About FCPA Compliance Report

Tom Fox has practiced law in Houston for 35 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.

DateTime Object ( [date] => 2020-01-20 16:08:44.410715 [timezone_type] => 3 [timezone] => UTC )
    DateTime Object ( [date] => 2020-01-20 16:08:53.871165 [timezone_type] => 3 [timezone] => UTC )
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    There is nothing like an internal whistleblower report about a compliance violation, the finding of such an issue, or (even worse) a subpoena from the DOJ or notice letter from the SEC to trigger the Board of Directors and senior management attention to the compliance function and the company’s compliance program. Such an event can trigger much gnashing of teeth and expressions of outrage followed immediately by proclamations “We are an ethical company.” However, it may well be the time for a very serious reality check.

    Three key takeaways:

    1. A serious FCPA allegation gets the attention of the Board and senior management. Use this time to move the compliance program forward.
    2. Be aware of how your investigation can impact and even inform your remediation efforts.
    3. Be prepared to deal with the dreaded “where else” question.


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  • There is nothing like an internal whistleblower report about a...
  • Array ( [id] => 7d48b31e-3ace-11ea-ac99-c3e75e493c46 [createdAt] => 2020-01-19T10:15:12.770-05:00 [updatedAt] => 2020-01-19T18:10:01.805-05:00 [title] => Dave Lefort on 10 Stories CW Will Follow in 2020 [pubdate] => 2020-01-20T02:01:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/7d48b31e-3ace-11ea-ac99-c3e75e493c46/image/uploads_2F1579445169068-2d5m44a7ln7-4890aca3399f8ba0c574b8129a6cb643_2FFCPAComplianceReport2.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 461 [subtitle] => In the Episode, I visit with Dave Lefort, Editor in Chief for Compliance Week. I asked him to come on the podcast and discuss his 10 predictions on what will dominate compliance headlines in 2020. [summary] =>

    In the Episode, I visit with Dave Lefort, Editor in Chief for Compliance Week. Dave recently wrote “It’s hard to tell whether the age we’re living in is the calm before the storm or if it is the storm. One way or another, we’ll likely get some clarity in the year ahead for CCOs navigating these choppy waters.” I asked him to come on the podcast and discuss his 10 predictions on what will dominate compliance headlines in 2020.

     

    1. Big Tech in antitrust crosshairs. Is everyone ganging up on big tech?
    2. Deregulation. Is it real or is it Memorex? 
    3. Recession worries: Impact on ethics and compliance. Will compliance have to do more with less or less with less? 
    4. 2020 elections. How could it impact the regulatory environment heading into 2021? 
    5. Protecting whistleblowers. Will Congress step in where the Supreme Court gutted protection? Will Trump’s public berating of the impeachment whistleblower embolden those accused of wrongdoing to retaliate? 
    6. Data privacy equation has changed. How so? 
    7. GDPR: Waiting for the big one. Which US company will it be?
    8. Regulators will reward good-faith efforts. Is it softening or a refocus?
    9. Ethics and Artificial Intelligence: Trouble ahead? Will Skynet become self-aware? 
    10. Supply chains, geopolitical risk, and third parties. If this is such a big problem, where are the resources to fix it? 

    Resources

    Dave’s article Ten Things We’ll Be Talking About in 2020

    Subscribe to Compliance Week here. Use the code, NEWYEAR2020 … for a $365 for a one-year membership.

    Register for Compliance Week 2020, here.

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  • In the Episode, I visit with Dave Lefort, Editor in...
  • Array ( [id] => 480ee1cc-37eb-11ea-9a57-63e68b3aeb5e [createdAt] => 2020-01-15T18:03:45.388-05:00 [updatedAt] => 2020-01-15T18:03:52.411-05:00 [title] => Day 19 | The investigation protocol [pubdate] => 2020-01-19T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/480ee1cc-37eb-11ea-9a57-63e68b3aeb5e/image/uploads_2F1579129360899-tm863kt0t8k-67aeb6876b00bbcb04b41925971ea2e1_2F19.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 19 [subtitle] => What is your investigation protocol? Find out why you need one and how to create one in 19 of 31 Days to a More Effective Compliance Program [summary] =>

    After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it, promptly, thoroughly and with competent personnel. Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal company hotline, anonymous tips, or a report directly from the business unit involved. You can make the decision on whether or not to investigate with consultation with other groups such as the Audit Committee of the Board of Directors or the Legal Department. The head of the business unit in which the claim arose may also be notified that an allegation has been made and that the Compliance Department will be handling the matter on a go-forward basis. Through the use of such a detailed written procedure, you can work to ensure there is complete transparency on the rights and obligations of all parties, once an allegation is made. This allows the compliance team to have not only the flexibility but also the responsibility to deal with such matters, from which it can best assess and then decide on how to manage the matter.

     Three key takeaways:

    1. A written protocol, created before an investigation, is a key starting point.
    2. Create specific steps to follow so there will be full transparency and documentation going forward.
    3. Consistency in approach is critical.


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  • After the internal report comes in and you have properly...
  • Array ( [id] => fbec3f98-37e9-11ea-a7a5-fbe1839b416d [createdAt] => 2020-01-15T17:54:28.151-05:00 [updatedAt] => 2020-01-15T17:54:50.190-05:00 [title] => Day 18 | Internal reporting and the triaging of claims [pubdate] => 2020-01-18T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/fbec3f98-37e9-11ea-a7a5-fbe1839b416d/image/uploads_2F1579128733307-fookk0yfb5-9888340624f12d2ba0984c7b7c7bc8ed_2F18.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 18 [subtitle] => What is your triaging of claims? Do you have a triage protocol? Find out why you should on Day 18 of 31 Days to a More Effective Compliance Program. [summary] =>

    The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin the process which will determine, in many instances, how the company will respond going forward.

    This scenario was driven home by the SEC in a 2015 FCPA enforcement action involving Mead Johnson Nutrition Company. In this enforcement action, the company performed two internal investigations into allegations that its Chinese business unit was engaged in conduct which violated the FCPA. Unfortunately, the first investigation, performed in 2011, did not turn up any evidence of FCPA violations. It was not until 2013, when the SEC made an inquiry to the company that it performed an adequate internal investigation which uncovered FCPA violations.

