Podcast appearances and mentions of Lisa Monaco

Republikanerne i Representantenes hus varsler at de vil stevne nøkkelpersoner i Det hvite hus for å få rede på hvem som egentlig styrte USA fra 2021-2024. Det sies nå at Hunter Biden fungerte som de facto stabsjef i Det hvite hus. I tillegg kommer en rekke personer som er ukjente for de fleste, som Steve Richetti, han finner vi var Bill Clintons fremste politiske rådgiver så langt tilbake som i 2004.Han ville vært i stand til å styre USA, men det ville vært illegitimt. Ingen valgte Richetti, eller Jan Psaki, eller Susan Rice eller Lisa Monaco og den skandaløse presssetalskvnnnen Karine Jean Pierre.Hvordan styrte de? Var det de som håndterte autopen - en penn montert på et stativ som kopierer signaturen til en hvilken som helst person, i dette tilfelle Joe Biden.Det sies at Biden var mestparten av tiden i huset sitt i Wilmington eller i villaen ved stranden. Han ante ikke hva som ble gjort i hans navn.Hvis dette stemmer vil det være det samme som statskupp.Hvis i tillegg Joe Bidens seier skyldtes valgfusk, nærmer vi oss et maktmisbruk som USA aldri har sett maken til.

Presidents have long pursued policy prerogatives through the Department of Justice, but traditionally, there's been a clear division between those and the Justice Department's enforcement decisions. On March 5, 2025, the NYU Law Forum and the Reiss Center on Law and Security at NYU School of Law co-hosted an all-star panel of experts who have served in senior positions at the White House and in the Department of Justice to assess the degree to which the division between the President and the Justice Department has now changed. Among the topics they discussed are: What is the origin of and reason for the Justice Department's measure of independence? How has this independence worked given the Justice Department's mix of political and career employees, and how is the current administration observing those lines?  The expert panel consisted of Vanita Gupta, a Distinguished Scholar in Residence at NYU School of Law and the former Associate Attorney General of the United States; Lisa Monaco, a Distinguished Scholar in Residence at the Reiss Center on Law and Security and the former Deputy Attorney General of the United States; and Breon Peace, the former United States Attorney for the Eastern District of New York.  Trevor Morrison, a former Associate White House Counsel, the Dean Emeritus, Eric M. and Laurie B. Roth Professor of Law, and a Faculty Co-Director of the Reiss Center on Law and Security, moderated the discussion.  Show Notes: Vanita GuptaLisa MonacoTrevor Morrison (Bluesky)Breon PeaceJust Security's coverage of the Department of JusticeJust Security's coverage of the Trump administration's executive actions Music: “Broken” by David Bullard from Uppbeat: https://uppbeat.io/t/david-bullard/broken (License code: OSC7K3LCPSGXISVI)

As Tulsi Gabbard strips the security clearances from dozens of former Biden administration bureaucrats, the walls close in on the Deep State grifters who need the money to keep flowing. The liberal excuse mill churns a victim narrative about Antony Blinken, Jake Sullivan, Lisa Monaco and the 51 intel officials who signed the laptop letter now being blocked from any access to federal buildings as just one government agency, the VA, drops staggering details of fraud, waste and abuse after auditing just 2% of its programs.

The Rich Zeoli Show- Hour 1: 3:05pm- Musk Derangement Syndrome: Social media users are now calling on Tesla owners to sell their vehicles in response to CEO Elon Musk's work with the Trump Administration's Department of Government Efficiency. In one viral clip, TikTok influencer Damien Slash vowed to send Tesla's stock to “zero” and questioned whether the electric vehicle company will even still exist one year from now. 3:10pm- Utah is set to become the first state to ban the use of fluoride in public water systems—Governor Spencer Cox confirmed he plans to sign a bill that will put the policy into effect in early May. 3:15pm- On Monday, the social media platform X was hit with a “massive cyberattack,” according to owner Elon Musk. Could Russia be responsible? Musk notably provided the Ukrainian military with access to his satellite constellation Starlink—allowing Ukrainians to communicate with one another efficiently on the battlefield while repelling Russian aggression. 3:30pm- In a post to social media, Director of National Intelligence Tulsi Gabbard wrote: “Per POTUS's directive, I have revoked security clearances and barred access to classified information for Antony Blinken, Jake Sullivan, Lisa Monaco, Mark Zaid, Norman Eisen, Letitia James, Alvin Bragg, and Andrew Weissman, along with the 51 signers of the Hunter Biden ‘disinformation' letter. The President's Daily Brief is no longer being provided to former President Biden.” 3:35pm- Why does Rich have chopsticks? 3:40pm- According to research from the Heritage Foundation's Oversight Project, former President Joe Biden signed dozens of executive orders with an “autopen”—raising questions about the legitimacy of those actions. Did Biden know what he was signing? Earlier this year, Speaker Mike Johnson (R-LA) revealed that during a closed-door meeting Biden had no recollection of signing an executive order that effectively froze new liquid natural gas export permits.

The Rich Zeoli Show- Full Episode (03/10/2025): 3:05pm- Musk Derangement Syndrome: Social media users are now calling on Tesla owners to sell their vehicles in response to CEO Elon Musk's work with the Trump Administration's Department of Government Efficiency. In one viral clip, TikTok influencer Damien Slash vowed to send Tesla's stock to “zero” and questioned whether the electric vehicle company will even still exist one year from now. 3:10pm- Utah is set to become the first state to ban the use of fluoride in public water systems—Governor Spencer Cox confirmed he plans to sign a bill that will put the policy into effect in early May. 3:15pm- On Monday, the social media platform X was hit with a “massive cyberattack,” according to owner Elon Musk. Could Russia be responsible? Musk notably provided the Ukrainian military with access to his satellite constellation Starlink—allowing Ukrainians to communicate with one another efficiently on the battlefield while repelling Russian aggression. 3:30pm- In a post to social media, Director of National Intelligence Tulsi Gabbard wrote: “Per POTUS's directive, I have revoked security clearances and barred access to classified information for Antony Blinken, Jake Sullivan, Lisa Monaco, Mark Zaid, Norman Eisen, Letitia James, Alvin Bragg, and Andrew Weissman, along with the 51 signers of the Hunter Biden ‘disinformation' letter. The President's Daily Brief is no longer being provided to former President Biden.” 3:35pm- Why does Rich have chopsticks? 3:40pm- According to research from the Heritage Foundation's Oversight Project, former President Joe Biden signed dozens of executive orders with an “autopen”—raising questions about the legitimacy of those actions. Did Biden know what he was signing? Earlier this year, Speaker Mike Johnson (R-LA) revealed that during a closed-door meeting Biden had no recollection of signing an executive order that effectively froze new liquid natural gas export permits. 4:05pm- Bill D'Agostino—Senior Research Analyst at Media Research Center—joins The Rich Zeoli Show to break down some of the best (and worst) clips from the Sunday shows. In an interview with Politico, Governor Tim Walz critiqued the campaign strategy of the Harris-Walz presidential campaign—suggesting they should have done more interviews instead of playing it safe. But, as D'Agostino notes, even friendly interviews were often disastrous for Kamala Harris. PLUS, host of The View Whoopi Goldberg says that if you oppose biological males participating in women's sports, you must think women are weak. 4:30pm- California Governor Gavin Newsom (D) is now suddenly claiming it is “deeply unfair” for biological males to participate in women's sports—pivoting away from the Democrat Party's stance. Interestingly, Newsom also invited conservative Charlie Kirk on his podcast recently. Is Newsom becoming a moderate, leaving his far-left preferences behind? Rich thinks this is nothing more than a political strategy to cement Newsom's status as a 2028 presidential front runner. 5:05pm- Dr. Wilfred Reilly—Professor of Political Science at Kentucky State University & Author of “Lies My Liberal Teacher Told Me”—joins The Rich Zeoli Show to discuss reports that the Trump Administration may disband the Department of Education. Plus, will President Donald Trump pardon former Minneapolis police officer Dereck Chauvin? Dr. Reilly notes that morally, it might be the right thing to do—however, practically speaking, a presidential pardon won't accomplish much since Chauvin is also in prison on state charges. AND will Dr. Reilly be making an appearance at the Grand Hotel of Cape May later this year? 5:50pm- Rich goes 40+ minutes without taking a break—and now he has no time to do anything else. 6:05pm- Make America Healthy Again: Rich notes one of the major shortcomings of the modern food pyramid: it fails to draw a distinction between healthy fats (like those found in avocados, nuts, and olive ...

There is a vote that's going to happen today that will decide whether or not we have a Senate Majority Leader or a Senate Majority Boss. So, which is which? We'll talk about that. Plus, I have a gut-check question for you that God put on my heart this morning. This question is particularly for those of us who voted for President Trump.Episode Links:Ron Johnson to push for a delay in the Senate Majority Leader Conf. vote! "Others are gonna be asking for a delay in that vote. It's grotesque. McConnell figured he has whoever he wants to grease the skids." "If nobody else proposes a delay I will.Lisa Monaco was Robert Mueller's chief of staff when he ran the FBI. She was one of Obama's closest aides—she participated in secret Situation Room meetings with John Brennan in 2016 to concoct Russia collusion hoax.The FEMA official who was just fired for telling workers to avoid homes impacted by the hurricanes in Florida if they had Trump signs says that it was not "isolated" and that FEMA workers were instructed to do it in the Carolinas too.Here's How A British Media Commentator Reported Trump's ElectionFederal Court Backs 2nd CNN Defamation Case, Calls Out Aversion to TruthAlan's Soaps https://www.alansartisansoaps.comUse coupon code ‘TODD' to save an additional 10% off the bundle price.Bioptimizers https://bioptimizers.com/toddUse code TODD to unlock up to $100 in free gifts and save an additional 10% off the special 3-product bundle for a 25% savings.Bonefrog https://bonefrogcoffee.com/toddMake Bonefrog Cold Brew at home!  Use code TODD at checkout to receive 10% off your first purchase and 15% on subscriptions.Bulwark Capital Bulwark Capital Management (bulwarkcapitalmgmt.com) Don't miss the next live Webinar November 21st 3:30pm pacific.  Sign up today by calling 866-779-RISK or go to KnowYourRiskRadio.com.Renue Healthcare The Centre for Regenerative Medicine & Stem Cell Therapy | RENUEYour journey to a better life starts at Renue Healthcare. Visit https://www.renue.healthcare

First up today we talked with John Rich about the challenges of a woke music industry a huge event happening tomorrow in North Carolina. Next, Darren Beattie came on to talk about some breaking new information about the J6 pipe bomber. Then, we talked with Sean Davis about Lisa Monaco and Sally Yates possibly being the next AG in a Harris administration, and the gaslighting going on about Kamala right now. Finally, Telegram founder getting arrested is a huge story and so is the war on global censorship. Dan went off on that. Learn more about your ad choices. Visit podcastchoices.com/adchoices

This week on Ring of Fire! Kellyanne Conway has returned to her previous role as the chief lie-teller for Donald Trump. Over the weekend, Conway appeared on Fox News to falsely claim that Trump spoke to about 8,000 people at a predominantly black church in Detroit, even though photos showed roughly 200, mostly-white people attending his speech. In spite of the photographic evidence to the contrary, Conway continued to push the lie to make Trump feel good, just like she used to do. Marjorie Taylor Greene is so desperate for Donald Trump to be granted immunity by the Supreme Court that she'll believe anything - including that a video from two years ago was somehow taken just hours ago. Greene fell for a deceptive video on social media that was originally posted by a Turning Points contributor that has a history of plagiarism accusations, with Greene claiming that the video was proof that SCOTUS was about to give Trump immunity. On Saturday, the soon-to-be incarcerated Steve Bannon rattled off the top names on Donald Trump's enemies lies that will be targeted first if Trump wins the election this year. Those names include special prosecutor Jack Smith, Merrick Garland, and Lisa Monaco. These Justice Department officials and prosecutor are the ones that have caused the most headaches for Trump, but they aren't the only people his allies have talked about targeting. And it may already be game over for Donald Trump in this year's election as a new poll has found that 21% of Independent voters say that his criminal convictions make it less likely that they will vote for him. They also say that these convictions WILL impact their voting decisions later this year. The only problem is that the public quickly forgets things, and this sentiment could easily die off before we get to November, especially since Trump's other legal cases are likely not happening this year. All that, and much more, on this week's Ring of Fire Podcast!

Segment 1: Doug Hagmann on the constitutional remedies that can and should be employed by a Trump presidency. Sources include Steve Bannon, Katie Hopkins, etc.Segments 2-3: Stan Deyo from https://standeyo.com/index1.htmlPLEASE SUBSCRIBE to our channels on Rumble & Brighteon, and give us a “Like,” and PLEASE share this episode and this channel on your social media feed, and THANK YOU for your support!----------------------SPECIAL: This stuff works better than ANYTHING I've used! Nana Soma - https://iwantmyhealthback.com/hagmann- PLEASE click & definitely watch the videos at link. You'll thank me later.----------------------For complete information, please visit, bookmark, and share The Hagmann Report at our website: https://www.HagmannPI.comTIPS: (Anonymity guaranteed):doug@hagmannreport.com. | rt@hhagmannpi.comON THE GO? SUBSCRIBE TO HAGMANN'S PODCAST:iTunes:https://podcasts.apple.com/us/podcast/hagmann-report/id631558915?uo=4Spotify: BANNED!iHeart: https://www.iheart.com/podcast/256-hagmann-report-30926499/Spreaker:https://www.spreaker.com/show/hagmann-reportFOLLOW HAGMANN AT:Twitter: https://twitter.com/HagmannReportGab: https://gab.com/DougHagmannGettr: https://gettr.com/user/doughagmannTruth Social: https://truthsocial.com/@DougHagmann

Host Gregg N. Sofer welcomes Husch Blackwell partner Christina Moore to the show to unpack recent remarks made by Deputy Attorney General Lisa Monaco concerning a new Department of Justice whistleblower program. Monaco described a “90-day sprint” to stand up the new program, which purports to enhance DOJ's corporate enforcement efforts by offering financial incentives to individuals who come forward with information about violations of federal law.Gregg and Christina discuss the peculiarities of the program as it is understood presently, including questions regarding the anonymity of whistleblowers, the complications of multiple competing whistleblower programs, and the complexities of handling information in parallel proceedings.Gregg and Christina also explore the practical matter of how the newly proposed program should be addressed by corporate compliance professionals and the importance of properly staffing and resourcing such programs so that employees utilize in-house channels to surface potential instances of wrongdoing. Gregg N. Sofer BiographyFull BiographyGregg counsels businesses and individuals in connection with a range of criminal, civil and regulatory matters, including government investigations, internal investigations, litigation, export control, sanctions, and regulatory compliance. Prior to entering private practice, Gregg served as the United States Attorney for the Western District of Texas—one of the largest and busiest United States Attorney's Offices in the country—where he supervised more than 300 employees handling a diverse caseload, including matters involving complex white-collar crime, government contract fraud, national security, cyber-crimes, public corruption, money laundering, export violations, trade secrets, tax, large-scale drug and human trafficking, immigration, child exploitation and violent crime.Christina Moore BiographyFull BiographyA St. Louis-based partner on Husch Blackwell's Healthcare and White Collar, Internal Investigations & Compliance teams, Christina represents clients in a wide variety of healthcare litigation and compliance matters, including insurance questions, reimbursement disputes, regulatory matters, and Department of Justice investigations. Previously, she served as an Assistant U.S. Attorney in Missouri for nearly a decade, often handling medical malpractice matters, healthcare fraud, and qui tam actions. She later accepted an in-house counsel role on the medical campus of a large private university, guiding the medical school, health sciences college, and nursing school, as well as a physician practice of more than 500 providers.Additional ResourcesChristina Moore and Madison Rector, “Let's Make a Deal with DOJ: The Impact of the DOJ's New Whistleblower Reward Program on Corporate Compliance,” Healthcare Law Insights, April 26, 2024U.S. Department of Justice, “Deputy Attorney General Lisa Monaco Delivers Keynote Remarks at the American Bar Association's 39th National Institute on White Collar Crime,” March 7, 2024Michaels, Dave,“Justice Department to Pay Whistleblowers Who Tip on Corporate Crime,” The Wall Street Journal, March 7, 2024Smagalla, David, “Justice Department to Flesh Out Whistleblower Program After 90-Day ‘Policy Sprint,'” The Wall Street Journal, March 8, 2024Freedman, Robert, “DOJ said to be opening can of worms with whistleblower awards,” Legal Dive, March 12, 2024

By Adam Turteltaub Matt Kelly (LinkedIn), Editor and CEO at Radical Compliance is a close watcher of all things compliance, and in this podcast he shares his take on both the top stories of 2023 and what he sees in the cards for 2024. FCPA On the Foreign Corrupt Practices Act front, he noted a change in enforcement. While the volume of resolutions declined on the DOJ side, the SEC has remained very active. Perhaps most notably, the Albermarle case had an interesting twist. The way the company did business was changed dramatically as a part of the settlement, he reports, with a restructuring of its overseas sales and the end of the use of third parties. He speculates this may be the start of a new trend in which monetary penalties are accompanied by required changes to the way companies do business. Also of note in FCPA was the announcement by Lisa Monaco at the SCCE Compliance & Ethics Institute of a leniency policy in mergers and acquisitions. Because of the relatively short timeline for finding and disclosing problems, there is a strong incentive for organizations to involve the compliance team early and deeply in these transactions. SEC Cybersecurity Rules The July SEC rules on disclosures of cyber incidents require firms to disclose an incident within four days. Companies will need to describe the nature, timing and material consequences. That will increase the importance of thorough and prompt cyber materiality assessments, as well as both quantitative and qualitative impacts. Greenhouse Gas Disclosures The SEC's proposed rule on greenhouse gas disclosures is now the longest and most commented rule in history. It also has not been finalized while, in the meantime, both California and Europe have passed their own laws. The rule is likely to be very complex and impose a significant burden on companies. Healthcare The biggest news he saw in 2023 was the new General Compliance Program Guidance issued by the Office of Inspector General at HHS. The document makes it clear that it expects a fully independent compliance program. As the document states: The compliance officer should: report either to the CEO with direct and independent access to the board or to the board directly; have sufficient stature within the entity to interact as an equal of other senior leaders of the entity; demonstrate unimpeachable integrity, good judgment, assertiveness, an approachable demeanor, and the ability to elicit the respect and trust of entity employees; and have sufficient funding, resources, and staff to operate a compliance program capable of identifying, preventing, mitigating, and remediating the entity's compliance risks. The Future Looking to the future he asks if others will be as supportive as the OIG at HHS. He also points to other things to watch such as the Foreign Extortion Prevention Act, the PCAOB's extremely controversial NOCLAR proposal and SEC v. Govil, which could eliminate disgorgement in many cases. Listen in to learn more about what has and may happen in the world of compliance.

Trump filed his opening brief to the D.C. Circuit Court of Appeals, arguing Jack Smith's prosecution should be completely dismissed based on Double Jeopardy and Presidential Immunity. Trump's defense warns the Court that allowing the shattering of 234 years of precedent will lead to reverberations across American political life for generations.Litigants in Maine are now using the Colorado decision to get Trump thrown off the ballot in their state as well. In a supplemental filing, the petitioners argue collateral estoppel/issue preclusion precedent prevents Trump from re-litigating the Colorado Supreme Court findings.Trump slammed Jack Smith over the Christmas break, wishing him and his deranged thug prosecutors a VERY warm holiday. Meanwhile, the FBI is investigating swatting against the Colorado judges and Lisa Monaco warns of an "unprecedented rise" in threats against the DOJ.

By Adam Turteltaub On October 4, 2023 at the SCCE Compliance & Ethics Institute in Chicago, US Deputy Attorney General Lia A. Monaco spoke live from Washington to the attendees and used this opportunity to announce a new Safe Harbor Policy for voluntary self-disclosures made in the context of the merger and acquisition process. Under the policy, acquiring companies that promptly disclose criminal misconduct voluntarily within the six-month safe harbor period, cooperate with investigators and engage in remediation, restitution and disgorgement will receive the presumption of a declination. She also explained that, absent aggravating factors at the acquired company, it will not impact the acquiring company's ability to receive a declination. She also shared how the Department of Justice has been fighting corporate crime including: The expansion of corporate enforcement efforts in the national security realm New tools DOJ is using to penalize corporate misconduct and provide invectives for good corporate citizenship Areas where they see further opportunity for innovation and expansion Listen in to learn more and hear her underscore the importance of compliance programs, proper corporate incentive plans, and the DOJ's expectation that the compliance team will have a seat at the deal table.

Washington Post intelligence and national security reporter Shane Harris and columnist and associate editor David Ignatius speak with Deputy Attorney General Lisa Monaco, former CISA director Chris Krebs and former State Department cyber coordinator Chris Painter about how America can protect its cybersecurity and prepare for the next generation of threats.

