs? · How does this decision intertwine with the Monaco Doctrine, CCO certification and the new Corporate Enforcement Policy? Resources Tom with a multipart series on the FCPA Compliance and Ethics Blog Matt Kelly with two posts in Radical Compliance 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. In this episode, we consider the ABB Foreign Corrupt Practices Act resolution. We deep dive into the case and ask three key questions: (1) How did ABB obtain such a superior resolution? (2) As a three-time FCPA violator, how did the company avoid a monitor? (3) Why was there no requirement for Chief Compliance Officer (CCO) certification? Some of the highlights included: The background facts. The corrupt supplier's ABB used to facilitate their bribery and corruption. The convoluted self-disclosure in this matter. (Should they have used Twitter with the notation #committedbribery?) What constituted extraordinary cooperation during the pendency of the investigation? What are the implications of real-time sharing during an investigation? What were the steps which demonstrated the exception remediation? A root cause analysis is a basic Hallmark of an effective compliance program. Why was it separately called out? Did the DOJ change its policy from mandatory CCO certification to discretionary? Resources Tom has a five-part series in the FCPA Compliance and Ethics Blog Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices
As the world emerges from a pandemic mindset, we find ourselves confronting new geopolitical realities with Putin's war in the Ukraine as well as increasingly fraught relations between the US and China. How is this geopolitical landscape changing the compliance landscape? In this episode of the Principled Podcast, host Susan Divers is joined by Tom Fox, the founder of the Compliance Podcast Network and aptly accredited “Voice of Compliance.” Listen in as the two discuss the impact of geopolitics on ethics and compliance, and what issues should be top-of-mind for E&C leaders in the near future. To learn more, download a copy of Tom Fox's white paper Never the Same: Five Key Areas in Which Business Will Never Be the Same After the Russian Invasion. Featured guest: Tom Fox Tom Fox is literally the guy who wrote the book on compliance with the international compliance best-seller The Compliance Handbook, 3rd edition, which was released by LexisNexis in May 2022. Tom has authored 23 other books on business leadership, compliance and ethics, and corporate governance, including the international best-sellers Lessons Learned on Compliance and Ethics and Best Practices Under the FCPA and Bribery Act, as well as his award-winning series "Fox on Compliance." Tom leads the social media discussion on compliance with his award-winning blog, and is the Voice of Compliance, having founded the award-winning Compliance Podcast Network and hosting or producing multiple award-winning podcasts. He is an executive leader at the C-Suite Network, the world's most trusted network of C-Suite leaders. He can be reached at tfox@tfoxlaw.com. Featured host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years' accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM's Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM's ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers' thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company's ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative. Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics. Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers: General Pete Schoomaker made a remark some years ago that's always stayed with me. He said, "People like to think that life is an opera that unfolds over several acts, but it's really a rodeo. You never know what's coming out of the shoot." So much of the ethics and compliance sphere clearly demonstrates the truth of the general's remarks, especially recently. LRN's last two program effectiveness reports focused specifically on the impact of the pandemic on ENC programs. Now we have the war with Russia in the Ukraine and increasingly fraught relationships with China. How is the geopolitical landscape changing the compliance landscape? Hello and welcome to another episode of LRN's Principled Podcast. I'm your host, Susan Divers, director of thought leadership and best practices at LRN. Today, I'm joined by Tom Fox, the founder of the Compliance Podcast Network and aptly accredited Voice of Compliance. In addition to his 30 plus years of legal experience, Tom is the author of the award-winning FCPA Compliance and Ethics blog, and The Complete Compliance Handbook now in its third edition, which is by far the best source for best practices in one place about ENC programs. We're going to be talking about the impact of geopolitics on ethics and compliance and what issues should be top of mind for ENC leaders in the near future. Tom, welcome. Tom Fox: Susan, thanks. I have wanted to be on this podcast for a long time. I particularly enjoyed your reference about rodeos because in the great state of Texas, that's a college sport, rodeoing, so lots of rodeos and it's certainly an apt metaphor for what we're going to talk about today. Susan Divers: Well, great, Tom and I really appreciate the opportunity to have any conversation with you, but particularly on the podcast. So Tom, first, generally, how do you see the ongoing war in the Ukraine as disrupting trade and the rules, both formal and informal, that have governed the world for the last 20 years and is the World Economic Forum vision of trade now dead? Tom Fox: Susan, in addition to the rodeo metaphor you gave us, the most prescient comment I heard during the COVID-19 pandemic is that we've moved from disaster recovery to business interruption to, excuse me, to business resiliency, to business as usual. Literally now, we can have a weather event, we can have an economic event, we can have a geopolitical event, we can have any event and the requirement of a company is how do you respond? How do you respond tomorrow? Have you planned for this? I think the type of thing that we saw with the Russian invasion, as tragic as that was, it's one more, it's just an event and we're going to talk about that in some detail. But every company has legal, ethical and business obligations around that event. I was also particularly struck by your reference to the World Economic Forum, and when I read that, it put a frown on my face. And it put a frown on my face because the World Economic Forum, in my mind, has been one of the biggest leaders for the global economy. Since at least 1990 when I started paying attention to a global economic framework because I was in the energy industry and began to think about these issues on a global basis, the World Economic Forum and their symposiums, their position papers and really their raison d'etre was to talk about a global economy. Although I certainly thought we would have regional conflicts, as we have always had, I never thought we would, I guess my hope was that the global economy would help drive us towards a more integrated global community and that we wouldn't be put near a brink again of a global conflict. I don't pretend to say that's where we're going in Ukraine, but when you start talking about tactical nuclear weapons, that's a conversation we haven't had in this country since the '60s with seriousness. The World Economic Forum, the world they envision, the world you and I grew up in professionally, I think that world is gone. We're moving to something else. I use the Russian invasion of Ukraine really as an ending point or an exclamation mark on trends that we have seen percolating probably 10, 5, 3 years that accelerated extraordinarily greatly in the COVID-19 pandemic up to the war in Ukraine and the disruption that that has caused really impacts businesses, and this is going to be something, I think, we're going to have to deal with literally on an ongoing basis forward. Lots, really, to unpack there, but I do have to acknowledge you for pointing out it was really the World Economic Forum that has led, I thought, the charge for a global economy and globalization and unfortunately, I think that world is now dead. Susan Divers: I hear you and I feel the same way about the Forum. LRN participated in it quite actively until fairly recently, and the Forum really did an excellent job of helping global leaders cooperate, frame some of the rules and the practices. Maybe when the current situation resolves itself one way or another, there'll be an opportunity to do that again. But getting a little bit more granular at this point. You've written about the impact of the Ukrainian war on the supply chain and certainly for business that's one area where the rubber really hits the road. Can you explain that a bit to our listeners? Tom Fox: Sure. The Ukraine War, the Russian invasion of Ukraine, as I said, put a exclamation point on this. One of the key disruptions from COVID-19 was indeed supply chain. Here, I think for the first time, Susan, we started to look at geography as a risk. Geopolitical risk has been known for quite some time, but with the COVID-19, we have the swaths of the world that were unavailable to us because of the pandemic. As the pandemic raged through China and moved to India and moved to Africa, large parts of the global supply chain were literally shut down completely and they couldn't get back up, couldn't get running again. We saw, from COVID-19, a geographic risk that we have perhaps not considered as much before. This is different than an island that may worry about climate risk or flooding or fires in California or something like that. We had real geographic risk. The Ukraine War really put an exclamation mark on geopolitical risk. What is the risk? What was the risk in 2019 of Russia invading Ukraine? Certainly there were discussions at the highest level of our government. Frankly, I don't think you and I, wasn't on our radar. Maybe if you read foreign policy, it was on your radar, but for the business practitioner, from the compliance professional, I don't think we were thinking about a Russian invasion and what that might do to either our supply chain or business partners or customers. Well now, if the Ukrainian grain cannot be put in the global food supply chain, that's a huge disruption. The question that I thought about is what would be the effect of the disruption of the global food chain on one of our former employers, Aecom, Halliburton, businesses that you and I have both been involved with, but we don't think of as having perhaps a food risk. Nevertheless, if grain is not available, what do those types of risks mean for employees in allegedly or apparently unrelated companies? Companies have to start thinking about these kinds of things in ways that we haven't done before. I did a podcast earlier this week where someone said, "Look, the issue now is China and Taiwan." And he was absolutely right. That could be a military issue, could be a geopolitical issue. 