    Three key takeaways:

    1. The DOJ and SEC put special emphasis on internal reporting lines.
    2. Test your hotline on a regular basis to make sure it is working.
    3. Have a triage protocol in place before the call comes in so you will be ready to go and not required to scramble to create a protocol.


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  • The call, email or tip comes into your office; an...
  • Array ( [id] => d50cc6a0-37e8-11ea-b1b9-4765d117b780 [createdAt] => 2020-01-15T17:46:13.474-05:00 [updatedAt] => 2020-01-15T17:46:35.586-05:00 [title] => Day 17 | Managing your third parties [pubdate] => 2020-01-17T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/d50cc6a0-37e8-11ea-b1b9-4765d117b780/image/uploads_2F1579128365945-ylur7duae6r-ae169c2870347e3b9412862e117712c9_2F17.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 17 [subtitle] => How can you best manage your 3rd parties? Find out in Day 17 of 31 Days to a More Effective Compliance Program [summary] =>

    The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a business justification, questionnaire, due diligence, evaluation and compliance terms and conditions in contracts. However, as many companies mature in their compliance programs, the issue of third-party management becomes more important. It is also the one where the rubber meets the road of operationalizing compliance. It is also an area the DOJ specifically articulated in the 2019 Evaluation that companies need to consider. 

    The key is to have a strategic approach to how you structure and manage your third-party relationships. This may mean more closely partnering with your third parties to help manage the anti-corruption compliance risk. It would certainly lead towards enabling your company to control risk while optimizing the performance of your third parties.

    Three key takeaways:

    1. Have a strategic approach to third-party risk management.
    2. Rank third parties based upon a variety of factors including compliance and business performance, length of relationship, benchmarking metrics and KPIs for ongoing monitoring and auditing.
    3. Managing the relationship is where the real work begins. 
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  • The building blocks of any compliance program lay the foundations...
  • Array ( [id] => 76f5f22c-37e7-11ea-b1b9-2f5746f593ca [createdAt] => 2020-01-15T17:36:26.114-05:00 [updatedAt] => 2020-01-15T17:36:38.298-05:00 [title] => Day 16 | The third-party risk management process [pubdate] => 2020-01-16T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/76f5f22c-37e7-11ea-b1b9-2f5746f593ca/image/uploads_2F1579127451001-bolnf2b4imj-2faf2ce094004200c70ab6473d65a4d0_2F16.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 16 [subtitle] => What is the third party risk management process? Find out in today's episode of 31 Days to a More Effective Compliance Program. [summary] =>

    As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) devotes an entire prong to third-party management. It begins with the following: A well-designed compliance program should apply risk-based due diligence to its third-party relationships. Although the degree of appropriate due diligence may vary based on the size and nature of the company or transaction, prosecutors should assess the extent to which the company has an understanding of the qualifications and associations of third-party partners, including the agents, consultants, and distributors that are commonly used to conceal misconduct, such as the payment of bribes to foreign officials in international business transactions.  

    This clearly specifies that the DOJ expects an integrated approach that is operationalized throughout the company. This means you must have a process for the full life cycle of third-party risk management. There are five steps in the life cycle of third-party risk management, which will fulfill the DOJ requirements as laid out in the 2012 FCPA Guidance and in the Ten Hallmarks of an Effective Compliance Program. They five steps in the lifecycle of third-party management are: 

    1. Business Justification;
    2. Questionnaire to Third-party;
    3. Due Diligence on Third-party;
    4. Compliance Terms and Conditions, including payment terms; and
    5. Management and Oversight of Third Parties After Contract Signing.

     

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  • As every compliance practitioner is well aware, third parties still...
  • Array ( [id] => d4fe67bc-3339-11ea-9f75-2fcdaecfab13 [createdAt] => 2020-01-09T18:43:26.770-05:00 [updatedAt] => 2020-01-09T18:43:38.528-05:00 [title] => Day 15 | How do you evaluate a risk assessment? [pubdate] => 2020-01-15T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/d4fe67bc-3339-11ea-9f75-2fcdaecfab13/image/uploads_2F1578613270300-7iquki6pcp-c0f85180af7c3694589e2c58eabaf2c4_2F15.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 15 [subtitle] => The evaluation of any risk assessment is a critical step for every compliance professional. [summary] =>

    After you complete your risk assessment, you must then translate it into a risk profile. If your estimate of where your bribery risk is greatest is wrong, it will be an effort to address it. As Ben Locwin explained in his  BioProcess International article, entitled “Quality Risk Assessment and Management Strategies for Biopharmaceutical Companies”: 

    Once we have assessed risks and determined a process that includes options to resolve and manage those risks whenever appropriate, then we can decide the level of resources with which to prioritize them. There always will be latent risks: those that we understand are there but that we cannot chase forever. But we need to make sure we have classified them correctly. With a good understanding of each of these, we are in a better position to speak about the quality of our businesses.

    A way to evaluate risks as determined by the company’s risk assessment is through a risk matrix. Once risks are identified, they are then rated according to their significance and likelihood of occurring, and then plotted on a heat map to determine their priority. The most significant risks with the greatest likelihood of occurring are deemed the priority risks, which become the focus of your remedial efforts or for continuous auditing. A variety of solutions and tools can be used to manage these risks going forward, but the key step is to evaluate and rate these risks. All your actions should flow from the risk ranking.

    Three key takeaways:

    1. Even after you complete your risk assessment, you must evaluate those risks for your company.
    2. The DOJ and SEC are looking for a well-reasoned approach on how you evaluate your risk.
    3. Create a risk matrix and rank your risks; then remediate and monitor as appropriate.


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  • After you complete your risk assessment, you must then translate...
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    One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based upon a risk assessment, to understand your organization’s business from the commercial perspective, how your organization has identified, assessed, and defined its risk profile and, finally, the degree to which the program devotes appropriate scrutiny and resources to this range of risks.  

     As far back as 1999, in the Metcalf & Eddy enforcement action, the DOJ has said that risk assessments that measure the likelihood and severity of possible FCPA violations should direct your resources to manage these risks. The 2012 FCPA Guidance stated it succinctly when it said, “Assessment of risk is fundamental to developing a strong compliance program and is another factor DOJ and SEC evaluate when assessing a company’s compliance program.