Gaslit Nation has been vindicated, and it sucks to be vindicated about the deadly inertia of a mafia state accomplice! After two years of describing obvious inaction on obvious crimes and being assured by an army of bot-brained propagandists that Merrick Garland is fighting the good fight but Must Keep Silent for Reasons You Will Understand in Time, we have new confirmation that, no, he's just a terrible Attorney General! And that Lisa Monaco, the deputy attorney general, is equally bad! In this episode we discuss the Washington Post expose “FBI resisted opening probe into Trump's role in Jan. 6 for more than a year”, dig into the background of Monaco (for more background on Garland, listen to our enormous archive of treasonous complicity), and talk about what Biden should do next. Happy Pride Month! For the second part of this episode, Andrea interviews Lindz Amer who is back on Gaslit Nation to discuss their new must-read book Rainbow Parenting Your Guide to Raising Queer Kids and Their Allies. From their author bio: “Lindz Amer created Queer Kid Stuff—an award-winning original LGBTQ+ educational webseries for all ages—that has reached millions of families. They perform at libraries, schools, and theaters all over the world spreading queer joy and working on numerous projects that bring queer and trans representation into mainstream children's media. In 2019, they gave a viral TED Talk on the importance of talking to kids about gender and sexuality. They currently write for preschool television and also host the parenting podcast Rainbow Parenting, as well as Activist, You! for kids featuring interviews with youth activists.” Check out Rainbow Parenting today!   Our bonus episode is our usual Q&A of questions from Patreon subscribers at the Democracy Defender lever or higher, and is available to listeners at the Truth-Teller lever or higher. If you asked a question and we haven't answered it yet, don't worry – we are getting through the backlog this month. Sarah took a couple weeks off due to a family emergency but is back so we will both have everything answered by the end of June. Next week June 27 12pm EST will be a live-taping of Gaslit Nation featuring Russian mafia expert Olga Lautman. To sign up for that, support the show at the Truth-teller level or higher to receive a link to join the virtual event on the morning of the show! Thank you for your support of Gaslit Nation!   Show Notes: FBI resisted opening probe into Trump's role in Jan. 6 for more than a year https://www.washingtonpost.com/investigations/2023/06/19/fbi-resisted-opening-probe-into-trumps-role-jan-6-more-than-year/ Susan Rice reportedly told the White House cyber team to 'knock it off' when they floated options to combat Russian meddling https://www.businessinsider.com/susan-rice-told-white-house-cyber-team-to-knock-it-off-on-combatting-russian-meddling-2018-3 Trump's Little Moscow: "63 Russians spent $98.4 million buying condos in Trump-branded luxury towers in Sunny Isles. Another 703 units in the seven Trump buildings had been purchased by limited liability companies, LLCs, that mask the owners' identities." https://www.sun-sentinel.com/2019/10/18/six-trump-towers-later-kitschy-sunny-isles-becomes-moscow-by-the-sea-fred-grimm/ Russia Sought to Kill Defector in Florida https://www.nytimes.com/2023/06/19/us/politics/russia-spy-assassination.html?campaign_id=190&emc=edit_ufn_20230619&instance_id=95515&nl=from-the-times®i_id=48614702&segment_id=136134&te=1&user_id=097a378032011d6e8be1570cdce0a176

In this episode, I address Donald Trump's social media post exposing the queen of the deep state.     News Picks: The sordid history of Lisa Monaco. RFK is being heavily censored by big tech. More dark money from the left supporting censorship. Gavin Newsom gets busted lying about the California exodus. Another delay in the FBI's January 6th “bomber” case. Libs don't want landlords to be able to conduct background checks. Copyright Bongino Inc All Rights Reserved Learn more about your ad choices. Visit podcastchoices.com/adchoices

EPISODE 231: COUNTDOWN WITH KEITH OLBERMANN A-Block (1:43) SPECIAL COMMENT: Obviously President Biden must fire Attorney General Garland and Deputy Attorney General Monaco and not merely because neither of them can possibly continue after yesterday's revelations in The Washington Post just as none of US can possibly continue holding our breaths wondering WHAT about the Trump and January 6th prosecutions they will screw up NEXT. Two years and nearly six months after the first attempted coup and Garland and Monaco still do not understand that this is about SELF-DEFENSE: of Justice, of Democracy, of America. If that ISN'T your attitude about the response to Trump and the coup attempt that was and the coup attempt that WILL be get out. But especially if you are in the Justice Department and you don't understand that the point WAS and WILL BE to eliminate YOU; if you don't understand that the ultimate goal of Trump and the creatures around him is to take the limitless finances they have been given, and the limitless TIME they have been given - BY YOU - and walk into the Department of Justice or whatever white shoe law firm you have escaped to, and hand you a piece of paper bearing a fascist order signed by a fascist judge convicting you of being an official Trump-brand enemy of the people and authorizing the Trump Police to HANG you - get out. Because, then, you will have rendered this nation – at its time of greatest peril - defenseless just as the coalition of Hate gears up for another attack. Because, then, you will have nowhere to hide from them because the rest of us, whom you have left without defense, will be fending for ourselves. And Merrick Garland and Lisa Monaco have to go, first. Because I don't know what's LEFT for them to screw up here but I'm sure Garland will find something in his style book for the Department of Justice that says that unless you deliver the subpoenas by Pony Express, you can't move against a criminally insane ex-president unless you make sure you wait just long enough that there's no way any of the verdicts can be rendered until after the election that might put him back in office, upon which he will have the charges withdrawn or will pardon himself or will simply ignore ALL the laws ALL at once and tell you to take you to take him to the Supreme Court.  B-Block (22:30) POSTSCRIPTS TO THE NEWS: If you're the president of MSNBC and you are asked 'If Trump were interested, would you put him on MSNBC in a live town hall format' and your answer is not "HELL NO" you must be fired. And if her answer was not "HELL NO" and you're one of the MSNBC hosts whose primetime show was spun off from mine all those years ago (Maddow, O'Donnell, Hayes) and you do not use your power to push back against the network's president and her journalistic perfidy, you have forfeited your credibility and reduced yourself to the status of Check-Cashing Talking Head. C-Block (48:00) SPECIAL COMMENT REDUX (Note: this is repeated from Monday's Episode 230) Special Counsel Jack Smith may be readying an indictment against Trump for illegally attempting to coerce Mike Pence to defy his legal duties in the Electoral College count? Ryan Goodman from “Just Security,” whom I cite here frequently though I don't know him and only because he knows this stuff, told Bill Kristol's podcast that he thinks Jack Smith quote “going to indict Trump for the False Slate of Electors scheme” – and with Goodman saying the odds Fonny Willis indicts on False Electors and election interference in Georgia are 90 percent, Trump could face twin federal and state cases on overlapping topics. And then Goodman adds something that took my breath away. Indicting Trump for False Electors, “AND quite probably/possibly the pressure campaign against Mike Pence.” Wait – what? Goodman sets the odds on Jack Smith indicting Trump ABOUT PENCE… at 60 to 70 percent. Pressuring the Vice President, Goodman says, quoting him again “is independent of whether or not he thought he won the election. He can think he won the election, doesn't matter. But you can't try to coerce a public official to defy their legal duties – which is just to count the votes.” Goodman doesn't mention that, but you will remember that Stewart Rhodes and other Oathkeepers were prosecuted for – and convicted of – interfering with Congress's ability to complete its legal duties. Ponder for a moment the prospect of Smith indicting Trump, running for the Republican nomination, for attempting to coerce PENCE, running for the Republican nomination. Oh and necessarily having Pence TESTIFY AGAINST TRUMP either before Trump is nominated or before the election.  I'm beginning to think we may have WILDLY under-estimated how many MORE things Jack Smith is about to indict Trump for. There is reason today to believe that the number of separate indictments OF Trump BY Smith could be as many as FOUR. Maybe even FIVESee omny.fm/listener for privacy information.

Hillary Clinton laundered campaign money through a disgraced law firm to pay disgraced foreign spies and fabricators of evidence to pretend Donald Trump was a Putin asset. That, we learned from the FBI, is not election interference.Mark Zuckerburg, Facebook CEO, refused to let most of his hundred-million users have access to the NY Post's story about the contents of Hunter Biden's laptop, which polls later indicated would have caused many Democrats to not vote for the FigureHead, Joe Biden. That same Zuckerburg spent half-a-BILLION dollars to place ballot drop boxes largely in Democrat areas, and to fund [read: buy] the offices where votes were counted. Those two steps literally changed the vote outcome. That, we learned from the FBI, is not election interference. Time Magazine detailed the coordinated, highly-detailed plan executed by Big Media, Big Tech, Big Leftist Groups known for street violence, Big Law Firms, Big Unions and Fortune 500 companies to hide TRUE information from voters, change election laws using either illegal or questionable methods and to stand prepared to call for--and get--street violence, all to prevent President Trump being re-elected. That, we learned from the FBI, is not election interference; Douglas Mackey has been found guilty of election interference for posting this meme. How many people were fooled into voting this way? The prosecutors found exactly: ZERO. Now that the government has determined it can imprison people so satirical social media posts, I assume this Pulitzer Prize nominated actress will be headed to prison for her “election interference.” Probably not, because: orange man bad. Meanwhile, Congress wants to give heads of federal agencies the power to charge all of us with election interference for using software not made in America. They are hiding this all in a TikTok ban, but this is far more than banning one app. This is the next, logical step in the Stalin-ification of America, as Michael Schellenberger explains, the feds very obviously fear an informed America, so much so that they are using East Germany inspired tactics on us. What does God say? My theory of why The Party is trying so hard to shut us up is this: great evil is being done through them and the source of that evil cannot stand The Light. 1 John 1: 5-7Light and Darkness, Sin and Forgiveness5 This is the message we have heard from him and declare to you: God is light; in him there is no darkness at all. 6 If we claim to have fellowship with him and yet walk in the darkness, we lie and do not live out the truth. 7 But if we walk in the light, as he is in the light, we have fellowship with one another, and the blood of Jesus, his Son, purifies us from all sin.Gulag America: Biden DOJ convicts Doug Mackey for anti-Hillary memes… faces up to 10 years in prison…Michael Shellenberger on the Moment the Twitter Files Investigation Revealed 'Something Seriously Sinister is Going On' - "It became clear to us over time that the U.S. Government had turned its propaganda and disinformation campaigns, that it had been waging abroad, against the American people"Hey

Deputy Attorney General Lisa Monaco discusses how the Department of Justice is countering new and evolving threats to the rule of law posed by hostile nation states, from transnational repression to foreign malign influence. This meeting is part of the Diamonstein-Spielvogel Project on the Future of Democracy.

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I dive into the hot topic of clawbacks, with a focus on Deputy Attorney General, Lisa Monaco's new pilot program and Kenneth Polite's take on the use of prosecutorial discretion for organizations. Our hosts explore the opportunities for corporate compliance and HR personnel for clawback solutions and the use of the Federation Corrupt Practices Act (FCPA). They also discuss the need for thorough documentation of personnel involved with and/or accused of illegal conduct, as well as the potential costs to shareholders. Bottom line: Tom Fox and Matt Kelly are here to take you on a deep dive into the complexities of clawbacks and help organizations get compliant and stay compliant. Key Highlights Prosecutorial Discretion and Credit [00:05:24] Implications of the Foreign Corrupt Practices Act on Corporate Compliance and HR [00:09:41] The Mathematics of Corporate Policy Development and Management [00:13:59] Corporate Compliance and the Foreign Corrupt Practices Act [00:17:47] Balancing Compliance and Risk in Business Practices [00:21:49]  Notable Quotes: 1.     "It is part of the department's larger effort to hold individuals more accountable and to have companies basically be participants in that project and to have companies embrace the culture of compliance, how would you hold individuals accountable if you're the company, you'd have that clawback clause over their head, and then you would now have more incentive to actually use it, which is not necessarily an easy thing." 2.     "What we expect companies that use programs to address not only employees who engaged and wrongdoing a connection with conduct under investigation, but also those who had supervisory authority over the employees or business area engaged in in the misconduct and knew of or were willfully blind to the misconduct."  3.     "You must have the clawback policies in place, at the time of resolution, then get a reserve credit for those clawback compensation moneys that you must successively claw it back within the term of the resolution."  4.     "If you do try to recoup the compensation and you fail, you'll still be eligible for up to 25 percent of whatever you were trying to recoup.""  Resources Matt in Radical Compliance Tom in FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you compliance related stories to start your day. Sit back, enjoy a cup of morning coffee and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership or general interest for the compliance professional. ·       Lisa Monaco announces changes to Corporate Enforcement Policy.  (WSJ)  ·       Text of Lisa Monaco speech.  (DOJ Press Release) ·       Matt Kelly weighs in. (Radical Compliance) ·       More on the clawbacks. (Law360) Learn more about your ad choices. Visit megaphone.fm/adchoices

2022 saw higher numbers of FCPA enforcement actions, settlements, and criminal prosecutions of individuals. One of the most important developments was the update of policy in the Monaco Doctrine, which was elaborated on in the Monaco Memo, providing important guidance for compliance professionals. Tom Fox joins Michael Volkov to discuss some of the more interesting cases from the past year.Tom Fox is hailed as the Voice of Compliance, serving and evangelizing for the compliance community for over 15 years. He is the founder and creator of the Compliance Podcast Network where he hosts various podcasts, such as Innovation In Compliance and the ESG Report, and the Executive Leader at the C-Suite Network. Some ideas you'll hear them explore are:The DOJ is getting better at communicating with the compliance community through resolution documents like DPA, NPA, and, occasionally, declinations. These documents provide insight into the DOJ's thinking and approach to cases, which compliance professionals can use to gain a better understanding of how to approach compliance issues.In Tom's upcoming book, “FCPA Year in Review 2022,” he highlights the KT Corp bribery case, which went back to the basics in its old-school rendition of corruption: bags of cash money. The lesson here is that bribery can be as simple as a $50 slipped into a handshake.In the curious case of Glencore, the FCPA enforcement action taken against them reflects the DOJ's focus on defective cultures within companies. This case involved multiple enforcement agencies across multiple countries and multiple bribery schemes, rounding up fines and penalties totalling up to $1.1 billion, with $700M for FCPA violations, and $441M for price and market manipulation. Glencore had a culture that was committed to profit at any cost, and the company paid over $100M to third parties knowing that some of the money would be used to bribe officials in various countries.The Oracle case involving bribery and corruption involving gifts, travel, and entertainment should serve as a reminder to companies to review their gift, travel, and entertainment policies and ensure they are aware of how their business officials are spending their travel, per diem, and entertainment money.Avoid hiring third-parties recommended by or at the direction of a state-owned official or executive.The Lisa Monaco memorandum emphasizes the need for effective compliance programs and the benefits of voluntary disclosure, full cooperation, and timely and appropriate remediation. KEY QUOTE“Internal controls are not simply due diligence, distributors, et cetera. It goes down to your payments, schemes and how you pay your vendors should all be a part of your internal controls.” - Tom FoxResourcesTom Fox on the Web | LinkedIn | Twitter | Blog

By Adam Turteltaub Last year was an eventful one for the world and the compliance profession. In this podcast, Matt Kelly, Editor and CEO of Radical Compliance, looks back at what he sees as the biggest events, and looks into the future. The conversation begins with the impact of the war in Ukraine. He observes that the increasing number of sanctions of Russian individuals and entities, as well as the variations from country to country, have forced companies to improve their sanctions compliance efforts. The sanctions have also complicated procurement, forcing organizations to review their suppliers more carefully to avoid sanctions issues. With the war has also come of host of ethical considerations. Organizations have had to decide what to do with their Russian operations and the people that work at them. Also on the international front, 2023 brought increased cooperation among prosecutors, with a rising number of anti-corruption enforcement actions combining the resources of prosecutors in multiple countries. ABB, Glencore and Danske Bank are three notable examples. This activity comes at the same time as Europe continues to lead the world in privacy and data protection requirements. Looking domestically, he points to statements by Lisa Monaco at the Department of Justice and the push to require certification of the effectiveness of the compliance program by the CEO and chief compliance officer. This could be a dramatic shift for compliance programs.  On the one hand, it could create stronger ties between the CEO and compliance, Matt observes. On the other hand, compliance officers would see greater personal risk, especially given the real likelihood that, despite a strong program, wrongdoing may occur. Whether certification truly becomes established practice, though, has yet to be seen. Thus far it has only been imposed in the context of recently signed DPAs. As a result, certification will come in three years, if at all. He notes that a change in Administration could see a reversal of the policy. What does he see in 2023? For one, a need for compliance teams to improve their ability to access and analyze data. The US Department of Justice has made it clear that it expects organizations to have robust compliance data analytics processes. Second, he sees increased data protection enforcement actions, both abroad and in the US. Listen in to learn more about what happened and what to expect for your compliance program in the year to come.

Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley. Today is the second part of a 2-part series that we have been planning for a while, and the timing turned out to be perfect.  Lisa is speaking with an all-star panel of Audrey Harris, Bethany Hengsbach and Dionne Lomax,  Managing Directors from Affiliated Monitors.  Audrey's area is  Global Anticorruption, Compliance, Ethics & Non–Financial Risk, Bethany focuses on Global Corporate Compliance, with a focus on healthcare, and Dionne works in Antitrust and Trade Regulation, as well as being a professor at Boston University. The timing for this series turned out perfectly, as the group was able to get into an in-depth discussion about Lisa Monaco's statements in September about the Monaco Doctrine and some of their key takeaways.  In Part 2, the group discusses the statements about compensation and clawbacks, and the importance of appropriate resources, among other topics. They also provide their individual perspectives on two other topics that many of us discuss.  One is the reporting line for CECOs, and the importance of a direct line to the Board or Audit Committees.  The other is the certification of Corporate Compliance programs by CEOs and CECOs. The entire discussion was extremely insightful, filled with practical ideas and good tips for everyone who is trying to build and/or maintain a program.  Listen to Part 1 here. The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings to listen in to.  If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it.  If you have a moment to leave a review at the same time, Mary and Lisa would be so grateful.  You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast.  Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We've Learned from Great Women in Compliance” (CCI Press, 2020).  If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don't forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you're done, or if you can't bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat. You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast. Join the Great Women in Compliance community on LinkedIn here. 

