FCPA Compliance Report

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox welcome Jonathan Armstrong to discuss the seismic shift in the UK’s political landscape following the election last week.

The election was literally one for the ages. It led to a significant Labor victory over the Conservatives. They delve into the implications for compliance and governance in both the UK and globally. Topics include the new government’s proactive approach, anticipated shifts in bribery enforcement, and fiscal policies.

They also explore potential changes in AI regulation, employment law, data protection, and international relations, especially concerning Russia and China. The conversation highlights Labor’s balanced strategy, aiming for sensible, centrist policies while addressing key issues like corruption, AI, and data privacy.

Highlights in this Episode:

• An election result for the ages
• Impact on Bribery and Corruption Enforcement
• Trade Sanctions, Russian Oligarch’s and Forced Labor
• AI and Beyond
• Data Privacy and Data Protection
• Labor and Employment Rights

 Resources:

Jonathan Armstrong on LinkedIn

UK General Election 2024 – What Might This Mean for Compliance?

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this edition of the FCPA Compliance Report, Tom Fox welcomes back Adrienne Bellehumeur, a chartered accountant and expert in internal controls and documentation.

Adrienne discusses her recent article on design-centric internal control and emphasizes the importance of focusing on design as the foundation for effective control programs. She outlines five key principles for improving control design and details her approach to challenging processes and governance systems. The conversation also touches on the necessity of continuously updating controls to adapt to evolving business and regulatory environments.

Adrienne shares tips on fostering better design through workshops, effective interviewing, and continuous improvement, while also addressing new developments such as AI and ESG. The episode finishes with insights into how internal controls can support whistleblower programs and the importance of back-to-basics documentation and information management.

Highlights in this Episode:

• Professional Background
• Design-Centric Approach to Internal Controls
• Challenges and Importance of Good Design
• Principles for Improving Control Design
• Back to Basics: Adapting to New Business Developments
• Whistleblower Programs and Internal Controls

 Resources:

Adrienne Bellehumeur on LinkedIn

Risk Oversight

New Approaches to Control Design

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report,  I have a take a deep dive into the Prevalent 2024 Third Party Risk Management Report with Brad Hibbert, the Chief Strategy Officer and COO at Prevalent.

Hibbert drives Prevalent’s product vision and strategy development, which draws from the Third Party Risk Management Report. The Prevalent Report outlines  the complexities of managing third-party vendor relationships, highlighting the various phases involved such as onboarding, contracting, and offboarding. It examines the inefficiencies and risks that arise from fragmented processes and technologies handled by different teams. Our conversation explores how these challenges impact risk visibility and resource management, emphasizing the downstream effects on program scalability and decision-making.

Highlights in this Episode

·       Introduction to Vendor Relationship Phases

·       Challenges in Managing Vendor Relationships

·       Inefficiencies and Risks in Vendor Management

·       Impact on Risk Visibility and Decision Making

·       Pressure on Teams and Resource Implications

Resources 

Brad Hibbert on LinkedIn

Prevalent

Prevalent’s 2024 Third Party Risk Management Report

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this edition of the FCPA Compliance Report, Tom Fox has a fascinating visit with Iveta (Evie) Wentink, a 15-year compliance veteran. Evie has worked in the public and private sectors and has expertise in compliance training, hotlines, government contract compliance, data privacy, reporting, & due diligence.

Evie has one of the most unique opening lines for hotline training, which is ‘Do You Know Your Hotline Number?” This simple yet incredibly important question encapsulates Evie’s approach to compliance training: make it simple, direct, and practical for the listeners. (Or, as Carsten Tams would say, ‘It’s all about the UX’).

Our conversation focuses on the critical role of hotline numbers in corporate compliance programs, emphasizing the need for employees to know and trust the hotline. Evie shares insights from her career, highlights the significance of marketing compliance hotlines effectively, and discusses the broader culture of compliance and non-retaliation in organizations. She shares practical tips for improving hotline awareness and usage, making this episode a valuable resource for compliance professionals and organizations alike.

Highlights in this Episode:

• Enhancing Trust through Active Compliance Reporting
• Promoting Reporting Culture Through Creative Marketing
• Ethical Culture: Encouraging Compliance Reporting Safely
• Enhancing Compliance Programs Through Anonymous Hotlines

Resources

Evie Wentink on LinkedIn

Evie’s Top 10 Compliance Back to Basics

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report,  I welcome Professor Andy Spalding, an expert in anti-corruption law, to discuss his extensive work with the Paris Olympic Committee in preparation for the 2024 Olympic Games. 