    This language was supplemented in the 2017 FCPA Corporate Enforcement Policy, which stated, “The effectiveness of the company’s risk assessment and the manner in which the company’s compliance program has been tailored based on that risk assessment.

    A risk assessment determines the areas at greatest risk for FCPA violations among all types of international business transactions and operations, the business culture of each country in which these activities occur, and the integrity and reputation of third parties engaged on behalf of the company. The reason is straightforward; one cannot define, plan for, or design an effective compliance program to prevent bribery and corruption unless you can measure the risks you face.

     Three key takeaways:

    1. Since at least 1999, the DOJ has pointed to the risk assessment as the start of an effective compliance program.
    2. The DOJ will now consider both your risk assessment methodology for identifying risks and gathered evidence.
    3. You should base your compliance program on your risk assessment.


    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/9948757e-3338-11ea-a608-eb1731df72f2/stripped_660d7a59b919fb516f248dc9cd3a3c4b.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN2454082991.mp3 [size] => 19974269 [duration] => 499.36 [uid] => CSN2454082991 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/9948757e-3338-11ea-a608-eb1731df72f2/id3/4ff739d892bd3488cbdbdd62dd23ca20.mp3 [id3FileProcessing] => [id3FileSize] => 182275 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Day 14-Risk Assessments - 1_9_20, 4.14 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • One cannot really say enough about risk assessments in the...
  • Array ( [id] => 55407526-3337-11ea-88f1-777032e8300b [createdAt] => 2020-01-09T18:25:33.463-05:00 [updatedAt] => 2020-01-09T18:25:40.688-05:00 [title] => Day 13 |Institutional Justice and The Fair Process Doctrine [pubdate] => 2020-01-13T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/55407526-3337-11ea-88f1-777032e8300b/image/uploads_2F1578612257973-zgks8xneh2k-2fb8aea9cdbde1cc9ea6c66dc0f1fc10_2F13.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 13 [subtitle] => What is the role of institutional justice in a best practices compliance program? [summary] =>

    Companies have finally come to realize that institutional justice and fairness are perhaps the most basic tenet of any successful workplace. If employees believe they will be treated fairly, it will engender a level of trust that can work to not simply motivate employees but lead to a more successful workplace and, at the end of the day, a more profitable company. This encompasses the entire lifecycle of the employment relationship, from hiring through separation. It works in areas as seeming disparate as compensation and incentives, discipline, promotion and internal reporting.

     Three key takeaways:

    1. The DOJ and SEC have long called for appropriate and consistent application of both incentives and discipline.
    2. The Fair Process Doctrinewill help set institutional justice as the norm in your organization.
    3. Inconsistent application of discipline will destroy your compliance program credibility.


    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/55407526-3337-11ea-88f1-777032e8300b/stripped_686cc8a8a35b0e26b6093a420e4e65db.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN3781033488.mp3 [size] => 19974269 [duration] => 499.36 [uid] => CSN3781033488 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/55407526-3337-11ea-88f1-777032e8300b/id3/5194b8aeaf2ae70395df20523daa3de4.mp3 [id3FileProcessing] => [id3FileSize] => 179965 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Day 13-Instituional Justice - 1_9_20, 4.00 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • Companies have finally come to realize that institutional justice and...
  • Array ( [id] => 812738ac-355b-11ea-829b-af820f393fb2 [createdAt] => 2020-01-12T11:49:31.324-05:00 [updatedAt] => 2020-01-12T11:49:45.500-05:00 [title] => André H. Paris on the Brazilian Compliance Scene [pubdate] => 2020-01-13T00:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/812738ac-355b-11ea-829b-af820f393fb2/image/uploads_2F1578847581598-aefq6k9sqie-114be6bbccc14599b609b074be0d4065_2FFCPAComplianceReport2.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 460 [subtitle] => In the Episode, I visit with André H. Paris, a Brazilian Compliance Consultant and Lawyer. He is the author of the recently released book Compliance - Ethics and Transparency as the Way Forward. [summary] =>

    In the Episode, I visit with André H. Paris, a Brazilian Compliance Consultant and Lawyer. He is a specialist in building a Corporate Culture based on Ethics, Transparency and Respect. Paris has experience in Corporate Risk Analysis and Management, as well as in Protecting Corporate Reputation and Crisis Management. He is also quite enthusiastic on building a more ethical and transparent business environment. Paris is the author of the recently released book Compliance - Ethics and Transparency as the Way Forward. I met Paris at a compliance conference in Brazil last year. I am always interested in the views on compliance from practitioners outside the US, most particularly those who have written on the subject. He came on to the podcast to discuss his book and the current compliance scene in Brazil.

    • Due to the numerous corruption scandals, many Brazilian companies have experienced an extreme reputation crisis.
    • Companies have suffered substantial reputational bumps, including loss of market value, frequent presence on police pages, destroyed careers and thousands of jobs down the drain, as well as a profound brand disruption.
    • Paris believes that many of these risks should never have been taken, seeking results at any cost.
    • One of the challenges is helping the market to understand the need and value of compliance.
    • Additionally, many companies are trying to catch by creating internal structures focused on this compliance.
    • Compliance needs to be further studied and deepened. Paris believes there is the need for constant updating.
    • While the book deals with the main themes of corporate compliance, Paris both in the podcast and in his book does not shy away from expressing his opinions on topics that are often considered controversial.