In September, the Department of Justice Fraud Section announced a new policy direction on corporate misconduct, clearly stating that personal accountability for employees, executives, and directors was their number one priority. The revised DOJ policy clearly states that an organization's compensation and benefits program must be aligned to its values and ethical culture. So, what does this mean for compliance? In this episode of the Principled Podcast, host Susan Divers discusses how to implement a meaningful performance management system that meets DOJ objectives with Stephanie Ragan, a Certified Compliance and Ethics Professional (recently of SOFEC) and now solo practitioner after 14 years as a compliance specialist and manager in the oil and gas industry.    Featured guest: Stephanie Ragan As an experienced, well-rounded compliance and ethics specialist, Stephanie has recently struck out on her own by launching Ragan Export Compliance, a consulting company focused on providing services and guidance for regulatory compliance. A subject matter expert in trade compliance for the past 10 years, she holds both a Masters of Science in Regulatory Trade Compliance and a degree in International Trade Management. Her credentials include special certifications as a Certified United States Export Compliance Officer (CUSECO), a Certified Compliance & Ethics Professional (CCEP) and an FCPA Expert (FCPA Blog).With a passion for developing efficient, integrated and automated compliance systems and programs, Stephanie's philosophy is that the intentional integration of compliance and ethics elements within an organization is at the core of every successful business model; and through making compliance accessible and approachable to all stakeholders, the value of a company's culture is significantly increased.   Featured host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years' accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM's Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM's ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers' thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company's ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.  Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics.    Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers: Last September, the Department of Justice Fraud Section announced a new policy direction on corporate misconduct. And they clearly stated that personal accountability for employees, executives, and directors was the department's number one priority. And as part of that, the revised policy that DAG, Lisa Monaco put out that day makes clear that an organization's compensation and benefits program must be aligned to its values and ethical culture. That means that positive behavior, for example, turning down a tainted business opportunity should be an essential factor in evaluating performance. And that there should be financial penalties, real financial penalties for misconduct. So what does that mean for compliance professionals? Hello, and welcome to another episode of LRN's DAG, Lisa Monaco. I'm your host, Susan Divers, director of thought leadership and best practices at LRN. Today I'm joined by Stephanie Ragan, a certified compliance and ethics professional, and most recently of Sofec, an oil and gas provider that's global in its operations. Stephanie has just left Sofec and is now consulting on her own after 14 years of a compliance specialist and a manager in the oil and gas industry. We're going to be talking about implementing a meaningful performance management system that meets DOJ objectives and how you go about that. Stephanie, thanks for joining me on Principled Podcast. Stephanie Ragan: Thanks for having me, Susan. Susan Divers: It's my pleasure. Interestingly, one of the questions we ask in LRN's annual program effectiveness survey is about organizations using ethical behavior as a significant factor in compensation, bonuses, hiring and promotion. And last year 69% of the over, I think it was about 1200 ENC programs that we surveyed, indicated that they required that an employee's ethical behavior be evaluated as part of their annual performance review. And we found that top rated programs were much more likely with 88% including such criteria. But Stephanie, as you know, with all things compliance, the devil is in the details. So I'd really like to hear about how you implemented your program that does just that at Sofec. And I'm sure our listeners would love to profit from your experience and your wisdom on this subject. So let's start at the beginning, how did you start this initiative or how did it start and how did you get support for it? Stephanie Ragan: Well, sure. So coming from a company like Sofec, we just celebrated our 50th year and we have a lot of mature programs and some that are still coming along. And our compliance program was one of our newer initiatives. We started it in about 2011. And it was interesting to see that when we formalized that department and all of our programs, policies, everything that helped sustain it, there was a need to measure it against other overhead type departments like HR, HSE and quality. So looking toward those types of departments for direction to see how we could measure effectiveness of programs and tie that back to our professional performance goal setting efforts that we do on an annual basis was a challenge for us. And we decided that as the new kid on the block, we could look at what worked for everybody and what didn't. And we decided that it would be necessary to look at what weight we needed to hold within the organization for each of our compliance initiatives. So for a starting point for our listeners, I would suggest that you look at the way your organizations measure performance. And if there is already an existing HSSEQ component or HR component, that you should also be including a compliance and ethics representation. And that should be a key area of focus for your personnel to align with your company culture and your company code and business operations. Susan Divers: That makes a great deal of sense. And I want to pick up on one thing you said in particular, which is that the ENC program needs to have equal status and weight with other similar programs, whether it's HR or audit or security or health and safety. And that's actually in the 2020 guidance from the Department of Justice as well. Because one of the questions prosecutors will ask or are told to ask companies accused of misconduct is, "Does your ENC program have equal status and resources?" So the approach you took fits very nicely with that. Let's talk about how you actually went about it. How did you enlist support? How long did it take? And what did you do in the end to get it up and running? Stephanie Ragan: Well, you know it takes a village to have any kind of success. And our compliance and ethics global team really took on this call to bring compliance and ethics to the forefront, it having an equal say in the performance measurements that we do in the company. And we were able to within the last few years, convince our management that along with performance measurement, which was a key area of concern, we needed to have regular meetings, at least an annual meeting, to be able to confer as a team globally and to discuss ideas, work on program development and get training initiatives ironed out. Kind of plan out our year as a whole so that globally we could have a cohesive plan that aligned everyone, didn't leave anyone behind from a planning standpoint for all of our entities, and made sure all personnel were covered by local compliance and ethics designees that could administrate and cover those programs as we rolled them out. So this was very well taken on. And again, we leaned back into HR and HSE were having these types of annual meetings and conferences internally in the company. So we wanted to say, again, we need to make sure compliance and ethics is represented. It was well received and management was very supportive. So in 2019, we had our first global gathering. And at that point, we all discussed how we measured and where we had gaps in measuring those compliance and ethics performance areas. And we figured that the global initiative of tying it into your bonus, your compensation that's measured annually by HR, that we needed to partner with them as well. So we were able to utilize the great guidelines that were out by the Department of Justice that came out in 2018, 2020. And then similarly, we had more guidelines come out again this September. These types of guidelines were helpful in getting the highest levels of buy-in. So using that as leverage, we were able to place value on measuring those individual participation to show evidence of a effective compliance program. And we were able to also work with legal. And I think that that's something that anyone who's struggling with finding a way to tie their individual performance metrics for users to compliance and ethics, that having your legal team work with you, if that's not already part of your compliance and ethics team and working with HR to jointly explain to senior management why the Department of Justice guidelines are so helpful and necessary to pay attention to. No one wants to have those types of individual penalties pointed back toward them. And letting them know what the enforcement and penalty details could entail, it can be a little scary and overwhelming for them, but it lets them know the weight of importance. So moving on, our CNE team wanted to then, after we had our senior buy-in, determine specific ways to quantify a compliance and ethics participation that was acceptable. So we developed a way to be able to measure and do a cumulative total for each employee throughout the year. And with the help and guidance of our compliance council, our general compliance council, which oversees all of our compliance and ethics initiatives from a senior level, and our chief compliance officer who's over our entire group, performance matrix was developed. So we determined what KPIs and metrics were most valuable to our company and also how participating in training and completing mandatory training assigned on time or early would be a key indicator that our personnel were engaged in in meeting their CNE goals. Now that was our initial concern that the training and focusing on training, on time training completion wouldn't be enough, but that's a great baseline. So if you are not measuring that, start there. And we also decided though that's a minimum expectation, that other avenues of participation engagement could then be easily added. This was a chance also for our CNE team to promote all of the tools and the outreach that we had been developing to engage individuals in our annual Compliance Week program, our local newsletters, which we could insert quizzes and different activities for them to complete, optional live and virtual training sessions, surveys, quizzes, and use of compliance videos and slides in their operational meetings and team meetings. And then it gave us an opportunity also for people that really went above and beyond to be recognized and have that tied back into their performance goals as a metric to, so our compliance champions who always went above and beyond, or personnel who brought forward potential compliance and ethics issues that were helping make formative changes to our program could also be recognized. That sounds like a lot to keep track of and could be really overwhelming for our listeners that have a new compliance program, limited resources, budget constraints, but there are a lot of great tools and support out there like LRN that is a great content provider and provides support with measuring that on time participation and a lot of other value that you can add into your program. Let's face it, at a minimum, any functioning compliance program is at least checking the box with mandatory compliance and ethics training like anti-corruption or your company code training, general CNE program awareness. So if you start with training as your first building block to measurement, it'll be less of a shock and easily accepted because your population and your personnel are already participating in those training initiatives. Susan Divers: That's a great story. And the way that you worked with other people in the company to identify where you were going to start with the criteria I think is very powerful for people who are grappling with this subject. And I know it's not just companies that are new or small, it's an area that I think a lot of people are still trying to chart their way. And also using the Department of Justice guidance strategically to help management understand why this is a risk that really needs to be managed. I think there is emphasis when you look at the guidance, it's important to realize that it's out there in part to help people like you and your team actually implement it by putting it under an official seal, if you will. So well done. Hey, tell us now, how is it working and are there any tweaks that you would make at this stage? Stephanie Ragan: Well, the great news is we've certainly seen improvement. So we've seen results of greater participation across the board in all of our areas. So whether it's people participating in Compliance Week because they know it ties back to their performance or they attend training that they would've otherwise blown off or not considered taking because it wasn't mandatory. And that is really energizing us to continue to grow the program and continue to find ways to reach people. And we've seen a lot of participation because of this initiative of tying it to performance goals in areas and regions where maybe culturally it wasn't important before to participate in compliance and ethics initiatives. But now they understand because they have something that's tangible material that ties back to their actual individual performance and they want to succeed in that area. So in general, it's helped us create different types of communications. We've been able to go and create management reports to provide managers live specific data on how each of their team members are performing throughout the year. Some managers reach out for that quarterly or semi-annually, but everyone reaches out for it toward the end of the year when they're wrapping up their performance evaluations. And it's great to have that kind of tool. So I do recommend that you work on creating something as simple as an Excel spreadsheet that can start capturing data to keep good records regarding the performance of your personnel. And also, if ever you are audited by a government authority, it's a great tool to provide your training records and say, "We're not just checking the box, we are going above and beyond by tracking every engagement with compliance and ethics." So also following that, we're able to use those participation records to quantify a score for each person. Now, it doesn't necessarily have to be a numeric score. Some companies may want to do it that way. We aligned with what our HR teams were already using, which is kind of a scale one to five, either unsatisfactory and then failed to meet expectations. You either met expectations, exceeded expectations, or you did outstanding work. So because that was already in use in our system, it was a language everybody understood and we created what fell into each category for our measurements on the compliance and ethics side. And again, we don't have to reinvent the wheel, you can use what you have and work smarter, not harder. But tracking the progress is really important. So if you can assign something that you can put a value against, then you can develop statistics over time and track trends within the organization. We did have a lot of discussion across the board about how much weight should be given to compliance and ethics performance compared to HSE or HR. So again, we fought to have equal footing because we preach in our company code of, we have a culture of compliance, we have our compliance code that gives guidelines on how to operate in every aspect and provides best business practices for everyone. So there was no reason to sell ourselves short or give ourselves a discount and say, "We don't want to be considered equally." Even though some companies may need to tweak that based on what their own business practices are, it should have some alignment with your culture and your code. And that way people understand it and can buy into it on an individual basis and an organizational basis. So looking forward in 2023, and this is largely in response to the new DOJ guidelines that you mentioned earlier, which came out September 15th, that does focus a lot on enforcement. So again, we have that leverage to push and say, "This is important. You don't want to be in trouble because this is how it can affect you as an individual." And that does garner a lot of attention and response from senior management, which is great. We don't want to scare anyone, but we want to make sure they understand the weight of their actions or inactions. But our tweaks moving forward would include tiered measurements, and that aligns with the Department of Justice newest guidelines so that you have different measurements and expectations for managers and supervisors and executives. And I think you should really look at that as three different categories, general personnel, people who have an influence over them, managers and supervisors, and then the people at the top. So your executives are going to be viewed differently if enforcement actions are ever taken. So you might as well prepare and have your program mirror that type of focus internally. We also have a lot of questions that come up then from managers that say, "What are my roles? What do I need to do to earn my points or to get a good rating?" And we always encourage them to infuse and integrate compliance and ethics into their team talks, their safety minutes that they have at a beginning of a meeting, replace some of those with compliance moments. And we make those tools available easily so that they can download it from our [inaudible 00:19:23] and they have full access to short videos, to content that we can pull from different training providers or that we've developed internally. That just makes it easier if they have one stop shopping, they can go to your compliance site. And if you don't have that type of setup, don't worry. Companies can always make it available by emailing that out to managers and just having kind of the library available to them. And as you develop and tweak your offerings, let people know. It's good to self-advertise within the organization so that send an email out to all of your managers and say, "Hey, we have a new video available if you want to share it with your teams." And let those managers come back to you and let you know how they used them and what the feedback is, because that's just going to help build the program and continue your process improvement. As the DOJ recommendations indicate, effective compliance program always points to individual emphasis for that compliance and ethics participation and compensation. And I think we can agree that those personnel who embrace and make an effort to incorporate compliance and ethics into their work are more likely to report potential issues, be less likely to become bad actors by breaking rules intentionally or unintentionally. And generally, they're going to support the best practices and the compliance and ethics program in the organization. Susan Divers: Well, we would certainly agree with that. And our research at LRN shows overwhelmingly over the years that I've been here, which are now six, that a culture of compliance that involves employees at as many levels as possible and helps them by giving them materials, you mentioned making it easy for managers to talk about ENC, that that is the best defense to misconduct and it's not how many times you reinvent in your code of conduct. But I do want to mention one other thing that you talked about early on, which is data points and having something that shows exactly where a particular individual is in their ENC journey, whether it's training or touchpoints. We've actually just redone major parts of our platform and we're very excited about it because there's a part that we're rolling out this month called Reveal, which is advanced data metrics from the training experience. And it shows what courses, what subjects people struggle with the most, how much time employees spend on a given subject and a lot of other very relevant data. It's very powerful and it allows you to benchmark against yourself and against other companies in your area. That's something everybody is very focused on. And using that in conjunction with your performance review system can really drive change. And then I'd also mention managing that data is important. We also are including a tool that we've had for some time called Disclosures where we're asking people to tell us when they attest to the code of conduct or when they roll out. You can use it to track how many times they roll out an ethical moment or other times when they talk about ethics and compliance. So the idea is to make it as easy as possible for the compliance team to track that. But we're starting to run out of time, so I want to talk quickly about what are the pitfalls. Because obviously this is a terrific program that has gained traction and is broadening and improving as you go along. But what are the pitfalls to avoid? And then I want to talk about your new company and your new initiative too. Stephanie Ragan: Well, first of all, the biggest pitfall that you can have is to not do anything or to be stymied and overwhelmed. So don't overthink or over design any initial measuring system. Remember that look to the offerings and tools that are made available to your personnel already. So start with finding the easiest way to measure what you're already doing. And you can always scale up as part of your continuous process improvement efforts. And then again, as you saw for development of our program, we could not have done this if we had worked in a silo. You have to engage and partner with HR and other stakeholders in the organization to find a way to infuse that measurement of your ethics and compliance participation. And be sure to include that there is a way to acknowledge excellent contributors. Because that drives people and excites them to participate more. So it can be an incentive for good behavior and make it specific to a task or event that's not evergreen. You can change this around and continue to improve it as years go on and set goals for your compliance and ethics team to be able to continue to develop every year something different to bring more users on board. Susan Divers: That makes a great deal of sense. And again, congratulations. That's a major accomplishment. And it sounds like the program was very well designed for your business and your particular culture and your risks. So let's turn to the future now with your own business, Ragan Export Compliance. What kinds of clients will you be aiding in the development of their ENC programs? I know you have deep experience in the oil and gas industry and are a certified FCPA expert and have the export control function as well. What are you going be focusing on and what risks do you see developing for exporters in particular as they seek to adhere to the DOJ guidance? Stephanie Ragan: Well, thank you for asking about that, Susan. At Ragan Export Compliance, I'll be providing trade compliance support and guidance focused on export or import compliance plans. And large focus now is technology. So we'll be helping develop technology control plans. And also because I do have a background coming from the last five years of doing the certified compliance and ethics professional from SCCE, I also can help develop the corporate compliance program enhancements for any industry, which can include developing training programs, conducting training, auditing, risk manages, strategies, due diligence and screening ,vendor management systems. And if a system needs overhaul, that's something that people sometimes forget. They develop a compliance program and then put it on the shelf, but it really does need continuous review, especially in the light of recent and constant regulatory changes and updates. To get back to your question about what risks do I see developing from an export angle, I do see two areas where exporters can pay additional attention, especially considering the current international policies and issues that are going on in the world. The enhanced due diligence is needed now as part of your program to identify military end users or MEUs. And this is primarily in China, Russia, Venezuela, and Burma. But it's a good habit to get into looking at that and incorporating, identifying military end users and uses as part of your, know your customer and screening system for your full supply chain. And then the second area where there can be some additional attention paid would be that your program includes a really strong level of control for not just your physical shipments, but technology. That's a blindside for a lot of exporters, importers, and just USPPIs in general because they don't realize how wide the definition for technology is when you look at the regulations. So for example, the EAR definition of technology for Department of Commerce for controlled technology is any specific information that relates to development, use or production of controlled items, those technologies would also be controlled. So pretty much any information that relates to those items, because the development use or production is so broad. And the ownness of that comes back to the exporter. Whenever regulations are vague, it puts more pressure on the exporter to understand and have systems in place to be able to address potential violations. And then because of regulatory changes, a lot of stagnant compliance programs can be a real risk for companies because they may not realize it's something that they have always been able to export. For example, certain valves or stainless steel items, things that were pretty innocuous for a large part, didn't need licenses up until recently when regulations changed. And now they fall into this large basket categories like 2B999 ECCN numbers, which I know might sound scary and very technical to people listening that don't have a real firm grasp on the ECCN, but there's a lot of guidance out there, and that's what we hope to provide and be able to help navigate at Ragan Export Compliance. So finally, just in general, I would say that my advice to our listeners today is just to continually evaluate your compliance program and make sure that your CNE engagement measurement that we've discussed today become truly effective ways to ensure that your organization is on the path to executing best practices and avoiding any regulatory infractions. If you follow the guidelines and reach out for help when needed, you won't go wrong. Susan Divers: Well, thanks Stephanie. I certainly agree with everything you've said and want to emphasize your point about don't fall into the trap of stagnant compliance. A lot of times I think it's easy to rely on backward looking metrics and saying, "Well, last year we trained 340 people, and this year we hope to do more." It's important to really keep evaluating what are the new risks that we're facing, and are the procedures that we have in place adequate for those new risks? And certainly that's consistent with the guidance too. So unfortunately, we've run out of time, but I want to thank you very much for spending these minutes with us and giving us the benefit of your insights. I hope you'll come back and speak to us again soon. Maybe we can do a session on export control. And we wish you all the best in your new venture. Stephanie Ragan: Thank you, Susan. Susan Divers: My name is Susan Divers and I want to thank you all for tuning in to the Principled Podcast by LRN. Outro: We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations by helping them foster winning, ethical cultures, rooted and sustainable values. Please visit us at lrn.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple podcasts, Stitcher, Google Podcasts, or wherever you listen. And don't forget to leave us a review.  