82% of US semiconductors are made in Taiwan. That's a huge issue. Let's go back to our former employers who are now heavily invested in tech and actually use semiconductors as part of their manufacturing process. They're going to be impacted, let alone the US semiconductor industry and the US computer industry. That is something now that we have to consider. Are there any other geopolitical conflicts that could erupt, which might negatively impact our supply chains? And when I mean negatively, I mean you can't get your supplies out of those countries, whether it's a raw mineral, whether it's a extractive mineral, whatever it may be. Those types of issues now are more front and center than they ever have been. From the business perspective, Susan, supply chains, since at least the late '70s or early '80s, the primary goal was efficiency. That was generally translated to just-in-time. It was seen because of the experience in the '60s where particularly in the auto industry, you had lengthy supply chains and actually large number of parts piling up in warehouses that was deemed to be inefficient. They wanted it just before they needed it. That led to just-in-time. That led to one or two suppliers. We found that sole suppliers or sole plus one suppliers has a risk. That risk is, if they're in a geographic area that's wiped out by COVID, if they're in a geopolitical area that is no longer available to us, then we, as a company, have a problem with our supply chain. Certainly there are many industries that have been offshored outside of the United States. From our industry and service, or rather service industry folks like us, to manufacturing, to everything in between. That is now trying to be reshored on American soil. Can we do it? Yes. Can we do it tomorrow? Probably not. Can we do it in time for Christmas? Probably not. We're going to have to retrain, we're going to have to retool. We may have to allow greater immigration to get people in to do those jobs and it brings up an entire series of questions. It brings up economic questions. How much more is it going to cost to reshore? How much more does it cost and pay an American wage as opposed to a Philippine, Bangladeshi or other wage? Or you name the country outside the United States where the wages are disparate. All of those issues are now in play in a way that certainly they were percolating around and percolating along in the second half of the last decade. COVID-19 accelerated those conversations, particularly around just-in-time and sole source suppliers. But now, I don't know how much of the globe Russia consists of. I think at one point, it was 12%. That's not available to us as a supply chain partner now and Russian partners are not available to us as supply chain partners. Now, what happens if China is not available to us as a supply chain partner or Taiwan because of an armed conflict with China. How is that going to play? Or can we even get semiconductor chips out of Taiwan if they're in an armed conflict with China? All of these issues are now front and center and I think every company has to be looking at their supply chain, who's in their supply chain. Then obviously, this ties into things that were not deemed to be connected to all of these issues before, such as conflict minerals. Conflict minerals required you as a company to determine or any of the minerals you're buying, the four Ts, I think, coming out of countries primarily in Africa under conflict. This was the first time companies had really taken a deep dive, not to their direct suppliers, but to their sub-suppliers and they found out we don't exactly know who all of our sub-suppliers are. Obviously the Uyghur Forced Labor Prevention Act has huge impact on supply chains and hopefully, we can talk about that at some length in a little bit, but all of these issues on supply chain, it's elevated the discussion of the corporate supply chain, I hope, to where it properly belongs, in the board of directors level. But for the people that we deal with, the CCOs and compliance professionals, I think it should be a part of an equal conversation because what are the risks? I was going to say implications, but what are the risks of moving your supply chain, reshoring it? It's a change so the risks change. It may not be an FCPA risk because you may be in the United States, but almost every state in the US has an anti-corruption law and a state anti-corruption law. I had to look at it one time, 37 states do. That's not that you can't bribe our state government officials, every state says that, but 37 with regular commercial private or private anti-bribery laws. When was the last time you, as a compliance professional, had to assess that issue, that risk? Lots of new risks and you, as a compliance professional, need to be a part of those discussions so you can begin preparing your corporation for those eventualities. Susan Divers: Well, that's a perfect example, or I should say it's an example on steroids of how you have to respond to the risks that face you today and hopefully, tomorrow, try to look around corners. I remember, I think it was in the 2020 guidance that DOJ put out. They said that you can't let your program be a snapshot in time or go on cruise control. That's one of the biggest traps I see people fall into. You ask them what their risks are and it's kind of like what the risks were last year. With this environment and with what you just outlined in terms of supply chain, there's going to be a lot for compliance teams to do. How should people be addressing that right now? I know we'll talk later about sanctions and anti-money laundering being the new FCPA as Deputy Attorney General Monaco said recently, but what's your advice today in terms of how to think about those risks? Tom Fox: Susan, you hit it exactly on the head. Assess your risks when your business changed. You reference the 2020 update to the Evaluation of Corporate Compliance Programs. That's where the first time the Department of Justice formally said, it's not an annual risk assessment. It's not a biennial, all-encompassing $100,000 risk assessment. It's an assessment when your business changed. The beauty of the timing of that statement, it was June, 2020, everyone's risk had changed because we were working from home. It didn't mean your risk increased or decreased, they changed. How do you assess working from home or how did you assess working from home from a compliance perspective? Once you made that assessment and then you found there were actually new risks, then you had to put a risk mitigation strategy in place, then you monitored that strategy to determine its effectiveness and then you used that information to upgrade your compliance program. The formula is in place for all of these things, but it starts with exactly what you said, Susan, assess your risks if your business has changed and everyone's business has changed literally, particularly in the supply chain. You've got to know who your suppliers are. From the business perspective, who can supply us is paramount. Pricing is going to be paramount. But from the compliance perspective, where are they getting those? If you're a clothing manufacturer, how many of your suppliers are coming out of Bangladesh and how many of those suppliers are violating any sort of fair trade or human rights laws? Even what's the safety, as we know from the Plaza collapse a few years back in Bangladesh. You have to know who's in your supply chain to a level and degree that you didn't previously think about unless you were in conflict minerals. But the beauty of that is that if you make that assessment down into your sub-suppliers from your supply chain, you as a business will be stronger. You will see, number one, if there are inefficiencies in our supply chain, but two, if there's a disruption, you'll be able to mitigate that if a disruption occurs because you can move to another supplier because you know where the parts are coming in from and hopefully, you'll be able to have prior knowledge or planning around that. But think of a weather event. In 2021, I was living in Houston. It hit seven degrees. That was the first time we'd had single-digit weather in Texas since 1890. Well, we can't prepare for that, yeah! This is a town that had gone through two 500-year floods and 1,000-year flood over the past 18 months. We had a wildfire north of Houston. We'd never had a wildfire in Houston, Texas in my lifetime. All of that's to say is that things have changed. I don't pretend to say I know which way it's going, I just know that you have to be there. You have to have assessed those risks and have a plan in place if you can't utilize all the way down in your supply chain, but that gives you the opportunity to be more business efficient and if a catastrophe does occur, you're more quickly able to respond. Starts with a risk assessment, put a risk management strategy in place, monitor that strategy, and then improve your compliance program as information becomes available to you. Susan Divers:I totally agree with that, Tom and I want to relate it back a little bit to a point you raised earlier too, which is this gives you an opportunity to make sure that you're dealing with ethical sub-suppliers and that your whole supply chain meets spec. I think I've seen in the past, in my long years as an ethics and compliance lawyer, and before that as more of a specialist on FCPA that a lot of times, people don't know who their sub-suppliers are and the first they find out is when there's fraud or potential bribery issue or diversion or a theft of intellectual property. It does give you an opportunity to get a more solid grip on your suppliers and make sure that they are the right people that you're dealing with. Let's turn from that, which is I think a very good segue to the issue of economic sanctions. There's really been a quantum leap in that area, even it was starting before Russia, I think, with the sanctions on Huawei and the heating up of tension in the US-China relationship, but now it's on a completely different level and that really, I think, has to be top of list for companies when they review their ENC programs. Can you talk about that and give us some guidance? Tom Fox: Sure. Once again, Susan, let me use the Russian invasion as the exclamation mark because under the Trump administration, we saw an exponential increase in the use of trade and economic sanctions. I had several friends in that space and every once in a while, I'd email them, "Well, we had three changes today. What do you expect this afternoon?" The point being that the prior administration saw those as legitimate and important tools for US national security. That has only increased now on steroids because of the Russian invasion. What the Trump administration's use of those tools did was it elevated the discussion of the trade compliance director in a corporation to the board of director level. It may have elevated them within the compliance function or generally within the C-suite because people now had to call trade compliance and say, "Anything new today?" Well, the sanctions that have come out after the Russian invasion have been all encompassing. Now, I looked before this podcast, I think we're on our seventh round of sanctions and more to come. That's seven rounds from the United States. That doesn't even count the UK and Western Europe who have equally sanctioned Russia. Many US multinational companies are also subject to UK or EU trade sanction directives. You need to be cognizant of those. But the current trade sanctions that have been levied, and when I say there's still more to come, we haven't gotten to the nuclear option, which is secondary sanctions. If we get to secondary sanctions, that's an entire level of trade and economic sanctions literally that we have not seen since World War II. Discussion though, around trade sanctions, and once again, I've talked to several of our colleagues who have that as their specific compliance remit and their specialization is they now feel elevated within the corporation. They feel that the issues they've been dealing with, their professional careers are now being discussed literally at the board of directors level because of these huge potential fines and penalties, the huge visibility. As important as these legal restrictions are, Susan, it's actually the reputational damage. Just think about the companies that either drag their feet about leaving Russia or were slow or less than somebody's idea of we need to be out of there. They were excoriated in the press for doing business in Russia after this invasion. Those conversations have largely on by the wayside because I think most US companies are out of Russia now, but the reputational damage for the violation of trade sanctions or even some sort of norm or standard now costs more than perhaps even the finer penalty would've cost. It's really a huge change for our colleagues. It's an important change because now, those issues are being evaluated together with supply chain at the board level in a way they have not been previously evaluated. You may now need to look, you need to call your trade director of trade compliance about issues in your supply chain. You need to call your director of trade compliance about where are we doing business? How are we doing business? Who are we doing business with? Who's our customer base? Are we selling with commission sales agents, company employees or distributors? If we're using distributors, are they reselling our products into Iran? Are they reselling our products into a country that's exporting to Russia? All of those issues now, I think, are being discussed at the highest level of a company. But for me, Susan, the real beauty of this discussion is finally, I think, the silos are coming down within a corporation and you're seeing a much more holistic approach to many of these issues that we'd not seen previously. Once again, if I could go back to the DOJ's June, 2020 update to the Evaluation of Corporate Compliance Programs as presaging all of this, they said in that document compliance must have access to all data silos within a company because compliance needs to know what everyone's doing so compliance can do its job. Well, that turned out to be true, but