Podcast appearances and mentions of mike volkov

This week, we bring you a replay of one of our most impactful podcasts from last year, featuring Alex Cotoia and Daniela Melendez. Listen in as we discuss the EU Whistleblower Directive of October 2019. We'll return next week with one of our regular updates.Directive 2019/1937 of the European Parliament and Council dated 23 October 2019 on the “protection of persons who report breaches of Union law” (the “Directive”) is currently being implemented by EU Member States. The directive has broad applicability to organizations operating in the EU internal market and applies to both public and private sector organizations alike. Whistleblowers are guaranteed legal protection to the extent: (1) they have reasonable grounds to believe that the information reported was true at the time of the report; and (2) the whistleblower reported either internally to the organization, externally to a competent authority, or publicly. Private sector organizations with 50 or more workers are legally required to establish channels and procedures for internal reporting of EU law breaches and conduct appropriate follow-up. In this episode, Mike Volkov is joined by Daniela Melendez and Alex Cotoia from the Volkov Law Group, who bring their expertise to the table as they delve into the EU Directive and its implementation by several member states. Listen to this discussion to understand and navigate the complexities of the EU Whistleblowing Directive.The EU Whistleblower Directive shifts the burden of proof on retaliatory actions to the person taking the detrimental action, requiring them to demonstrate it was not linked to reporting concerns.Global companies are taking a proactive stance by increasingly focusing on robust ethics and compliance programs. This strategic move is aimed at mitigating risks and promoting positive corporate citizenship in today's economy, where adherence to legal and ethical standards is paramount.France signed the EU Directive into law on March 21, 2022, outlining protocols for gathering and handling whistleblower reports, including a two-month deadline for imposing disciplinary sanctions.Germany enacted the EU Directive on May 12, 2023, allowing anonymous reports and setting a three-month investigation deadline after receiving the report.Spain addressed the EU Directive on February 2023 by covering additional topics like occupational health and safety breaches. The directive established a three-month deadline for investigations and allowed anonymous reports.Italy transposed the EU Directive on August 4, 2022, including administrative, financial, civil, and criminal offenses not covered by the Directive, with a 30-day deadline to conduct investigations upon receipt of reports.Companies are advised to make resources available to conduct investigations quickly due to the short timeframes set by various countries' whistleblower protection laws.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law GroupAlex Cotoia on LinkedIn Email: acotoia@volkovlaw.comDaniela Melendez on LinkedInEmail: dmelendez@volkovlaw.com

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. We take things in a different direction today as Tom Fox reposts the recent webinar with Sam Silverstein and Mike Volkov, where we took a deep dive into the Boeing Plea Agreement, the Monitorship, and why culture is the key to a Boeing turnaround. We explore the recent plea agreement filed by Boeing, the outrage among victims' families over the proposed penalties, and the appointment of an independent compliance monitor. Key issues discussed include the necessity of a culture overhaul at Boeing, the implications of excluding court jurisdiction over the monitorship, and the role of the board in fostering a culture of compliance and safety. The discussion highlights the critical need to focus on values, accountability, and transparent processes to rebuild trust and ensure long-term organizational integrity. Highlights of this episode: Details of the Plea Agreement Compliance Monitor Appointment and Transparency The Importance of Culture The Role of Compliance Monitors Board Involvement and Accountability Victims' Families and Organizational Accountability Resources: Sam Silverstein Mike Volkov The Culture Audit Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices

Bryn Sedlacek, Vice President and Product Manager at Aravo, joins us on the podcast to discuss third-party risk management focusing on holistic risks and unified visibility. In a wide-ranging discussion, Mike Volkov and Bryn Sedlacek discuss the challenges in implementing a third-party risk management program that captures holistic risks and maintains a consistent, unified line of sight across the organization's risk profile. They focus on sanctions, capturing the source and ultimate destination of products/services and including those in screening, leveraging how to handle conflict minerals as a model, and how data intelligence providers can help. Additionally, Bryn discusses unified visibility, which provides comprehensive visibility to executives and decision-makers across risk domains and performance. Finally, they discuss InfoSec risk with third parties, where to start, and the future of risk - technology and alternative risk strategies. Join Michael and Bryn as they navigate the complexities of compliance in today's corporate landscape.Bryn discusses how crucial it is to start with a realistic approach to building a compliance program and continually improve compliance programs to mitigate risks effectively.Having a platform like Arvao's is valuable for companies as it is highly configurable and tailored to meet the unique needs of each client's business structure and risk management requirements.The partnership between IT and cyber security in a compliance program is vital for addressing cybersecurity risks effectively within organizations. It is a growing trend for IT and cyber security to focus on collaboration and meeting the unique needs of each department.Unified visibility across different risk domains and third-party activities is essential for making informed decisions and managing risks effectively. Continuous monitoring and auditing are crucial in compliance programs, with a risk-based approach to optimize resources and ensure proactive risk management.Sanctions compliance is a growing area of focus, requiring proactive monitoring, risk-based approaches, and continuous updates to mitigate risks effectively.ResourcesBryn Sedlaceck on the WebEmail: bsedlacek@arvavo.comMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

Over the last ten years, we have seen a marked shift from the Delaware Chancery Court chipping away at corporate board member liability claims. In a number of seminal cases involving Boeing airplane crashes (In re the Boeing Co. Derivative Litig., No. 2019-0907 (Del. Ch. Sept 7, 2021)), and deadly listeria outbreaks from tainted ice cream (Marchand v. Barnhill, 212 A.3d 805 (Del. 2019)), Delaware Courts have upheld plaintiffs' cases against claims of failing to adequately plead violations of the standards set forth in Caremark, 698 A.2d 959 (Del. Ch. 1996), (establishing basic pleading requirements to withstand motions to dismiss). In this episode, Mike Volkov provides a comprehensive update on the recent Caremark decisions issued by the Delaware Chancery Court, underscoring their importance for accountability and governance in the corporate world.Caremark oversight duties stem from the well-established duty of loyalty and its subsidiary duty of good faith. To plead a Caremark claim, a plaintiff is required to put forth adequate facts from which a factfinder can make a reasonable inference that the fiduciary acted in bad faith. Under Caremark, bad faith can be established when a fiduciary: “(1) utterly fail[s] to implement any reporting or information system or controls," or (2) having implemented such a system or controls, consciously fail to monitor or oversee its operations, which results in a failure to act or attend to a risk or problem requiring their attention or response. Last year, the Chancery Court made a groundbreaking decision, extending the so-called Caremark oversight obligations and governance requirements to senior management in the McDonald's case. In re McDonald's Corp. S'holder Derivative Litig., 289 A.3d 343 (Del. Ch. 2023). This ruling is one of the most significant developments in recent years, advocating for increased accountability for oversight and governance failures.Recent cases, such as the Boeing 737 MAX crashes and the Listeria outbreak from tainted Blue Bell ice cream, have highlighted failures in proper board governance and oversight responsibilities.In a case involving Segway, the Chancery Court dismissed a motion against an officer for failing to detect financial discrepancies, emphasizing the need to demonstrate a lack of good faith in monitoring central compliance risks.The trend in Delaware Chancery Court decisions is moving towards holding directors and officers accountable for failures to act in response to indications of potential illegal conduct, with a focus on bad faith actions.The Boeing case exemplifies the consequences of board members ignoring safety concerns and focusing solely on the bottom line, leading to tragic outcomes that could have been prevented with proper oversight and accountability.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law Group