    Resources

    To purchase a copy of Compliance - Ethics and Transparency as the Way Forward (in Portuguese) click here

    André Paris LinkedIn Profile

    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/812738ac-355b-11ea-829b-af820f393fb2/stripped_ec6a07e18de31e981c833185b2679c74.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN4964960552.mp3 [size] => 43986024 [duration] => 1099.65 [uid] => CSN4964960552 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/812738ac-355b-11ea-829b-af820f393fb2/id3/a9e9720e942278ca77eb37fbcb283649.mp3 [id3FileProcessing] => [id3FileSize] => 182723 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => 460.Andre Paris - 1_12_20, 10.41 AM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • In the Episode, I visit with André H. Paris, a...
  • Array ( [id] => 3e1d6b2a-3336-11ea-8983-6fab766c941a [createdAt] => 2020-01-09T18:17:45.146-05:00 [updatedAt] => 2020-01-09T18:17:55.070-05:00 [title] => Day 12 | Financial Incentives for Compliance [pubdate] => 2020-01-12T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/3e1d6b2a-3336-11ea-8983-6fab766c941a/image/uploads_2F1578611819159-jqvbvwybb0i-f00b94401f2776494f510010f525f635_2F12.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 12 [subtitle] => What financial incentives should be used in a best practices compliance program? [summary] =>

    One of the areas that many companies have not paid as much attention to in their compliance programs is compensation. However, the DOJ and SEC have long made clear that they view monetary structure for compensation, rewarding those employees who do business in compliance with their employer’s compliance program, as one of the ways to reinforce the compliance program and the message of compliance. As far back as 2004, then SEC Director of Enforcement Stephen M. Cutler noted that integrity, ethics and compliance needed to be part of promotion, compensation and evaluation processes: “At the end of the day, the most effective way to communicate that “doing the right thing” is a priority, is to reward it.” 

    The 2012 FCPA Guidance stated the “DOJ and SEC recognize that positive incentives can also drive compliant behavior. These incentives can take many forms such as personnel evaluations and promotions, rewards for improving and developing a company’s compliance program, and rewards for ethics and compliance leadership.”

    This same concept around compensation and incentives was brought forward in the 2019 Guidance - Incentives and Disciplinary Measures, which read:

    Incentive System – Has the company considered the implications of its incentives and rewards on compliance? How does the company incentivize compliance and ethical behavior? Have there been specific examples of actions taken (e.g., promotions or awards denied) as a result of compliance and ethics considerations? Who determines the compensation, including bonuses, as well as discipline and promotion of compliance personnel?

    The first question posed in the 2019 Guidance requires you to start with the basic question of what does your employee compensation consist of? Is it a straight salary? Is it variable? If so, what does the variable component consist of? Is it a discretionary bonus based upon the overall success of the entire business enterprise or some small subset such as a business unit or geographic region? Is it solely personal? Or is it some combination of all of the above?

    Three key takeaways:

    1. The DOJ and SEC have long advocated compensation as a way to motivate employees into ethical and compliant behaviors
    2. Keep the compliance aspects of your compensation structure simple and easy for your employees to understand
    3. Have full transparency in the framework of your compensation structure


    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/3e1d6b2a-3336-11ea-8983-6fab766c941a/stripped_b2d901fd4a3c28e9cacee9a1bbd9ab10.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN9587848160.mp3 [size] => 20033828 [duration] => 500.85 [uid] => CSN9587848160 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/3e1d6b2a-3336-11ea-8983-6fab766c941a/id3/72923058bb1ddece62e54d6b7c3529ac.mp3 [id3FileProcessing] => [id3FileSize] => 183023 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => day 12-Financial Incentives for Compliance - 1_9_20, 3.14 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • One of the areas that many companies have not paid...
  • Array ( [id] => 987b618e-3332-11ea-951e-bb78222c056e [createdAt] => 2020-01-09T17:51:38.771-05:00 [updatedAt] => 2020-01-09T17:51:46.527-05:00 [title] => Day 11 | What is Effective Compliance Training? [pubdate] => 2020-01-11T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/987b618e-3332-11ea-951e-bb78222c056e/image/uploads_2F1578610248317-3zjra63p7um-426f42b75b72a51f73c40b52bb3f1a3b_2F11.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 11 [subtitle] => How can you determine effective compliance training? [summary] =>

    One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance program; and to create and foster a culture of compliance. While it seems axiomatic that compliance training is a mainstay of any best practices compliance program, the conversation around training has evolved over the years. The 2012 FCPA Guidance started the conversation.

    Beginning in the fall of 2016, through the announcement of the FCPA Enforcement Pilot Program, the DOJ began to talk about whether you have determined the effectiveness of your training. This conversation continued with the 2017 Evaluation where it asked, “How has the company measured the effectiveness of the training?” This point has bedeviled many compliance professionals yet is now a key metric for the government in evaluating compliance training. It evolved further in the 2019 Guidance with the mandate that training must be “truly effective”. Finally, the training must be presented in a language in which the employees understand, which means in a local language, if the training is outside the US or other non-English-speaking countries.

    Also raised in the 2017 Evaluation was the focus of your training programs, where the DOJ inquired into whether your training was “tailored” for the audience. This added two requirements. The first was to assess your employees for risk to determine the type of training you might need to deliver by risk ranking your employees. Obviously, the sales force would be the highest risk but there may be others who are deserving of high-risk training as well. From this risk ranking, you were required to develop tailored training for the risks those employees will face.

    The 2019 Guidance spells this out in greater detail. Not only in the design but who receives it, all coupled with backend determination of effectiveness. Finally, all of this must be documented.

    Three key takeaways:

    1. How and why have you tailored your compliance training?
    2. The DOJ has mandated demonstrating the effectiveness of compliance training
    3. How is your training presented: both in languages and media?


    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/987b618e-3332-11ea-951e-bb78222c056e/stripped_625efe2a634838480fd51fdb4e9d684a.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN1766915692.mp3 [size] => 20033828 [duration] => 500.85 [uid] => CSN1766915692 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/987b618e-3332-11ea-951e-bb78222c056e/id3/e8e3aa178ceb03993f3168041b11ef73.mp3 [id3FileProcessing] => [id3FileSize] => 182441 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Day 11-Effective Compliance Training - 1_9_20, 3.03 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • One of the key goals of any compliance program is...
  • Array ( [id] => c72256b0-2e7c-11ea-9012-6398edf2eff1 [createdAt] => 2020-01-03T18:00:03.984-05:00 [updatedAt] => 2020-01-03T18:00:11.348-05:00 [title] => Day 10 | The use of social media in compliance [pubdate] => 2020-01-10T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/c72256b0-2e7c-11ea-9012-6398edf2eff1/image/uploads_2F1578092314955-d6omzjm165a-3d498ccf9916d1a203b1233f412f1d03_2F10.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 10 [subtitle] => In today's episode of 31 Days to a More Effective Compliance Program, I discuss the use of social media in a best practices compliance program. [summary] =>

    What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the message of compliance going forward. Many of the applications that we use in our personal communications are free or available at very low cost. Why not take advantage of them and use those same communication tools in your internal compliance marketing efforts going forward? 