it turned out to be true much broader. I think the DOJ was onto something when they said that, and I think now, companies are realizing you have to have this holistic approach. Trade sanctions and export control sanctions are here to stay. The other insight from the Trump administration use of them and the Biden administration use of them is they're administration agnostic. They're not going to go away and if 2024, we have a Republican administration, they are probably going to continue those and they're not going away. If there's a Democratic administration, they're not going away. They're probably going to continue those. Sanctions, trade sanctions, export control sanctions are here to stay. They're probably going to get more robust. And until Russia pulls out of Ukraine, I think companies have to take these very, very seriously, both for a potential legal finer penalty, but even more important is in the commerce or the business place of public opinion. Susan Divers: I totally agree with everything you've said and you've made a very articulate vision of what a major challenge is for compliance teams. The only thing I would add is, it's interesting to me, that this can affect small and medium-sized companies that don't think in these terms and may not even really be very sophisticated. When I was looking a couple of months ago, I came across a case involving a false eyelash manufacturer who was importing what turned out to be false eyelashes that sourced in North Korea. I mean, it was a Chinese supplier, but the sub-supplier was North Korean and they got in trouble. As you know, it doesn't really matter if you don't know. That's no defense and they paid a fine for that. It was a good reminder that trade sanctions can affect everyone and that you really, hopefully, have to have that on your radar. Let's take an interesting topic off of this, which is have the enhanced sanctions started to really impact whistleblowers? I mean, we know that FCPA enforcement has certainly inspired a lot of whistleblowers, as well as SOX and other areas such as that. But what about trade sanctions and what about AML and what we're seeing? Tom Fox: That's been, I don't want to say it was an unintended consequence, but one of the most interesting outcomes or aspects of the Russian invasion. For the first probably 30 days, the most ubiquitous picture of the Russian invasion was a yacht steaming away because it was a Russian oligarch's yacht and they were trying to steam to a port where the US couldn't come in and forfeit them because of trade sanctions and sanctions put on the Russian oligarchs. But here's what happened. On January 1st of 2021, US Congress overrode President Trump's veto of the National Defense Authorization Act. In that bill, there was something called the AML law of 2020. The AML law of 2020 was the first update to our anti-money laundering laws and trade sanctions laws since the Patriot Act passed in the wake of 911. As part of that change, a bounty program for whistleblowers was put in place similar to the SEC bounty program put in place in Dodd-Frank. That Department of Treasury money laundering or anti-money laundering bounty program applies to those Russian yachts because if a yacht is seized and sold, the person who reported it can be eligible for up to 30% of the proceeds of that sale. This created an entire cottage industry of marine yacht hunters who knew and they are working with law firms to actively, and when they find one in a port that the US can get jurisdiction over, these law firms notify the DOJ and then the DOJ does whatever they need to do to try to get seizure of that yacht in a foreign country. That was viewed as hugely popular and the American public is cheering them on in a way whistleblowers have never been cheered on in our lifetimes. I remember I interviewed a woman whose law firm specializes in whistleblowing and I said sort of in an offhand manner, "Are you telling me that whistleblowing is sexy?" Her response is, "You mean, it hasn't always been that way?" No, it hadn't. But now, it was seen as directly in the interest of the United States, particularly our national security for these whistleblowers to come forward. As important as whistleblowing is to the SEC, I don't think it had ever been considered a national security issue. That ties to what the Department of Treasury has announced publicly that they expect US corporations to be in on the fight of trade and economic sanctions and money laundering by self-reporting. I had had a little trouble tying self-reporting of your own violation to the fight against national security. But what the Treasury Department argued was, come to us, tell us if you find people within your organization violating trade sanctions or economic sanctions and we'll give you credit for that, that may be a declination up to it, including a declination. The DOT has truly tried to incentivize companies to be a part of this fight and that is now the same for whistleblowing. Whistleblowers are now seen. There's one other document called US Strategy on Combating Corruption, which came out in December, 2021. In that document, the Biden administration pointed to whistleblowers as a component of the fight against bribery and corruption, which that document elevated to national security status. Now, we have whistleblowers who before the Russian invasion, certainly were a part of the legal landscape and part of the compliance landscape, but now they're being told, you are a part of our national security interest and you are a part of our national security fight and if you bring us this information in the form of blowing the whistle, you will be rewarded. The US public is saying, you go. You go find those yachts. You go find those people who are doing business with those that are not in the national security interest of the United States and we'll support that. That's, in my mind, just a huge psychological change. Susan, I know you have written and said more about whistleblowing and how to treat whistleblowers than about anybody and I know this is something that you've been talking about for a long, long time, but I really see this as a true shift in the way whistleblowers are thought of in the United States. Susan Divers: Well, I'm glad you brought that point out because I think that's true. Tying it furthermore to the impact of corruption on national security, I think is an idea whose time has come and we're going to do a whole other podcast on that as part of this series so I won't get into it a lot. But the concept of corruption as a victimless crime has been around as long as I've been practicing, which is a long time. It's not a victimless crime. I don't need to convince you. But it basically corrodes good governance, it corrodes social structures, it makes it harder for the poor. I mean, if I can go bribe my way, get a MRI ahead of everybody else in some less developed country, I'm jeopardizing the other people who can't afford that in that country and I'm also corroding ethics and good governance, but it hasn't been seen that way in the past, either by the government really or in the corporate community, and so we'll get into that more in the next podcast. But that's fascinating to tie the whistleblowing into that and it has the additional benefit of being true, if you will. I have to say, I love the image of the yacht hunters. It's one of the first things I read when I open The Wall Street Journal in the morning to see if there's some oligarch's yacht that's being towed away or whatever, but it's definitely an idea whose time has come. Tom Fox: For those of you who think our ever new ideas, I think if you look back in history, that was called piracy and or rading by English- Susan Divers: Letters of marque. Tom Fox: Yes, exactly. Letters of marque. It's an old concept, but it's equally valid today. Susan Divers: Well, let's close off this session because we're going to do another podcast and talk more about anti-corruption and sustainability. But one of the things I was curious about is how does all of this tie in to the level of transparency that we're seeing in international trade, in commerce? Our chairman of the board, Dov Seidman, whom I know you know of and know has written a lot in the past about radical transparency and how does that tie in to what we've been talking about? Tom Fox: Susan, let me go back to 2015 and the Volkswagen emission testing scandal. I read a speech by the head of the German Manufacturer's Council, so the German trade group for manufacturers. In that speech he said, "The answer is compliance and transparency." One, be in compliance, but two, be transparent about it. That is how we, as a German industry, will get through this. Volkswagen has done what they've done. We can't stop that or do anything about that, but we, the rest of German manufacturing, can be in compliance and can be transparent about that compliance. That really struck me at the time and it stuck with me since then. The transparency, the radical transparency that Dov talks about is even more important in 2022 because of things like the Business Roundtable Statement on the Purpose of a Corporation. How many stakeholders are there now? Previously, there have been only shareholders, but now you have multiple stakeholders. It can be your employees, it can be your third parties. It can be those localities where you do business and that's where that radical transparency is so critical because they may not own shares and they may not be able to vote, but they can vote with their pocketbook. The radical transparency allows you to demonstrate to stakeholders who are going to vote with their pocketbook that we do business ethically and we are in compliance, and that you can and should do business with us because our values are what your values are. That's, to me, the power of radical transparency and it's the ability to demonstrate to those who are not regulators. Because remember, if you're fined for a regulatory violation, that's seen as a below the line sunk cost. Just the cost of doing business. Tell me how much my fine is and I can reserve for it, whatever it is. What I cannot reserve for is if 5, 10, 25 or 50% of my customer base chooses not to buy my products because I've been found to have violated sanctions or I've been found to have used Uyghur labor in product site sourced out of China, or you name the issue. That's not a bottom line cost. That's a top of the line cost. That's a cost you can never get back because you can't reserve for non-sales. It's a cost you can't anticipate, you can't reserve for, you can't mitigate the risk because once you don't have sales, you don't have sales. To me, that concept of transparency, that concept of doing business ethically, in compliance and that concept of radical transparency all really protects you and allows you as a corporation to say, "This is what we stand for. This is why we're proud to sell a product to you and hopefully, you're proud to buy a product from us." Susan Divers: Well, you're right and that really tees up the heart of sustainability. Sustainability isn't one giant checklist after another. It's what are we really doing and how are we doing it? What you're also saying too is, and it ties with things Dov said in the past, that we live in an age of radical transparency where anyone can go on Twitter, I guess, if they pay the $8 now or post on Facebook or Instagram or wherever and expose concerns. And with the incredible increase in sanctions and money laundering controls, it's just a further reason, if anyone needed one, why you have to get your house in order and you have to make sure that you are dealing with those risks effectively and of course, walk the walk as well as talk the talk. We are running out of time, unfortunately, but I'm excited to mention again that we're going to continue this conversation in an upcoming podcast. It's been such a pleasure having you today, and I know we could keep talking for another couple of hours, but we'll have further opportunities in the future. Tom Fox: I always have way too much fun when you and I sit and chit chat, whether it's over a lunch, a coffee, or a podcast, so thank you, Susan. Susan Divers: Oh, I feel the same way, Tom. My name is Susan Divers and I want to thank you all for tuning into the Principled Podcast by LRN. Outro: We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance and global organizations by helping them foster winning, ethical cultures rooted in sustainable values. Please visit us at lrn.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts or wherever you listen. And don't forget to leave us a review.