Directive 2019/1937 of the European Parliament and Council dated 23 October 2019 on the “protection of persons who report breaches of Union law” (the “Directive”) is currently being implemented by EU Member States. The directive has broad applicability to organizations operating in the EU internal market and applies to both public and private sector organizations alike. Whistleblowers are guaranteed legal protection to the extent: (1) they have reasonable grounds to believe that the information reported was true at the time of the report; and (2) the whistleblower reported either internally to the organization, externally to a competent authority, or publicly. Private sector organizations with 50 or more workers are legally required to establish channels and procedures for internal reporting of EU law breaches and conduct appropriate follow-up. In this episode, Mike Volkov is joined by Daniela Melendez and Alex Cotoia from the Volkov Law Group, who bring their expertise to the table as they delve into the EU Directive and its implementation by several member states. Listen to this discussion to understand and navigate the complexities of the EU Whistleblowing Directive.The EU Whistleblower Directive shifts the burden of proof on retaliatory actions to the person taking the detrimental action, requiring them to demonstrate it was not linked to reporting concerns.Global companies are taking a proactive stance by increasingly focusing on robust ethics and compliance programs. This strategic move is aimed at mitigating risks and promoting positive corporate citizenship in today's economy, where adherence to legal and ethical standards is paramount.France signed the EU Directive into law on March 21, 2022, outlining protocols for gathering and handling whistleblower reports, including a two-month deadline for imposing disciplinary sanctions.Germany enacted the EU Directive on May 12, 2023, allowing anonymous reports and setting a three-month investigation deadline after receiving the report.Spain addressed the EU Directive on February 2023 by covering additional topics like occupational health and safety breaches. The directive established a three-month deadline for investigations and allowed anonymous reports.Italy transposed the EU Directive on August 4, 2022, including administrative, financial, civil, and criminal offenses not covered by the Directive, with a 30-day deadline to conduct investigations upon receipt of reports.Companies are advised to make resources available to conduct investigations quickly due to the short timeframes set by various countries' whistleblower protection laws.ResourcesMichael Volkov on LinkedIn | TwitterThe Volkov Law GroupAlex Cotoia on LinkedIn Email: acotoia@volkovlaw.comDaniela Melendez on LinkedInEmail: dmelendez@volkovlaw.com

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special episode, I am joined by Mike Volkov, founder of the Volkov Law Group. We conclude with Part 2 looking back on the year 2022 in FCPA and Compliance. We consider the Monaco Memo, the key cases and some of the important issues which arose in 2022 and how they might impact compliance in 2023. In this episode we consider: ·      Building trust and credibility in the investigative process ·      The ABB FCPA enforcement action ·      The Honeywell FCPA enforcement action ·      Why the heat is on compliance after the Monaco Memo ·      Corporate incentives and discipline including clawbacks ·      The Glencore FCPA enforcement action and CCO Certification Resources Mike Volkov on LinkedIn The Volkov Law Group 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 special episode, I am joined by Mike Volkov, founder of the Volkov Law Group. We begin a two-part podcast on looking back on the year 2022 in FCPA and Compliance. We consider the Monaco Memo, the key cases and some of the important issues which arose in 2022 and how they might impact compliance in 2023. In this episode we consider: ·      The Monaco Memo ·      The Stericycle FCPA enforcement action ·      The KT FCPA enforcement action ·      The upcoming trial of Cognizant executives and internal investigations ·      Key individual prosecuted Resources Mike Volkov on LinkedIn The Volkov Law Group Learn more about your ad choices. Visit megaphone.fm/adchoices

In this Episode Tom Fox and Mike Volkov review recent DOJ trial successes and stumbles -- Tom and Mike review DOJ trial strategy, successes and failures and approach of the antitrust division.

In this episode of the FCPA Compliance Report I visit with Mike Volkov. Mike recently did a three-part blog post series reviewing the DOJ trial strategy, successes and failures and approach of the antitrust division. In this podcast we take a deep dive into FCPA trials, other white collar fraud trials and antitrust trials the DOJ has had over the past few years. We assess the key approaches, discuss some important wins and unfortunate stumbles.     Resources Mike Volkov on Corruption Crime & Compliance Part 1 - A Mixed Bag Part 2 – Big Victories and Misguided Targets Part 3 – Antitrust Division Stumbles Learn more about your ad choices. Visit megaphone.fm/adchoices

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

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

The SEC releases regulations around climate change as Tom take a solo turn to look at some of the week's top compliance and ethics stories in the Seeing Green edition. Stories 1.     SEC comes out with climate change regs. Andrew Ross Sorkin in NYTimes Dealbook. Matt Kelly in Radical Compliance. Tom and Matt in Compliance into the Weeds. 2.     SFO spanked again. Andrew Crowley in MLex.  3.     Getting rid of old data critical. Debevoise lawyers in Compliance and Enforcement.  4.     The ‘S' in ESG. Mike Volkov in Corruption Crime and Compliance.  5.     FINRA and CCO liability. Matt Kelly in Radical Compliance.  6.     IDB debars construction company. Harry Cassin in the FCPA Blog.  7.     First ZTE monitorship ends. Jaclyn Jaeger in Compliance Week (sub req'd) 8.     DOJ raises stakes. Todd Fishman, Noah Brumfield, Eun Woo Jhang and Elaine Johnston in CCI.  9.     Top 6 ESG issues for 2022. Giles Newman in Risk and Compliance Matters.  10.  A Privacy Shield replacement on the horizon? Neil Hodge in Compliance Week. (sub req'd)  Podcasts and More 11.  In March on The Compliance Life, I visit with Audrey Harris, Managing Director at AMI, formerly CCO at BHP. In Part 1, she discussed her academic background and early professional career. In Episode 2, Audrey moved to the CCO chair at BHP. In Episode 3, she moved back to private practice. In Episode 4, she moves to AMI. 12.  Tom has a two part series with Aly McDevitt on her recent Ransomware case study, on Greetings and Felicitations,  Part 1 and Part 2. 13.  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.  14.  Tom visits with Pop Hair Art Salon founder, Michele Van Fossen on The Hill Country Podcast. 15.  An undergrad degree focusing on ESG? Jules Oringel 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