Spalding shares insights about his involvement with the French Anti-Corruption Agency (AFA) and elaborates on how anti-corruption and human rights reforms are being integrated into the Olympic preparations. The discussion also delves into the historical significance of these reforms and their potential to leave a lasting positive impact. Furthermore, Fox and Spalding explore the groundbreaking work done by Qatar during the FIFA World Cup and its implications for future mega sporting events. The episode concludes with thoughts on how the accumulated knowledge and best practices from different countries could shape the future of global sporting events, emphasizing the importance of collaboration among stakeholders.

Highlights in this Episode

·       Involvement with Paris 2024 Olympics

·       Role and Impact of French Anti-Corruption Agency (AFA)

·       Innovative Compliance Measures for Paris Olympics

·       Comparison with Qatar’s World Cup Reforms

·       Future of Anti-Corruption in Mega Sporting Events

Resources 

Andy Spalding at University of Richmond – School of Law

CCI Webinar on A New Era in Megasports Anti-Corruption

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this special edition of the FCPA Compliance Report, welcome back fan favorite Kenyen Brown, now at his new firm, Thompson Coburn LLP.

Kenyen Brown joins Tom Fox to discuss his experience reviewing the Mobile AL Police Department use of force on behalf of his client, the City of Mobile.

Kenyen Brown is a renowned legal expert with a wealth of experience in investigations and legal work concerning constitutional standards in the use of force. His perspective on this topic is heavily influenced by his extensive background in various roles, such as US Attorney and counsel for Senate and House ethics committees, which has allowed him to deeply understand the intricacies of law enforcement and constitutional standards.

Brown firmly believes that police departments ought to adopt proactive measures, including independent third-party oversight, to align their practices with constitutional standards, particularly in the utilization of force. His experiences, notably his review of the Mobile Police Department’s use of force incidents, have led him to advocate for proactive, independent oversight to improve community relations and prevent deadly force incidents.

He underscores the necessity of reevaluating and enhancing general orders, principles, and training to ensure law enforcement officers’ compliance with constitutional standards, thereby reducing the likelihood of deadly force incidents and potential civil rights violations.

 Highlights in this Episode:

• Preventing DOJ Intervention Through High Policing Standards
• Community-Led Oversight: Enhancing Police Department Practices
• Constitutional Standards for Use of Force
• Public Involvement in Police Accountability and Transparency
• Controversial Police Practice: No-Knock Raids

Resources :

Kenyen Brown on LinkedIn

Thompson Coburn LLP

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this special edition of the FCPA Compliance Report, we welcome back fan favorite Mary Inman, now at her new firm, Whistleblower Partners LLP, a firm dedicated to assisting whistleblowers navigate various reward programs.

Mary joins Tom Fox to discuss what we know so far about the DOJ Whistleblower Incentive Initiative.

Mary has a positive perspective on the Department of Justice’s (DOJ) White Collar Whistleblower Program. She acknowledges the gaps in existing whistleblower reward programs across multiple agencies and sees the DOJ program as a crucial opportunity to fill these lacunae. Inman’s expertise, particularly in the SEC program, allows her to identify specific gaps, such as the lack of financial protections for whistleblowers reporting Foreign Corrupt Practices Act violations involving companies not publicly listed on US exchanges.

From her perspective, the DOJ program will address serious financial crimes, including domestic corruption. Inman also anticipates that the DOJ will establish its own office of the whistleblower, mirroring similar initiatives in other agencies, hence providing both confidential and anonymous reporting avenues.

Topics Covered in This Episode:

• Specialized Law Firm for Whistleblower Reward Programs
• Financial Crime Reporting Enhancement Initiative
• Establishing a Central Office for Whistleblowers
• Championing Transparency: Grassley’s Whistleblower Advocacy
• Wellness Fund Support for Whistleblowers

Resources:

Mary Inman on LinkedIn

Whistleblower Partners LLP

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this special edition of the FCPA Compliance Report, welcome Sam Silverstein. They take a deep dive into how Boeing can begin to overhaul and reform their toxic culture, which led to the 2024 compliance and ethics failures. They discuss the power of the Culture Audit™, which is the sponsor of this podcast.