What you'll learn in this podcast episode Over the last few years, federal regulators have provided detailed guidance on what they expect to see in E&C programs when it comes to misconduct inquiries or investigations. What do these recent reports, policies, and guidance mean for compliance professionals? In this episode of the Principled Podcast, LRN Director of Thought Leadership and Best Practices Susan Divers is joined by Jon Drimmer, a partner at the law firm Paul Hastings. Listen in as the two discuss the recent guidance from the US Department of Justice as well as DOJ policy impacting corporate compliance programs and ethical culture.      Featured guest: Jon Drimmer Jonathan C. Drimmer is a partner in the Investigations and White Collar Defense practice and is based in the Washington, D.C. office of Paul Hastings. He resolves complex cross-border problems with the benefit of having sat in every chair at the table: senior legal officer for a global 500 company, federal prosecutor, and seasoned advocate. He is a recognized international expert on anti­corruption and business and human rights, and is a frequent speaker, author, and commentator on issues related to both topics. Before joining Paul Hastings, he was Deputy General Counsel and Chief Compliance Officer of Barrick Gold, one of the world's largest mining companies, with operations on five continents. The compliance program he built at Barrick has served as an industry standard, and elements of it have largely been duplicated by numerous other companies inside and outside of the extractive sector. Mr. Drimmer has directed hundreds of investigations around the world related to anti-corruption, human rights, AML and export controls, tax controversies, environmental incidents, public disclosures, fatalities and health and safety injuries, sexual harassment and discrimination, and other areas. He has represented companies and individuals in numerous government enforcement proceedings in the U.S. and overseas, in relation to FCPA and bribery claims, human rights issues, and a wide array of other matters. He has participated in dozens of major disputes in the U.S., Canada, and abroad, including transnational torts, anti-corruption claims, environmental cases, international arbitrations, tax disputes, construction claims, and land controversies. He previously served in the Justice Department as Deputy Director of the Criminal Division's Office of Special Investigations, where he led cross-border investigations, first-chaired numerous prosecutions, and argued federal appeals. He was a partner at an Am Law 100 law firm in Washington, D.C., a former Bristow Fellow in the Office of the U.S. Solicitor General, and a judicial clerk on the U.S. Court of Appeals for the Ninth Circuit. Mr. Drimmer served on the board of directors of the Voluntary Principles on Security and Human Rights Initiative from 2012-2014, and again from 2015-2017. He served on the board of TRACE International from 2012 until 2018, and currently sits on the board of the TRACE Foundation. He has also taught international law courses at Georgetown University Law Center for nearly 20 years.   Featured Host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years' accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM's Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM's ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers' thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company's ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.  Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics.    Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers:  Good afternoon. From time to time, but particularly in the last few years, federal regulators have provided detailed guidance on what they expect to see in ethics and compliance programs when companies present them as a defense to misconduct inquiries or investigations. What do the recent flurry of reports, policies and guidance mean for compliance professionals? How should they be applied to improve E and C programs? Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Susan Divers, director of thought leadership and best practices at LRN. And today, I'm joined by Jon Drimmer, a partner at the international law firm of Paul Hastings. We're going to talk about the recent DOJ guidance and policy impacting corporate compliance programs and ethical culture, and hopefully help everyone understand what it is and how they should apply it to their programs. Jon is a real expert, as well as a friend in this space. He has the unusual distinction of serving in three of the principal seats that affect ethics and compliance, once as a federal prosecutor at DOJ, another time as a chief ethics and compliance officer and deputy general council for a large mining company, and now as an ethics and compliance advocate with a leading law firm. Jon, thanks so much for joining me at Principled Podcast. Jon Drimmer: Thanks, Susan. It's great to be with you. Susan Divers: Super. Well, let's jump right in. Last week, we saw a new policy come out of the Department of Justice that both Lisa Monaco and also Ken Polite have talked about with great emphasis. We've also seen the report come out of the sentencing commission about their 30 years of accomplishments. And we've also seen some major guidance in the last two years. Can you put it in perspective for us and talk about how it fits together, and how they interplay. And then we can jump in and start figuring out what they mean. Jon Drimmer: Yeah. No, happy to do it. So let me take each one in sequence. So what we saw come down from the deputy attorney general was a new policy memo. And in essence, what that means is policies are, they are the rules that apply to federal prosecutors and prosecuting entities around the country. They are the standards that are going to be applied. Guidance, which is something that we see come out in a number of different ways through formal guidance as well as through statements and speeches and other informal approaches, this is basically how those rules are interpreted, how prosecutors should be thinking about the application of those policies as they're applied to any given circumstance. And then finally, reports, and you mentioned the sentencing commission's 30 year look back, those are more general. And they do tend to come out for transparency purpose, they're often retrospective, like the sentencing commission report. But they generally talk about how these rules have been applied. So policies are the rules, the guidance effectively aids in their interpretation, and the reports generally are a bit of a look back as to how they have been applied to date. Susan Divers: That's really helpful. It really helps me put all of those in perspective. Talk a little bit more than about the policies and the guidance. Are they mandatory? Are they voluntary? Jon Drimmer: Well, for prosecutors, they're mandatory. So when you look at the policies, this is effectively how prosecutors are to approach any given situation. It is a directive to them in terms of how it is they should go about doing their jobs. And I'll tell you it's critical. It's critical for chief compliance officers to understand those types of initiatives, those types of emphases. It's critical to prosecutors as well, as they get that direction in terms of what they should be focusing on. So really, it's a very important part of the process and helping to shape how investigations are run and scoped from the government's end, and what can be expected on the company side as well for chief compliance officers. Susan Divers: But it's not technically a rule, if I'm correct. But it sounds like you strongly recommend that ethics and compliance professionals pay great attention to it. Jon Drimmer: Yeah, yeah. No, that's fair. It's not a regulation. It isn't something that goes through a formal regulatory process. It's not the equivalent of a law. It's a direction. It's a directive that's basically given. And so it doesn't have the force of law, but it is a very important set of instruments to understand the relevant DOJ policies, the justice manual. So yeah, that's a fair assessment. I do strongly recommend understanding it in detail, but it isn't technically a law or regulation. Susan Divers: And if I understand correctly, and I've been in this situation myself too as a chief ethics compliance officer, if there's a misconduct inquiry or investigation, and 95% of those are resolved without prosecution or probably more, basically, you'll be asked to come in and meet with the Department of Justice prosecutors, possibly the SEC too, and part of that is talking about your ethics and compliance program. Can you put that in context and explain why they want you to do that, and how you should do it? Jon Drimmer: Yeah, absolutely. So what they're really looking for is a discussion of A, what the compliance program was at the time of the incident in question, and where it is today at the time of charging. It's really both time periods are really quite important to them. And they want to understand how with a compliance program the issue or event might have occurred. But they also want to understand what changes have been made to improve its effectiveness since that time period. And often, given the way that investigations go and timelines, there may be a good bit of time between the original incident and the time a formal compliance program presentation is ultimately made. And in making that presentation, the guidance, the policies, these are incredibly important in shaping the factors that you're ultimately going to present on. But the real tip is not just presenting on the formal approach, the formal program, the policies, procedures. But how do you know they are working in practice? And that has been a huge emphasis from the government in the last couple of years, and one that ethics and compliance professionals should take heed of. It's not just a matter of rolling out the program, but with the rollout, including those steps to validate its effectiveness in mitigating the relevant risks it's designed to address. Susan Divers: I want to get into that in more depth in just a second. But before we leave sort of setting the scene for why this is so important. So if you go in and you meet with the Department of Justice and its prosecutors, and you do a good job, a credible job, of presenting your ethics and compliance program, and it's clear that it's a strong program, and you've got hopefully evidence of effectiveness, what's the consequence of that? Jon Drimmer: Well, at the end of the day, I mean, the most significant issue is monitors. And if you've been involved in an issue that violates a federal law, federal criminal law, and the question is: Are you sufficiently capable of addressing your compliance issues going forward without day to day regular oversight from a monitor? That is a critical inquiry, and so number one, an effective compliance program and design and implementation is really important for a monitor. It's also important in charging decisions. It can be important in terms of disgorgement and fines and penalties as well. It's taken into account in the federal sentencing guidelines. So in the end, an effective compliance program really is a critically important part of a resolution process for a DOJ investigation. Susan Divers: So that's basically why ethics and compliance programs, if I understand correctly, came into being. It's really to mitigate the impact of misconduct investigations, and hopefully allow the company to go forward with it's E and C program. We won't talk about monitors today. That can be another podcast. But that's something that you want to avoid, generally. Jon Drimmer: Yeah. You generally want to avoid that, yeah. I mean, look, there's another element we probably won't get into today as well, that you and I have talked about extensively, and that is how programs ultimately help shape the values and culture of a company, so aside entirely from proactively mitigating relevant risks, affirmatively driving a culture that does increase productivity, increase retention, increase morale, that's a critical component of a compliance, an ethics and compliance program as well. It does dovetail a bit with culture of compliance, which is something that is important to demonstrate when you're in front of the government. It's something the government is increasingly emphasizing. There's a positive aspect that isn't just preventing potential problems from happening that are associated with ethics and compliance programs, as you've written about quite persuasively. Susan Divers: Well, you too. And I'm glad you reminded everybody of that because that is a critical reason for having an effective ethics and compliance programs. So let's leave the sort of rewards and penalties side and start talking about: What are the prosecutors and the Department of Justice leadership really saying in this plethora of policies, guidance that's come out in the last couple of years? What are the key messages? Jon Drimmer: Yeah. I would say in reading through the recent speeches, the policies, coupled with the guidance, I think we can take away several messages. And two of them are, number one, there is this enormous focus on program effectiveness, and I can't say that enough. And as I read the memo from the deputy attorney general colloquially calling the Monaco memo, I see as a major sub theme, and as a former chief compliance officer, this absolute drive towards the effectiveness of programs. And just to take a step back for a minute, in some ways, this is how the sentencing commission's report actually becomes relevant in this discussion, and the 30 year look back report was issued roughly at the same time as the DAG memo. And if you look at the report, a few interesting statistics jump out. And these again, this is focusing on companies that actually went through a court sentencing, so it isn't settlements, which is typically how corporate resolutions are resolved. But 2021 was the first year that more than half of the companies sentenced under the guidelines had a compliance and ethics program. And the previous high was 2018, when it was about 28%. But in 30 years, since 1992, only 11 companies have had a reduction by a court because their compliance program was effective. That's .5% of all of the companies sentenced, and most of those are actually small companies. So most of the time, for those companies that are going through the process, they aren't getting credit for having an effective program. And with the Monaco Memo, if you actually look at a lot of what policies are ultimately looking to drive, it does center around effectiveness, driving performance, driving commitment through a focus on individuals. And so it talks about producing information in a timely way, focusing on individuals because that is what incentivizes effective performance. For chief compliance officers, it might mean if you're going to do an investigation, a thorough investigation, you do have to include that within your scope, the focus on individual culpability to a degree that you might not have before. The same is true with ephemeral messaging, which is a big emphasis in the recent memo. Ephemeral messaging has been part of their calculus for several years now. But here, they do want to focus on whether the company policies regarding ephemeral messaging are effective. Is the company capturing messaging that's occurring on company related devices? Are we allowing personal devices? If so, are they limited to certain apps that are capturing company business related discussions? Is there training? Is there auditing? Are there other steps on ephemeral messaging? So they really want to see not just: Are there policies? But are they effective? And those are just two examples. But if you do dig into what's behind a lot of these policy announcements in the memo, it really is looking to drive effective programs. Susan Divers: Well, I want to dig in a little bit. And just to clarify by ephemeral messaging, you mean that if we have senior execs using What's App to communicate, rather than company systems that are subject to discovery, then we might have a problem. Jon Drimmer: Yeah. It can be company, it can be teams messaging, it can be What's App on company issued devices or personal devices. It's any of the messaging systems that are used to communicate that ultimately may not ordinarily be retained by the company in the way that email is. Susan Divers: So that's an area that the policy makes clear, compliance officers ought to really take a hard look at and may need to make some changes, or at least provide some clarity. I want to get information effectiveness more in a minute too. But just to deal with the other very specific granular recommendation that I saw in the Monaco Memo, it was that you really have to have an incentive system that's aligned to ethics and compliance. And by that, it's both positive and negative. In other words, you have to reward ethical behavior as part of your system of incentives, whether it's bonuses, compensation, promotions. And you have to penalize misbehavior, whether it's bonuses, compensation, promotions, but also claw backs. Can you talk about that a little bit? Jon Drimmer: Yeah, yeah. It really was fairly prescriptive, as you say, in terms of, in ways that I think should make chief compliance officers happy. That's the stuff that we always advocate for with human resources and with executives. Hey, we want ethics. We want ethics and compliance included in hiring decisions and promotions and bonus frameworks and performance commitments. And that's really what helps integrate ethics and compliance into business operations and prioritize it along with operational considerations, so that should be welcome news for chief compliance officers. The claw back aspect, which is the stick, that's the carrot, this is the stick, it's interesting. They really emphasize it's not good enough just to have claw back provisions that are theoretically applicable, that are present in policies and are never applied. They want to see them applied in cases where there is appropriate individual culpability. And that may mean applied in different ways. They're clearer that there is no uniform approach to a claw back provision, but it isn't good enough just to have it as a policy. You need to talk about it. You need to train on it. And you need to actually implement it in appropriate situations, which is part of the focus on the individual responsibility and again, driving effectiveness. Susan Divers: That's a very good segue into effectiveness. I do want to emphasize what you said, which is this is something that ethics and compliance professionals need to pay attention to. And it should be a welcome development to have that kind of accountability and importance placed on ethics and compliance considerations. But it's: What do you do about it, as you said, if you've got claw back? I think the SEC says that about 50% of publicly traded companies have claw back, but you have to use it. Otherwise, you're probably worse off if you have it as a tool and then you don't use it if you've got senior level misconduct. Jon Drimmer: Yeah, I think that's right. But better to have it than not have it, and if you've got it, you've actually got to apply it, is kind of what they're signaling. But look, this is hard. I mean, it is really hard when you are doing investigations of your own people. As a chief compliance officer, this was the least favorite part of my job is doing investigations into people I work with, people I knew, people who in other aspects of my job, I had to trust. I had to trust them in terms of implementing or overseeing certain aspects of the program. And when you have to do an investigation into them, it feels lousy. It screams out for why independence is important. And those particular instances is just a matter of investigative integrity, but it's a lousy part of the job. And applying a claw back provision to senior executives who you have worked with, who you have traveled with, whatever it is, it's a lousy part of the job, but they are saying it is an important part and a part that has to be applied in practice. Susan Divers: Yeah. I agree with you. That is really the worst part of being a chief ethics and compliance officer, for sure. Let's dive deeper into effectiveness. As I've gotten to know you and worked with you on thought leadership, I've always been extremely impressed with you focus when you're a chief ethics and compliance officer on effectiveness. And I remember some of the things you did, even including short pulse surveys in your investigations to get feedback from employees, so that's just one example. But can you talk about what do we really mean by effectiveness in terms of ethics and compliance programs? What should we be measuring? What should we be looking at? And where should the focus be? Jon Drimmer: Yeah. I mean, really what effectiveness means is: Are the goals of any particular element of your program being achieved? Are you meeting the goals that you have set out for that particular element of the program? So for instance, your goal might be to roll out a new training, and to roll it out to 90% of everybody on a mapped basis. That isn't going to get into effectiveness. Effectiveness is: How well do they retain the critical aspects of the content that is being conveyed? And that can be done through surveys, that can be done through tests, et cetera. But when we're talking about effectiveness here, again, it isn't just about roll out, it isn't just about robustness and good faith commitment to implementing a program. But is it working in practice? How do you know it? How do you test it? How do you validate it? Often, that's done through KPIs and through metrics. I personally like surveys, sentiment survey, I've always liked surveys as a way of getting information. And beyond that, it brings employees into the program when they are talking to you, providing information about their own experiences. I think that's a very effective way to do it. I think 360s in terms of reviews that include ethics compliance is another important part, so you do again get perspectives of employees on individual performance, particularly for supervisors, from an ethics and compliance standpoint. I think you need to look at audit results. I think you need to look at investigations. I think you need to look at a number of different factors that all indicate on a lag indicating basis, what is working and what isn't working. But I think that should be a relentless focus, personally. And I think for every element of your program, you should be looking at multiple ways to try to assess. Is what I'm doing actually working to the degree that I want it to, and in the way that I want it to? And if not, you have to make an adjustment. That's what effectiveness is about. Susan Divers: That's a really good definition. I think one of the traps people can fall into easily is to focus on activities rather than impact. And I like your phrasing of it as a relentless focus on effectiveness. I mean, one of the things we're just doing is rolling out a short, I think it's 10 question ethical culture pulse survey that comes up at the end of a code of conduct course. And it asks questions about respect and trust and organizational justice, which as you know are key elements of an ethical culture. So always trying to get at perceptions and concerns and to the degree that you can measure how that's playing out, I think is really essential to effectiveness. I want to talk about in a minute how non US companies are affected by all this, and also the most common mistakes you've seen people make in your long and in depth, varied career. But before we get there, I was just looking at some of the DOJ material, and I see that Matt Galvin has joined the team. And now I think there's at least three or four former chief ethics and compliance officers. And Matt came for Anheuser, and he has a particular focus on data analytics. What are you seeing in terms of using data analytics for effectiveness? And what do you recommend in that area? Jon Drimmer: I think that's a great hire. I think it'll be great for Matt, and I think that's a great hire for the government, really bringing in somebody who ran a compliance program and who has had a very substantial focus on data analytics. And at AB InBev, the Brew Right program that he put together is one that's usually been held up as an industry leader. I mean, I do think data analytics is critically important. One of the challenges with data analytics that you have to always get around is making sure that your data is good, that things are being recorded and described in like manners that allows for apples to apples comparison. And you have to understand what to do with that information. And so it's not enough to run the analytics, but when you get the analytics back, you have to have a program in place, resources in place, to act on it. And so thinking through holistically what the data is, where it's coming from, how you're going to act on it, depending on what you get is all a really important part of the equation to think about ahead of time before you just start collecting and running. Look, it's critically important. It's been something that's been emphasized for years as a key way of identifying effectiveness, as well as potential risks that you might not otherwise see, and trends, and patterns. So it really is a very important part of a program with the caveat that you've got to make sure that your data is really good and that you know what you're going to do with it on the back end. But that's a great hire, and I'm sure it's really going to advance compliance thinking in the government around the use of data. Susan Divers: I think that's a good way to characterize the importance of data metrics and particularly stressing that it's not enough to have them and get the insights, you have to act on them. It's similar to risk analysis and risk assessment. It's great that you're running a yearly risk assessment, but are you factoring those results into your training or your policies? So that's part of that focus on effectiveness. Talk to me a little bit, Jon, if you would, about we've been talking about the Department of Justice. It does seem to me that what DOJ does in areas like this has a lot of impact on international companies. It's not limited to the US. And you're in a great position to discuss that a bit, if you would. Jon Drimmer: Yeah, sure. Of course. No, absolutely. Look, and to be clear, when the government emphasizes things like data and benchmarking and metrics and KPIs, I can't applaud them enough for bringing in someone like Matt, who has seen it on the ground, has put into place a great program to really help educate. And that's going to be true for US and non US companies. The government focuses on violations of the law, where there is jurisdiction, where there's something that will touch the US, or you have US companies or US issuers. But if you're a foreign company and you're doing business in the United States, or you're listed on a US exchange, the US laws very well may apply to you. The FCPA certainly very well may apply to you. And some of the biggest settlements, again just sticking with the FCPA, have been with non US companies in the last two years. And I don't want to limit this to the FCPA because the memo from Lisa Monaco, it's not limited to the FCPA, but it will extend to throughout the criminal division. And so whether it's antitrust, or healthcare fraud, or other areas that the criminal division might oversee, this is going to apply to companies regardless of whether they're US or non US, depending on the jurisdictional components, so it's a very important part for all companies doing business in the United States, not just US companies. Susan Divers: And I think sometimes people forget how broad that actually is. People sort of think, "Okay, there's US companies, there's French companies, there's Indian companies," but if you're doing business here, or you're using the banking system, then you are basically within the ambit of US jurisdiction if you commit bribery violations, or antitrust, or sanctions violations, or whatever they happen to be. So it really is a very broad net. And I think for that reason, I think the guidance has driven the evolution of ethics and compliance programs globally, not just in the US. Is that your sense too? Jon Drimmer: Yeah. Yeah. No question about it. I think if you look around the world, whether it's the UK, or France, or throughout Latin America, for those governments that have formally put out either guidances, or they've integrated into their laws what compliance programs ought to look like, I mean, it really looks a lot like what the Department of Justice and the SEC have put out, which of course is premised on a sentencing guidelines foundation. But really, it is driving global compliance processes and programs around the world, even for those companies that don't touch the US, even in their home jurisdictions. It's driving very similar approaches and ways of thinking about compliance. Susan Divers: Yes. And I think if anybody needs proof of that, they should read the Glencore CPA settlement, which I was just looking at, which is a huge fine for anti bribery for basically a non US company. But we're starting to run out of time. I could do this all day, as you know. But let's wrap up with: Given your unique perspective, having sat in all of the key positions, what are the most common mistakes you see people make in ethics and compliance programs? And if you can relate some of those to the guidance, that would be great. Jon Drimmer: Yeah, sure. Look, I mean,  I think first and foremost, it isn't really understanding and looking to integrate into programs what drives an ethical culture. And we talked before about the absolute importance of organizational justice as one of the key drivers in thinking about how that should get integrated into your program. And another is managerial modeling. And truthfully, what people seem to often forget is that most employees look at their supervisors, and maybe their supervisors' supervisors as the company. They look at them as management. And so focusing on, quote, unquote, tone from the top, and the most senior leaders of a company, to the exclusion of direct supervisors, middle managers, I think is often a mistake. And so driving behaviors expected of managers is critically important. I think people also ignore the absolute singular importance of confidence in internal reporting mechanisms and hotlines, which is often a proxy for whether your culture of compliance is strong, and whether organizational justice exists, whether managerial modeling is occurring. But I think beyond that, we've talked about the focus on effectiveness. And I think too often, you do see compliance programs that really are driving towards activities and robustness and metrics and numbers that don't take into account. Is it really working in practice? And I do think that has to be, especially in light of the guidance, which talks about culture, it talks about effectiveness, it focuses on effectiveness, I think that's got to be a critical emphasis for any program. And I think a lot of programs aren't sufficiently mature in that particular aspect, which may be why this guidance or this policy is coming out now. Susan Divers: So it sounds like if you were advising let's say a startup, or a relatively small company that's program is just getting underway, you would advise them to focus very much on the value side on getting organizational justice right, on getting speak up culture going and creating that atmosphere of trust, and also on making sure that managers know what the ethical and compliance considerations that affect them are, and what that means in practice. Jon Drimmer: Yeah. Yeah, that's exactly right. And look, that relates directly to the guidance as we look at rewards, in terms of pay, of performance commitments, presumably of bonuses, of promotions. So setting those expectations for management, along with organizational justice and speak up, I think are really vital components. And so if you are just starting out, the sooner you look to embed that within the company, the more effective it's going to be hopefully as the company grows. Susan Divers: Wow, this has been such a terrific, insightful conversation. And I really feel like I've benefited a lot personally just from hearing the way you've wove together the policy, the guidance. And just for one point of clarification before we sign off, I've been looking at the guidance since I think 2013. I've seen an evolution, actually. It's gotten stronger and it's gotten smarter in focusing on the right things like culture. I don't see it really weakening or changing, even during the Trump administration, interestingly. Is that your perception as well? Is that your expectation for the future? Jon Drimmer: Yeah, yeah, absolutely. Look, they are clearly sharpening the guidance. They are sharpening their policies in a way that is actually quite healthy. And I completely applaud the degree of transparency that we've seen in terms of talking about how these are applied, in terms of talking about how these are to be interpreted. So I applaud the transparency and I completely agree. It is getting much sharper, particularly around those aspects that really impact compliance professionals, like culture, like incentivization, like trying to establish commitments, like integrating compliance into employment processes. So I think it is getting smarter. And again, I think the transparency is really helpful, and particularly for chief ethics and compliance officers. Susan Divers: Great. And I agree. I mean, it's actually making people's jobs easier if they take the key messages in the guidance and are able to use the guidance to drive change in their organizations. So Jon, thanks so much for joining me on this episode. Just to wrap up, I'm Susan Frank Divers, and I want to thank everyone for listening to Principled Podcast by LRN. Jon Drimmer: Thank you. Outro: We hope you enjoyed this episode. The Principled Podcast is brought to by LRN. At LRN, our mission is to inspire principled performance in global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us at lrn.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen. And don't forget to leave us a review.  

Hi this is Garrison Hardie with your CrossPolitic Daily News Brief for Thursday, October 20th, 2022. FLF Magazine: We are on a mission to make magazines great again. So, subscribe to our Fight Laugh Feast magazine. This is a quarterly mini-book like experience, packed full of a variety of authors that includes theologically-driven cultural commentary, a Psalm of the quarter, recipes for feasting, laughter sprinkled throughout the glossy pages, and more. Sign your church up, sign your grumpy uncle up, and while you are at it…sign up the Pope, Elon Musks, and Russel Moore. Disclaimer: This magazine will guarantee various responses and CrossPolitic is not held liable for any of them. Reading the whole magazine may cause theological maturation, possibly encourage your kids to take the Lord’s Supper with you, and will likely cause you to randomly chuckle in joy at God’s wondrous world. Sign up today! Four issues and $60 per year, that is it. Go to fightlaughfeast.com right now to sign up! https://thepostmillennial.com/breaking-cdc-moves-to-add-covid-vaccine-to-child-immunization-schedule-for-federal-programs?utm_campaign=64487 CDC moves to add Covid vaccine to child immunization schedule for federal programs On Thursday, the Center for Disease Control (CDC) is set to vote on whether or not to include the Covid vaccine in their recommended schedule of shots for children and teens. The CDC’s Advisory Committee on Immunization Practices (ACIP) is scheduled to meet on Wednesday and Thursday to discuss, amongst other topics, whether to include the Covid vaccines and other vaccinations into their child and adolescent immunization schedule. According to WBOY, the CDC is considering adding the vaccine to their schedule in order for it to be covered under the federally-funded Vaccines for Children (VFC) Program and other programs. In order for vaccines to be covered under health plans, shots must be approved by the CDC director, and appear on the CDC’s immunization schedule, according to a document from the CDC. According to the CDC, VFC is a federally funded program that provides vaccines to children at no cost to families. The CDC’s immunization schedule for kids is seen as a recommendation for parents and physicians on when certain vaccines should be administered. The schedule also serves as a building block for school districts nationwide, many of whom chose to follow these guidelines as requirements for children to enter public schools. The inclusion of the Covid-19 vaccine on this schedule could give the green signal for school districts to enforce mandates on their students, with some schools across the country pausing their mandates over low vaccination numbers in minors. Many European nations have said that Covid vaccines are not necessary for children. https://thepostmillennial.com/abc-news-investigative-producer-disappears-after-fbi-raid?utm_campaign=64487 ABC News investigative producer disappears after FBI raid, was working on book about Biden’s Afghanistan withdrawal An award-winning ABC News national security investigative producer has seemingly gone missing following an FBI raid on his home in April for unclear reasons. James Gordon Meek was in the process of writing a book on the Biden administration's controversial withdrawal from Afghanistan when his neighbors spotted armored vehicles outside of his home, and he hasn't been heard from since. Meek, 52, was best known for his breaking news stories on high levels of corruption within the US military. His bombshell report of the Army’s coverup of the fratricidal death of Pfc. Dave Sharrett II in Iraq landed Meek a meeting with then-President Obama. He seemed to be at the height of his career, with nine years at ABC, a newly-released documentary on Hulu, and a book on the way. That's why so many are baffled at his mysterious and uncharacteristically abrupt disappearance. It was on April 27 of this year when police cruisers and unmarked utility vehicles were spotted blocking the street outside of Meek's Arlington, Virginia apartment building, according to a Rolling Stone report. That was around the time of his last online activity, with one last "like" being sent from his Twitter account on May 2. Since then, he's been silent. An FBI representative confirmed that agents were present that morning "at the 2300 block of Columbia Pike, Arlington, Virginia, conducting court-authorized law-enforcement activity." "The FBI cannot comment further due to an ongoing investigation," they said. A federal magistrate judge signed off on the search warrant the day before the raid. In accordance with a new policy enacted last year, federal prosecutors are not allowed to seize journalists' documents without approval from the Deputy Attorney General, meaning that Biden-appointed Lisa Monaco had to have given her blessing if that's what the raid was for. Despite the bureau's involvement, Meek has not been charged with any crime. Anonymous sources claimed to Rolling Stone that federal agents found classified information on Meek's laptop, but the contents of said information are unknown at this time. His lawyer, Eugene Gorokhov, responded to the claims. "Mr. Meek is unaware of what allegations anonymous sources are making about his possession of classified documents. If such documents exist, as claimed, this would be within the scope of his long career as an investigative journalist covering government wrongdoing. The allegations in your inquiry are troubling for a different reason: they appear to come from a source inside the government. It is highly inappropriate, and illegal, for individuals in the government to leak information about an ongoing investigation. We hope that the DOJ [Department of Justice] promptly investigates the source of this leak." Still, no comment on where exactly his client is. https://hotair.com/ed-morrissey/2022/10/19/abrams-you-can-fight-inflation-by-aborting-more-babies-you-know-n504398 Stacey Abrams suggests having an abortion as solution to inflation: 'Economic realities of having a child' Democratic Georgia gubernatorial candidate Stacey Abrams was criticized on Wednesday after suggesting that having an abortion could be a solution to high inflation and claiming that "having children" is why people are worried about the price of gas and groceries. https://twitter.com/i/status/1582726622859624449 - Play Video 0:00-1:32 Abrams made her remarks a day after President Biden pledged that if Democrats keep control of Congress, he will codify in January the federal right to abortion once granted by the recently overturned Roe v. Wade Supreme Court decision. At no point during the speech did the president, who was a freshman senator nearly 50 years ago when Roe v. Wade was decided in January 1973, mention inflation or the economy. The same day, House Speaker Nancy Pelosi (D-Calif.) rejected a New York Times poll that found voters believe the economy and inflation are the top two issues facing the nation, calling it an “outlier.” Abrams said at the end of September that there was "no such thing" as a fetal heartbeat at 6-weeks. https://thepoliticalinsider.com/fake-news-zelenskys-famous-quote-of-need-ammunition-not-a-ride-never-happened/ Fake News: Zelensky’s Famous Quote of ‘Need Ammunition, Not a Ride’ Never Happened A senior official claims that a famous quote by Ukrainian president Volodymyr Zelensky appears to be fake news, war propaganda. The quote about needing ammunition helped catapult his credentials as a defiant wartime leader. The revelation came amidst a sprawling report by the New Yorker on the Biden administration’s support for Ukraine, which is far more extensive than previously known and includes operational planning at the highest levels. But Zelensky’s famous line – “I need ammunition, not a ride” – and the fact that it may have been completely fabricated and promoted by the media ad nauseam casts a further pall on a war narrative that has at times seemed crafted by the heavy hand of a former actor. From the New Yorker: Two days into the invasion, the Associated Press reported that Zelensky had rejected a U.S. offer to evacuate him from Kyiv, saying, “I need ammunition, not a ride.” A senior U.S. official said, “To the best of my knowledge, that never happened.” The official added, “But hats off to Zelensky and the people around him. It was a great line.” If you’re searching for evidence that the American media are perfectly fine with helping to perpetuate falsehoods in the war effort in Ukraine, you need look no further than the Washington Post and fact-checker Glenn Kessler. Kessler analyzed the claim that Zelensky had uttered the quote: “I need ammunition, not a ride.” Though he admitted the claim was not easily verifiable, he concluded using Zelensky’s press secretary that “the quote, even if not accurate, reflects the moment.” At least he tried. The rest of the media simply ran with it. This isn’t the first time stories coming out of Ukraine had proven to be completely orchestrated in an effort to drum up emotional support from the United States. Around the same time as the Zelensky ‘ammunition’ quote, a story was developing about a defiant group of 13 Ukrainian border guards defending Snake Island in the Black Sea who reportedly told a Russian warship to “go f*** yourself” after being ordered to surrender. The 13 Ukrainian border guards were initially widely reported as killed as the Russian warship opened fire with barreled guns and aircraft bombing Snake Island. Zelenskyy said during a press briefing that the guards died “heroes” and even said the 13 would be posthumously awarded the title of Hero of Ukraine. It was later reported they were still alive and in Russian captivity. Then, of course, there is the infamous ‘Ghost of Kyiv‘ propaganda promoted by some prominent figures here in the United States. Some, like Rep. Adam Kinzinger, were so willing to believe the story they promoted fake images of a meme-character known as Samuel Hyde. It’s breathtaking the number of stories like the Zelensky ammunition fairytale that have been thrust upon the American people as a means to justify the absurd level of financial and military support being offered to Ukraine at our expense. Fox News host Tucker Carlson has seemingly had enough, eviscerating Zelensky for making further outrageous demands for financial aid while the United States economy, and the American people, are suffering. https://twitter.com/i/status/1580717198703611904 - Play Video “Zelenskyy is now shaking down our cowardly Congress for more cash at the very moment our own economy and our own borders are collapsing,” Carlson added. New Saint Andrews: Today’s culture shifts like sand. But New Saint Andrews College is established on Christ, the immovable rock. It is a premier institution that forges evangelical leaders who don’t fear or hate the world. Guided by God’s Word, they take the world back because they’re equipped with the genius of classical liberal arts and God-honoring wisdom, thanks to a faculty dedicated to academic rigor and to God’s kingdom.Find out more, at nsa.edu/ Now it’s time for my favorite topic… sports! https://www.boundingintosports.com/2022/10/la-chargers-kicker-dustin-hopkins-gives-glory-to-jesus-christ-after-powering-team-to-overtime-victory-over-denver-broncos/ LA Chargers Kicker Dustin Hopkins Gives Glory To Jesus Christ After Powering Team To Overtime Victory Over Denver Broncos With less than three minutes left in overtime, Hopkins hit a 39-yard field goal to give the Chargers the 19-16 win. https://twitter.com/i/status/1582213865101672448 - Play Video Not only did he hit the game winning field goal, but he did while playing with a hamstring injury that he suffered after hitting the first extra point of the game. Following the game winning field goal, Hopkins spoke with ESPN’s Lisa Salters, where he gave all glory to Jesus Christ. https://twitter.com/i/status/1582288626876317696 - Play 0:28