MLB and the players manage to work out their differences as Tom Brady unretires. Jay and  Tom to look at some of the week's top compliance and ethics stories in the Baseball is Back edition. Stories 1.     Is ESG in crisis? Lawrence Heim in practicalESG. 2.     Compliance-The Single. Matt Kelly in Radical Compliance. 3.     Corporate investigations and waiver of privilege. Debevoise lawyers in Compliance and Enforcement.  4.     Fear based compliance. Mike Volkov in Corruption Crime and Compliance.  5.     A view on corruption from the front lines. Tom and Matt interview Tim Khasinov-Batirov on Compliance into the Weeds. Matt blogs in Radical Compliance.  6.     Holistic 3rd party management. Mike Volkov, Susanna Cagle and Carol Williams in Risk and Compliance Matters.  7.     What kind of person resists a bribe? Gary Drevitch in Psychology Today. 8.     Ethisphere announces 2022 WME.  Ethisphere Press Release. Erica Salmon Byrne on the FCPA Compliance Report.  9.     Are cyber whistleblowers different. Kenji Price, Scott Ferber and Mark Schreiber in CCI. 10.  If you are going to IPO, better ESG first. Bob Conlin in Forbes.com. Podcasts and More 11.  In March on The Compliance Life, I visit with Audrey Harris, Managing Director at AMI, formerly CCO at BHP. In Part 1, she discusses her academic background and early professional career. In Episode 2, Audrey moves to the CCO chair at BHP. In Episode 3, she moves back to private practice.  12.  Tom and Megan Dougherty are back with 2 more episodes of the MCU series. Guardians of the Galaxy Part 1 and Part 2. 13.  Taxman: On the Intersection of Tax and Compliance. A 5-part series with Tracy Howell. Part 1-why compliance needs to talk to tax. Part 2-transfer pricing. Part 3-why tax needs a seat at the table. Part 4-tax and supply chain. Part 5-tax and ESG. 14.  Tom visits with Hill Country Joanne Easley on The Hill Country Podcast. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

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

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

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

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

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 are pleased to host Mike Volkov, host of the Corruption Crime and Compliance podcast on the Compliance Podcast Network. Mike formerly worked in the DOJ, Antitrust Division. We consider the current evolution of antitrust enforcement by the DOJ and FTC and how it might impact the Microsoft acquisition of Activision Blizzard. Some of the issues we consider include: ·      Is the focus of antitrust enforcement changing from consumers to others? ·      What is a Section 2 Sherman Act claim? ·       What are structural v. behavioral remedies?  ·      Have partial divestitures fallen out of favor? ·      How might all this play out in the Microsoft acquisition of Activision Blizzard? ·      What is the role of compliance going forward? Resources Matt in Radical Compliance Mike Volkov in  Corruption Crime and Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

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

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

The college football season has ended with UGA finally defeating UA. Tom and Jay turn their full attention to the NFL playoffs now and also look at some of the week's top compliance and ethics stories this week in the Georgia Finally Beats Alabama edition. Stories 1.     Carnival and Princess Cruise Lines violated DPA yet again. Matt Kelly in Radical Compliance. DOJ Press Release.  2.     Prioritizing items from the Strategy on Countering Corruption. Worth McMurray in the FCPA Blog. 3.     DOJ to look at short sellers. Jaclyn Jaeger in Compliance Week (sub req'd). 4.     Proposed framework for CCO liability analysis. Mengqi Sun in WSJ Risk & Compliance Journal.    5.     Manipulation on timing of FCPA enforcement action? Matthew Stephenson debunks a new article in GAB. 6.     ComTech comes to financial institution compliance. Christian Wunderly in the FCPA Blog.   7.     Phil Tetlock and Superforecasting come to risk management. Jim DeLoach in CCI. 8.     Ethics and FCPA predictions for 2022. Mike Volkov with a double dose of Carnac the Magnificent. Ethics here. FCPA here.  9.     Banks develop climate risk consortium. Aaron Nicodemus in Compliance Week. (sub req'd) 10.  Liability of local representatives under GDPR. Kelly Hagedorn and Matthew Worby in Compliance and Enforcement.  Podcasts  11.  Tom and Matt Kelly conclude a 2-part podcast series on issues they are following in 2022.  On Compliance into the Weeds, Part 1 and Part 2.  12.  In January on The Compliance Life, I visit with Valerie Charles, partner at StoneTurn. Val has one of the most interesting journeys in compliance. In Part 1, she discussed her academic background and early professional career. In Part 2, she discusses her move to ComTech. 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. In Episode 4, Colin Manchester discusses the evolution of the disclose or abstain rule.  14.  Mikhail Reider-Gordon returns in Lies, Spies & Corporate Crimes: The Wirecard Saga, with Season 2, Episode 3 Shell Games. 15.  Check out 31 Days to a More Effective Compliance Program returns, which runs for the month of January, from January 1 to January 31. Available on the Compliance Podcast Network, Megaphone, iTunes, and all other top podcast platforms.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.   Learn more about your ad choices. Visit megaphone.fm/adchoices

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

Mike Volkov has said, “Even when a company does all the right things at the senior management level, the real issue is whether or not that culture has embedded itself in middle and lower management. A company's culture is reflected in the values and beliefs that exist throughout the company.” To fully operationalize your compliance program, you must articulate the message of ethical values and doing business in compliance and then drive that message from the top down, throughout your organization. What should the tone in the middle be? What should middle management's role be in the company's compliance program? This role is critical because the majority of company employees work most directly with middle, rather than top management and, consequently, they will take their cues from how middle management responds to a situation. Perhaps most importantly, middle management must listen to the concerns of employees. Even if middle management cannot affect a direct change, it is important that employees have an outlet to express their concerns. Your organization should train middle managers to enhance listening skills in the overall context of providing training for their “Manager's Toolkit.” This can be particularly true if there is a compliance violation or other incident which requires some form of employee discipline. Most employees think it important that there be organizational justice so that people believe they will be treated fairly. For if there is organizational justice, it engenders perceived procedural fairness which makes it more likely an employee will be willing accept a decision that they may not like or disagree with the end result. Even with great “tone at the top” and positive “mood in the middle”, you cannot stop. One of the greatest challenges of a compliance practitioner is how to impact the most front-line employees or the “tone at the bottom”. One of the things you can do is assemble a compliance focus group to find out how business is done in the field and if it differs from what your company expects from an ethical and compliance perspective. Begin by assembling a group of employees who are familiar with the challenges of doing business in a compliant manner in certain geographic regions to discuss the challenges of doing business ethically and in compliance. Ask them questions about their understanding of your compliance regime. Then categorize the answers into the theory and practice of compliance in your company. Employees often look to their direct supervisor to determine what the tone of an organization is and will be going forward. Many employees of large, multi-national organizations may never have direct contact with the CEO or even senior management. By moving the values of compliance through an organization into the middle, you will be in a much better position to inculcate these values and operationalizing compliance with them.  Three key takeaways: 1. Tone at the top—direct supervisors become the most important influence on people in the company 2. Give your middle managers a Tool Kit around compliance so they can fully operationalize compliance 3. Organizational justice is an additional way to help operationalize compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

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

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

Welcome to the Shout Outs and Rants from Episode 81 1. Mike Volkov rants about the DOJ investigations into Democratic members of Congress under the Trump Administration.   2. Jonathan Marks shouts out to the FBI for recovering the bitcoin payment made by Colonial Pipeline to the cyber hackers who breached it.   3. Kortney Nordrum rants about OSHA who after promising guidance for companies on return to work after Covid-19, only does so for health care organizations.  4. Matt Kelly has his own epic rant about Texas' own Congressman Louis Gohmert who asked a Department of Forestry representative if they had looked at altering the orbit of the earth or moon to combat the effects of climate change. 5. Tom Fox shouts out to the Department of Justice who indicted two US citizens who were engaged in bribery and corruption in trying to persuade the Trump Administration to order the DOJ to drop its investigation into 1MDB.