    Why should you do so? Start with the tech-savvy nature of the today’s workforce. It is not simply about having a younger workforce but a workforce whose primary tool for communication is social media. If your company is in the services business, it probably means your employee base is using technological tools to deliver business solutions. Finally, consider the data-driven nature of business today so using technological tools to deliver products and solutions is something your company most probably does now.

    Finally, never forget the social part of social media. Social media is a more holistic, multiple-sided communication. Not only are you setting out expectations but also these tools allow you to receive back communications from your employees. The D&B experience around the name change for its Code of Conduct is but one example. You can also see that if you have several concerns expressed it could alert you earlier to begin some detection and move towards prevention in your compliance program.

    Three key takeaways:

    1. Incorporation of social media into your compliance communications can pay big dividends.
    2. Focus on the ‘social’ part of social media.
    3. Use internal corporate social media to facilitate a 360-degree conversation.


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  • What is the message of compliance inside of a corporation...
  • Array ( [id] => 2af904e2-2e7b-11ea-9d6e-af21dffeac36 [createdAt] => 2020-01-03T17:48:32.493-05:00 [updatedAt] => 2020-01-03T17:48:39.432-05:00 [title] => Day 9 | 360 degrees of compliance communications [pubdate] => 2020-01-09T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/2af904e2-2e7b-11ea-9d6e-af21dffeac36/image/uploads_2F1578091491609-qj1hy6bo11-21c27b9ee5be78b6bb142f716c5d3b2d_2F9.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 9 [subtitle] => A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. [summary] =>

    A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive brand philosophy of compliance which is centered on your consumers. In other words, it helps a compliance practitioner to anticipate all the aspects of your employees needs around compliance. This is especially true when compliance is either perceived as something that comes out of the home office or is perceived as the “Land of No.” A 360-degree view of compliance gives you the opportunity to build a new brand image for your compliance program. This is important as the Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) mandates that for a compliance program to be effective, it must be understood by a wide variety of stakeholders.

     Communications is often thought of as a two-way street - upward and downward, inbound and outbound, or side-to-side. However, it is better to think of it as a 360-degree effort. You simply can no longer effectively communicate in just two ways. You now communicate in a more holistic manner, and in multiple ways. If you are just thinking about communications in the classic form, you are missing something that is happening around you.

    360-degrees of compliance communication is not just a classic form of communication but rather it is a communication in the concept of every interaction, whether they be planned or accidental interactions. It is all a form of communication. This is particularly true if you are a compliance professional, practitioner or Chief Compliance Officer. The things you do, the way you act, and the way people see you, you are always communicating. It is not simply communicating one to one as often you may be communicating to a group across siloed boundaries, to the constituencies you had not even planned to communicate with initially.

    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/2af904e2-2e7b-11ea-9d6e-af21dffeac36/stripped_3e38d21c684df5a7fda165ab604d5911.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN7994996563.mp3 [size] => 19379722 [duration] => 484.49 [uid] => CSN7994996563 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/2af904e2-2e7b-11ea-9d6e-af21dffeac36/id3/3ee40925047941ea5aa1c67b38ee118e.mp3 [id3FileProcessing] => [id3FileSize] => 182319 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Day 9-360 Degrees of Compliance Communication - 1_3_20, 3.08 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • A 360-degree view of compliance is an effort to incorporate...
  • Array ( [id] => 4f8b7804-2e7a-11ea-aabd-3f32c3bf85e4 [createdAt] => 2020-01-03T17:42:24.353-05:00 [updatedAt] => 2020-01-04T15:52:48.643-05:00 [title] => Day 8 | Internal controls and compliance [pubdate] => 2020-01-08T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/4f8b7804-2e7a-11ea-aabd-3f32c3bf85e4/image/uploads_2F1578091210318-g1mqhkpyjaq-19db74f95c5f92faffa51d549dcb336b_2F8.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 8 [subtitle] => What is the role of internal controls in a best practices compliance program? Find out in Day 8 of 31 Days to a More Effective Compliance Program. [summary] =>

    What specifically are internal controls in a compliance program? The starting point is the FCPA itself, which requires issuers to devise and maintain a system of internal controls that can reasonably assure:

    1. Transactions are executed in accordance with management’s general or specific authorization;
    2. Transactions are recorded as necessary (I) to permit preparation of financial statements in conformity with generally accepted accounting principles or any other criteria applicable to such statements, and (II) to maintain accountability for assets;
    3. Access to assets is permitted only in accordance with management’s general or specific authorization; and
    4. The recorded accountability for assets is compared with the existing assets at reasonable intervals and appropriate action is taken with respect to any differences.

    The DOJ and SEC, in the 2012 FCPA Guidance, stated:

    Internal controls over financial reporting are the processes used by compa­nies to provide reasonable assurances regarding the reliabil­ity of financial reporting and the preparation of financial statements. They include various components, such as: a control environment that covers the tone set by the organi­zation regarding integrity and ethics; risk assessments; con­trol activities that cover policies and procedures designed to ensure that management directives are carried out (e.g., approvals, authorizations, reconciliations, and segregation of duties); information and communication; and monitoring. … The design of a company’s internal controls must take into account the operational realities and risks attendant to the company’s business, such as: the nature of its products or services; how the products or services get to market; the nature of its work force; the degree of regulation; the extent of its government interaction; and the degree to which it has operations in countries with a high risk of corruption.

    Three key takeaways:

    1. Effective internal controls are required under the FCPA.
    2. Internal controls are a critical part of any best practices compliance program.
    3. There are four significant controls for the compliance practitioner to implement initially. (a) Delegation of authority (DOA); (b) Maintenance of the vendor master file; (c) Contracts with third parties; and (d) Movement of cash/currency.