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent SEC requirement for companies to publicly report clawback provisions and their effects in conjunction with the DOJ requirements for clawbacks. Highlights include: · What are clawbacks? · What does the SEC rule require? · Are clawbacks the mirror of executive incentives? · How does the DOJ position, as laid out in the Monaco Memo differ (if any) from the SEC requirements? · How far down the corporate chain must a clawback provision impact? Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices
The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent guilty plea by Lafarge, the French cement giant now owned by Holcim, for paying bribes and protection money to ISIS and doing business in Syria with ISIS. Highlights include: · What are the background facts? · What were the bribery and payment schemes? · What are the compliance lessons learned? · How will the victim status play out? · Who will guarantee the compliance of Lafarge with the Plea Agreement. Resources Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced SEC Foreign Corrupt Practices Act enforcement action involving Oracle. Highlights include: Recidivist behavior in same countries with similar schemes. Policy, procedure and internal controls failures. Why no monitor. Compliance programs lessons learned. What about the DOJ? Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Background The Schemes in Action Parking in India The Comeback and DOJ What it all means Learn more about your ad choices. Visit megaphone.fm/adchoices
In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, we have the Award-Winning Everything Compliance quartet of Jonathan Marks, Jonathan Armstrong, Karen Woody, and Tom Fox on the Monaco Memo. 1. Tom Fox looks at the Monaco Memo through the monitorship language and answers a listener's questions about compliance programs under the Monaco Memo. 2. Karen Woody reviews the Monaco Memo, the self-disclosure angle, and investigatory considerations and ponders the role of defense counsel going forward. 3. Jonathan Marks also looks at investigatory issues under the Monaco Memo, the role of the Board of Directors, and the role of the forensic auditor under the Monaco Memo. 4. Jonathan Armstrong's self-disclosure from a UK angle joins Karen Woody in questioning how defense counsel should move forward. Resources Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog 1. A Jolt for Compliance 2. Timely Self-Disclosure 3. Corporate Compliance Programs 4. Monitors 5. The Heat is On Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices
In this special 5 part podcast series, I am taking a deep five into the Monaco Memo and analyzing it from a variety of angles. In this episode of the FCPA Compliance Report, I am joined by Hughes Hubbard partner Laura Perkins to take a deep dive into the Monaco Memo. Some of the highlights include: 1. Determination of Monitor Need. 2. Roadmap to proa-active compliance. 3. Timely self-disclosure as criteria for monitorship? 4. Monitor selection criteria. 5. Monitor review and oversight. Resources Laura Perkins on HughesHubbard.com Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog 1. A Jolt for Compliance 2. Timely Self-Disclosure 3. Corporate Compliance Programs 4. Monitors 5. Polite Speech Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices
In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, I am joined by my Compliance into the Weeds co-host Matt Kelly for a deep dive into the weeds of the Monaco Memo. Some of the highlights include: Corporate accountability. Timeliness in turning over evidence of wrongdoing. Baby Carrots in evaluating the corporate history of misconduct. Additions to Evaluation of Corporate Compliance Programs. Tweaks to the Yates Memo formulation. Monitors and Monitorships. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Introduction Self-Disclosure Corporate Compliance Programs Monitors What it all means Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced Monaco Doctrine as encapsulated in the Monaco Memo. Highlights include: Corporate accountability. Timeliness in turning over evidence of wrongdoing. Baby Carrots in evaluating corporate history of misconduct. Additions to Evaluation of Corporate Compliance Programs. Tweaks to the Yates Memo formulation. Monitors and Monitorships. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Introduction Self-Disclosure Corporate Compliance Programs Monitors The heat is on Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices
In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, I am joined by my Affiliated Monitors founder Vin DiCianni to take a deep dive into the monitors and monitorship portions of the Monaco Memo. Some of the highlights include: Determination of Monitor Need. Roadmap to proa-active compliance. Timely self-disclosure as criteria for monitorship? Monitor selection criteria. Monitor review and oversight. Resources Vin DiCianni on Affiliated Monitors Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog A Jolt for Compliance Timely Self-Disclosure Corporate Compliance Programs Monitors Polite Speech Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices
In this special 5 part podcast series, I am taking a deep five into the Monaco Memo and analyzing it from a variety of angles. In this episode of the FCPA Compliance Report, I am joined by fan fav James Koukios, partner at MoFo. James is a former member of the FCPA Unit and in this podcast we take a deep dive into the Monaco Memo. Some of the highlights include: 1. Issues involving individual accountability. 2. Burden shifting on communications devices and timeliness of self-disclosing and reporting. 3. How the Monaco Memo lays out DOJ expectations? 4. Monaco Memo at 30,000 ft and ground level. . 5. Tweaks to the Yates Memo formulation. 6. New requirements to the FCPA Corporate Enforcement Policy 7. Will the incentives be enough? Resources James Koukios on MoFo Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog 1. A Jolt for Compliance 2. Timely Self-Disclosure 3. Corporate Compliance Programs 4. Monitors 5. Polite Speech Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recently released Stericycle FCPA enforcement action. Highlights include: · What is a business strategy based upon corruption? · Over-expansion and under due diligence in M&A. · Document Document Document · The Monaco Doctrine at work. · Lessons learned going forward. Resources DPA SEC Order Matt in Radical Compliance Tom in FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices
On this April Fool's Day for 2022, Tom and Jay are back to look at some of the week's top compliance and ethics stories in the Slap Seen ‘Round the World edition. Stories The Slap Seen ‘Round the World and Compliance. Tom in FCPA Compliance and Ethics Blog. Will CCOs have to certify compliance? Text of Kenneth Polite speech. Tom and Matt in Compliance into the Weeds. Matt in Radical Compliance. Coal exec indicted under the FCPA. Harry Cassin in the FCPA Blog. Good bribes. Dick Cassin in the FCPA Blog. Why controls are key to compliance. Chris Audet in CCI. MarshMac UK sub garners Declination with Disgorgement. Dylan Tokar in WSJ Risk & Compliance Journal. ZTE whistleblower feared for his life. Ashley Yablon in CCI. Whistleblowing keys. Jan Stampers In Risk and Compliance Matters. Fine line between compliance and evasion of OFAC sanctions. Mike Volkov in Corruption Crime and Compliance. ISSB delivers sustainability guidelines. IFRS Press Release. Podcasts and More What is the intersection of Sports and Ethics? Each year, Jason Meyer holds Ethics Madness, a discussion of this intersection done during March Madness. This year, Jason engaged Tom for Ethics Madness in the podcast format. It was cross-posted on Jason's site Eight Mindsets, which he co-hosts with Nicole Rose and on Tom's site, Greetings and Felicitations. Tom has a two part series with Aly McDevitt on her recent Ransomware case study, on Greetings and Felicitations, Part 1 and Part 2. Why should you attend Compliance Week 2022? Find out on this episode of From the Editor's Desk. Listeners get a $200 discount to CW 2022 with the code Fox200. More here. Tom visits with longtime MS 150 rider Alan Peterson on The Hill Country Podcast. Donate to the fight against MS here. Why should compliance lead corporate ESG? Kristy Grant-Hart explains on the ESG Compliance Podcast. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Super Sunday passed with fun but poorly played, poorly officiated, and poorly coached. Tom and Jay are back to look at some of the week's top compliance and ethics stories this week in the Rams Win It All Edition. Stories Ericsson is in more FCPA trouble. Mengqi Sun in the WSJ Risk and Compliance Journal. Aaron Nicodemus in Compliance Week. (sub req'd) DD impeding compliance in developing markets? Katya Lysova explores in the FCPA Blog. ESG-no longer a nice to have. Karen Alonardo in Risk and Compliance Matters. State AGs are waiting. Ashley Taylor and Chris Carlson in CCI. The latest case on CCO liability. Matt Kelly in Radical Compliance. Broken windows and compliance enforcement. Anthony O'Reilly in Compliance and Enforcement. Companies yet again ask the EU for rules around ESG. Lawrence Heim in practicalESG. White-collar enforcement trends in 2021. Jamie Rosenberg in Grand Jury Target. HP-Autonomy from the auditors' perspective. Francine McKenna in The Dig. South African courts deny Zuma's attempt to remove the SA corruption prosecutor. Rick Messick in GAB. Podcasts and More In February on The Compliance Life, I visited Ellen Smith, a former Director of Trade Compliance who recently started her consulting firm. In Part 1, she discussed her academic background and early professional career. In Part 2, Ellen discussed her move in-house. In Part 3, Ellen discusses being a part of the Compliance Dream Team at Weatherford. Tom and Richard Lummis are in the middle of their annual review of Best Picturing winning movies on 12 O'Clock High, a podcast on business leadership. Part 1 reviews Schindler's List for leadership and ethical lessons. In Part 2, the look at Gladiator. CCI releases a new e-book from Mike Volkov, "Compliance Culture Revolution." Available free from CCI. Tom looks at some innovation in compliance with a 3-part blog post series in the FCPA Compliance and Ethics Blog. Topics include Compliance Ecosystem Governance, Compliance Branding, Building Culture & Compliance Coaching. Are you a Star Wars fan? How about an uber-Geek? You will love the 5-part series appearing next week on the Greeting and Felicitations podcast series on the Compliance Podcast Network if you are either or both. In this series, Tom visits astrophysicist Dr. Ben Locwin on the following topics: Traveling in Hyperspace, Fighting with a Light Saber, Mechanical Prosthetics, Cyborgs and Robots, and the Death Star. It is a ton of fun, and you will love it. Each episode will post at 10 each day next week. Check it out daily. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