Hannukah came early this year and we are now in the full holiday swing of things. Tom and Jay are back to look at some of the week's top compliance and ethics stories this week in the Happy Holidays edition.  Stories 1.     New Biden Administration anti-corruption strategy revealed. Matt Kelly in Radical Compliance.   2.     Mike Volkov asks where are the FCPA enforcement actions? In Corruption Crime and Compliance. 3.     Global ESG efforts and compliance. Mike Munro in explores in the FCPA Blog. 4.     More on the OECD recommendations.  Jessica Tillipman in the FCPA Blog.    5.     DOL proposal may change ESG game. Melissa Khan in Harvard Law School Forum on Corporate Governance. 6.     Nurturing ethical culture. Matt Kelly in Risk and Compliance Matters.  7.     Is Italy a safe haven for bribe payors? Rick Messick asks in GAB.   8.     How to avoid a dystopian office culture. Rob Shavell in CCI.  9.     Top ethics and compliance failures in 2021. Jaclyn Jaeger in Compliance Week (sub req'd). 10.  When is a potential fine a threat? Keith Paul Bishop in California Corporate and Securities Law.     Podcasts and Events 11.  The recent announcement by DAG Monaco on the refocus of the DOJ's use of monitors has caused much consternation. To analyze, Affiliated Monitors sponsored a 5-part podcast series this week Not Your Father's Monitor. In this Episode 1, Bethany Hengsbach considers this change in monitorships from the white-collar enforcement and defense perspective. In Episode 2, Mikhail Reider Gordon looks at global aspects of the new DOJ monitor's focus. In Episode 3, Cristina Revelo discusses how E&C assessments help drive more compliant companies. In Episode 4, Jesse Caplan brings his views on the intersection of the twin topics of antitrust and healthcare compliance. In Episode 5, Vin DiCianni looks at where monitors and monitorships are going in 2022 and beyond. 12.  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.  13.  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.  14.  The Compliance Podcast Network welcomes Professor Karen Woody and her new podcast, Once Upon a Trading Law: The History of Insider Trading. In this most unique pod, Karen interviews some of her student to tell the history of insider trading. Check out Episode 1, which looks at the beginnings of insider trading.  15.  Join Tom, Mike Volkov, Carrie Penman, Dr. Pat Harned and Skip Lowney (an all-star panel if there ever was one) for the ECI webinar on the intersection of compliance and E&C programs. Wednesday, December 15, from 2-3:30 ET. Registration and information 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

Hanukkah comes early this year. As the Rosen household begins its annual celebration, Tom and Jay are back to look at some of the week's top compliance and ethics stories this week in the Happy Hanukkah edition.  Stories 1.     Preparing for dawn raid in the era of hybrid work? Andrew Reeves and Annie Birch in FCPA Blog.  2.     When you fight corruption, it fights back. Rick Messick in GAB. 3.     Why does Walmart want to keep an exec quiet about its compliance program? Dick Cassin explores in the FCPA Blog. 4.     Board effectiveness survey.  Paul DiNicola and Leah Malone in the Harvard Law School Forum on Corporate Governance.    5.     New OECD ABC suggestions. Nicola Bonucci and Nat Edmonds in the FCPA Blog. 6.     Graybeards and Youngbloods working together. Carrie Root in CCI.  7.     Trust in companies ‘shockingly' low? Lawrence Heim in PracticalESG.   8.     Are senior level compliance positions becoming harder to find and fill? Matt Kelly explores in Radical Compliance.  9.     Role of PwC in Tesla/JPMorgan dispute. Francine McKenna explores in The Dig (sub req'd). 10.  How will tech change the work landscape in 2022? Check out this pod with Mrs. Monitor (AKA Rebecca Rosen) on Freshbrewed Tech.    Podcasts and Events 11.  How can you show ROI from your internal investment in compliance? Nick and Gio Gallo join Tom Fox in the most unusual pod series, Mining the Gold in Compliance. Part 1 - ROI on Compliance. Purchase Decisions. Part 2 - Extending Compliance Value Across an Organization. Part 3 – Compliance and ESG Investments. Part 4 – Finance and Investing Models for Compliance. Part 5 - Investment Strategies for the Compliance Professional. 12.  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 11, a birthday party battle through text messages.  13.  In November on The Compliance Life, I visited with Wendy Badger, CCO at Tennant. In Part 1, she detailed her academic career and early professional life. In Part 2, changing ladders to advance your career. In Part 3, Wendy moved into the CCO Chair. In Part 4, Wendy talked about having courage in your career choices and compliance into the future. Next week, we begin the December series with Matt Silverman, Director of Trade Compliance at VIAVI.  14.  The Compliance Podcast Network welcomes Professor Karen Woody and her new podcast, Once Upon a Trading Law: The History of Insider Trading. In this most unique pod, Karen interviews some of her student to tell the history of insider trading. Check out Episode 1, which looks at the beginnings of insider trading.  15.  Join Tom, Mike Volkov, Carrie Penman, Dr. Pat Harned and Skip Lowney (an all-star panel if there ever was one) for the ECI webinar on the intersection of compliance and E&C programs. Wednesday, December 15, from 2-3:30 ET. Registration and information 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

Is compliance the happiest profession? Are you passionate about compliance? If you are either or both, you are not alone. Guest Host Karen Woody and Tom Fox look at these and other stories this week in the Happiest Profession edition. Stories Is Compliance the happiest profession? Amii Bernard-Bahn explores in Compliance Week (Sub Req'd) Report on SEC Enforcement Activity: Public Companies and Subsidiaries for 2021. Tom Gorman in SEC Actions. Supply chain and compliance. Mike Volkov in Corruption Crime and Compliance. Dick Cassin in the FCPA Blog. What does ESG mean for the SEC? Commissioner Crenshaw remarks to the Pepsico-PWE Conference in the Harvard Law School Forum on Corporate Governance.  Corruption as psychic revenge. Richard Bistrong in the FCPA Blog. Mitigating cyber risks. Debevoise Plimpton lawyers in Compliance and Enforcement. COP26 wrap up. What are the lessons for compliance? Lawrence Heim in PracticalESG. SEC broke all whistleblower awards in FY 2021. Aaron Nicodemus in Compliance Week (Sub Req'd) Carrie Penman says it's a wakeup call for companies in Ethics and Compliance Matters. Diversity at the top. Jim Deloach in CCI. How did Classical Athenians define corruption? Kellam Conover in GAB. Podcasts and Events Have you or a loved one been impacted by Lyme Disease? This week I have run a 5-part series on this most misunderstood malady with Dr. Ben Locwin and Scott Endicott. In Part 1 we looked at Origins. In Part 2 we considered the Diagnosis Dilemma. In Part 3 we reviewed Treatment and Innovation. In Part 4, we discussed Prevention and Immunity. In Part 5, we looked ahead for where this disease detection, prevention and treatment might be heading. 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 10, a trip on the New Jersey Turnpike. This month on The Compliance Life, I visit with Wendy Badger, CCO at Tennant. In Part 1, she details her academic career and early professional life. In Part 2, changing ladders to advance your career. In Part 3, Wendy moves into the CCO Chair. 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. Karen Woody is Associate Professor at Washington and Lee University School of Law and can be reached at kwoody@wlu.edu. Learn more about your ad choices. Visit megaphone.fm/adchoices