    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/4f8b7804-2e7a-11ea-aabd-3f32c3bf85e4/stripped_2e5c701471de0c04ce0a4b0de997dc6a.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN3872771328.mp3 [size] => 19558400 [duration] => 488.96 [uid] => CSN3872771328 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/4f8b7804-2e7a-11ea-aabd-3f32c3bf85e4/id3/d629e87cbab25be08a8b369027a68ffe.mp3 [id3FileProcessing] => [id3FileSize] => 182991 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Day 8-Internal Controls - 1_3_20, 2.49 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • What specifically are internal controls in a compliance program? The...
  • Array ( [id] => 0b6b8ab6-2e79-11ea-9e0e-a351f586d9de [createdAt] => 2020-01-03T17:33:20.561-05:00 [updatedAt] => 2020-01-03T17:34:04.170-05:00 [title] => Day 7 | Policies and Procedures [pubdate] => 2020-01-07T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/0b6b8ab6-2e79-11ea-9e0e-a351f586d9de/image/uploads_2F1578090170272-j0pvl0z7imt-99c7a1da8c0dba87c615d29954ef1193_2F7.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 7 [subtitle] => Compliance policies lay out your expectations and compliance procedures set out the details of how to do so. [summary] =>

    There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the government comes knocking. The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) made clear that “Any well-designed compliance program entails policies and procedures that give both content and effect to ethical norms and that address and aim to reduce risks identified by the company as part of its risk assessment process.” This statement made clear that the regulators will take a strong view against a company that does not have well thought out and articulated policies and procedures against bribery and corruption; all of which are systematically reviewed and updated. Moreover, having policies written out and signed by employees provides what some consider the most vital layer of communication and acts as an internal control. Together with a signed acknowledgement, these documents can serve as evidentiary support if a future issue arises. In other words, the “Document, Document, and Document” mantra applies just as strongly to policies and proceures in anti-corruption compliance.

    The specific written policies and procedures required for a best practices compliance program are well known and long established. According to the 2012 FCPA Guidance, some of the risks companies should keep in mind include the nature and extent of transactions with foreign governments (including payments to foreign officials); use of third parties; gifts, travel, and entertainment expenses; charitable and political donations; and facilitating and expediting payments. Policies help form the basis of expectations for standards of conduct in your company. Procedures are the documents that implement these standards of conduct.

    Compliance policies do not guarantee employees will always make the right decision. However, the effective implementation and enforcement of compliance policies demonstrate to the government that a company is operating professionally and ethically for the benefit of its stakeholders, its employees and the community it serves.

    Three key takeaways:

    1. Written compliance policies and procedures, together the Code of Conduct, with form the backbone of your compliance program.
    2. The DOJ and SEC expect a well-thought out and articulated set of compliance policies and procedures and that they be adequately communicated throughout your organization.
    3. Institutional fairness for the application of policies and procedures demands consistent application across the globe.
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  • There are numerous reasons to put some serious work into...
  • Array ( [id] => e6e33930-2e75-11ea-9909-7fc7592fc8df [createdAt] => 2020-01-03T17:10:50.781-05:00 [updatedAt] => 2020-01-03T17:10:59.508-05:00 [title] => Day 6 | The Code of Conduct [pubdate] => 2020-01-06T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/e6e33930-2e75-11ea-9909-7fc7592fc8df/image/uploads_2F1578089426563-h4aptgwvak-9e06de93914a51acaa2d23b949c78a56_2F6.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => The Code of Conduct is one of the foundational pieces in your compliance program. [summary] =>

    What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to wave in regulator’s face during an enforcement action as proof of ethical overall behavior. Is such a legalistic code effective? Is a Code of Conduct more than simply your company’s internal law? What should be the goal in the creation of your company’s Code of Conduct?

     How important is the Code of Conduct? Consider the 2016 SEC enforcement action involving United Airlines, Inc., which turned on violation of the company’s Code of Conduct. The breach of the Code of Conduct was determined to be a FCPA internal controls violation. It involved a clear quid pro quo benefit paid out by United to David Samson, the former Chairman of the Board of Directors of the Port Authority of New York and New Jersey, the public government entity which has authority over, among other things, United’s operations at the company’s huge east coast hub at Newark, NJ.

    The actions of United’s former CEO, Jeff Smisek, in personally approving the benefit granted to favor Samson violated the company’s internal controls around gifts to government officials by failing to not only follow the United Code of Conduct but also violating it. The $2.4 million civil penalty levied on United was in addition to its 2016 Non-Prosecution Agreement (NPA) settlement with the DOJ, which resulted in a penalty of $2.25 million. The scandal also cost the resignation of Smisek and two high-level executives from United.

    In the 2012 FCPA Guidance, the DOJ and SEC states:

    A company’s Code of Conduct is often the foundation upon which an effective compliance program is built. As DOJ has repeatedly noted the most effective codes are clear, concise, and accessible to all employees and to those conducting business on the company’s behalf.

    The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) further specified “As a threshold matter, prosecutors should examine whether the company has a code of conduct that sets forth, among other things, the company’s commitment to full compliance with relevant Federal laws that is accessible and applicable to all company employees.” The Department of Justice (DOJ) Antitrust Division, Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (Antitrust Guidance) also specified “If the company has a Code of Conduct, are antitrust policies and principles included in the document?”

    Three key takeaways:

    1. Every formulation of a best practices compliance program starts with a written Code of Conduct.
    2. The substance of your Code of Conduct should be tailored to the company’s culture, and to its industry and corporate identity.
    3. “Document, Document, and Document” your training and communication efforts.