Hi this is Garrison Hardie with your CrossPolitic Daily News Brief for Thursday, October 20th, 2022. FLF Magazine: We are on a mission to make magazines great again. So, subscribe to our Fight Laugh Feast magazine. This is a quarterly mini-book like experience, packed full of a variety of authors that includes theologically-driven cultural commentary, a Psalm of the quarter, recipes for feasting, laughter sprinkled throughout the glossy pages, and more. Sign your church up, sign your grumpy uncle up, and while you are at it…sign up the Pope, Elon Musks, and Russel Moore. Disclaimer: This magazine will guarantee various responses and CrossPolitic is not held liable for any of them. Reading the whole magazine may cause theological maturation, possibly encourage your kids to take the Lord’s Supper with you, and will likely cause you to randomly chuckle in joy at God’s wondrous world. Sign up today! Four issues and $60 per year, that is it. Go to fightlaughfeast.com right now to sign up! https://thepostmillennial.com/breaking-cdc-moves-to-add-covid-vaccine-to-child-immunization-schedule-for-federal-programs?utm_campaign=64487 CDC moves to add Covid vaccine to child immunization schedule for federal programs On Thursday, the Center for Disease Control (CDC) is set to vote on whether or not to include the Covid vaccine in their recommended schedule of shots for children and teens. The CDC’s Advisory Committee on Immunization Practices (ACIP) is scheduled to meet on Wednesday and Thursday to discuss, amongst other topics, whether to include the Covid vaccines and other vaccinations into their child and adolescent immunization schedule. According to WBOY, the CDC is considering adding the vaccine to their schedule in order for it to be covered under the federally-funded Vaccines for Children (VFC) Program and other programs. In order for vaccines to be covered under health plans, shots must be approved by the CDC director, and appear on the CDC’s immunization schedule, according to a document from the CDC. According to the CDC, VFC is a federally funded program that provides vaccines to children at no cost to families. The CDC’s immunization schedule for kids is seen as a recommendation for parents and physicians on when certain vaccines should be administered. The schedule also serves as a building block for school districts nationwide, many of whom chose to follow these guidelines as requirements for children to enter public schools. The inclusion of the Covid-19 vaccine on this schedule could give the green signal for school districts to enforce mandates on their students, with some schools across the country pausing their mandates over low vaccination numbers in minors. Many European nations have said that Covid vaccines are not necessary for children. https://thepostmillennial.com/abc-news-investigative-producer-disappears-after-fbi-raid?utm_campaign=64487 ABC News investigative producer disappears after FBI raid, was working on book about Biden’s Afghanistan withdrawal An award-winning ABC News national security investigative producer has seemingly gone missing following an FBI raid on his home in April for unclear reasons. James Gordon Meek was in the process of writing a book on the Biden administration's controversial withdrawal from Afghanistan when his neighbors spotted armored vehicles outside of his home, and he hasn't been heard from since. Meek, 52, was best known for his breaking news stories on high levels of corruption within the US military. His bombshell report of the Army’s coverup of the fratricidal death of Pfc. Dave Sharrett II in Iraq landed Meek a meeting with then-President Obama. He seemed to be at the height of his career, with nine years at ABC, a newly-released documentary on Hulu, and a book on the way. That's why so many are baffled at his mysterious and uncharacteristically abrupt disappearance. It was on April 27 of this year when police cruisers and unmarked utility vehicles were spotted blocking the street outside of Meek's Arlington, Virginia apartment building, according to a Rolling Stone report. That was around the time of his last online activity, with one last "like" being sent from his Twitter account on May 2. Since then, he's been silent. An FBI representative confirmed that agents were present that morning "at the 2300 block of Columbia Pike, Arlington, Virginia, conducting court-authorized law-enforcement activity." "The FBI cannot comment further due to an ongoing investigation," they said. A federal magistrate judge signed off on the search warrant the day before the raid. In accordance with a new policy enacted last year, federal prosecutors are not allowed to seize journalists' documents without approval from the Deputy Attorney General, meaning that Biden-appointed Lisa Monaco had to have given her blessing if that's what the raid was for. Despite the bureau's involvement, Meek has not been charged with any crime. Anonymous sources claimed to Rolling Stone that federal agents found classified information on Meek's laptop, but the contents of said information are unknown at this time. His lawyer, Eugene Gorokhov, responded to the claims. "Mr. Meek is unaware of what allegations anonymous sources are making about his possession of classified documents. If such documents exist, as claimed, this would be within the scope of his long career as an investigative journalist covering government wrongdoing. The allegations in your inquiry are troubling for a different reason: they appear to come from a source inside the government. It is highly inappropriate, and illegal, for individuals in the government to leak information about an ongoing investigation. We hope that the DOJ [Department of Justice] promptly investigates the source of this leak." Still, no comment on where exactly his client is. https://hotair.com/ed-morrissey/2022/10/19/abrams-you-can-fight-inflation-by-aborting-more-babies-you-know-n504398 Stacey Abrams suggests having an abortion as solution to inflation: 'Economic realities of having a child' Democratic Georgia gubernatorial candidate Stacey Abrams was criticized on Wednesday after suggesting that having an abortion could be a solution to high inflation and claiming that "having children" is why people are worried about the price of gas and groceries. https://twitter.com/i/status/1582726622859624449 - Play Video 0:00-1:32 Abrams made her remarks a day after President Biden pledged that if Democrats keep control of Congress, he will codify in January the federal right to abortion once granted by the recently overturned Roe v. Wade Supreme Court decision. At no point during the speech did the president, who was a freshman senator nearly 50 years ago when Roe v. Wade was decided in January 1973, mention inflation or the economy. The same day, House Speaker Nancy Pelosi (D-Calif.) rejected a New York Times poll that found voters believe the economy and inflation are the top two issues facing the nation, calling it an “outlier.” Abrams said at the end of September that there was "no such thing" as a fetal heartbeat at 6-weeks. https://thepoliticalinsider.com/fake-news-zelenskys-famous-quote-of-need-ammunition-not-a-ride-never-happened/ Fake News: Zelensky’s Famous Quote of ‘Need Ammunition, Not a Ride’ Never Happened A senior official claims that a famous quote by Ukrainian president Volodymyr Zelensky appears to be fake news, war propaganda. The quote about needing ammunition helped catapult his credentials as a defiant wartime leader. The revelation came amidst a sprawling report by the New Yorker on the Biden administration’s support for Ukraine, which is far more extensive than previously known and includes operational planning at the highest levels. But Zelensky’s famous line – “I need ammunition, not a ride” – and the fact that it may have been completely fabricated and promoted by the media ad nauseam casts a further pall on a war narrative that has at times seemed crafted by the heavy hand of a former actor. From the New Yorker: Two days into the invasion, the Associated Press reported that Zelensky had rejected a U.S. offer to evacuate him from Kyiv, saying, “I need ammunition, not a ride.” A senior U.S. official said, “To the best of my knowledge, that never happened.” The official added, “But hats off to Zelensky and the people around him. It was a great line.” If you’re searching for evidence that the American media are perfectly fine with helping to perpetuate falsehoods in the war effort in Ukraine, you need look no further than the Washington Post and fact-checker Glenn Kessler. Kessler analyzed the claim that Zelensky had uttered the quote: “I need ammunition, not a ride.” Though he admitted the claim was not easily verifiable, he concluded using Zelensky’s press secretary that “the quote, even if not accurate, reflects the moment.” At least he tried. The rest of the media simply ran with it. This isn’t the first time stories coming out of Ukraine had proven to be completely orchestrated in an effort to drum up emotional support from the United States. Around the same time as the Zelensky ‘ammunition’ quote, a story was developing about a defiant group of 13 Ukrainian border guards defending Snake Island in the Black Sea who reportedly told a Russian warship to “go f*** yourself” after being ordered to surrender. The 13 Ukrainian border guards were initially widely reported as killed as the Russian warship opened fire with barreled guns and aircraft bombing Snake Island. Zelenskyy said during a press briefing that the guards died “heroes” and even said the 13 would be posthumously awarded the title of Hero of Ukraine. It was later reported they were still alive and in Russian captivity. Then, of course, there is the infamous ‘Ghost of Kyiv‘ propaganda promoted by some prominent figures here in the United States. Some, like Rep. Adam Kinzinger, were so willing to believe the story they promoted fake images of a meme-character known as Samuel Hyde. It’s breathtaking the number of stories like the Zelensky ammunition fairytale that have been thrust upon the American people as a means to justify the absurd level of financial and military support being offered to Ukraine at our expense. Fox News host Tucker Carlson has seemingly had enough, eviscerating Zelensky for making further outrageous demands for financial aid while the United States economy, and the American people, are suffering. https://twitter.com/i/status/1580717198703611904 - Play Video “Zelenskyy is now shaking down our cowardly Congress for more cash at the very moment our own economy and our own borders are collapsing,” Carlson added. New Saint Andrews: Today’s culture shifts like sand. But New Saint Andrews College is established on Christ, the immovable rock. It is a premier institution that forges evangelical leaders who don’t fear or hate the world. Guided by God’s Word, they take the world back because they’re equipped with the genius of classical liberal arts and God-honoring wisdom, thanks to a faculty dedicated to academic rigor and to God’s kingdom.Find out more, at nsa.edu/ Now it’s time for my favorite topic… sports! https://www.boundingintosports.com/2022/10/la-chargers-kicker-dustin-hopkins-gives-glory-to-jesus-christ-after-powering-team-to-overtime-victory-over-denver-broncos/ LA Chargers Kicker Dustin Hopkins Gives Glory To Jesus Christ After Powering Team To Overtime Victory Over Denver Broncos With less than three minutes left in overtime, Hopkins hit a 39-yard field goal to give the Chargers the 19-16 win. https://twitter.com/i/status/1582213865101672448 - Play Video Not only did he hit the game winning field goal, but he did while playing with a hamstring injury that he suffered after hitting the first extra point of the game. Following the game winning field goal, Hopkins spoke with ESPN’s Lisa Salters, where he gave all glory to Jesus Christ. https://twitter.com/i/status/1582288626876317696 - Play 0:28

Hi this is Garrison Hardie with your CrossPolitic Daily News Brief for Thursday, October 20th, 2022. FLF Magazine: We are on a mission to make magazines great again. So, subscribe to our Fight Laugh Feast magazine. This is a quarterly mini-book like experience, packed full of a variety of authors that includes theologically-driven cultural commentary, a Psalm of the quarter, recipes for feasting, laughter sprinkled throughout the glossy pages, and more. Sign your church up, sign your grumpy uncle up, and while you are at it…sign up the Pope, Elon Musks, and Russel Moore. Disclaimer: This magazine will guarantee various responses and CrossPolitic is not held liable for any of them. Reading the whole magazine may cause theological maturation, possibly encourage your kids to take the Lord’s Supper with you, and will likely cause you to randomly chuckle in joy at God’s wondrous world. Sign up today! Four issues and $60 per year, that is it. Go to fightlaughfeast.com right now to sign up! https://thepostmillennial.com/breaking-cdc-moves-to-add-covid-vaccine-to-child-immunization-schedule-for-federal-programs?utm_campaign=64487 CDC moves to add Covid vaccine to child immunization schedule for federal programs On Thursday, the Center for Disease Control (CDC) is set to vote on whether or not to include the Covid vaccine in their recommended schedule of shots for children and teens. The CDC’s Advisory Committee on Immunization Practices (ACIP) is scheduled to meet on Wednesday and Thursday to discuss, amongst other topics, whether to include the Covid vaccines and other vaccinations into their child and adolescent immunization schedule. According to WBOY, the CDC is considering adding the vaccine to their schedule in order for it to be covered under the federally-funded Vaccines for Children (VFC) Program and other programs. In order for vaccines to be covered under health plans, shots must be approved by the CDC director, and appear on the CDC’s immunization schedule, according to a document from the CDC. According to the CDC, VFC is a federally funded program that provides vaccines to children at no cost to families. The CDC’s immunization schedule for kids is seen as a recommendation for parents and physicians on when certain vaccines should be administered. The schedule also serves as a building block for school districts nationwide, many of whom chose to follow these guidelines as requirements for children to enter public schools. The inclusion of the Covid-19 vaccine on this schedule could give the green signal for school districts to enforce mandates on their students, with some schools across the country pausing their mandates over low vaccination numbers in minors. Many European nations have said that Covid vaccines are not necessary for children. https://thepostmillennial.com/abc-news-investigative-producer-disappears-after-fbi-raid?utm_campaign=64487 ABC News investigative producer disappears after FBI raid, was working on book about Biden’s Afghanistan withdrawal An award-winning ABC News national security investigative producer has seemingly gone missing following an FBI raid on his home in April for unclear reasons. James Gordon Meek was in the process of writing a book on the Biden administration's controversial withdrawal from Afghanistan when his neighbors spotted armored vehicles outside of his home, and he hasn't been heard from since. Meek, 52, was best known for his breaking news stories on high levels of corruption within the US military. His bombshell report of the Army’s coverup of the fratricidal death of Pfc. Dave Sharrett II in Iraq landed Meek a meeting with then-President Obama. He seemed to be at the height of his career, with nine years at ABC, a newly-released documentary on Hulu, and a book on the way. That's why so many are baffled at his mysterious and uncharacteristically abrupt disappearance. It was on April 27 of this year when police cruisers and unmarked utility vehicles were spotted blocking the street outside of Meek's Arlington, Virginia apartment building, according to a Rolling Stone report. That was around the time of his last online activity, with one last "like" being sent from his Twitter account on May 2. Since then, he's been silent. An FBI representative confirmed that agents were present that morning "at the 2300 block of Columbia Pike, Arlington, Virginia, conducting court-authorized law-enforcement activity." "The FBI cannot comment further due to an ongoing investigation," they said. A federal magistrate judge signed off on the search warrant the day before the raid. In accordance with a new policy enacted last year, federal prosecutors are not allowed to seize journalists' documents without approval from the Deputy Attorney General, meaning that Biden-appointed Lisa Monaco had to have given her blessing if that's what the raid was for. Despite the bureau's involvement, Meek has not been charged with any crime. Anonymous sources claimed to Rolling Stone that federal agents found classified information on Meek's laptop, but the contents of said information are unknown at this time. His lawyer, Eugene Gorokhov, responded to the claims. "Mr. Meek is unaware of what allegations anonymous sources are making about his possession of classified documents. If such documents exist, as claimed, this would be within the scope of his long career as an investigative journalist covering government wrongdoing. The allegations in your inquiry are troubling for a different reason: they appear to come from a source inside the government. It is highly inappropriate, and illegal, for individuals in the government to leak information about an ongoing investigation. We hope that the DOJ [Department of Justice] promptly investigates the source of this leak." Still, no comment on where exactly his client is. https://hotair.com/ed-morrissey/2022/10/19/abrams-you-can-fight-inflation-by-aborting-more-babies-you-know-n504398 Stacey Abrams suggests having an abortion as solution to inflation: 'Economic realities of having a child' Democratic Georgia gubernatorial candidate Stacey Abrams was criticized on Wednesday after suggesting that having an abortion could be a solution to high inflation and claiming that "having children" is why people are worried about the price of gas and groceries. https://twitter.com/i/status/1582726622859624449 - Play Video 0:00-1:32 Abrams made her remarks a day after President Biden pledged that if Democrats keep control of Congress, he will codify in January the federal right to abortion once granted by the recently overturned Roe v. Wade Supreme Court decision. At no point during the speech did the president, who was a freshman senator nearly 50 years ago when Roe v. Wade was decided in January 1973, mention inflation or the economy. The same day, House Speaker Nancy Pelosi (D-Calif.) rejected a New York Times poll that found voters believe the economy and inflation are the top two issues facing the nation, calling it an “outlier.” Abrams said at the end of September that there was "no such thing" as a fetal heartbeat at 6-weeks. https://thepoliticalinsider.com/fake-news-zelenskys-famous-quote-of-need-ammunition-not-a-ride-never-happened/ Fake News: Zelensky’s Famous Quote of ‘Need Ammunition, Not a Ride’ Never Happened A senior official claims that a famous quote by Ukrainian president Volodymyr Zelensky appears to be fake news, war propaganda. The quote about needing ammunition helped catapult his credentials as a defiant wartime leader. The revelation came amidst a sprawling report by the New Yorker on the Biden administration’s support for Ukraine, which is far more extensive than previously known and includes operational planning at the highest levels. But Zelensky’s famous line – “I need ammunition, not a ride” – and the fact that it may have been completely fabricated and promoted by the media ad nauseam casts a further pall on a war narrative that has at times seemed crafted by the heavy hand of a former actor. From the New Yorker: Two days into the invasion, the Associated Press reported that Zelensky had rejected a U.S. offer to evacuate him from Kyiv, saying, “I need ammunition, not a ride.” A senior U.S. official said, “To the best of my knowledge, that never happened.” The official added, “But hats off to Zelensky and the people around him. It was a great line.” If you’re searching for evidence that the American media are perfectly fine with helping to perpetuate falsehoods in the war effort in Ukraine, you need look no further than the Washington Post and fact-checker Glenn Kessler. Kessler analyzed the claim that Zelensky had uttered the quote: “I need ammunition, not a ride.” Though he admitted the claim was not easily verifiable, he concluded using Zelensky’s press secretary that “the quote, even if not accurate, reflects the moment.” At least he tried. The rest of the media simply ran with it. This isn’t the first time stories coming out of Ukraine had proven to be completely orchestrated in an effort to drum up emotional support from the United States. Around the same time as the Zelensky ‘ammunition’ quote, a story was developing about a defiant group of 13 Ukrainian border guards defending Snake Island in the Black Sea who reportedly told a Russian warship to “go f*** yourself” after being ordered to surrender. The 13 Ukrainian border guards were initially widely reported as killed as the Russian warship opened fire with barreled guns and aircraft bombing Snake Island. Zelenskyy said during a press briefing that the guards died “heroes” and even said the 13 would be posthumously awarded the title of Hero of Ukraine. It was later reported they were still alive and in Russian captivity. Then, of course, there is the infamous ‘Ghost of Kyiv‘ propaganda promoted by some prominent figures here in the United States. Some, like Rep. Adam Kinzinger, were so willing to believe the story they promoted fake images of a meme-character known as Samuel Hyde. It’s breathtaking the number of stories like the Zelensky ammunition fairytale that have been thrust upon the American people as a means to justify the absurd level of financial and military support being offered to Ukraine at our expense. Fox News host Tucker Carlson has seemingly had enough, eviscerating Zelensky for making further outrageous demands for financial aid while the United States economy, and the American people, are suffering. https://twitter.com/i/status/1580717198703611904 - Play Video “Zelenskyy is now shaking down our cowardly Congress for more cash at the very moment our own economy and our own borders are collapsing,” Carlson added. New Saint Andrews: Today’s culture shifts like sand. But New Saint Andrews College is established on Christ, the immovable rock. It is a premier institution that forges evangelical leaders who don’t fear or hate the world. Guided by God’s Word, they take the world back because they’re equipped with the genius of classical liberal arts and God-honoring wisdom, thanks to a faculty dedicated to academic rigor and to God’s kingdom.Find out more, at nsa.edu/ Now it’s time for my favorite topic… sports! https://www.boundingintosports.com/2022/10/la-chargers-kicker-dustin-hopkins-gives-glory-to-jesus-christ-after-powering-team-to-overtime-victory-over-denver-broncos/ LA Chargers Kicker Dustin Hopkins Gives Glory To Jesus Christ After Powering Team To Overtime Victory Over Denver Broncos With less than three minutes left in overtime, Hopkins hit a 39-yard field goal to give the Chargers the 19-16 win. https://twitter.com/i/status/1582213865101672448 - Play Video Not only did he hit the game winning field goal, but he did while playing with a hamstring injury that he suffered after hitting the first extra point of the game. Following the game winning field goal, Hopkins spoke with ESPN’s Lisa Salters, where he gave all glory to Jesus Christ. https://twitter.com/i/status/1582288626876317696 - Play 0:28