As Aaron Rogers is fined less than a player who had his shirttail untucked, he and Jay are back to reflect on some of the top compliance and ethics stories in the Immunized Not Vaccinated edition.  Stories 1.     Will corruption forestall climate change? Monica Guy in the FCPA Blog.  2.     Driving culture through sustainability. Linda Luty in Risk and Compliance Matters.  3.     Stope little problems from becoming big ones. Mike Volkov in Corruption Crime and Compliance.  4.     More on ‘effective compliance'? Michael Julian in the FCPA Blog.  5.     What is ‘success' in ABC compliance? Matthew Stephenson in GAB.   6.     Revisiting your whistleblower program. Debevoise Plimpton lawyers in Compliance and Enforcement.  7.     The role of BOD in ESG.  Jurgita Ashley and Randy Vai Morrison in Harvard Law Forum on Corporate Governance.  8.     Disclosing cybersecurity issues. Matt Kelly in Radical Compliance.  9.     Mashreqbank fined $100MM by DFS. Jaclyn Jaeger in Compliance Week. (sub req'd)  10.  Tailoring a Design Thinking program that fits for you. Carsten Tams on LinkedIn. Podcasts and Events 11.  How can a 1st responder deal with PTSD? One way is through poetry. Check out my interview with Detective Ed Gillespie, Policeman Poet of Baltimore in a very special episode of Greetings and Felicitations.  12.  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 9, a lost purse and panic in Shubert Alley. 13.  This month on The Compliance Life, I visit with Wendy Badger, CCO at Tennant. In Part 1, she details her academic career and early professional life. In Part 2, changing ladders to advance your career.  14.  In a sponsored podcast series, I visit with 6clicks on their innovative GRC solutions. In Episode 1, Joe Schorr on the hub and spoke approach. In Episode 2, Andrew Robinson on AI and ML in GRC. In Episode 3, Stephen Walter on building a content library. In Episode 4, Heather Buker on producing audit ready reports. In Episode 5, Ant Stevens on what's next for 6clicks.   15.  Next week, I am running a 5-part series on Understanding Lyme Disease. The episodes will post daily at 10AM. You can check out all episodes on the Greetings and Felicitations podcast. Episode 1: Origins and Evolution; Episode 2: The Diagnosis Dilemma; Episode 3: Treatment and Innovation; Episode 4: Protection and Immunity; Episode 5: Looking Ahead 16.  How does a Compliance Bible become a best-seller? Check out Tom's appearance on the C-Suite Network's Best Seller TV to find out.  Purchase The Compliance Handbook, 2nd edition here.  Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

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

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

Either the Astros or Red Sox are headed to the World Series. Flashing lights in Fenway? What will the baseball gods decree? Tom and Jay reflect as they are back to review some of the top compliance and ethics stories on the Headed to the WS edition. Stories 1.     Credit Suisse and Tuna boats equals nearly $500 MM in fines. Harry Cassin in the FCPA Blog. Matt Kelly in Radical Compliance. Jaclyn Jaeger in Compliance Week (sub req'd) 2.     CCOs as problem solvers. Mike Volkov in Corruption Crime and Compliance. 3.     Testing compliance. Brandon Garrett in Compliance and Enforcement.  4.     3rd party risk management and SOC 2.  Eva Pittas in CCI.  5.     Activision promises compliance upgrades. Should we believe them? Jaclyn Jaeger in Compliance Week. (sub req'd)  6.     Is ESG reporting risky? Mike Munro explores in the FCPA Blog.   7.     Facebook fined for changing CCOs without reporting to the CMA? CMA Press Release. 8.     The intersection of compliance and IT. Kyle Martin in Risk and Compliance Matters. 9.     What does the oldest COI tell us about professional misconduct? Jeff Kaplan in the FCPA Blog.  10.  Contesting the narrative of compliance failures. Robert Barrington in GAB.  Podcasts and Events 11.  Compliance Week is going ‘Inside the Mind of the CCO'. Participate in the survey 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 6, Billy Joel and exasperation.  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. 15.  Why is the Texas Hill Country one of the most special places on earth? Check out the newest edition to the CPN, as Tom Fox celebrates the people, places and things of the Hill County. In Episode 1, he visits with Camp Stewart for Boys matriarch, Kathy Ragsdale. 16.  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

The Astros and Red Sox meet in the ALCS. Is it the Cheater's Ball? Tom and Jay are back to review some of the top compliance and ethics stories on the Back in the ALCS edition.  Stories Who knows what values lurk in the heart? The Shadow know (and your emails as well). The John Gruden firing. ESPN, Sports Illustrated, NYT, WSJ. Tom with a 2-part blog post series. Confronting Ethical and Moral Dilemmas: Don't Go It Alone. Richard Snell in Knowledge@Wharton. Evolution of 3rd party risk management. Mike Volkov in Corruption, Crime and Compliance. The role of employees in weeding out corp misconduct. David Smagalla in the WSJ Risk and Compliance Journal. Ex-Braskem CEO gets 20 months. Kyle Brasseur in Compliance Week. (sub req'd) Cooperating (or not) with the SFO. Lloydettte Bai-Marrow in the FCPA Blog. Inconsistency in UK and EU banking regs? Deepali Nijhawan in CCI. What is tech risk? Carol Williams in Risk and Compliance Matters. Ozy from the audit perspective. Francine McKenna in The Dig. (sub req'd) ESG channels Watergate (as in follow the money). Lawrence Heim in practicalESG.  Podcasts and Events Compliance Week is going ‘Inside the Mind of the CCO'. Participate in the survey here. Ethisphere's World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here. 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 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. In Episode 4, the ubiquitous ‘Couples Dinner'. In Episode 5, a tennis journeyman's lament. 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 moves into the corporate world and into compliance. What is Design Thinking in Compliance? Check out the newest edition to the CPN, where co-hosts Tom Fox and Carsten Tams discuss the social engineering tool of design thinking and how it creates greater compliance engagement and effectiveness. In Episode 2, we take up co-creation. 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