As the GOAT of pro football, Tom Brady retires, Brian Flores sues the NFL and the Bengals/Rams make the Super Bowl, Tom and Jay are back look at some of the week's top compliance and ethics stories this week in the Brady Retires edition. Stories 1. DOJ issues the first Opinion Release of 2022. DOJ website. Tom in FCPA Compliance and Ethics Blog. 2. Do BODs have unrealistic expectations of compliance? Dick Cassin explores in the FCPA Blog. 3. KPMG mislead FRC through forged docs. Risk and Compliance Platform Europe. 4. LRN releases the 2022 Program Effectiveness Report. Download report here. Matt Kelly in Radical Compliance. 5. A ‘how-to' on remediating. The HeadSpin enforcement action. Tom in FCPA Compliance and Ethics Blog. Aaron Nicodemus in Compliance Week. (sub req'd) 6. Learning to scale up ethically. Hemant Taneja in CCI. 7. Why compliance should lead ESG. Carrie Penman in Ethics and Compliance Matters. 8. The Boardroom agenda in 2022. Deloitte in Harvard Law School Forum on Corporate Governance. 9. Changes in antitrust enforcement and its impact on compliance. Mike Volkov, Matt Kelly and Tom in Compliance into the Weeds. Mike Volkov with a 3-part blog series in Corruption Crime and Compliance. 10. Unclear values can lead to unethical behavior. Brett Beasley in Center for Ethical Leadership. Podcasts and More 11. In February on The Compliance Life, I visit Ellen Smith, a former Director of Trade Compliance who recently started her own consulting firm. In Part 1, she discussed her academic background and early professional career. 12. Aly McDevitt with a multipart series in Compliance Week on the end-to-end story of a ransomware attack. Here is more about the series on this month's edition of From the Editor's Desk, with Tom and Dave Lefort. A subscription is required but Compliance Week is running a membership special of $199 for the year. Use Promo Code RNSM199. For information and details click here. 13. CCI releases a new e-book from Tom “FCPA 2021 Year in Review”. Available free from CCI. 14. Trial of the Century-the Enron Trial. This week, Tom premiered a 5-part podcast series on the Enron Trial with Loren Steffy, who covered the trial for the Houston Chronicle. In Part 1, the run-up to the trial. In Part 2, the trial begins. In Part 3, the star witnesses and key testimony. In Part 4, the Verdict comes in. In Part 5, what did it all mean? It is available on the Compliance Podcast Network, Megaphone, iTunes, Spotify and all other top podcast platforms. 15. Looking for a quick daily bite of trade compliance? Check out the Compliance Kitchen with Silvia Surman, who gives a short 3-5 minute update on one trade compliance topic each day. On the Compliance Podcast Network. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
In today's edition of Daily Compliance News: DOJ releases first Opinion Release in 2022. (FCPA Compliance & Ethics Blog) Does AI hurt or help in hiring? (WSJ) CCN chief Zucker resigns over relationship. (NYT) Indonesia stands out in East Asia in ABC fight. (Nikkei Asia) Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode of the FCPA Compliance Report, I am joined by Mike Volkov to take a look back at FCPA enforcement and compliance from 2021 and prognosticate to where it may be going in 2022. Highlights of this podcast include: Three FCPA enforcement actions. DAG Lisa Monaco's October Speech to the ABA White Collar Defense Conference. The Biden Administration's Strategy on Countering Corruption. Where will FCPA enforcement head in 2022. Where will ABC compliance go in 2022? Resources Tom in the FCPA Compliance and Ethics Blog FCPA Year in Review Compliance Year in Review Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode of the FCPA Compliance Report, I am joined by Professor Karen Woody. We discuss the recent SEC enforcement actions involving JPMorgan and Nikola which were announced in December 2021. Highlights of this podcast include: Background on both cases. Why was the SEC so excised with JPMorgan? What are the broader lessons for the Compliance Professional? Compliance Consultant or Monitor or both? Nikola and the trouble with SPACs? What is the intersection of puffing, faking it til you make it and illegal conduct? SPACs and Due Diligence. Could Nikola change the SEC approach to SPACs? From visionary to founder to CEO of a public company? The shadow of Elizabeth Holmes? Resources-Tom on the FCPA Compliance and Ethics Blog JPMorgan Nikola Learn more about your ad choices. Visit megaphone.fm/adchoices
With Jay on a holiday assignment, Tom is joined by Professor Karen Woody to look at some of the week's top compliance and ethics stories this week in the Naughty List edition. Stories 1. JPMorgan tagged for $200MM for failures in electronic record keeping. Tom in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Tom and Matt in Compliance into the Weeds. 2. Nikola fined $125MM for former CEO's imprudent tweets. Tom in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Jaclyn Jaeger in Compliance Week. (sub req'd). 3. SOX 20 years later. Michael Peregrine looks back at the upcoming 20th anniversary of Sarbanes-Oxley in the Harvard Law School Forum on Corporate Governance. 4. France updating its ABC regime. Frederick Davis in GAB. 5. Another Unaoil defendant appeals conviction based upon SFO misconduct. Dylan Tokar in WSJ Risk and Compliance Journal. 6. What happened to FCPA Compliance in 2021? Dick Cassin explores in the FCPA Blog. 7. The story of internal controls and Netflix? Jonathan Marks in BakerTilly. 8. Vietnam imposes 14-year sentence for wildlife trafficking. Jon Rusch in Dipping Through Geometries. 9. Lawyers and ESG. Lawrence Heim in PracticalESG. 10. Prioritizing your policy updates. David Banks in Risk and Compliance Matters. Podcasts 11. Want some fun over the holidays? Join Tom and One Stone Creative co-founder Megan Dougherty for an exploration of the full MCU. In Episode 1, Captain America. In Episode 2, Captain Marvel. Next week in Episode 3, Iron Man. 12. In December on The Compliance Life, I visit with Matt Silverman, Director of Trade Compliance at VIAVI. Matt is the first Trade Compliance Director I have hosted on TCL. In Part 1, Matt details his academic career and early professional life. In Part 2, Matt moves into trade compliance. In Part 3, Matt moves into the Director's chair. 13. The Compliance Podcast Network welcomes Professor Karen Woody and her new podcast, Classroom Insider. In this most unique pod, Karen interviews some of her student to tell the history of insider trading. Check out Episode 1 where they discuss the history of insider trading. In Episode 2, the disclosure or abstain rule. On Episode 3, (premiering Dec. 31), they will take up narrowing the scope of the disclose or abstain rule. 14. The Shout Outs and Rants of Everything Compliance gets its own iTunes show. Everything Compliance has its first-year end review episode. 15. On Hidden Traffic, Gwen Hassan hosts Andrew Wallis, head of Unseen UK. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Karen Woody is Professor of Law at Washington and Lee. She can be reached at kwoody@wlu.edu. Learn more about your ad choices. Visit megaphone.fm/adchoices
Tom takes a solo turn to look at some of the week's top compliance and ethics stories this week in the Bags of Cash edition. Stories 1. Why subcontractors continue to cause FCPA grief. Dick Cassin the FCPA Blog. 2. More on the Strategy on Countering Corruption. Tom takes a deep dive in a 5-part blog post series in the FCPA Compliance and Ethics Blog. Mike Volkov in Corruption Crime and Compliance. 3. Neil Hodge says non-US companies should beware in Compliance Week. (sub req'd). 4. What next Brazilian President must do re: ABC. Marcelo Cerqueira in GAB. 5. Yet another son of ex-Panamanian President pleads guilty. Rick Vanderford in WSJ Risk and Compliance Journal. 6. NatWest took bags of cash for deposits. $341MM in fines later. Dylan Tokar in WSJ Risk and Compliance Journal. 7. How CCOs use guidance from DOJ? Matt Kelly in Radical Compliance. 8. Should you fall on your sword? Calvin London in CCI. 9. Sustainability not universal. Lawrence Heim in PracticalESG. 10. McDonalds claws back CEO severance. Heather Haddon in WSJ. Podcasts and Events 11. Are you exasperated? Then check, F*ing Argentina. In this podcast series co-hosts Tom Fox and Gregg Greenberg, author of F*ing Argentina explore the current American psyche of being overworked, over leveraged, overtired and overwhelmed. Find out about modern America's exasperation with well…exasperation. In our final episode, we wrap up what we learned from the series. 12. In November on The Compliance Life, I visit with Matt Silverman, Director of Trade Compliance at VIAVI. Matt is the first Trade Compliance Director I have hosted on TCL. In Part 1, Matt details his academic career and early professional life. In Part 2, Matt moves into trade compliance. 13. The Compliance Podcast Network welcomes Professor Karen Woody and her new podcast, Classroom Insider. In this most unique pod, Karen interviews some of her student to tell the history of insider trading. Check out Episode 2, the disclosure or abstain rule. 14. The Shout Outs and Rants of Everything Compliance gets its own iTunes show. Everything Compliance has its first-year end review episode. 15. On Hidden Traffic, Gwen Hassan hosts Andrew Wallis, head of Unseen UK. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom continue their look at the recent speech by DAG Lisa Monaco to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Today we consider potential changes to DPAs and NPAs and other settlement mechanisms. Some of the issues we consider are: · Are DPAs and NPAs simply the cost of doing business? · Is the Wells Fargo growth cap a valid model? · What about greater DOJ or Monitor oversight? · Longer terms for DPAs? · New enforcement tools coming? · New review of DPAs and NPAs. Resources Matt in Radical Compliance So What Happens Next with DPAs Tom in the FCPA Compliance and Ethics Blog Monaco Speech - Individual Accountability Monaco Speech - Monitors Text of DAG Monaco Speech Learn more about your ad choices. Visit megaphone.fm/adchoices