Är Börje på väg att förlora sin oskuld? " UPPDRAG GRANSKNING · USA:s regering utlovar tuffare tag mot bolag som mutar. I synnerhet mot företag som brutit mot uppgörelser med amerikanska myndigheter – som svenska Ericsson. Vd Börje Ekholm riskerar åtal och fängelse, enligt advokat och korruptionsexpert Peter Utterström. – De har full möjlighet att ta en person till domstol. USA:s biträdande justitieminister Lisa Monaco gjorde nyligen i ett tal klart att USA:s regering nu siktar in sig på individer i bolagen för att utkräva ansvar. – Vår högsta prioritet är att jaga de individer som begår och tjänar på bolagets brott. Vi ger våra åklagare större resurser att hålla dessa personer ansvariga. Ericsson har en lång historia av mutskandaler. 2019 tvingades företaget betala rekordböter på 10 miljarder kronor till justitiedepartementet i USA. Uppgörelsen är en slags villkorlig dom, där Ericsson sattes under bevakning och förband sig att rapportera minsta misstanke om fler mutor i bolagets verksamhet. Utreds av amerikanska myndigheter Kort efter avslöjandet i februari om misstänkta mutor till IS i Irak meddelade justitiedepartementet att Ericsson brutit mot uppgörelsen. – Då är du rökt, säger Peter Utterström, advokat till Uppdrag granskning. Han är korruptionsexpert och jobbar med amerikanska bolag. – Du måste vara extremt betydelsefull för att amerikanska myndigheter ska kunna se mellan fingrarna, fortsätter Peter Utterström. Han pekar på att Ericsson inte bara kan ha gjort sig skyldigt till mutbrott, utan även sanktionsbrott för den misstänkta finansieringen av terrorsekten IS. Ericsson utreds nu av såväl justitiedepartementet som finansinspektionen i USA. – Ericsson har lyckats göra det mest allvarliga man kan göra när det gäller brott mot den amerikanska lagstiftningen. Min gissning är att Ericsson kommer få böta mer än de 10 miljarder man redan betalat, säger advokat Peter Utterström. Varnades för “katastrofala” följder Uppdrag granskning kan avslöja att Ericsson redan i våras varnades för en intensiv granskning av flera amerikanska myndigheter som skulle kunna ge “katastrofala” följder. En expertgrupp med tunga jurister och personer med bakgrund i de mest centrala delarna av det amerikanska rättssystemet var tydlig: Ericsson måste låta genomföra en extern, oberoende, utredning av IS-skandalen, för att minimera skadan för företaget, styrelsen, aktieägarna och ta ansvar för de potentiella offren. Men Ericsson följde inte rekommendationen. Ericsson avböjer intervju SVT:s Uppdrag granskning har upprepade gånger bett om en intervju med Ericssons ledning. De har konsekvent avböjt. I ett mail som skickas till Uppdrag granskning den 17 oktober skriver bolaget: “… vi tar det här och alla liknande anklagelser mycket allvarligt – såväl det påstådda uppförandet som det faktum att det amerikanska justitiedepartementet meddelat oss att Irakutredningen från 2019 inte var tillräckligt redovisad för dem... ...Vi arbetar direkt med myndigheterna, inklusive DOJ och SEC, för att där det behövs lösa och uppmärksamma alla problem.” Black Lies Matter! #CarlNorberg #DeFria De Fria är en folkrörelse som jobbar för demokrati genom en upplyst och medveten befolkning! Stöd oss: SWISH: 070 - 621 19 92 (mottagare Sofia S) PATREON: https://patreon.com/defria_se HEMSIDA: https://defria.se FACEBOOK: https://facebook.com/defria.se

By Adam Turteltaub United States Deputy Attorney General (DAG) Lisa Monaco recently gave a speech in which she outlined both new policies at the Department of Justice (DOJ) as well as enhancements to existing ones that can have a profound effect on compliance and ethics programs. To better understand both what she said and what it all means we sat down with DOJ veteran Daniel Kahn (LinkedIn), a partner in the Washington, DC office of Davis, Polk & Wardwell, for an in-depth and longer than usual podcast. He explains that while the emphasis on individual accountability is not new, there is a significant change. The Department expects that individual prosecutions will take place prior to or at the same time as corporate resolutions. Given the extra time it often takes to prosecute an individual, that will make it harder for organizations to reach a swift conclusion and move forward. There is also one other significant change in terms of how individuals are treated: the Department is now looking to see if the organization is clawing back compensation from employees who committed wrongdoing, at least in those jurisdictions where it is permitted. When it comes to leniency, the Department had previously stated that repeat offenders were not likely to receive a Non-Prosecution Agreement (NPA) or a Deferred Prosecution Agreement (DPA). The DAG's latest comments reflected a more nuanced approach and reflect the idea that all incidents are not created equal, and that in a large organization it is possible for more than one violation to occur over time, without it being a sign of dysfunctionality. Other notable elements of her comments: The Department expects that when an organization seeking cooperation credit comes across hot new evidence it will share it with Justice immediately For the first time there will be policies on voluntary disclosures across all the various departments within Justice There will be a presumption against a guilty plea if a company voluntarily self-discloses, cooperates and remediates Non-Disparagement Agreement clauses will be looked at unfavorably if they interfere with whistleblowing One other notable element of her talk, which was, perhaps, lost in most discussions about her comments, is the call for organizations to getter a better handle on messaging by employees on their personal devices. Finally, Dan addresses what some perceive as a slowdown in corporate prosecutions over the last few years. He notes that during the Obama and Trump administration there was an uptick in cases. Any slowdown over the last two years is likely the results of changes in leadership at the DOJ with a new Administration. Bottom line is that now is not the time to assume the DOJ is not active. Listen in to learn more about what you should take away from DAG Monaco's comments.  

What you'll learn in this podcast episode “Thirty years of innovation and influence” is the subtitle of the recent report issued by the United States Sentencing Commission. But what does that really mean in the context of the organizational sentencing guidelines? In this episode of LRN's Principled Podcast, Eric Morehead, LRN Director of Advisory Services Solutions, is joined by one of the report's authors: Kathleen Grilli, the General Counsel for the US Sentencing Commission. Listen in as the two discuss how the commission impacts business leaders and the creation of compliance programs.    Read LRN's takeaways from the report here.  Principled Podcast Show Notes coming soon   Featured guest: Kathleen Grilli Kathleen Cooper Grilli is the General Counsel for the United States Sentencing Commission, having been appointed to the position on October 7, 2013. Ms. Grilli has been on the staff of the Commission since 2003, serving as an assistant general counsel from 2003-2007 and deputy general counsel from 2007-2013. As the General Counsel, Ms. Grill provides legal advice to the Commissioners on sentencing issues and other matters relating to the operation of the Commission. Ms. Grilli is the agency's Ethics Officer and has conducted training on white collar crime and the organizational guidelines at numerous training events.Prior to working for the Sentencing Commission, Ms. Grilli was with the Office of Staff Counsel for the Fourth Circuit Court of Appeals. Before relocating to Virginia, Ms. Grilli was a partner in a small firm in Fort Lauderdale, Florida, handling civil and criminal litigation. Her previous work experience includes serving as an Assistant Federal Public Defender in the Southern District of Florida and as an associate at Akerman, Senterfitt and Edison, handling commercial litigation. Ms. Grilli is a member of the Bars of Florida and Virginia. She received a Bachelor of Arts in International Relations, with honors, from Florida International University. She graduated cum laude from the University of Miami School of Law.   Featured Host: Eric Morehead Eric Morehead is a member of LRN's Advisory Services team and has over 20 years' experience working with organizations seeking to address compliance issues and build effective compliance and ethics programs. Eric conducts program assessments and examines specific compliance risks, he drafts compliance policies and codes of conduct, works with organizations to build and improve their compliance processes and tools, and provides live training for Boards of Directors, executives, managers and employees.    Eric ran his own consultancy for six years where he advised clients on compliance program enhancements and assisted in creating effective compliance solutions.  Eric was formally the Head of Advisory Services for NYSE Governance Services, a leading compliance training organization, where he was responsible for all aspects of NYSE Governance Services' compliance consulting arm. Prior to joining NYSE, Eric was an Assistant General Counsel of the United States Sentencing Commission in Washington, DC. Eric served as the chair of the policy team that amended the Organizational Sentencing Guidelines in 2010. Eric also spent nearly a decade as a litigation attorney in Houston, Texas where he focused on white-collar and regulatory cases and represented clients at trial and before various agencies including SEC, OSHA and CFTC.     Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers.   Eric Morehead: 30 Years of Innovation and Influence is the subtitle of the recent report issued by the United States Sentencing Commission, but what does that really mean in the context of the organizational sentencing guidelines?   Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host today, Eric Morehead, Director of Advisory Service Solutions at LRN. Today, Kathleen Grilli, the General Counsel of the United States Sentencing Commission is joining us. She's one of the authors of this recent report, and we're going to be talking about how the commission impacts business leaders and the creation of compliance programs across the world. Kathleen is a real expert in this space and is a guest of ours last season where we talked about the seven hallmarks of an effective ethics and compliance program enshrined in the US Sentencing Commission's federal sentencing guidelines. Kathleen Grilli, thanks for joining us again on the Principled Podcast.   Kathleen Grilli: Well, thanks for inviting me, Eric. I appreciate it.   Eric Morehead: The commission just released this new report, The Organizational Sentencing Guidelines: 30 Years of Innovation and Influence. Even after more than 30 years, there are still, I think, at least from my perspective, many people who, when they start their career in compliance, are confused a little bit about why the Sentencing Commission is involved in corporate compliance. Can you talk just a little bit about how the US Sentencing Commission came to assume the role it has regarding compliance standards?   Kathleen Grilli: Sure. You say that people in compliance are confused about it, but the truth is, even in the criminal justice arena where the commission operates... Our guidelines are used in federal courts for sentencing organizations and offenders. Even in that arena, there's not really widespread knowledge about Chapter 8 and the hallmarks for an effective compliance and ethics program. That's because there aren't a lot of organizational cases sentenced every year.   But the reason the commission got into the business of corporate compliance has to do with its statutory mission. The commission was created in 1984 through a bipartisan piece of legislation called the Sentencing Reform Act, and that act did a couple of things as it related to sentencing of organizations. It provided that organizations could be sentenced to a term of probation, sentenced by way of a fine, and it required that at least one of those be imposed. This was something new.   It also subjected organizations to orders of criminal forfeiture, meaning the proceeds of the criminal activity could be taken from them, order of notice to victims, and orders of restitution. That act also created the commission, which is a bipartisan agency and tasked the commission with developing guidelines for use in criminal cases for sentencing. It told us what the purposes of sentencing are, which is just punishment, deterrence, protection of the public, and rehabilitation of the offender. The commission had to decide what to do for sentencing of an organization. Obviously, you cannot put an organization in prison. Unlike individual offenders where sentencing ranges in terms of incarceration are something of the norm, you had to figure out what to do to sentence organizations.   With an organization, as we know, the bottom line is they're in business to make money. In developing the organizational guidelines, the commission came up with its notion that it should use fines to incentivize self-policing. It would punish organizations who were not self-policing or not trying to prevent a crime or commit the offense with certain aggravating factors more severely than those who were trying to prevent and detect crime. That's how we got into the business of corporate compliance.   Eric Morehead: Yeah. And it is interesting that the original writ was from the statute that you examine this. Can you talk a little bit about how the commission got specifically to those hallmarks, those programmatic pieces that we talked about a little bit on our last podcast a while ago? What was the process for the commission to get to those standards, those specific compliance pieces of the puzzle, if you will?   Kathleen Grilli: The commission started its work in 1986 on organizational guidelines with a public hearing at which it received testimony from a variety of witnesses across various different wakes of the world: academics, people in business, government agencies, and the like. Over about a five-year period, because as I said, the Commission started its business in 1986 and didn't actually promulgate the organizational guidelines until 1991. During that period of time, there were numerous public hearings attended by a wide range of witnesses from different areas of the law, academics, government agencies, business owners, representatives of just different industries, and the like. The Commission had these hearings, they heard testimony, the Commission went back and developed drafts with proposals for how organizations would be sentenced. They published those drafts. The process of publishing is really a solicitation for public comment, so they got public comment on the drafts. This went on for a good period of time.   In the meantime, the Commission was doing research. We had academics writing proposals and giving us ideas on how to implement the purposes of sentencing, which again, as I said, were just punishment, deterrents, protection of the public, and rehabilitation. Eventually, it came back to how does an organization get in trouble to begin with? An organization doesn't act alone. We have this theory in the law called vicarious liability where an organization is held responsible for the acts of its agents, meaning its employees. If the employees are the bad actors, everyone finally came to the conclusion that the best way to incentivize or prevent corporate crime was for the organization itself to self-police and to direct its employees and talk about what is and is not appropriate. That's how we ended up with compliance standards.   At the time that they started all this work, compliance and ethics was not widely accepted in the industry. There was a little bit of compliance in the context of antitrust and then there was, in the defense industry, there was an initiative relating to that. Those ideas got floated before the commission and it generated a lot of interest. That's how they started developing the standards.   Again, the standards were included in proposed guidelines that were published and they got public comment and not long before the actual vote where they adopted these guidelines. Even folks who were skeptical about whether this was going to work or not thought that the Commission had gotten the hallmarks of a compliance program right. They thought that they made sense and that they gave sufficient guidance to folks on what would and would not work.   Eric Morehead: That's a really important point too, and I often will say this when I'm talking to people and I talk about my background. Full disclosure, I'm a former employee of the US Sentencing Commission, so I have a strong belief in the mission of the organization. But oftentimes, I will say, "Well, they were first," and part of being first is you've tried different things and maybe you don't know exactly what's going to work and what is going to be successful. But I think over time, and this report really homes in on that, this notion that the direction that the Commission took from '86 to '91 really has paid off a lot of benefits.             One of the conclusions, one of the key conclusions from the report is that perhaps one of the biggest wins for the organization over the years is the widespread of adoption of the guidance and, in particular, the standards for what makes an effective compliance program.   I have a two-parter here. Do you think the Commission recognized in '91 how important that might be? And does the Commission today understand the overall importance of the organizational guidelines, and in particular, 8B2.1, those compliance hallmarks? Did they understand it then and what's the understanding of the Commission now of the relative importance of these?   Kathleen Grilli: Well, let me just back up a minute and just say that the commissioners who promulgated the organizational guidelines in 1991 no longer serve on the Commission. Commissioners have term limits. It's a different group then. It was a different group in 2004 that made the changes that brought ethics into the standards for compliance and ethics programs. As we were talking about before we started this podcast, we have a brand new group of seven new commissioners recently nominated by the President and confirmed by the Senate. You have different folks working on it. I can say that in the process of doing the research for this publication and others that I've worked on in this area, the Commission I don't think ever expected what we see today 30 years later. This widespread influence not only in terms of its use in the criminal justice arena, but how it has impacted other agencies.   And we'll talk about that and the global reach. The Commission itself said, "This is an experiment." They had hopes that it would lead to better actors in the corporate world, but those were hopes and there was a lot of skepticism from the business community when this process was ongoing about whether this was going to work or not. I think we're always blown away when we realize the impact of it, and I say that from a personal point of view, too. Because when I came to the Commission and I've been on the staff for some time, I was not aware of Chapter 8. I had never represented in court an organization, but only individuals.   And the first time I went to a compliance and ethics program where I saw and understood how well received and well regarded and what an impact we had had outside of the criminal justice arena, it sort of blew my mind that I know Judge Murphy and her Commission in 2004 or just before 2004, when they adopted the changes, they learned about it too when they came on board and it sort of blew them away. And I don't know with my current new bosses how well informed they are about this. This is really one of the reasons why, before they came on board, the staff and the then Commission, the one member, Judge Brier wanted to put this report out, memorializing the 30-year anniversary of the organizational guidelines. We're very excited about it, I have to say.   Eric Morehead: No, it is an amazingly effective rubric that the Commission put together and that the Commission is taken a measured approach from my opinion, both in 2004. And then I had an up-close look in 2010 when I was on staff through that process. I think that its impact is pretty incredible 30 years later, looking back.   One of the other things that's incredible... And I talk about new things when you come to the Commission. I had never really paid much attention to sentencing data until I joined the Commission in 2007. And the majority of the actual pages of this report have a lot of really interesting data about the organizations that have been sentenced over 30 years. Some key takeaways include trends that many of us, for those of us who are sentencing nerds, have seen over the years about the impact on small organizations, for example, versus larger organizations, making up the vast majority of defendants in that data set.   To me, a lot of looking for what makes... Because compliance professionals that are listening to this podcast and that are not necessarily interested in sentencing per se, but interested in the sentencing guidelines because of compliance, they're looking for what makes a successful compliance program from sentencing data. To me, a lot of it is what you don't see. It's sort of like looking for... I liken it to looking for a black hole when you're an astronomer. You can kind of tell the telltale characteristics of a black hole existing because of how it affects everything else. And we don't really see organizations that have successful programs in this data. There were just 12 organizations out of those 5,000 or so in 30 years.   Kathleen Grilli: 11.   Eric Morehead: 11. See? I even increased the number. It's just 11 organization out of 5,000 or so, 4,900 and some change, that have ever been deemed to have a successful program. What are some other striking things that you and the team noticed looking over this data and these trends for 30 years?   Kathleen Grilli: Let me just first say what this data is and what it is not so that listeners can understand why they may not find what they're looking for as to what makes a successful compliance program from the data. This data is for organizations, whether it be a corporation, a closely held corporation, partnership, whatever, but organizations that a federal prosecutor has decided to charge and gets convicted of a federal crime. It doesn't include organizations that the prosecutors decide, "Oh, we're going to enter into a deferred prosecution agreement or a non-prosecution agreement." It doesn't include organizations where a regulatory agency has seen that they violated some of the regulations, but they've decided not to proceed against them criminally but to pursue civil adjudications. I mean, in some ways, this data is about the folks that prosecutors decided were the worst of the worst organizations. You don't see what makes a successful compliance program in this data, but I like to say what we do see is that some of the things that the Department of Justice says to you about what they're looking for in deciding whether to prosecute an organization or not might find support in this data. We concluded that the lack of an effective compliance and ethics program might be a contributing factor to criminal prosecutions against organizations. And what specifically led us to that?   Well, in the 30 years that we've been collecting data, overwhelming majority of the organizational offenders in our data set didn't have any program at all, much less an effective program. 89.6%, as you said, as you mentioned and asked me the question, there were only 11 sentences in fiscal year 1992 that got a culpability score reduction for having an effective compliance and ethics program. And I want to stop on those 11 because we went back. Everybody's always interested in what happens with those organizations or why was their program effective? And we were not able to suss a lot of information from the documentation to sort of tell people what it was. There wasn't a lot of descriptive information in the documents we received that would answer that question, but there's only 11 of them. And most of those 11 were very small organizations. It means they didn't have to have a very complex type of program.             More than half, 58.3%, of organizational offenders sentenced under the fine guidelines got a culpability score increase for involvement in or tolerance of criminal activity by upper management would suggest to you. If the management or the substantial authority personnel are in on it, they may well end up sentenced before a federal court. I think that's an important point, too. And very few of these organizations, we'd only saw 1.5% overall that did the three things that get you the maximum reduction off your culpability score, which is self-report, cooperate, and accept responsibility. There were very few organizations, even though there were many that pleaded guilty and accepted responsibility, that actually self-reported. That's important because you hear the Department of Justice talk about why that matters. And this data sort of offers support for the fact that it does.             And then the other thing we saw is that courts are now ordering organizations to implement effective programs in about 20%, one-fifth of the cases that come before them when they impose probation. This was the kind of data that we thought would help fuel the discussion or the debate on the importance of having an effective compliance and ethics program. The other thing you should note about our data, I think it's important too, is that a good percentage of the organizations that have been sentenced over the last 30 years are smaller organizations. It's not large publicly-traded Fortune 500 companies. It's smaller, less number of employees. I think that matters too.   Eric Morehead: That's a trend that I think we've noted in the data, because the size of organizations, the number of employees has been a data point that the commission has released over the years on an annual basis. And by the way, as it's worth mentioning for people who are interested, there'll be a link in the show notes here for this particular report we're talking about. But the Commission puts out data all the time. And at least on an annual basis, there's the Sentencing Commission's Sourcebook on sentencing, which has discussion on organizational cases and includes some of this data. You don't have to wait 30 years to see the trends again. You can keep up with it at the Sentencing Commission website.   Yeah. The small organizations... I think a big surprise to people who have first heard about this because we see the headlines all the time about the Enrons and, I'm going to date myself here, World Comps and Volkswagen and some of the other organizations. Some of those aren't actually even criminal sentences, as you point out. Those are deferred prosecution agreements or civil settlements of some sort, but those are the companies that make the headlines. It's the little guys, small and medium-sized organizations, that take these big hits more frequently than the larger organizations. That, I think, is surprising to people who aren't familiar with the data, but that's a consistent trend throughout the entirety of the enforcement, at least throughout the 30 years that the Commission's been keeping track.   Kathleen Grilli: Yeah. It may change now, given what the Department of Justice said last week.   Eric Morehead: Yeah. You never know. Yeah never know. We'll have to pay attention and then look at the Sourcebook next year and see what the differences are. The other impact beyond our friends at the Department of Justice and the courts throughout the United States is the impact that the Commission and the organizational sentencing guidelines and these standards have had on other enforcement agencies besides the criminal enforcement and also internationally, which I think is very interesting.   Can you talk a little bit... And that's documented in chapter three of this report. The first chapter is talking a little bit about the history. The second chapter is the data that we were just discussing. And then chapter three talks about how the USSC has encouraged other enforcement agencies and regulators to focus on good governance and compliance. Can you discuss a little bit about what the team found when you researched that?   Kathleen Grilli: Yeah. I think that using the word that the USSC has encouraged suggests that there's some sort of active work going on by the Commission. Let me just say that I don't think that is a fair statement. The Commission did its work and let its work speak for itself, and it has sort of spread throughout regulatory agencies and/or the globe just because it makes sense, I think. Anyway, that's my personal opinion. But I made reference to the Department of Justice, and so I'll start with a Department of Justice if I could.   The Attorney General, where it's his designee is an ex-officio member of the Commission, a non-voting member. Obviously, the Attorney General Department of Justice were actively involved in the development of the chapter eight itself and then the subsequent amendments in 2004 and 2010. But you see the impact of the guidelines in their evaluation of corporate compliance programs and all of the information that they release and discuss on how they focus on compliance in deciding how to prosecute an organization.   Just last week, the Deputy Attorney General, Lisa Monaco, talked about changes that they're going to make. There was sort of an oblique reference to our data, which is that there's been a drop in corporate prosecutions that we see in the data. I think there were less than a hundred last year, and they talked about sort of reversing that trend and looking at that, that the department thinks this is important. And they've placed a lot of importance recently on compliance programs because she said companies need to actively review their compliance program to ensure that they adequately monitor for and remediate misconduct or it's going to cost them down the line.   Kenneth Polite, who is the... I think it's Assistant Attorney General of the Criminal Division. He's a former chief compliance officer and they've made a lot of emphasis in the department on active review of programs and true independence for the chief compliance officer. That's the Department of Justice who obviously are actively involved in using the guidelines in federal courthouses, but then you have other regulatory agencies.   I'm going to run through them real quick and just say the SEC, HHS, EPA, FERC, which is Federal Energy Regulatory Commission, and the FAR all have requirements built into them about compliance programs. And most of them say that they're looking to the guidance on the guidelines. Some of them adopted them full scale, some of them may have modified them a little bit. And all of that came after chapter eight in 1991. All of those agencies look to the guidelines.             And then we see that if you look internationally at what's happening around the world in terms of anti-corruption, anti-bribery, and all the like, that elements of the hallmarks for an effective compliance and ethics program found in the guidelines are making their way into legislation, into programs, into initiatives that foreign governments are releasing. And I can't even keep track of it, truthfully, but it seems to be coming up more and more and more.             When the Commission promulgating the guidelines in 1991, they described them as an experiment. We wanted in this publication to sort of show, did the experiment bear fruit? And I think all of that suggests that it did. These changes and everything that goes back to those original seven steps laid out in the guidelines and elevated in 2004 to give them a little more prominence. It really is very, very exciting. I feel bad. I sound sort of like I'm patting myself on the back, and so I want to make it really clear to the listeners. I was not on this staff in 1991. I wasn't working on this. I did not have anything to do with the 2004 amendments. I came into it after the fact, but it's just really exciting to see it and to see the impact and how well regarded the Commission's work is.   Eric Morehead: No, I think that's right. I think the report really sums up what I think a lot of us have felt. Again, I'm probably biased, but a lot of us have felt this way for a while, that the standards, really, have set the bar and provided kind of a North Star for compliance programs for that whole generation, that whole 30 years. And it's made a difference in millions of people's daily lives in their working lives, because it affects how their company operates for the good or for the bad. And that really makes all the difference to us. I think you guys can successfully pat yourselves on the back a little bit.   Well, last thing, again, knowing that we're talking to a lot of compliance officers who hopefully have, if they're new, have a little bit more appreciation as to why the US Sentencing Commission is involved in their lives, are there other takeaways from the research and work that the team put into this report that you think are particular importance for compliance professionals or things they should be aware of? Kathleen Grilli: Well, one of the things that I hear when I intend conferences and one of the things that I think folks [inaudible 00:26:26] is the fact that there's not enough investment in compliance. The bottom line in business is money and making money, and you can't necessarily provide metrics that show how your work is going to add to the bottom line. Then it's hard to make the case. Now, I know these days, in recent years, folks have come up with ways to measure how compliance and ethics does contribute to the bottom line, and I really believe it does. But this data can offer you the picture of what happens if you don't.   Eric Morehead: Yeah.   Kathleen Grilli: Because since 1992, courts have imposed nearly $33 billion in fines on organizational offenders. The average fine was over $9 million. Although the median was a little lower, it was only $100,000. But for a small mom and pop organization, a hundred grand is a lot of money. And the other thing is that courts will sentence organizations to probation. Over two thirds of the organizational offenders in the last 30 years have been placed on probation with an average term of 39 months, where you're going to have to be reporting to a probation officer and complying with all these requirements. And that's time consuming and costly, too, when you think about it. There's a little bit there that can answer the mail in terms of why am I going to invest in compliance and ethics.   Eric Morehead: I'm a big believer in making the positive business case, but you also need to make the "everybody's going to go to jail" case too.   Kathleen Grilli: Well, especially in light of the recent guidance that the Department of Justice, I mean, where they're going to be looking at individuals and they're going to be requiring organizations to give up all individuals who might be involved, I think that's something that folks should keep in mind as well. It's important because it's not just going to be the company, it's going to be the employees too.   Eric Morehead: Yeah. And again, that's important data. That's in chapter two of this report, that over 50% of the time over the period, you've got at least one living, breathing human being who's also faced charges consistent with the charges that the organizations faced. It includes actual human beings in this process, not just the organization.   Kathleen Grilli: I think we're only going to see an increase if the department's guidance holds true that those numbers may go up.   Eric Morehead: Yeah. We'll have to check. We'll check in next year after the Sourcebook comes out and see if the trend has moved. Kathleen Grilli, it's been a tremendous honor again to have you on our podcast and really appreciate you taking the time.   Kathleen Grilli: Oh, it's an honor for me to be here. Thank you so much for inviting me.   Eric Morehead: No problem. My name is Eric Morehead and I want to thank all of you for tuning in once again to the Principled Podcast by LRN. Outro: We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us lrn.com To learn more. And if you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen, and don't forget to leave us a review.  