Tom is on for a solo run this week to review some of the top compliance and ethics stories on the Facebook Whistleblower edition.  Stories 1.     The Facebook Whistleblower. 60 Minutes appearance and Congressional Testimony. Matt Kelly in Radical Compliance. Aaron Nicodemus in Compliance Week.  (sub req'd) 2.     Petrofac settles with SFO. Harry Cassin in the FCPA Blog.  3.     ESG and business risks. Mike Volkov in Corruption, Crime and Compliance.  4.     DOJ to emphasize white collar criminal cases.  Dylan Tokar in the WSJ Risk and Compliance Journal.  5.     Ancient history and FCPA enforcement. Dick Cassin in the FCPA Blog.   6.     Lessons learned from the Pandora Papers. Jaclyn Jaeger in Compliance Week. (sub req'd) 7.     Using AI for pattern recognition in investigations. Veeral Gosalia in CCI. 8.     Will ethical lapses at the Fed sink the Powell nomination? Jeanna Smialek and James Tankersly in the NYT. 9.     The Big Stink and Green Bonds. Lawrence Heim in PracticalESG.  10.  Would you trust Ozy? Ozy says its open for business (after a short hiatus).  What does it mean for compliance? Megan Leonhardt and Jessica Mathews in Fortune. 11.  Risk based compliance and ransomware. SheppardMullin lawyers on JDSupra.    Podcasts and Events 12.  Congrats to Great Women in Compliance for being honored as a top pod by w3 in the DEI category; Everything Compliance as a top roundtable in podcasting and CPN for top compliance podcast network.  13.  Compliance Week is going ‘Inside the Mind of the CCO'. Participate in the survey here.  14.  Ethisphere's World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here.  15.  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 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. In Episode 4, the ubiquitous ‘Couples Dinner'. 16.  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.  17.  What is Design Thinking in Compliance? Check out the newest edition to the CPN, where co-hosts Tom Fox and Carsten Tams discuss the social engineering tool of design thinking and how it creates greater compliance engagement and effectiveness. Check out Episode 1 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 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

Jay is once again traveling this week so we are joined by Professor Karen Woody as special guest co-host. I know you will enjoy her comments on this special Focus on the SEC edition. Stories 1.     Coinbase v. the SEC. Andrew Ross Sorkin previews in NYT Dealbook. Francine McKenna takes a deep dive in The Dig (sub req'd) Gary Gensler testifies before Congress, Paul Keiran in the WSJ. 2.     Why compliance should lead ESG. Kyle Brasseur  in Compliance Week (sub req'd) 3.     Another cheating scandal at KPMG. Matt Kelly on Radical Compliance. Leadership 4.     Leadership lessons from the fall of Kabul. Sandra Erez in CCI. 5.     What are the Big 3 issues from this year's proxy season? Eric Knox, Sehrish Siddiqui and David Venturella in CCI. 6.     How large a problem is corporate recidivism? Dick Cassin in the FCPA Blog. 7.     The Great Resignation and meaningful work. Brett Beasley in Notre Dame's Deloitte Center for Ethical Leadership. 8.     Boeing safety woes hit the Boardroom. Wachtel Lipton lawyers in Harvard Law School Forum on Corporate Governance. 9.     On the intersection of culture and corporation reputation. Mike Volkov in Corruption Crime and Compliance. 10.  Learned Hand on leadership and humility. Jeff Kaplan in the Conflict of Interests blog. Podcasts and Events 11.  CCI surveying stress in compliance. Henry Kronk in CCI. Take the survey here 12.  On Innovation in Compliance, Tom has run a 6-part special podcast series on Looking Back on 9/11, sponsored by Affiliated Monitors. In this series he will visit with professionals from a variety of compliance perspectives who will discuss how 9/11 changed our profession, including three who were in NYC during the attacks. Hear thoughts and reflections from Gabe Hidalgo, Juan Zarate, Alex Dill, Eric Feldman, Scott Moritz and John Lee Dumas. 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. 14.  Ethisphere's World Most Ethical Company awards for 2022 are open for submission. For more information on the Application Process, click here. 15.  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. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Matt Kelly, Jonathan Marks, Mike Volkov, Jonathan Armstrong and Jay Rosen episode dedicated as our collective reflections on the 20thanniversary of 9/11. We end with a veritable mélange of shouts outs and one epic rant.     1. Mike Volkov has a melancholy shout out for the US soldiers killed in the recent bombing in Kabul who were not yet born or very young children on 9/11.   2. Jonathan Marks shouts out to the first responders of 9/11 and the men and women of the US military.   3. Jay Rosen shouts to civility and unity, lost commodities in 2021 America and hopes we can reclaim those qualities that brought us together after 9/11. 4. Matt Kelly has an epic rant on backsliders in politics and society that are running away from what America stands for.  5. Jonathan Armstrong shouts out to all those first responders who run towards the danger and to Dr. Peter Holden and his colleagues who treated bombing victims on 7/7 in London. 6. Tom Fox shouts out to men and women of the US military who went to war some 20 years ago when they were in the late teens and early 20s. He also shouts out to Iraq veteran John Lee Dumas who reminds us all that we are the Land of the Free because of the Brave. Additional Resources: For more reflections on 9/11, check out my podcast series, Looking Back on 9/11.  The full schedule is: Sept. 6-Gabe Hidalgo Sept. 7-Juan Zarate Sept. 8-Alex Dill Sept. 9-Eric Feldman Sept. 10-Scott Moritz Sept.11-John Lee Dumas  The podcasts will post at midnight on iTunes, YouTube, Megaphone and Spotify. It will post at 6 AM on the Compliance Podcast Network and JDSupra. The members of the Everything Compliance are: •       Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com •       Mike Volkov – One of the top compliance commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com •       Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com •       Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at jonathan.armstrong@corderycompliance.com •       Jonathan Marks is Partner, Firm Practice Leader - Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at jonathan.marks@bakertilly.com The host and producer, ranter (and sometime panelist) of Everything Compliance is Tom Fox the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.  Learn more about your ad choices. Visit megaphone.fm/adchoices