As we head to Halloween, Tom and Jay reflect on some of the top compliance and ethics stories on the Happy Halloween edition. Stories 1. More on Credit Suisse and Tuna bonds. Mike Volkov in Corruption Crime and Compliance. Tom in the FCPA Compliance and Ethics Blog. Tom and Matt Kelly in Compliance into the Weeds. 2. What is FARA. Jamie Rosenberg starts a 2-part series in Grand Jury Target. 3. Digital innovation and continuous improvement. Jim Deloach in CCI. 4. Banks and FinTech. Davis Polk lawyers in Compliance and Enforcement Blog. 5. What will happen to exec clawbacks? Aaron Nicodemus in Compliance Week. (sub req'd) 6. SARs and appalling inaction. Martin Kenney in the FCPA Blog. 7. Board readiness for shareholder activism. Paul DeNicola in Harvard Law School Forum on Corporate Governance. 8. Scrutiny of the Arts and Antiquities market. Linklaters client alert. 9. Hiding evidence from regulations costs KPMG in UK. Risk and Compliance Platform Europe. 10. The SEC on auditor independence. Matt Kelly in Radical Compliance. Podcasts and Events 11. Compliance Week 2022 opens for registration. Sign up here. 12. Ethisphere's World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here. 13. Are you exasperated? Then check, F*ing Argentina. In this podcast series co-hosts Tom Fox and Gregg Greenberg, author of F*ing Argentina explore the current American psyche of being overworked, over leveraged, overtired and overwhelmed. Find out about modern America's exasperation with well…exasperation. In Episode 7, a Malodor on the Subway. 14. This month on The Compliance Month, I visit with John Melican, Managing Director at Exiger on his journey to and from the CCO chair. In Episode 1, college and early professional career at NY County DA's Office. In Episode 2, Melican moved into the corporate world and into compliance. In Episode 3, John moves into the CCO chair. In Episode 4, John talks about what he learned and how he uses that knowledge. 15. How does a Compliance Bible become a best-seller? Check out Tom's appearance on the C-Suite Network's Best Seller TV to find out. Purchase The Compliance Handbook, 2nd edition here. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the issue of compliance and artificial intelligence. Some of the issues we consider are: What are the AI risks for compliance? What guidance does the COSO Framework provide? What are some of the top areas of AI failure? Are we governing AI in the right manner? What about the audit of AI tools? Compliance, governance, ethics and AI. Resources Matt in Radical Compliance Thoughts on AI From the Audit Perspective Grappling With Artificial Intelligence Tom in the FCPA Compliance and Ethics Blog Compliance Communications: Using an AI Marketing Strategy – Part 1 Compliance Communications: Using an AI Marketing Strategy – Part 2 Learn more about your ad choices. Visit megaphone.fm/adchoices
Jay and Tom are back to unpack some of the stories that caught their collective eye on the Monsterfest Month Returns edition. Stories 1. WPP FCPA enforcement action. Tom with 5-part series on the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Tom and Matt on Compliance into the Weeds. Mike Volkov has a 3-part series in Corruption Crime and Compliance. 2. Human rights litigation on the EU. Salomé Lemasson in the FCPA Blog. 3. BOD structure as key to compliance oversight. David Katz and Laura McIntosh in Harvard Law School Forum on Corporate Governance. 4. Bringing clarity to the chaotic world of the CCO. Chris Audet in CCI. 5. Another week, another Wells Fargo fraud related penalty. Jaclyn Jaeger in Compliance Week (sub req'd) 6. Dan Kahn returns to private practice. Dylan Tokar in the WSJ Risk and Compliance Journal. 7. Do ABC academics fail? Matthew Stephenson in GAB. 8. Conquering the last mile of delivery of your Code of Conduct. Harper Wells in CCI. 9. What is Ozy and what does it mean for compliance. Ben Smith in the NYT. 10. Who owns ESG? Matt Kelly explores on Radical Compliance. Podcasts and Events 11. CCI surveying stress in compliance. Henry Kronk in CCI. Take the survey here. 12. Compliance Week is going ‘Inside the Mind of the CCO'. Participate in the survey here. 13. Ethisphere's World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here. 14. Check out the latest addition to the Compliance Podcast Network, A Yank at Oxford. It details the journey of Foley & Lardner partner David Simon as he heads back to university to matriculate for a MBA at Oxford. Episode 1. 15. Are you exasperated? Then check, F*ing Argentina. In this podcast series co-hosts Tom Fox and Gregg Greenberg, author of F* Argentina explore the current American psyche of being overworked, over leveraged, overtired and overwhelmed. Find out about modern America's exasperation with well…exasperation. In Episode 1, the dreaded Parent Meeting night at your child's elementary school. In Episode 2, why F*ing Argentina? In Episode 3, one of the most beloved characters in musical theater, Officer Krupke is exasperated. 16. Tom and Compliance Week EIC Dave Lefort look back at September in CW and forward to October (and talk some sports) in this month's edition of From the Editor's Desk. 17. K2 Integrity's Edoardo Fiora will present at, “ESG Getting Hitched to Business (and IP) Strategy—From Resilience Framework to Recovery Path,” on October 14th. Registration and Information here. 18. Join Jay, Tom and the top E&C professionals at Converge21, a virtual conference on October 12 & 13. Registration and information here. Why should you attend? Check out some of the panelists discuss their presentation on the Converge21 podcasts. Michael Randrup Wendy Badger, Lloydette Bai-Marrow, Tom and Philip Winterburn. 19. How does a Compliance Bible become a best-seller. Check out Tom's appearance on the C-Suite Network's Best Seller TV to find out. Purchase The Compliance Handbook, 2nd edition here. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Jay returns from his travels to report on the 1st compliance conference since 2019. He and Tom unpack some of the stories that caught their collective eye on the Heading to October edition. Stories 1. ESG and Compliance. Mike Volkov on the ‘G' in ESG. Tom has a 5-part series on why compliance should lead the ESG effort in the FCPA Compliance and Ethics Blog. 2. Asking more of your auditors. Neil Hodge in Compliance Week (sub req'd) 3. ISO weighs in on good governance standards. Dylan Tokar in the WSJ Risk and Compliance Journal. 4. Regulating the wild west of crypto. Henry Kronk in CCI. 5. Which Mozambique countenance or prosecute its President's corruption? Rick Messick in GAB. 6. Making the most from your risk assessment? Jeff Kaplan in the FCPA Blog. 7. What is a criminal COI? Sara Kropf in Grand Jury Target. 8. Revisiting whistleblower procedures. Wachtel Lipton lawyers in Harvard Law School Forum on Corporate Governance. 9. The SEC investigation into Activision. Professor Stephen Bainbridge in his blog. 10. Jay's reflections on the first compliance conference since 2019. Podcasts and Events 11. CCI surveying stress in compliance. Henry Kronk in CCI. Take the survey here 12. Check out the latest addition to the Compliance Podcast Network, A Yank at Oxford. It details the journey of Foley & Lardner partner David Simon as he heads back to university to matriculate for a MBA at Oxford. 13. Are you exasperated? Then check out the latest offering from the Compliance Podcast Network, F*ing Argentina. In this podcast series co-hosts Tom Fox and Gregg Greenberg, author of F* Argentina explore the current American psyche of being overworked, over leveraged, overtired and overwhelmed. Find out about modern America's exasperation with well…exasperation. In Episode 1, the dreaded Parent Meeting night at your child's elementary school. In Episode 2, why F*ing Argentina? 14. Jay spreads his wings by hosting his first podcast. He interviews Lisa Beth Lentini Walker and Stef Tschida about their new book, Raise Your Game, Not Your Voice, on this episode of Integrity Through Compliance. 15. K2 Integrity is partnering with the DIFC Academy for a webinar, “Virtual Assets and FATF Guidelines—A Risk-Based Approach for Financial Institutions,” on September 28, 2021. Registration and Information here. 16. Join Jay, Tom and the top E&C professionals at Converge21, a virtual conference on October 12 & 13. Registration and information here. Here some of the panelists discuss their presentation on the Converge21 podcasts. Wendy Badger and Philip Winterburn. 17. Ethisphere's World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here. 18. Breaking News features The Compliance Handbook, 2nd edition. Check out the Breaking News feature here. Purchase The Compliance Handbook, 2nd edition here. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
The Foreign Corrupt Practices Act (FCPA) continues to be a key regulatory priority of US enforcement agencies and a central compliance concern for businesses around the world. In this episode of the Better Intelligence Podcast, PSA's Michael Olver speaks with veteran FCPA litigator Charles Duross, who spent seven years at the DOJ's FCPA unit before entering private practice to counsel clients on FCPA matters. Charles shares insights into how the DOJ and SEC pursue investigations, discusses the management of internal and government-facing investigations, and highlights key risk areas in dealing with third parties. _ To learn more about Pacific Strategies & Assessment's investigative and due diligence capabilities go to www.psagroup.com