Hello, and welcome to this week in financial crime. I'm your host, Chris Kirkbride. As ever with financial crime, there is always decent range of stories to ensure that things never get boring. A little bit on sanctions, but I still cover it first. Secondly, some interesting cyber initiatives announced, together with some announcements relating to combatting financial crime from a professional body and the DoJ in the US. And, we end this week with some bits and pieces on money laundering. These are the links to the principal documents mentioned in the podcast:Council of the EU, Russian aggression against Ukraine: EU individual sanctions over territorial integrity prolonged for a further six monthsDraft The Sanctions (Damages Cap) Regulations 2022EU Council Implementing Regulation (EU) 2022/1501 of 9 September 2022 implementing Regulation (EU) No 208/2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in UkraineFinancial Action Task Force and INTERPOL Joint Asset Recovery InitiativeInternational Federation of Accountants (‘IFAC') and International Bar Association, Action Plan to Tackle Economic Crime and CorruptionJoint Committee of the European supervisory authorities (European Banking Authority, the European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority) this week issued their Autumn Joint Risk ReportOFSI Russia Financial Sanctions NoticeOFSI DPRK Financial Sanctions NoticeUS DoJ speech by Lisa Monaco at NYU

What you'll learn in this podcast episode What is top of mind with board directors when they think about corporate culture, ethics, and compliance? How can leaders best assess culture in the companies they oversee? In the season 8 premiere of the Principled Podcast, LRN Director of Advisory Services Emily Miner is joined by Dr. Marsha Ershaghi Hames and Dr. Eric Baldwin at Tapestry Networks to discuss how board members can improve oversight. Listen in as the group shares insights from Tapestry Networks and LRN's joint report Assessing Corporate Culture: A Practical Guide to Improving Board Oversight, which draws from a working group of nearly 40 directors and executives representing over 60 public companies. Principled Podcast Show Notes [0:29] - Emily welcomes listeners to this episode with Marsha and Eric of Tapestry Networks.  [1:46] - A discussion on the recently published report, “Assessing Corporate Culture: A Practical Guide to Improving Board Oversight.” [6:14] - Why the report offers a practical framework and what needs it seeks to address. [9:59] - The key findings or pillars of the report. [15:22] - How the report helps leaders answer “How?” questions. [20:30] - What is the potential broader impact of the report?   Featured guest: Dr. Eric Baldwin Eric Baldwin is a principal at Tapestry Networks, working with teams in the firm's corporate governance and financial services practices. Prior to coming to Tapestry, he served for several years as a research associate at Harvard Business School (HBS), where he collaborated with faculty on a variety of research and writing projects covering topics ranging from organizational culture and change management to corporate strategy and healthcare policy. Prior to his time at HBS, Eric taught in the religious studies departments at Franklin & Marshall College and Boston University, while earlier in his career he served in engineering and operations roles at ON Technology Corporation, a software development firm based in greater Boston.  Eric holds a PhD in religious studies from Boston University and a BA in history from the College of William and Mary.   Featured guest: Dr. Marsha Ershaghi Hames Dr. Marsha Ershaghi Hames is a partner with Tapestry Networks and a leader of our corporate governance practice. She advises non-executive directors, C-suite executives, and in-house counsel on issues related to governance, culture transformation, board leadership, and stakeholder engagement. Prior to joining Tapestry, Marsha was a managing director of strategy and development at LRN, Inc. a global governance, risk and compliance firm. She specialized in the alignment of leaders and organizations for effective corporate governance and organizational culture transformation. Her view is that compliance is no longer merely a legal matter but a strategic and reputational priority.  Marsha has been interviewed and cited by the media including CNBC, CNN, Ethisphere, HR Magazine, Compliance Week, The FCPA Report, Entrepreneur.com, Chief Learning Officer, ATD Talent & Development, Corporate Counsel Magazine, the Society of Corporate Compliance and Ethics and more. She hosted the Principled Podcast, profiling the stories of some of the top transformational leaders in business. Marsha serves as an expert fellow on USC's Neely Center for Ethical Leadership and Decision Making and on the advisory boards of LMH Strategies, Inc. an integrative supply chain advisory firm and Compliance.ai, a regulatory change management firm. Marsha holds an Ed.D. and MA from Pepperdine University. Her research was on the role of ethical leadership as an enabler of organizational culture change. Her BA is from the University of Southern California. She is a certified compliance and ethics professional.   Featured Host: Emily Miner Emily Miner is the Director of Advisory Services at LRN's Ethics & Compliance Advisory practice. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN's ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.     Principled Podcast Transcript Intro: Welcome to the Principled Podcast brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Emily Miner: What is top of mind with board directors when they think about corporate culture, ethics and compliance? How can leaders best assess culture in the companies they oversee? Hi, and welcome to another episode of LRN's Principled Podcast. I'm your host, Emily Miner, director of advisory at LRN. And today I'm joined by Dr. Marsha Ershaghi Hames and Dr. Eric Baldwin partner and principal respectively at Tapestry Networks. We're going to be talking about corporate culture and how board members can improve oversight. Marsha and Eric have just collaborated with us at LRN on a report entitled, "Assessing Corporate Culture: A practical guide to improving board oversight." The report presents insights from a working group of nearly 40 directors and executives representing over 60 public companies, including some of the largest companies in the world: Cigna, Sony, McKesson, Lockheed Martin, CDW, Coca-Cola, Excel Energy and Palo Alto Networks included. Marsha, Eric, thanks for joining me on the Principled Podcast today. Marsha Ershaghi Hames: It's great to be here. Eric Baldwin: Thanks for having us, Emily. Emily Miner: Okay, so let's jump right in. This report, a guide really, assessing corporate culture is the result of working group sessions of the ethics, culture and compliance network. Marsha, let me start with you. What is the ECCN, who are its members, and how did it come to be? Marsha Ershaghi Hames: Sure. Great. We're happy to continue to share the Ethics Culture Compliance Network progress. This network was founded in the summer of 2020. I mean, it was during the thick of a pandemic. Companies were spiraling. It was just a lot of crisis management and companies were starting to take a real reflective step back. They were assessing where do we need to look? How do we need to assess our planning for longer term future? And the conversation emerged initially, Emily, as a forum. It was a safe space to convene. Public company directors and senior executives, namely chief ethics and compliance officers, to really start exploring values, corporate culture and the role of ethical decision making in business. Emily, if I can highlight just a few key aspects that the stakeholders of ECCN started to really prioritize over the last two years, number one, the need for boards and executive teams to align and articulate culture so that management feels supported. Number two, to address the challenge of getting ethics and culture on board agendas and to really promote directors going deeper with management, we're going to get to shortly. Number three, ECCN stakeholders have continued to really want a forum to share peer to peer examples, pragmatic examples of the need for better communication and greater transparency between the CECO, the broader management team and the board. Emily Miner: Thanks, Marsha. Having sat in on some of these sessions, I know that those specific examples that you just alluded to, those were among some of the most powerful conversation prompts. So I think that the members got a lot of value out of that. I certainly know I did. And so this report builds on a report that we, Tapestry Networks and LRN, collaborated on last year, activating culture and ethics from the boardroom, which was a really insightful temperature check on board's attitudes about culture. Eric, can you talk about that project and how it led to this latest one? Eric Baldwin: Sure. With the last year's activating culture report, we had set out to understand the realities facing boards and their oversight of ethics and culture. What were their key concerns, the challenges they face, current practices. So to get at that, we interviewed 40 directors who occupied about 80 seats on public company boards with the aim of getting a really broad view of board oversight of ethics and culture. What we found was a pretty diverse range of practices across boards, in terms of what kinds of information they were receiving, their engagement with their management teams, including how often they heard from their chief ethics and compliance officer, a range of assignments of committee responsibilities and really it's just a variability and how much attention the issues get from boards. We also found a real lack of comfort among directors. So directors recognize the importance of culture and the risks associated with ethical lapses or with unhealthy cultures, but recognize that their ability to oversee culture doesn't have the level of clarity and rigor that you find in other aspects of board oversight, like say financial reporting. So there's a real gap between the seriousness of the risk associated with culture and the importance of culture on the one hand and director's sense of their ability, or lack of ability, frankly, to effectively oversee that set of issues. So given that, it seemed crucial to start to develop some board-level tools and practices that could help directors make their oversight of ethics and culture more robust. Emily Miner: Thanks, Eric. I know that this latest report traces its roots back to those earlier insights that you were just describing and the need for a practical framework that board members could adopt. Tell us why this framework and the specific needs it seeks to address. Marsha Ershaghi Hames: Yeah. So maybe I'll take that one. So to Eric's point, we have conversations with 40 directors in 2021 and coming out of it, it was the spirit of action. How can we now take action? So the consensus was, we want a simple, practical framework to start to advance a conversation, just get the conversation started. Think of it like a simple roadmap. How can we take this into the boardroom? How can we start to connect with management with simple prompts, questions. Help us organize our thoughts about how to activate and get the conversation started. Then, another goal was the input was we want to have a peer-reviewed framework. We don't want a treatise. We don't want a commission study by a third party. We want to be a part of driving the frame for what we think will have the greatest impact, both within board rooms and for the boards to explore directly with management. Emily Miner: You've talked a little bit about the approach to developing the framework, talking to the 40 directors and the peer-to-peer nature of it. What else about the approach of how the framework was developed, do you think contributes to the power of what it ultimately offers to boards and management teams? Eric Baldwin: Yeah, I can jump in here. As Marsha noted, we really wanted this to be as useful and practical for boards as possible so we thought it was really important that it'd be grounded in the experience of directors. We knew that there was a lot of good practice already going on in boardrooms. So if we could tap into that collective knowledge and pull that together, it could be really valuable. So the way we went about that was to recruit and convene a working group of about 12 to 15 members, 10 of whom were sitting public company directors. Several of those directors are current or former chief ethics and compliance officers so they've got deep experience in that space that they bring into the boardroom. We also included a couple of sitting senior ethics and compliance executives who report into boards on these matters on a regular basis to bring their perspective, as well as our colleagues from LRN, who brought their expertise in culture measurement. So, we brought the group together several times for virtual discussions, for peer exchange, to really surface the challenges and gaps that they're experiencing, to share and vet existing practices and tools and identify some key insights and good practices that are already going on. So out of that, our team developed a draft framework, which we shared then with a larger group of about 40 directors and ethics and compliance executives to pressure test our recommendations and get additional feedback before publishing the piece this summer. So I think what really gives it its power is that it's grounded in the experience of the boardroom, it's peer developed and peer vetted and rooted in the efforts of directors and practitioners. Emily Miner: Yeah. Thank you, Eric. And just to underline something that both you and Marsha shared, I think something that's so compelling about it in terms of being grounded in that experience is, as you mentioned, many of those directors are current or former chief ethics and compliance officers. So being able to hear from people that have worn both of those hats or are wearing both of those hats, I think is so powerful. So let's keep on talking about the framework. What are the key findings or pillars? I know that there are five pillars of the framework and I'd love for you to expand upon those five pillars for us. Eric Baldwin: Yeah. I'm happy to try to do that. There's a lot of insights there, so I'll try to be brief. As you mentioned, there are five key themes here, and we see them not so much as a series of steps, but more as sets of interlocking practices or that can mutually reinforce each other. So briefly, the first is really just to make ethics and culture a priority. We've heard from directors that culture and ethics often don't get enough time and attention in the boardroom. They get pushed to the bottom of crowded board agendas. So a key step is simply just to ensure that they get priority on the agenda, that they get enough time and attention. It's really crucial. We heard that boards communicate to management that culture and ethics are priorities, which they can do by pushing for information, asking questions, following up, probing. Management needs to know that ethics and culture are board priorities. The second is for boards to take a look at their own culture. Boards have their own internal cultures and the culture of the board influences the culture of the organizations. They sort of set the tone from the top. But directors tell us that boards don't often examine their own cultures in a rigorous way. So it's really important for boards as one member put it, to take a hard look at their own culture. In this, it's especially important for boards to assess their openness and transparency and the level of trust, both among the directors and between the board and the management team, and especially their willingness to hear difficult news and how the board responds to bad news or to hard truths. A key element we heard of ethical culture is trust and transparency and to foster an environment where bad news travels fast. That starts with the board and the board's willingness to hear bad news. The third is the challenge of being able to articulate the elements of culture and really to describe and articulate the culture you're aiming at, what you want to see in your corporate culture. The challenge here is that culture can be a very fuzzy and abstract concept. It's implicit, it's unspoken rules and norms, and that makes it really hard to measure and assess. So anything boards and management teams can do to make discussions of culture more concrete and precise will really help. This can mean breaking down ethical culture into various components, things like trust, willingness to speak out, fairness, organizational justice, so that boards and management teams have a clear answer to the question, "When we talk about culture, what exactly are we talking about?" A key insight here was the importance for boards to be active partners with their management teams in defining and articulating the attributes of a desired ethical culture, rather than just sort of hearing them from management. Contributors told us that the process of defining what a good culture looks like by fostering a robust and structured discussion of culture is as important as the outcome. So boards need to be involved in those discussions early, rather than just the management team coming to them and saying, "Here's what we think our culture should look like." The fourth is really about the tools that they use to measure and monitor culture. This is all about information and data and how it comes to the board. There's a pretty common range of data and information sources that boards depend on and there's plenty of data. But the key is for boards to get that information presented to them in the right way so that it has enough context that it can really make sense to them. So one key issue for boards we found is to push their management teams to report to them in such a way that insights from a range of data sources are integrated into a coherent picture or narrative. So survey data or data from culture surveys is overlaid with safety data, turnover data, and cost of hotline for example. Boards are really looking for a more integrated view from their management teams. Anything that will help generate a narrative or surface patterns that help boards know where they need to follow up and probe and potentially allocate more resources is really helpful. Then finally is the issue of establishing clear communication lines. There's a lot of information relevant to culture that comes from a lot of different functional areas bearing on ethics and culture. So boards need to push their management teams to be able to develop a holistic view and really ask the question who, if anyone, in the management team owns culture and owns reporting on it and can give a really coherent and holistic view of culture. The same goes for the board. At the board level, different committees on the board, get reporting from different management teams and information can become siloed. So the key question is how can boards overcome that tendency and make sure that the entire board is getting a full picture of culture. Emily Miner: Thanks, Eric, you did a great job of covering a lot of detail, very succinctly so I appreciate that. You framed a lot of those pillars in the form of a question: so how can boards do this, how can boards and management team collect the right data and interpret it together and break down those silos, et cetera, so I want to go into those hows a little bit because we call it a practical guide. So how does that manifest? How can this guide, I'll call it a guide and not a report, how can this guide help boards in their oversight of culture? Marsha Ershaghi Hames: Yeah, so Emily, maybe I'll jump in on that one. So to Eric's point as he went through these five key pillars and big insights or meta themes that jumped out, each pillar is supported with countless examples, practical scenarios, and we've even lifted up some direct quotes that came from all of the contributors. So part of this is practically speaking, we want to help agitate that curiosity from the directors. We want to encourage them, look behind the numbers, start asking some of those uncomfortable questions. We wanted to give them, when you talk about sort of manifesting, how do we give directors a simple roadmap or framework to go into, to start within their own boardrooms, and then to look at opportunities to connect and communicate with management, to build that bridge, to forge an ongoing dialogue. So this is not an overnight put your hero cape on. This is to start to create essentially more of that accountability partnership, a dialogue between management and the board and framing it in these five buckets. So it's, step one, are we even prioritizing this? So that can be a series of conversations. Step two, have we aligned as a board and management team? Have we been engaged as a part of articulating and assessing and understanding what is that desired culture? Are we as a board reflecting? So as Eric was going through these, it's you need to have a roadmap essentially to start agitating some of that dialogue. We wanted these pillars to become levers to begin that process to engage with management. Emily Miner: I love the way that you are framing this as agitating the dialogue. There's such a great mental, descriptive image. So thank you for that, Marsha. I know that one of the features of the report or the guide to help agitate that dialogue is a series of questions that can serve as a starting point for this dialogue with management teams and within boards. Can you share some of those compelling prompts? Eric Baldwin: Yeah, I'd be happy to give some examples. I think questions for boards are really a key tool in their tool belt. One of the things that boards are expected to do is offer a credible challenge to management, and it's really through asking questions that they do that. So we did include a number of questions, I think they're probably more than two dozen appended to the end of the report. I will not read anything like all of them at this point, but I'll give you a couple of examples of some of the questions that we include in the report. Again, many of them line up with some of the key buckets that we identified above. One would be just to ask yourselves as boards, have we identified the cultural attributes and behaviors that align with our stated values and our purpose? How can we effectively articulate the culture we're trying to achieve? This in turn would guide management's efforts to measure culture. Another question for the board to reflect on is, does our culture, that is the board's culture, encourage management to share those difficult truths with us? How open to debate and disagreement is our board? Then we also include some questions that boards can ask their management teams. One is to simply ask, to what extent can you provide the board with an integrated view that incorporates information from a range of sources of data into a single picture for us? How can you give us an integrated view of culture? Then another question for management is, are you able to communicate directly to the board when necessary? Do you feel you have the necessary independence to bring issues and questions to the board? So those are just a few examples of a number of questions that we've included in this report. Emily Miner: Thank you. I think that's another feature of the practicality of this. I mean, boards can in some sense sort of lift these questions up and apply them in their own contexts. So recently LRN's Ty Francis, our chief advisory officer had a conversation with Tom Fox, who I think we all know as the voice of compliance and founder of the Compliance Podcast Network. Tom called this report prescient more than once and cited both recent statements of Lisa Monaco, deputy attorney general, and rulings of the Delaware Supreme Court about the need for boards to take a more active role in monitoring and measurement. So with those statements, that context, occurring around the same time as the release of this guide, what do you see is the potential broader impact of the guide, the framework with the five pillars, the practical examples and discussion prompts? What do you see as the potential impact of that? Marsha Ershaghi Hames: So maybe I'll take the lead here and, Eric, if you want to share any other thoughts ... But if we take a step back, this came up in ... so we had a summit, Emily, that you, of course participated in, where we brought together all of the Ethics Culture Compliance Network contributors, not only of the report, but other key stakeholders. It was interesting, a few people pointed to this and they said that if you look at the foundations of corporate scandals over the last few decades, there's a pattern that points to the failure to speak up and a correlating fear of retaliation. So it's that notion of someone always knows what's going on. Right? So when you look at the statements of Lisa Monaco and the Delaware Supreme Court about boards taking a more active role, you have to take a step back and look at what is the role that boards can play to encourage and drive a culture that is more transparent and more open. How can a board activate open dialogue? How can a board establish a more transparent tone. We know, there's enough research around this, that culture's fundamental to business and tone at the top matters. I could even say, and Emily, you and I have collaborated, full disclosure, over years in my consulting days. I saw this. I can just draw anecdotally that in 22 years of consulting, I would come across so many compliance executives who just felt like, "Hey, is my company going to make the investment in my team, and are they going to prioritize culture?" CECOs, they're under a lot of pressure to operate as a resource, enforce policy, developed policy. They're regarded as the primary architects of culture, but oftentimes we're also labeled as a cost center. So some of this stuff has been coming out as you know, Emily and Eric, and our conversations around like, "Are we leading on this or are we in a reactive mode?" So I would say in terms the broader impact of this framework, it's the notion of how can we be proactive? How can we put a framework and a roadmap in front of the board to agitate the curiosity, to ask for more data behind the numbers and to empower boards and management teams to get the conversation started. To Eric's point, it's like, is it a toolbox? Is it a tool set? Well, yes, it is. It's been pressure tested by peers. It was developed by peers. They're trying it in their own boardrooms. Some of these stakeholders are current or former chief ethics and compliance officers so there's an appreciative inquiry of the tensions on both sides of the table. So in my opinion, I really forecast that this is going to have a catalyzing impact on the industry. Eric, I don't know, thoughts on your end too. Eric Baldwin: No, I would just say, I think one of our hopes here is that as directors bring this into the boardroom and, Emily, you're right to point out that it does seem like the expectations for boards in oversight in this area are going nowhere but up. It is our hope that this is a tool that helps them meet those heightened expectations. But also that it's only a starting point, that boards will use the tools in this framework to get the conversation started and come back to us with further recommendations of what would be additionally helpful to assist them in their oversight here. Emily Miner: Well, I, for one look forward to following along and participating and seeing what the impact is and how this framework is used and what the feedback is from those that use it. Marsha, Eric, it has been such a delight speaking with you today about the genesis of this report and all of the insights assembled from such a stellar working group. We're out of time for today. But for those listening, if you're interested in learning more about the report, the framework, et cetera, please look at the link in the podcast description. My name is Emily Miner, and I want to thank you all for listening to the Principled Podcast by LRN. Outro:  We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN our mission is to inspire principled performance in global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us at lrn.com to learn more. And if you enjoyed this episode, subscribe to our podcasts on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen. And don't forget to leave us a review.  