As Jay returns from an extended road trip, he and Tom look forward to an extended Labor Day weekend and are back to look at some of this week's top compliance and ethics stories which caught their interest on This Week in FCPA in the Labor Day edition.  Stories 1.     Is ESG on your radar? Vince Walden, Rich Goode and Steve Speigelhalter in Fraud Magazine. 2.     The intersection of business and compliance. Mike Volkov in Corruption Crime and Compliance. 3.     China to set world standard for data privacy? Aaron Nicodemus in Compliance Week (sub req'd) 4.     Is Covid-19 the biggest challenge to compliance ever? Calvin Gordon in CCI.  5.     UK signals different approach on data transfer from EU. Aaron Nicodemus in Compliance Week (sub req'd) 6.     3 compliance officers get SEC whistleblower award. Matt Kelly in Radical Compliance.  7.     Email break-ins sanctionable. Dylan Tokar in WSJ Risk & Compliance Journal.  8.     ISO 37002 and EU Whistleblower standard. Kelly Maxwell in Convercent by One Trust blog. 9.     Trial of the Century in Mozambique, Part 2. Rick Messick in GAB. 10.  Diversity training that fosters acceptance and collaboration.  ComplianceLine blog. Podcasts and Events 11.  On Innovation in Compliance this week I interviewed Ethisphere's Erica Salmon Byrne and Doug Allen on the opening of submissions to the World's Most Ethical 2022 awards. You can listen to the pod here. You can find out more about the submission process here.  12.  On The Compliance Life, in August I visited with Kortney Nordrum CCO at Deluxe. In Episode 1, from Red Wing to Israel. In Episode 2, From Freddie Mac to the law. In Episode 3, how Kortney found her professional passion – Compliance. In Episode 4, Kortney moves into the CCO chair.  13.  Breaking News features The Compliance Handbook, 2nd edition. Check out the Breaking News feature here. Purchase The Compliance Handbook, 2nd edition here.  14.  Join K2 Integrity September 15 for a round-table discussion as we reflect on the 20th Anniversary of September 11 and consider its impact on countering terrorist financing and illicit financing, and the continuing risks to national security. The roundtable will include members of the team that spearheaded the post-9/11 counter illicit finance regime: Juan Zarate, Chip Poncy, Danny McGlynn, moderated by Dr. Michele L. Malvesti. Information and Registration here.    15.  The week of 9/11, Tom will run a 6-part special podcast series on Looking Back on 9/11. In this series he will visit with professionals from a variety of compliance perspectives who will discuss how 9/11 changed our profession, including three who were in NYC during the attacks. Check it out 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

As drumheads worldwide mourn the death of Rolling Stones drummer Charlies Watts and Jay goes ‘on the road'; Tom is joined by special guest host, Kristy Grant-Hart to look at some of this week's top compliance and ethics stories which caught their interest on This Week in FCPA in the Charlie Watts Tribute edition.  Stories 1.     Is ESG replacement for government inaction? Lawrence Heim in practicalESG.  2.     Why compliance should lead the ESG effort. Kristy Grant-Hart in Compliance Kristy 3.     What did the current Freddie Mac CCO learn from the 2008 financial crisis? Mengqi Sun in WSJ Risk and Compliance Journal.  4.     What is ‘intentional integrity'? Aly McDevitt in Compliance Week.  5.     Defense industry struggles with cybersecurity. Matt Kelly in Radical Compliance. 6.     How has the pandemic impacted the ABC fight in Latin America? Geert Aalbers in the FCPA Blog. 7.     More oral argument as both sides appeal Hoskins trial verdict. Dylan Tokar in WSJ Risk & Compliance Journal.  8.     Debunking attacks on the Business Roundtable's Statement on the Purpose of a Corporation. Marty Lipton in Harvard Law School Forum on Corporate Governance 9.     The Mozambique hidden debt scandal. Rick Messick in GAB. 10.  What happens to compliance when you have a fractured C-Suite?  Mike Volkov in Corruption Crime and Compliance.   Podcasts and Events 11.  On Innovation in Compliance this week I interview Kristy Grant-Hart, Joe Murphy and Kirsten Liston about their latest book, The Compliance Entrepreneur. Check out the show here. 12.  On The Compliance Life, in August I visit with Kortney Nordrum CCO at Deluxe. In Episode 1, from Red Wing to Israel. In Episode 2, From Freddie Mac to the law. In Episode 3, how Kortney found her professional passion – Compliance.  13.  Compliance Week is having an open house this month as they have dropped their firewall. You can check out the entire publication for no charge. Check it out here.  14.  Breaking News features The Compliance Handbook, 2nd edition. Check out the Breaking News feature here. Purchase The Compliance Handbook, 2nd edition here. Find out more about The Compliance Handbook, 2nd edition in an upcoming Zoom webinar, on Wednesday, September 1 at 8:30 AM ET; hosted by the Azevedo Sette law firm and Charles River Associates. To RSVP email tcintra@azevedosette.br 15.  Join K2 Integrity September 15 for a round-table discussion as we reflect on the 20th Anniversary of September 11 and consider its impact on countering terrorist financing and illicit financing, and the continuing risks to national security. The roundtable will include members of the team that spearheaded the post-9/11 counter illicit finance regime: Juan Zarate, Chip Poncy, Danny McGlynn, moderated by Dr. Michele L. Malvesti. Information and Registration here.    16.  The week of 9/11, Tom will run a 6-part special podcast series on Looking Back on 9/11. In this series he will visit with professionals from a variety of compliance perspectives who will discuss how 9/11 changed our profession, including three who were in NYC during the attacks. Check it out on the Compliance Podcast Network.  17.  Tom pays tribute to Charlie Watts. Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Special guest host Kristy Grant-Hart can be reached at kgranthart@sparkcompliance.com. Learn more about your ad choices. Visit megaphone.fm/adchoices