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  • What is the value of having a Code of Conduct?...
  • Array ( [id] => 782b32c6-2ff7-11ea-8803-f720147baa39 [createdAt] => 2020-01-05T15:10:50.760-05:00 [updatedAt] => 2020-01-05T15:11:08.739-05:00 [title] => Fry Wernick on the Hoskins Jury Instructions [pubdate] => 2020-01-06T00:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/782b32c6-2ff7-11ea-8803-f720147baa39/image/uploads_2F1578254991093-ee03m5walid-b138efbf34bbd88da2e179417b646fda_2FFCPAComplianceReport2.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 459 [subtitle] => In this episode of the FCPA Compliance Report, I visit with Fry Wenrick on the Hoskins jury instructions. [summary] =>

    In the Episode, I visit with Ephraim (Fry) Wernick. He is a partner in the Government Investigations and White-Collar Practice Group at Vinson & Elkins LLP in Washington, DC. Mr. Wernick joined V&E in June 2019 after serving 11 years as a federal prosecutor, including most recently as Assistant Chief of the U.S. Department of Justice, Criminal Division’s Fraud Section, where he supervised dozens of FCPA cases, including four of the largest-ever corporate criminal resolutions. Mr. Wernick now represents public and private companies and individuals in connection with government and internal investigations. Mr. Wernick is a graduate of Brown University and the University of Texas School of Law. In this podcast we take a deep dive into the jury instructions in the recent Hoskins FCPA trial. Some of the highlights include:

    • What was the procedural history of the Hoskins case leading up to trial?
    • The court’s agency instruction required the government to establish three elements: (1) “a manifestation by the principal that the agent will act for it”; (2) “acceptance by the agent of the undertaking”; and (3) “an understanding between the agent and the principal that the principal will be in control of the undertaking.” The court further instructed that “[t]he undertaking consists of the acts or services which the agent performs on behalf of the principal.” Hoskins’ arguments focus primarily on the element of control. Did the DOJ satisfy this element?
    • At trial, the DOJ presented evidence that although Hoskins worked for the French parent, for the purposes of his actions around bribery and corruption, he was the agent of the US subsidiary. What was some of evidence presented at trial to show agency? Will it be enough to satisfy the Second Circuit definition in the inevitable appeal?
    • At the ACI National Conference, Assistant Attorney General Brian Benczkowski said that the DOJ would analyze each case individually to determine if there was such an agency relationship present. What will the DOJ likely take into account?
    • Might there be further clarification from the trial court or Second Circuit?
    • Does the DOJ trial win against Hoskins open up wider individual prosecutions under the FCPA for foreign employees of foreign subsidiaries who may never set foot in the US?

    Resources

    Vinson and Elkins’ firm page on Fry Wernick

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  • In the Episode, I visit with Ephraim (Fry) Wernick. He...
  • Array ( [id] => a73085fe-2a74-11ea-8532-fff1617f44d6 [createdAt] => 2019-12-29T14:51:49.763-05:00 [updatedAt] => 2020-01-01T12:21:47.163-05:00 [title] => Day 5 | The Board and operationalizing compliance [pubdate] => 2020-01-05T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/a73085fe-2a74-11ea-8532-fff1617f44d6/image/uploads_2F1577648916616-4ytgob1mj9t-f8f57dbce253ea6830cbabf82b990f30_2F5.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 5 [subtitle] => In Day 5 of 31 days to a more effective compliance program, I consider the role of the Board of Directors in both oversight and operationalizing compliance. [summary] =>

    In addition to a company’s senior management, there is a Board of Directors at the top. Yet the role of the Board is different than that of senior management. For the Board of Director, the Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) stated:

    Oversight – What compliance expertise has been available on the board of directors? Have the board of directors and/or external auditors held executive or private sessions with the compliance and control functions? What types of information have the board of directors and senior management examined in their exercise of oversight in the area in which the misconduct occurred?

     The DOJ Antitrust Division’s Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (Antitrust Compliance Program Guidance) was even more explicit in announcing  their expectation for robust Board oversight of a corporate compliance function. The Antitrust Compliance Program Guidance stated “For the antitrust compliance program to be effective, those with operational responsibility for the program must have sufficient autonomy, authority, and seniority within the company’s governance structure, as well as adequate resources for training, monitoring, auditing and periodic evaluation of the program. The Antitrust Compliance Program Guidance then went on to ask the following questions: Who has overall responsibility for the antitrust compliance program? Is there a chief compliance officer or executive within the company responsible for antitrust compliance? If so, to whom does the individual report, e.g., the Board of Directors, audit committee, or other governing body? How often does the compliance officer or executive meet with the Board, audit committee, or other governing body? How does the company ensure the independence of its compliance personnel? 

     Three key takeaways:

    1. The DOJ Evaluation requires active Board of Director engagement and oversight around compliance.
    2. Board communication on compliance is a two-way street; both inbound and outbound.
    3. Does the Board of Directors have a Compliance Expert?
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  • In addition to a company’s senior management, there is a...
  • Array ( [id] => 73f314f0-2a73-11ea-9627-1ff8c024fb12 [createdAt] => 2019-12-29T14:43:14.303-05:00 [updatedAt] => 2020-01-01T12:23:41.571-05:00 [title] => Day 4 | Moving compliance tone down through an organization [pubdate] => 2020-01-04T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/73f314f0-2a73-11ea-9627-1ff8c024fb12/image/uploads_2F1577648541305-szz2e8769aa-28962643d2e598bb8494ef4ece2facb8_2F4.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In Day 4 of 31 days to a more effective compliance program, I consider how best to move tone downward into the middle and lower ranks of a corporation. [summary] =>

    Mike Volkov, in a blog post entitled “Mood in the Middle Versus Tone at the Top”, said, “Even when a company does all the right things at the senior management level, the real issue is whether or not that culture has embedded itself in middle and lower management. A company’s culture is reflected in the values and beliefs that exist throughout the company.” To fully operationalize your compliance program, you must articulate the message of ethical values and doing business in compliance and then drive that message from the top down, throughout your organization.

    The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) made clear a company must have more than simply good ‘Tone-at-the-Top’; it must move down through the organization from senior management to middle management and into its lower ranks. This means that one task is to get middle management to respect the stated ethics and values of a company, because if they do so, this will be communicated down through the organization. The 2019 Guidance stated:

    Shared Commitment – What actions have senior leaders and middle-management stakeholders (e.g., business and operational managers, finance, procurement, legal, human resources) taken to demonstrate their commitment to compliance or compliance personnel, including their remediation efforts? Have they persisted in that commitment in the face of competing interests or business objectives?

    This requirement speaks to the greater role of non-compliance functions in fully operationalized compliance program. Indeed, one sign of a mature compliance and ethics program is the extent to which a company’s other corporate disciplines are involved in implementing and then taking forward a compliance solution. This approach can act as a lynch pin in spreading a company’s commitment to compliance throughout the employee base. It can also be used to ‘connect the dots’ in many divergent elements of a corporate compliance and ethics program.