As the Trump Organization and its CFO are criminally indicted, Tom and Jay prepare for the 4th of July and are back to take a look at this week's stories top compliance and ethics stories which caught their interest on This Week in FCPA in the Trump Organization Indicted edition. Stories Trump Organization and CFO indicted on criminal charges. NYT, WSJ, FT, WaPo How whistleblowers protect the bottom line. Bob Conlin in Navex Global's Risk and Compliance Matters. Amec Foster Wheeler, the first FCPA corp enforcement action in 2021. Tom takes a deep dive in a 3-part series on the FCPA Compliance and Ethics Blog. Tom and Matt Kelly take a deep dive in Compliance into the Weeds. Mike Volkov goes deep on Corruption Crime and Compliance. Harry Cassin (as usual) breaks the story on the FCPA Blog. US government AML priorities. FinCen issues report, here. Kyle Brassuer in Compliance Week (sub req'd) Dylan Tokar in WSJ Risk and Compliance Journal. Do lawyers make good gatekeepers? Sung Hui Kim says ‘perhaps'. Keith Bishop says you shouldn't even ask the question. Human-Centered Design: An Engaging Ethics & Compliance Program Serves Users' Needs. Carsten Tams in Part 2 of his five-part series on LinkedIn. Reducing your CCPA risk. Debevoise lawyers on NYU's Compliance and Enforcement blog. Was Amec Foster Wheeler afraid of its agents? Dick Cassin explores in the FCPA Blog. Auditing your climate risk. Mark Texler in a two-part series on PracticalESG. How do you evaluate the value of ethics? Henry Kronk in CCI. Podcasts and Events How does history inform compliance? What are the leadership lessons from ancient Greeks and Romans? Find out in this special 10 part podcast series on famous Greeks and Romans from Plutarch's Lives this week on 12 O'Clock High, a podcast on business leadership, hosted by Richard Lummis and Tom Fox. In Episode 1, they mined Plutarch about the lives of and leadership lessons from Themistocles and Camillus. In Episode 2, they looked at Solon and Popsicola. In Episode 3, Pericles and Fabius Maximus. In Episode 4, Alcibiades and Coriolanus. Are you a MCU fan? If so check out the special series on the Disney streaming service Loki and Tom Fox and Megan Dougherty who return to review the entire series. They catch up on Episode 1-3 in this edition of Popcorn and Compliance. Trekking Through Compliance Returns! Tom reviews all 79 episodes of Star Trek, the Original Series beginning June 1. Each day at 3 PM on the Compliance Podcast Network. This week's offerings included Operation Annihilate, Amok Time, Who Mourns for Adonias, The Changeling and Mirror Mirror. On this episode of Integrity Through Compliance, join Affiliated Monitor's Rod Grandon, Jenner & Block Partner, David Robbins, and former Engility Holdings, Inc. General Counsel, Tom Miller, for an in-depth discussion focusing on crisis management from the perspectives of a General Counsel, outside legal counsel, and federal acquisition official. On July 13, join K2 Integrity for its Virtual Compliance Conference on Environment, Social, and Governance Compliance Risks for Financial Institutions. Information and Registration here. It is now HERE, the book you have all been waiting for, The Compliance Handbook, 2nd edition is available for purchase. The Compliance Handbook 2ndedition is available in both print and eBook editions. Available here. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the first FCPA enforcement action involving a company in 2021, the Amec Foster Wheeler global anti-corruption enforcement action. Some of the issues we consider are: What were the underlying facts? Were red flags missed, consciously avoided or outright ignored? Where was compliance? How corrupt was the culture of Foster Wheeler? What does this mean for compliance going forward? Resources Matt in Radical Compliance Foster Wheeler's FCPA Lessons Tom in the FCPA Compliance and Ethics Blog Not a Siren's Song Silk Shirts and Corruption Ba-da-Bing; Ba-Da-Bing Learn more about your ad choices. Visit megaphone.fm/adchoices
Jay is back from moving. He and Tom are shocked, shocked that there is another cheating scandal in baseball. While ruminating on just how shocked they are, they take a look at this week's stories top compliance and ethics stories which caught their interest on This Week in FCPA in the More Cheating in Baseball edition. Stories This year's cheating scandal in baseball. Stephanie Apstein and Alex Prewitt in SI. David Waldstein in NYT. Buster Olny in com. Tom takes a deep dive in three blog posts on the FCPA Compliance and Ethics Blog. EU Prosecutor's Office opens for business. Jon Rusch in Dipping Through Geometries. Exxon BOD vote should be a wake up call. Jaclyn Jaeger in Complinace Week. (sub req'd) Compliance when no one is watching. Julie DeMauro in the FCPA Blog. What are 5 things CCOs can do to comply with Biden's Statement on Corruption? Al Barbarino in Law360. What do pirates teach us about leadership? Fransesca Gino in XpertsLeague. Should CCOs run ESG? Mike Volkov say ‘No' in Corruption, Crime and Compliance. Is your Supply Chain ethical? Andrew Blasi and Nicolas Diamond in CCI. What are some reasons for the lack of FCPA enforcement? Harry Cassin speculates in the FCPA Blog. Get on one page for risk management. Sandar Erez in CCI. Podcasts and Events CPN premiers a new podcast, The ESG Report. In the first episode, Tom has a two-part series featuring Trysha Daskem, head of ESG at Silver. Check out Part 1 and Part 2. How does history inform compliance? What are the leadership lessons from ancient Greeks and Romans? Find out in this special 10 part podcast series on famous Greeks and Romans from Plutarch's Lives this week on 12 O'Clock High, a podcast on business leadership, hosted by Richard Lummis and Tom Fox. In Episode 1, they mined Plutarch about the lives of and leadership lessons from Themistocles and Camillus. In Episode 2, they looked at Solon and Popsicola. Trekking Through Compliance Returns! Tom reviews all 79 episodes of Star Trek, the Original Series beginning June 1. Each day at 3 PM on the Compliance Podcast Network. This week's offerings included The Conscience of a King, Balance of Terror, Shore Leave, The Galileo Seven and The Squire of Gothos. Vin DiCianna turns the tables on Tom by interviewing him for this week's Integrity Through Complaince. Check it out here. Join Convercent for a Converge Innovation Forum, with a look into the future of compliance on risk visibility up, down, and across the businesson June 23 at 11 AM CT. for information and registration click here. On July 1, join K2 Integrity's Snezana Gebauer and Darren Matthews will present a webinar on asset tracing at the IBA Global Influencer Forum. Learn more and register: https://www.k2integrity.com/en/events/k2-integrity-webinar-at-iba-global-influencer-forum-fraud-debt-and-judgements-how-to-maximize-asset Tom announces his latest book, The Compliance Handbook, 2nd edition is available for presale purchase. Use the code FOX25 and go here. The Compliance Handbook 2ndedition will be available in both print and eBook editions. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
With Jay moving this week, Tom is joined by Complinace Kristy (Kristy Grant-Hart) as special guest host. They take a look at this week's stories top compliance and ethics stories which caught their interest on This Week in FCPA in the Biden Statement on Corruption edition. Stories President Biden's Statement and Memorandum on corrption. Tom takes a deep dive in four blog posts on the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance. Alexandra Wrage on the FCPA Blog. Rick Messick in GAB. Jessica Tillipman in the FCPA Blog. Don't get caught up in endless internal investigations. Lloydette Bai-Marrow in the FCPA Blog. Biden Dumps PCAOB Board. Aaron Nicodemus and Kyle Brasseur in Complinace Week. (sub req'd) More on Caremark. Jeff Kaplan in the Conflict of Ethics Blog. What is conflict due diligence? Lawarence Heim in PracticalESG Blog. Can you measure a ‘speak-up' culture by the number of complaints? Martin Lønstrup in the FCPA Blog. Two former Chadean diplomats indicted for corruption. Mike Volkov in Corruption, Crime and Compliance. Are there smoking guns in your Board minutes? Terry Quimby in the Compliance Cosmos. Do you need a People Committee on your BOD? Reshmi Paul and Jeff McLean in Compensation In Context. Podcasts and Events How does history inform compliance? What are the leadership lessons from ancient Greeks and Romans? Find out in this special 10 part podcast series on famous Greeks and Romans from Plutarch's Lives this week on 12 O'Clock High, a podcast on business leadership, hosted by Richard Lummis and Tom Fox. In Episode 1, they mine Plutarch about the lives of and leadership lessons from Themistocles and Camillus. Trekking Through Compliance Returns! Tom reviews all 79 episodes of Star Trek, the Original Series beginning June 1. Each day at 3 PM on the Compliance Podcast Network. This week included Mudd's Women, What are Little Girls Made Of?, Miri, Dagger of the Mind and The Corbomite Maneuver. AB InBev invites you to the Compliance Open House on June 15 at 10AM EST on the topic “Collaboration Framework for Democratizing Compliance Analytics – where are we and what is next." Registration and information here. On July 1, join K2 Integrity's Snezana Gebauer and Darren Matthews will present a webinar on asset tracing at the IBA Global Influencer Forum. Learn more and register: https://www.k2integrity.com/en/events/k2-integrity-webinar-at-iba-global-influencer-forum-fraud-debt-and-judgements-how-to-maximize-asset What is the role of compliance in managing Environment, Social, and Governance (ESG) initiatives? Join this Convercent Global Forum to learn what's ahead for ESG and what you should start thinking about now, to be prepared before regulations go into effect. On June 16, 11 AM ET. Registration and information here. Tom announces his latest book, The Compliance Handbook, 2nd edition is available for presale purchase. Use the code FOX25 and go here. The Compliance Handbook 2ndedition will be available in both print and eBook editions. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Rarely do we hear or read about the names of third-party bribe payers or the names of their companies. Global companies, particularly those who ship products internationally or rely on third-parties in other ways to bring their products and services to market, are heavily reliant on virtual armies of third-party intermediaries to operate internationally. They are a necessary evil who can act on an organization’s behalf, represent them in the marketplace and potentially trigger significant liability under the FCPA, sanctions or anti-money laundering laws.