As the Tokyo Olympics conclude and Biden passes an infrastructure bill, Tom and Jay 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 Infrastructure Bill edition.  Stories 1.     Navex Global new benchmark report. Carrie Penman, Andrew Burt and Mary Bennett in Navex Global's Risk & Compliance Matters blog. 2.     Conducting a double materiality assessment. Donota Calace in PracticalESG, Part 1 and Part 2.  3.     Dangers lurking in internal investigations? Mike Volkov in Corruption, Crime and Compliance.  4.     What can ‘ethics refugees' teach us about E&C? Richard Shell in CCI.  5.     Running a design sprint. Carsten Tams with Part 4 of his 5-part series on Design Thinking in LinkedIn.  6.     Amazon tagged for €746MM for GDPR violations.  Cordery Compliance news alert.  7.     What are the factors driving change in the investigation process? Jaclyn Jaeger in Compliance Week.  8.     The Achilles Heel of Compliance? Scott Moritz in LinkedIn.  9.     Ted Lasso and corruption. Harry Cassin in the FCPA Blog. 10.  100 bottles of booze on the wall, 100 bottles of booze.  Jeff Kaplan in the Conflict of Interest Blog.    Podcasts and Events 11.  Innovation in Compliance hits its 200th anniversary show. I celebrate with Dan Skolnick from Accuity. Check out the show here. 12.  On The Compliance Life, in August I visit with Kortney Nordrum CCO at Deluxe. In Episode 1, from Red Wing to Israel.  13.  How do the Greek Timoleon and the Roman Aemilius inform compliance leadership today? Find out as Tom and Richard Lummis continue their exploration of Plutarch's Lives in this episode of 12 O'Clock High, a podcast on business leadership. 14.  Compliance Week is having an open house this month as they have dropped their firewall. You can check out the entire publication for no charge. Check it out here.  15.  K2 Integrity's Sepideh Rowland will moderate an ABA Webinar: Managing Compliance Under Pressure, August 17. Register and information here. 16.  The Compliance Handbook, 2nd edition is released. Learn about it here. Purchase it here. 17.Each month Affiliated Monitors, Inc. introduces our readers and listeners to members of our AMI team. This month, in addition to our web Spotlight feature https://lnkd.in/g9aUbMaJ  we recorded a companion podcast with Deann Conroy, who is a Compliance Solutions Manager. She is an experienced attorney, leader, and educator of healthcare legal issues. Please follow the link in the show notes for this month's double shot of our colleague Deanne! https://lnkd.in/gfTdF5mq 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 Tokyo Olympics continue and FirstEnergy settles one of the largest domestic corruption cases ever, Tom and Jay 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 Domestic Corruption edition.  Stories The First Energy domestic corruption scandal. Rick Messick in GAB. Matt Kelly in Radical Compliance. Obstacles to compliance training. Dick Cassin in the FCPA Blog. Should companies go into space? Mike Volkov says no in Corruption, Crime and Compliance. Is your compliance relationship with HR unleavened? Then leaven it, says Amy Dufrane in CCI. Can the Olympics be saved? Perhaps from the corruption angle. Andy Spalding in the FCPA Blog. What's it like to be a whistleblower? Aaron Nicodemus with a 5-part series in Compliance Week (sub req'd). Aaron discusses the series on this edition of From the Editor's Desk. (No Sub Req'd) What happens when a CCO acts like a GC? They ‘step in it' says Matt Kelly in Radical Compliance. Are you afraid of your own shadow? Michael Rasmussen says you might well should be in Navex Global's Risk and Compliance Matters. If you step in it, RAC it. Ngozi Okeh in PracticalESG. Boards and Corporate Strategies in the post-pandemic world. Wachtell, Lipton lawyers in the Harvard Law School Forum on Corporate Governance. Podcasts and Events Jonathan Keller reviews the evolution of healthcare compliance in this episode of The Compliance Handbook. Scott Moritz turns the tables on Tom by interviewing him about his recently released book The Compliance Handbook, 2nd edition on this week's edition of Fraud Eats Strategy. On The Compliance Life, in July I visited with Asha Palmer, CECO at Convercent. In Episode 1, from Claire Huxable to the DOJ. In Episode 2, ‘What do you think about Abu Dhabi?' In Episode 3, she moves into compliance consulting and is surprised with what she observed. In Episode 4, Asha talks about moving into the CECO role and beyond. How do the Greek Cleomenes and the Roman Giaus Graccus inform compliance leadership today? Find out as Tom and Richard Lummis continue their exploration of Plutarch's Lives in this episode of 12 O'Clock High, a podcast on business leadership. In Integrity Through Compliance, Episode 14, Joe Miller Returns to Discuss Anticipated Antitrust Enforcement Trends in the Biden Administration. The Compliance Handbook, 2nd edition is released. Learn about it here. Purchase it 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 False Claims Act is a powerful enforcement tool.  The Justice Department with its partner agencies are ramping up enforcement efforts.  The Biden DOJ is preparing to implement an aggressive FCA program across healthcare, defense industries and other government contractors. The False Claims Act stands as a major risk – businesses that depend on government business, including healthcare, defense and other contractors, have to address proactively the risks associated with False Claims Act liability.  Compounding this situation is an active and major whistleblower bar that generates qui tam relators needed to fuel Lengthy and costly government investigations. In this Episode, Mike Volkov reviews the flurry of recent False Claims Act cases brought by the Justice Department.

Corporate board members have an obligation to oversee and monitor a company's compliance program.  In two recent cases, Delaware courts have tightened the standard governing board liability under the Caremark decision.  Several months ago, in a case involving the Blue Bell Ice Cream listeria outbreak, the Delaware Supreme Court applied a heightened standard when relating to "mission-critical" issues involving food safety to a food company.  In another decision, on October 1, 2019, in Clovis Pharmaceuticals, a Delaware Court denied a motion to dismiss a complaint finding that a board's failure to react to red flags concerning a clinical trial protocol satisfied the Caremark standard. In this Episode, Mike Volkov discusses these two important cases and board member liability under Caremark.

The government has stated that a well-designed compliance program includes “appropriately tailored training and communications.” Compliance policies cannot work unless effectively communicated throughout a company. Communications and training programs ensure that directors, officers and employees are aware of and follow compliance policies and procedures.   Indeed, the Justice Department's recent Evaluation of Compliance Program Guidance noted that integration of a company's policies and procedures should include periodic training of all directors, officers and relevant employees and where appropriate agents and business partners. Further, the Guidance states that the company's training program has to be tailored to the audience's size, sophistication or subject matter expertise.   In this Episode, Mike Volkov outlines effective strategies for a training program.

In July 2019, the Justice Department's Antitrust Division issued its Guidance for Evaluation of Compliance Programs.  Based on this comprehensive document, companies need to review and enhance their antitrust compliance programs to address risks of anti-competitive cartel activity, including price-fixing, bid-rigging, territorial and customer allocations. In this Episode, Mike Volkov reviews the elements of an antitrust compliance programs and provides practical advice for implementing an effective antitrust compliance program.

Global banks are the poster children of sanctions violations and the importance of trade compliance. At the top of the heap is Standard Chartered Bank. In a long-awaited resolution of a multi-year investigation, the Justice Department, the Treasury Department's Office of Foreign Asset Control (OFAC), the New York District Attorney's (DANY), the Federal Reserve, the New York State Department of Financial Services (DFS) and the United Kingdom's Financial Conduct Authority (FCA) announced a number of settlement agreements in connection with SCB's violations of Iran Sanctions Programs. Under the agreements, SCB agreed with the: (1) Justice Department to forfeit $240 million, a fine of $480 million and to extend its existing deferred prosecution agreement (DPA) for an additional two years; (2) Department of Treasury's Office of Foreign Asset Control (OFAC) to pay total penalties of $657 million; the Federal Reserve to pay penalties of $163 million; the New York Department of Financial Services to pay total penalties of $180 million; and the UK's Financial Conduct Authority to pay total penalties of $133 million; and (3) New York District Attorney's Office to pay a financial penalty of $292 million and extend its DPA with DA-NY for two years. The Justice Department agreed to credit a portion of these payments and reduced its fine for SCB from $480 million to $52 million, along with the $240 million forfeiture.   In this episode, Mike Volkov reviews the Standard Chartered Bank enforcement action and the implications of the action.  

Tom Fox is a thought leader for the ethics and compliance profession.  He is a prolific writer who has produced a steady body of work -- podcasts, books, blogs, articles -- to advance the compliance function.  He is knowledgeable, practical and insightful on how to implement and maintain an effective compliance program. Tom has just released a new and important book -- The Complete Compliance Handbook.  His latest book is the culmination of years of writing, insights and leadership. In this episode, Mike Volkov interviews Tom about his new book, his perspective on the compliance function and the insights he has gained over the years. To purchase a copy of The Complete Compliance Handbook on Amazon.com click here. To purchase an autographed copy of The Complete Compliance Handbook from the author click here.  

Global companies face ever-increasing risks with sanctions screening and compliance.  The US Treasury Department's Office of Foreign Asset Control ("OFAC") have aggressively enforced complex sanctions regulations against global companies, including banks, oil service and technology companies.  In this aggressive enforcement era, companies have to implement robust screening and compliance controls to identify sanctioned entities and individuals among their business partners and customers. In this podcast episode, Mike Volkov interviews Jacqui Merrill, Senior Associate at The Volkov Law Group, about basic screening and investigation techniques.