President Trump continues to expose the swamp and the traitors that protect it. And the recent fbi move against President Trump has shown that there is a small group of traitors inside the fbi and they are using their position to try and get President Trump in some kinda of trouble so he can't run for President. This is continuation of what Schiff for brains, pos Pelosi, and others did while President Trump was in office, wasting our time and money creating fake stories to discredit while in reality showing the world that they are criminals. ________________________WE THE PEOPLE are at war with the deepstate criminal cabal!!!Turn off your tv, radio, and stop listening to paid professional liars spreading propaganda.***SUPPORT Independent Free Speech Reporting***NEO420 = News Intelligence Entertainment- Real News + Real Information- Here is our direct Paypal account.https://www.paypal.com/donate/?hosted_button_id=URXRDL6AJ8H7GThank you for the SUPPORT & SHARING the TRUTH!!!Go to GOD for discernment and wisdom.Know the Truth as the Truth will make you free! (John 8:32)___________________________Listen and learn as we have an extensive coverage within our reporting and analysis.  The link is here http://neo420.com/talks-podcast/The link to our video channel is here. https://odysee.com/@NEO420TALKS:4The Viral Delusionhttp://www.theviraldelusion.com/IT IS TIME FOR WE THE PEOPLE OF THE WORLD TAKE DOWN the criminal cabal. WE know who they are, and now it is time to bring them to JUSTICE!!!_______________________________NEVER FORGET!!!9/11 was a day that global*cabal*conspired to take our freedoms!!!Rumsfeld admitted $2.3 Trillion missing from Pentagon.  https://odysee.com/@NEO420TALKS:4/rumsfeld-2.1Trillionunaccountedforb-ccriminalsstoleit:7Planes did NOT bring down the two towers.AE911Truth.orgGeorge Bush Sr was CIA director before being Vice President then President. MANY are a part of this crime against US.Towers that fell:-Building 1-Building 2-Building 7 (seldom reported even though BBC reporter reported building down before it happened) https://www.youtube.com/watch?v=J0VFMqinkcsSupport the show

Three women close to Obama are causing pain for Trump and the American people from inside the Biden regime.

Falangen mot Trump har tilsynelatende hatt initiativet. Nå rakner det. Budskapet fra velgerne i Wyoming var ikke til å ta feil av. Liz Cheney hadde den frekkhet å påstå at hun lett kunne vunnet hvis hun også hadde støttet Trump, men det ville hun ikke. Det var jo hele poenget. Velgerne strøk henne fordi hun ikke ville stå for hans politikk, men kun var opptatt av å ødelegge politikerne eliten hater. Cheney sier hun kunne vunnet hvis hun ikke var Cheney. Nettopp. Hun ville ikke. Hun trodde det lå en fremtid i å bekjempe Trump. Lykken smiler til Trump. Det spør om Garland og Biden tør å gå løs på Trump med denne beskjeden fra velgerne. Ønsker de å tape i november? Det er forresten ikke Garland og Biden som styrer, det er Susan Rice og Lisa Monaco, begge Obama-håndlangere.   Hvis du setter pris på sendingene: Vipps oss på 63 89 41. Alle bidrag hjelper. Lag en konto på Odysee her! – Odysee vil da gi oss poeng som hjelper oss å klatre i algoritmene! Følg oss på Rumble. Følg oss også på PodBean, iTunes og alle steder der podcasts finnes. Husk å rate oss med 5 stjerner, så flere likesinnede sannhetssøkere finner oss der! Kjøp «Et varslet energisjokk» her!

Questions continue to swirl over the FBI's raid on former President Donald Trump, with suspicions being raised that the raid may have been driven by intelligence community fears that Trump possessed potentially damaging and incriminating information relating to the Russiagate hoax. During an impromptu DOJ press conference last week, Garland stated that the DOJ had filed a motion to unseal the search warrant used in the FBI's raid of Trump—which we now know was extremely open-ended, and not tightly focused as Garland had indicated. Notably, the affidavit, which is far more important and informative, will remain sealed. Garland also admitted during the press conference that he “personally approved the decision to seek a search warrant.” In reality, Garland is not much more than a figurehead, installed by the Biden regime with Lisa Monaco, the deputy attorney general, pulling the true strings of power behind the curtains at the DOJ. ⭕️Watch in-depth videos based on Truth & Tradition at Epoch TV

On Wednesday's Mark Levin Show, President Biden is still silent on the Mar-A-Lago raid and the FBI director is in hiding. Newsweek reported that the raid was from a confidential human source. Trump's attorneys had met with the DOJ in June at Mar-A-Lago where the feds advised Trump to keep any classified documents behind a locked door. One DOJ leaker says that conducting the raid when Trump was out of town was done to minimize the spectacle of it. This is false, a raid conducted at dawn on a former US President would not go unnoticed. Then, under the plain view doctrine, law enforcement doesn't need to include every element they are investigating in a warrant. Therefore they say it's about presidential records, but it's likely that they are interested in anything they can find. It was not routine for lawyers to not be present during the raid or for the FBI to search the former First Lady's wardrobe. Later, the DOJ has charged a member of the Iranian Revolutionary Guard for plotting the assassination of former Secretary of State and former National Security Advisor. Why is the Biden Administration still negotiating with Tehran if they are committing acts of war against this country? Afterward, reporter Julie Kelly calls in to discuss how several January 6th detainees have killed themselves seemingly because of the pressure. Kelly also mentioned how a former Obama staffer, Lisa Monaco, was involved in the Russia hoax known as Crossfire-Hurricane and is thought to be pulling strings with DC US Attorney Matthew Graves on the Trump raid.  Learn more about your ad choices. Visit podcastchoices.com/adchoices

In this episode of the FCPA Compliance Report, I am joined by Mary Inman, partner at Constatine Cannon. We look at recent developments in whistleblowing and how the Ukraine War has increased the visibility of whistleblowers. Highlights of this podcast include: Whistleblower Reward Program at the US Treasury Department/FinCEN – what is its relevance to corruption, anti-money laundering and the Ukraine conflict. The House Committee on Financial Services voted to strengthen the U.S. Treasury's Anti-Money Laundering (AML) whistleblower program. What does this mean for this nascent program? How does a minimum whistleblower reward threshold, whistleblower incentives and injects more certainty into the Anti-Money Laundering whistleblower program. How has expanding AML whistleblower rewards to cover laws applicable to Russian sanctions, Congress enlisted the help of the private citizenry. Lisa Monaco recently spoke about the government relying on corporations to ID instances of money-laundering and other activities to help enforcement Russia economic sanctions and broader trade sanctions. Are private citizen or other whistleblowers as a key component of this fight? How has the Ukraine War raised the profile of whistleblowers and whistleblowing? Starting with SOX, then Dodd-Frank and the AML Law of 2020 has the US government began to understand whistleblowers as a key component in the fight against fraud, waste and abuse. Has the government embraced these same strategies and tactics in the wider fight against corruption? Tribute to Chuck Grassley for his advocacy of whistleblowers.  Resources Mary Inman on Constantine Cannon website Learn more about your ad choices. Visit megaphone.fm/adchoices

Earlier this month, Deputy Attorney General Lisa Monaco spoke at the University of Chicago's Institute of Politics about the role of the Department of Justice in a time of intense partisan division. She discussed the rule of law, impartiality, institutional reform at the Justice Department and more. The audio for this event was provided by the University of Chicago's Institute of Politics. See acast.com/privacy for privacy and opt-out information.

Archegos Felon in Possession of a Family Office Blues by Matthew Russell Lee, April 30, 2022 He was felon in possession of a family office Archegos' use of swaps had gotten a bit too raucous 34 billion dollars later, they let him out on bail Unlike a luckless Bronx junkie not a single day in jail So who is it, making these big decisions Letting Hwang go and subjecting the junkie to derision? Then expecting applause and silence on disparity Putting the Bronxites in jail and throwing away the key? Credit Suisse and Nomura, they must have been in on it The underregulation of the family office has become somewhat chronic Congress talks but nothing done, the scam was used in One Coin Bill Hwang out in Tenafly eating a big sirloin Support https://www.patreon.com/MatthewRussellLeeStory: http://www.innercitypress.com/sdny2archegosicp042722.html After SDNY Indicts Hwang For Archegos $34B Fraud Freed For $5M Cash With Tri-State Travel By Matthew Russell Lee, Patreon Maxwell Book BBC-Guardian UK - Honduras - ESPN NY Mag SDNY COURTHOUSE, April 27 – In the wake of the Archegos meltdown, the other shoe dropped on April 27, when the US Attorney for the SDNY unsealed and indictment charging Bill Hwang Patrick Halligan, Archegos's CFO with racketeering conspiracy, securities fraud, and wire fraud offenses. Inner City Press went to the SDNY press conference to ask, What about Credit Suisse and Nomura and people in those banks? What about the massive family office loophope to the Investment Advisors Act of 1940? This has come up in the OneCoin fraud case, on which the Office used perjured testimony and now agrees to delay after delay. Damian William referred obliquely to Hwang doing it in the dark, but otherwise the issue - which is addressed by a pending bill in Congress - did not come up. Nor did Lisa Monaco, present in New York for the presser, address it. Later, release: SUNG KOOK (BILL) HWANG The defendant will be released today upon his own signature to $100 million personal recognizance bond, to be secured by $5 million in cash and 2 properties, and co-signed by two financially responsible individuals, including his wife. The defendant agrees to attest that he lost his passport and his wife will surrender her passport. Travel will be restricted to the SDNY, EDNY, District of Connecticut, and District of New Jersey. Mr. Hwang will be released today on his signature, with remaining conditions to be met by May 6. Co-defendant PATRICK HALLIGAN The defendant will be released today upon (i) $1,000,000 personal recognizance bond; (ii) co-signed by two financially responsible persons, one of them being his wife; (iii) travel restricted to EDNY and SDNY; (iv) regular pre-trial supervision; and (v) surrender of passport (which has occurred). Meanwhile later - after re-up of book and talk to NYU Journalism School, here and here - in the SDNY Magistrate a defendant was detained until trial, charged as a felon in possession. We'll have more, much more, on this. *** @SDNYLIVE courthouse #CourtCastCast 200 Worth Street Your support means a lot. As little as $5 a month helps keep us going and grants you access to exclusive bonus material on our Patreon page. Click here to become a patron.

As the Celtics win Game One with a buzzer beater, Tom and Jay are back to look at some of the week's top compliance and ethics stories in the NBA playoffs are here edition. Stories 1.     Mike Volkov takes a deep dive into the recent DOJ trial record. In a 3-part series on Corruption Crime and Compliance. 2.     Sexual harassment case too implausible for Hollywood? Adam Manno in the Daily Mail. 3.     KT Corp FCPA enforcement action analysis. Lawyers from Debevoise in Compliance and Enforcement.  4.     Stericycle FCPA settlement. DOJ Press Release. Harry Cassin the FCPA Blog. Tom begins a 3-part series on the FCPA Compliance Report.    5.     Data analytics informs SEC enforcement action. Jaclyn Jaeger in Compliance Week.  6.     SEC Chair Gensler reflects on 1st year of Chairmanship? Ephrat Livny in NYT. 7.     Into the crystal ball on climate disclosures. Mai-Khoi Nguyen-Thanh and Taylor Wirth   in CCI. 8.     Should Elon Musk have been stopped long ago? Francine McKenna in Time. 9.     What should be on your audit committee agenda for 2022? Maureen Bujno, Krista Parsons and Kimia Clemente in Harvard Law School Forum on Corporate Governance.   10.  Putting the ‘G' first in ESG. Lawrence Heim in practicalESG Podcasts and More 11.  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 a FCPA investigation and thereafter. In Part 2 we took a deep dive into the Lisa Monaco speech and what it means for compliance professionals.  12.  What is the only podcast dedicated to the intersection of Compliance and ESG? It's the Compliance ESG Podcaston the CPN. Check out this week's episode with Erika Peters of Exiger on the ESG Standards. For your added viewing pleasure check out the video pod on YouTube.  13.  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. In Part 3, Susan moves into the CCO chairs at AECOM. 14.  Are you a MCU fan? If so check out the latest 2 episodes of Popcorn and Compliance-the MCU Series as Tom and Megan Dougherty are going through the full MCU in chronological, not release date order. The latest two episodes are Black Widow and Black Panther. 15.  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 discount code TFLAW $200 OFF. More 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

On Thursday, February 17th, Deputy Attorney General Lisa Monaco delivered the keynote address at the Munich Cyber Security Conference 2022. She spoke about past enforcement actions against cyber criminals, including the seizure of ransomware payments and other hacks, the FBI's Virtual Asset Exploitation Unit, the DOJ's appointment of former AUSA Eun Young Choi as director of the DOJ's national cryptocurrency enforcement team, and other matters related to cryptocurrency regulation and incident responses to malevolent cyber actors. See acast.com/privacy for privacy and opt-out information.

In this episode of the FCPA Compliance Report, I am joined by fan favorite James Koukios, partner at Morrison and Foerster. In this episode we take a deep dive into the Lisa Monaco speech from October and related remarks from other DOJ representatives about the DOJ refocus on white collar enforcement and related issues. Highlights of this podcast include: ·       Who is the DAG and what does that position entail? ·       Reinstatement of Yates Memo. ·       Does this change an investigation focus? ·       The new focus on culture and how do you assess corporate culture? ·       What about reports of all violations, enforcements and even investigations even is outside FCPA?  ·       What are the implications of this change? ·       How will all this work with current FCPA Corporate Enforcement Policy? ·       The revocation of Benczkowski Memo. What are the implications? ·       The new focus on monitorships? ·       What about recidivists or those who fail to meet the obligations of their DPA/NPA? Resources James Koukios on the MoFo website.  Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode of the FCPA Compliance Report, I am joined by fan favorite Mike DeBernardis, partner at Hughes Hubbard. In this episode we look at compliance and temporal timeline developments from Q4 2021. Highlights of this podcast include: A deep dive into the Lisa Monaco speech, how it impacted the compliance temporal timeline whether it was a change or recalibration. Anti-Trust developments. The Biden Administration Strategy on Countering Corruption? Compliance in 2022 and moving forward. Resources Mike DeBernardis on HughesHubbard website.  Learn more about your ad choices. Visit megaphone.fm/adchoices

From October 15, 2019: A couple of weeks ago, Lawfare and the Strauss Center for International Security and Law sponsored a series of panels at the Texas Tribune Festival. For this episode, we bring you the audio of our Tribfest event on domestic terrorism—what it is, how we define it, how we outlaw it, and what more we can do about it.David Priess sat down with Bobby Chesney, Lawfare co-founder and professor at the University of Texas School of Law, and former U.S. government officials Lisa Monaco, Mary McCord, and Nick Rasmussen.Support this show http://supporter.acast.com/lawfare. See acast.com/privacy for privacy and opt-out information.

How Kevin McCarthy lost the leadership test, Lisa Monaco got the DOJ's groove back, Bannon and Flynn may do time and Kyle Rittenhouse 4K drone footage could prove his guilt. Jen Taub joins Zev Shalev, with special participation of Ponzu. Support our sponsors: Embrace the radically-efficient Mack Weldon “Daily Wear System”. The Daily Wear System is a selection of clothes rooted in smart design, made with performance fabrics, and built to work together. Get 20% off your first order, go to https://mackweldon.com/narativ and use code: NARATIV Bacon lover, this is for you! FREE bacon for a year! Visit https://www.moinkbox.com/narativ and subscribe to their meat boxes. Get the highest quality meat you've ever tasted while supporting real Family Farms. Help us tell the true story of our time through an independent lens. Narativ uses emerging technologies to empower informed action. Support us at https://www.patreon.com/narativ. Learn more about your ad choices. Visit megaphone.fm/adchoices

The clock ticks perilously down towards the day the nuclear deal goes into effect. For Jason, it feels like the door is closing. What he doesn't know is that his family, the Post, and the Obama administration are increasing the pressure on Iran. Featuring Marty Baron, Brett McGurk, Lisa Monaco, Ben Rhodes and John Kerry. Learn more about your ad choices. Visit podcastchoices.com/adchoices

Based on new Washington Post reporting today we've learned that "The Big Lie" was actually cooked up two years ago by a Republican political dirty trickster as a way to cast aside the will of the American voters and corruptly keep Donald Trump in power. The Republicans are insisting that all party members adhere to The Big Lie and pledge allegiance to The Big Liar or face ouster. This is yet another reason Merrick Garland's Department of Justice must move toward charging Donald Trump for his crimes. It seems like it's taking an eternity for justice to come for Trump. But we should take heart that DOJ made dramatic legal moves just one week after Lisa Monaco was confirmed by the Senate as the Deputy Attorney General. Here is why the indicators are trending toward justice. For our newly launched Team Justice and Justice Matters merchandise shop, please visit: https://shop.spreadshirt.com/glennkirschner/ Please consider becoming a #TeamJustice patron at: https://www.patreon.com/glennkirschner My podcast, "Justice Matters with Glenn Kirschner" can be downloaded where you get your podcasts. Follow me on: Twitter: https://www.twitter.com/glennkirschner2 Facebook: https://www.facebook.com/glennkirschner2 Instagram: https://www.instagram.com/glennkirschner2 Learn more about your ad choices. Visit megaphone.fm/adchoices See Privacy Policy at https://art19.com/privacy and California Privacy Notice at https://art19.com/privacy#do-not-sell-my-info.