As Ethisphere announces its World’s Most Ethical Company awards for 2021, Tom and Jay look at this week’s stories top compliance and ethics stories which caught their interest on This Week in FCPA. Ethisphere announces 2021 World’s Most Ethical Company awards. In CCI. In Radical Compliance. Data Privacy under Biden. Colin Rahill in Jolt. What the NDAA did regarding the SEC and disgorgement. David Levintow in the FCPA Blog. SFO wants companies to invest more in compliance. Dylan Tokar in the WSJ Risk and Compliance Journal. Board lessons from a crisis. Stephen Davis and Sandra Guerra in the Harvard Law School Forum on Corporate Governance. A Texas transplant reflects on weather and lessons learned. Dick Cassin in the FCPA Blog. Of Citibank and Black Swan events. Tom Explores in a 3-part blog post series on the FCPA Compliance and Ethics blog. Tom and Matt take a deep dive in Compliance into the Weeds. On The Compliance Life, Natalia Shehadeh, CCO at ABB joins me this month. In the first episode, Natalia explained why she choose the compliance profession. Check out the Episode 1 and Episode 2. In Episode 3, Natalia discussed moving into the CCO chair. This week is Episode 4. The Compliance Handbook, a podcast on the nuts and bolts of compliance premiered this month. In Episode 1, Tom is joined by Stephen Martin to talk about how to best think through a comprehensive compliance program. In Episode 2, Tom was joined by Mike Volkov to discuss the Board’s role in Compliance. In Episode 3, Ronnie Feldman and Ricardo Pelleton talked about training and communications from their own very unique perspective. It is also available on the traditional audio formats. A new AMI podcast is out, Integrity Through Compliance. It has AMI’s expert observations and guidance in the fields of ethics, antitrust, healthcare, government contracting, corporate governance, cybersecurity, construction, telecommunications, consumer protection and more. In the Episode 1, AMI founder Vin DiCianni visited with AMI MD Jerry Coyne the future of telehealth & home healthcare during a pandemic and beyond. In Epsiode 2, Brenda Morris and Dionne Lomax visited with Jennifer Newton. In Episode 3, Joseph K. West, Partner & Chief Diversity and Inclusion Officer, Duane Morris joined the podcast to talk about the benefits of D&I. Interested in podcasting? Want to be a part of a Guiness World Record attempt? PodFest Global Summit is a gathering for those who are passionate about sharing their voice and message with the world through audio and video. Join Tom and others at Podfest Global Summit at any time during March 1-5. Best all of listeners to this podcast can attend at no charge. Register here, using promo code CPN. Tom announces his latest book, The Compliance Handbook, 2nd edition is available for presale purchase. Use the code FOX25 and go here. The Compliance Handbook 2ndedition will be available in both print and eBook editions. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into one of the most delicious legal decisions recently seen: the attempt by Citibank to recoup $500MM of the $900MM it erroneously wired out on behalf of Revlon. Some of the issues we consider are: · How did this Fubar occur? · What was the role of complexity? · Why did the employees make this mistake? · What about training? · Where were internal controls? · What is the ‘value for discharge’ defense? · Does this all just come down to finders keepers? · What are the compliance lessons? Resources Tom’s blog posts on the FCPA Compliance and Ethics Blog: Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 1 - The Facts Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 2 – Lessons Learned The Citibank decision Learn more about your ad choices. Visit megaphone.fm/adchoices
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Last week we considered the SEC regulations requiring companies to detail human capital issues in their annual reports and what it meant for compliance. This led to a week-long dialogue between Matt and myself about the current state of employee trust and its role in corporate culture and a best practices compliance and ethics program. Some of the issues we consider are: Trust is down. The now former UK KPMG Chairman who told employees to ‘quit whining’ about the Coronavirus health crisis issue. Employees are under more pressure to deliver results. What does this do to trust? Employee to employee trust issues in WFH. Trust issues around RTW, both employee to employee and management response to employee health and safety issues at the workplace. Benjamin Moore getting rid of legal department and then restricting employee access to legal assistance. Greater fear toward retaliation stopping whistleblowers from coming forward. Resources Matt’s blog post in Radical Compliance: Corporate Culture and Human Capital Disclosures Tom’s blog posts on the FCPA Compliance and Ethics Blog: A Macro Approach for Human Capital Compliance Hal Holbrook, Mark Twain and Employee Trust How to Destroy Employee Trust Leadership Lessons from Abraham Lincoln Learn more about your ad choices. Visit megaphone.fm/adchoices
With two black swan events in January alone, Tom and Jay wonder what else 2021 will bring. Jay bemoans Tompa Bay in the Super Bowl.They are also back to look at some of the top compliance articles and stories which caught their eye this week. What does GameStop portend for compliance? Toms take a deep dive on the FCPA Compliance and Ethics Blog. Part 1-Background, Part 2-the Shorts, Part 3-the Squeeze, Part 4-the Regulators, Part 5-Final Thoughts. Tom and Matt Kelly take a deep dive on Compliance into the Weeds. Enterprise risks going forward. Matt Kelly looks down the road in Radical Compliance. Solar Winds turning into a Pandora’s Box? Jaclyn Jaeger explores in Compliance Week. (sub req’d) Risk culture in the digital age. Jim DeLoach explores in CCI. What does the CFTC settlement with Vitol portend for enforcement (and compliance). Gibson Dunn lawyers in NYU’s Compliance and Enforcement. Top regulatory trends to watch under the Biden Administration. Rachel Wooley in CCI. Is your compliance team too big? Dick Cassin asks in the FCPA Blog. Can compliance help with a workplace morale crisis? Richard Bistrong opines in the FCPA Blog. On The Compliance Life, Natalia Shehadeh, CCO at ABB joins me this month. In this first episode, Natalia explains why she choose the compliance profession. Check out the Episode 1. New podcasts out on the Compliance Podcast Network this month. In ComTech, Valerie Charles joins Tom for an exploration of the intersection of compliance and technology. Check out Episode 1. Episode 2 posts Monday, February 8. In Big Brains in Compliance Tom is joined by Stephen Martin to visit with some of the top thinkers and doers in compliance. It premiers February 22. Finally Tom premiers The Compliance Handbook, a podcast focusing on the nuts and bolts of compliance. In Episode 1, he is joined by Stephen Martin to talk about how to best think through a comprehensive compliance program. It premiers Tuesday, February 10. A new AMI podcast is out, Integrity Through Compliance. It will have AMI’s expert observations and guidance in the fields of ethics, antitrust, healthcare, government contracting, corporate governance, cybersecurity, construction, telecommunications, consumer protection and more.In this first episode, AMI founder Vin DiCianni visits with AMI MD Jerry Coyne the future of telehealth & home healthcare during a pandemic and beyond. Check it out here. Join K2 Integrity and the AIBACP for a webinar on February 17—National Defense Authorization Act: AML Compliance Implications and Priorities for the Banking Industry. Information and Registration here. On Thursday, February 25, join the “Ask an Expert FINQuiry” webinar on DOLFIN: K2 Integrity’s financial crimes compliance experts will respond to your AML/CFT, sanctions, and other financial-integrity-related questions. Information and Registration here. Compliance Week is accepting nominations for its Excellence in Compliance Award. Submit your nominee here. Join the Baker Tilly Fraud 1st Annual Fraud and Compliance Summit, Tuesday, Feb 23, 2021, to Thursday, Feb 25, 2021. Details and registration here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
As Trump becomes the only person to have 2 impeachment trials, Tom and Jay are back to look at some of the top compliance articles and stories which caught their eye this week. Beny Steinmetz found guilty for corruption in Guinea mining concession. Imogen Foulkes in the com. Tom take a deep dive on the FCPA Compliance and Ethics Blog. Part 1-Background, Part 2-the Trial, Part 3-the Vale JV, Part 4-Final Thoughts. Do compliance officers need a peer review? Dick Cassin explores in the FCPA Blog. Should you have reps and warranties in your compliance terms and conditions? Bill Steinman considers in the FCPA Blog. 7 key changes to CA privacy laws. Andrew Burt in Navex Global’s Risk and Compliance Matters. A Significant ruling on HIPPA out of the 5th David Saunders and Allison Glover in NYU’s Compliance and Enforcement. Is an increase in SEC enforcement coming? Morgan Lewis lawyers in Harvard Law School Forum on Corporate Goverance. Why is FCA compliance so critical? Mike Debernardis in CCI. How to investigate a 60MM document case? Michael Dempsey in the BBC. On The Compliance Life, Gwen Hassan- Director of Compliance at CNH Industrial is back for her fourth and final episode. In it, Gwen explains her passion around fighting the international scrourge of human trafficking. Check out the episode here. This month, on 31 Days to a More Effective Compliance Program, I look back over 2020 and set out some of the key enhancements you need to do for your compliance program in 2021. Day 23 | Assessing compliance internal controls; Day 24 | Updates and feedback; Day 25 | CCO authority and independence; Day 26 | the role of compliance in an organization; Day 27 | operationalizing compliance though payroll; Day 28 | Continuous Improvement; Day 29 | Internal Reporting. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. A new AMI podcast is out, Integrity Through Compliance. It will have AMI’s expert observations and guidance in the fields of ethics, antitrust, healthcare, government contracting, corporate governance, cybersecurity, construction, telecommunications, consumer protection and more.In this first episode, AMI founder Vin DiCianni visits with AMI MD Jerry Coyne the future of telehealth & home healthcare during a pandemic and beyond. Check it out here. Join K2 Integrity and the AIBACP for a webinar on February 17—National Defense Authorization Act: AML Compliance Implications and Priorities for the Banking Industry. Information and Registration here. Compliance Week is accepting nominations for its Excellence in Compliance Award. Submit your nominee here. Join the Baker Tilly Fraud 1st Annual Fraud and Compliance Summit, Tuesday, Feb 23, 2021, to Thursday, Feb 25, 2021. Details and registration here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
Tom Fox rejoins Corruption, Crime & Compliance for a 2017 FCPA Review. Tom discusses important trends and events from 2017 in FCPA enforcement and compliance. Tom is the thought-leader on FCPA and compliance issues. He maintains the popular blog, FCPA Compliance & Ethics, the Podcast Network and is a prolific author of numerous books, articles, and e-books.
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