Sam Silverstein is a seasoned professional with over three decades of experience in corporate culture. Silverstein believes that a strong leadership role is crucial in driving culture change within an organization. His philosophy is that action follows belief, stressing that leaders must genuinely prioritize creating a culture of quality, compliance, and safety for it to truly thrive.

Silverstein maintains that the CEO’s primary role is to protect the organization’s culture, while the COO should ensure operations align with the board and CEO’s strategic plan. His experiences, particularly his insights drawn from Boeing’s situations, have shaped his belief that prioritizing culture over short-term profits, along with a culture audit and specific implementation plan, can help address systemic issues and foster a high-performance workplace culture. 

Topics Covered in This Episode:

• Transition from Safety to Profit Culture at Boeing
• Measuring Organizational Culture through Employee Engagement
• Creating Accountable Leaders for Organizational Culture Transformation
• Cultivating Sustainable High-Performance Organizational Culture
• Cultivating Employee Trust Through Genuine Leadership Efforts
• Rewarding Ethical Behavior for Organizational Integrity
• Data-Driven Organizational Culture Enhancement Process
• Recognition and Amplification through Personalized Engagement

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special edition of the FCPA Compliance Report, Tom welcomes Ron Karr, long time thought leader in the art of leadership, persuasion and influence. They take a deep dive into the science of influence and persuasion and help the compliance professional understand how they can use this science to move the compliance ball forward in an organization.

Ron Karr is a speaker, and author with over three decades of experience in the sales and consulting industry. His career saw its inception in retail, later transitioning to the computer industry, and eventually culminating in the establishment of his own consulting business. Karr’s perspective on the “Velocity Mindset”, as detailed in his book, revolves around the concept of speed with direction, where goals and aspirations are the key drivers of actions.

His belief that self-imposed limitations can hinder our progress is deeply rooted in his experiences, leading him to emphasize the importance of self-evaluation, proactive approach adjustments, and reshaping our narratives to facilitate our goals. Karr underscores the value of networking and learning from others, seeing it as a vehicle to expedite success and achieve professional velocity.

Topics Covered in this Episode

• Purposeful Reflection for Effective Decision-Making
• Neurochemical Impact on Influencing Others Successfully
• Propelling Success through Adaptive Strategies
• Empowering Personal Growth Through Story Rewriting
• Enhancing Professional Success Through Peer Engagement
• The Velocity Mindset: Achieving Success Through Networking

Resources:

Ron Karr on LinkedIn

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The Velocity Mindset

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this special edition, Tom welcomes Jessica Nall, a partner at Baker McKenzie who leads the firm’s West Coast investigations and compliance practice, and Maria Piontkovska, a Senior Associate in the same practice group.

We deeply dive into their article about the recent speeches by Department of Justice representatives at the ABA White Collar Conference on the new DOJ whistleblower program, AI, data protection, and intellectual property protection.

Jessica Nall and Maria Piontkovska are prominent legal professionals specializing in white-collar defense and corporate investigations. Jessica, a seasoned attorney with over 20 years of experience, leads Baker McKenzie’s white-collar practice in California, and Maria is a skilled US white-collar attorney originally from Ukraine.

Both regard the ABA White Collar Conference as an essential platform for the defense bar, government investigators, and compliance leaders to gather for discussions and networking. Nall sees the conference as vital for disseminating new compliance expectations and enforcement trends announced by government officials. At the same time, Piontkovska highlights the importance of the direct line of communication with these officials, providing insights straight from the source.

Their perspectives on the conference are shaped by their extensive experiences in the field and drive their contributions to the discussions and policies related to white-collar defense and compliance.

Topics Covered in This Episode:

• Key Figures Discussing Trends in Compliance
• Corporate Transparency Incentive Initiative
• Financial Incentives for Anti-Corruption Self-Disclosure
• Navigating Risks: AI in Corporate Compliance
• Data Mapping for International Data Security

Resources:

Jessica Nall on LinkedIn

Maria Piontkovska on LinkedIn

Compliance Steps After ABA White Collar Crime Conference

United States: Department of Justice announces new corporate compliance directives for AI along with increased penalties for AI-related misconduct

Baker McKenzie

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