    Three key takeaways:

    1. Tone at the top - direct supervisors become the most important influence on people in the company.
    2. Give your middle managers a Tool Kit around compliance so they can fully operationalize compliance.
    3. Organizational justice is an additional way to help operationalize compliance.
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  • Mike Volkov, in a blog post entitled “Mood in the...
  • Array ( [id] => 56218516-2a72-11ea-98ea-3fbfb62a99bc [createdAt] => 2019-12-29T14:35:14.767-05:00 [updatedAt] => 2019-12-29T14:35:41.739-05:00 [title] => Day 3 | Leadership’s conduct at the top [pubdate] => 2020-01-03T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/56218516-2a72-11ea-98ea-3fbfb62a99bc/image/uploads_2F1577647912661-1x4wxhesmrt-7782f327d121717f20e6742fa9c65a4c_2F3.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => In this episode of 31 Days to a more effective compliance program we consider leadership's conduct at the top of an organization and it sets the ethical tone for every organization. [summary] =>

    Obviously, in every compliance program, the ethical tone of a company and accountability all starts at the top and most specifically senior management. The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) stated, “The company’s top leaders – the board of directors and executives – set the tone for the rest of the company. Prosecutors should examine the extent to which senior management have clearly articulated the company’s ethical standards, conveyed and disseminated them in clear and unambiguous terms, and demonstrated rigorous adherence by example. Prosecutors should also examine how middle management, in turn, have reinforced those standards and encouraged employees to abide by them.” To assist companies in understanding this requirement the 2019 Guidance sets out the following inquiries.

    Conduct at the Top – How have senior leaders, through their words and actions, encouraged or discouraged compliance, including the type of misconduct involved in the investigation? What concrete actions have they taken to demonstrate leadership in the company’s compliance and remediation efforts? How have they modelled proper behavior to subordinates? Have managers tolerated greater compliance risks in pursuit of new business or greater revenues? Have managers encouraged employees to act unethically to achieve a business objective, or impeded compliance personnel from effectively implementing their duties?

    This requirement is more than simply the ubiquitous “tone-at-the-top,” as it focuses on the conduct of senior management. The DOJ wants to see a company’s senior leadership actually doing compliance. The DOJ asks if company leadership has, through their words and concrete actions, brought the right message of doing business ethically and in compliance to the organization. How does senior management model its behavior on a company’s values and finally, how is such conduct monitored in an organization?

    Three key takeaways:

    1. Senior management must actually do compliance; walk-the-walk, not simply talk-the-talk.
    2. Use your CEO to talk about current events and how those ethical failures are lessons to be learned for your organization.
    3. CEO as Compliance Ambassador.
    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/56218516-2a72-11ea-98ea-3fbfb62a99bc/stripped_a7d171551a15db574557d8682dea0af8.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN7960252647.mp3 [size] => 17537567 [duration] => 438.44 [uid] => CSN7960252647 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/56218516-2a72-11ea-98ea-3fbfb62a99bc/id3/2c85eba2cf25e8903087948ed0eb7d64.mp3 [id3FileProcessing] => [id3FileSize] => 182981 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Day 3-Leadership's Conduct at the top - 12_27_19, 10.42 AM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • Obviously, in every compliance program, the ethical tone of a...
  • Array ( [id] => ddec43d2-268a-11ea-950c-e3f51a9c4f4d [createdAt] => 2019-12-24T15:20:45.867-05:00 [updatedAt] => 2019-12-24T15:20:52.119-05:00 [title] => Day 2 | Measuring your risk [pubdate] => 2020-01-02T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ddec43d2-268a-11ea-950c-e3f51a9c4f4d/image/uploads_2F1577218720554-c2bijttz74o-3999e08c78212e07ab8829a0b85ef1ee_2F2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 2 [subtitle] => In Day of 31 days to a more effective compliance program, we consider measuring your risk and then what to do with the information after you have obtained it. [summary] =>

    Operationalizing your compliance program can take many shapes and forms. Using the entire risk management process to embed your compliance program within the contours of your organization is an important key step that will allow you to have full visibility of your compliance risks through a longer life cycle. Forecasting allows you to consider your business strategy and wed the risks you can foresee. Risk assessments allow you to evaluate and measure known risks. Risk-based monitoring allows you to monitor both the compliance risks you know about and detect those you do not know, on an ongoing basis.

    Three key takeaways:

    1. The risk management process is an important backbone of operationalizing compliance.
    2. You should be able monitor and measure both known and unknown risks.
    3. All of these steps help a business to run more efficiently and more profitably.


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  • Operationalizing your compliance program can take many shapes and forms....
  • Array ( [id] => 1bc0a868-2683-11ea-b456-8302200d80a0 [createdAt] => 2019-12-24T14:25:13.629-05:00 [updatedAt] => 2019-12-28T15:20:26.094-05:00 [title] => Day 1 | What 2019 Brought to Compliance Programs [pubdate] => 2020-01-01T12:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/1bc0a868-2683-11ea-b456-8302200d80a0/image/uploads_2F1577214834405-w1jsjufl39i-d9517d342ef5d78f3a12cf3d2e47d2c3_2F1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 1 [subtitle] => In Day 1 of my podcast series on 31 Days to a More Effective Compliance Program, I discuss the key information from the regulators for the compliance practitioner. [summary] =>

    2019 was a very significant year for every compliance practitioner and compliance program. Not only was it the year with the single highest amount of FCPA enforcement actions, fines and penalties assessed against corporations but it also saw the greatest number of individual prosecutions. Yet perhaps most significantly there were three noteworthy releases of information by the federal government which directly impacted compliance professionals in 2019. Two came from the Department of Justice (DOJ) and one came from the Department of Treasury, Office of Foreign Asset Control (OFAC). These three guidances contributed to the continued evolution of what constitutes a best practices compliance program.

    Three key takeaways:

    1. The 2019 Compliance Guidance asks three key questions of every corporate compliance program and adds a mandate for culture assessment, management and improvement.
    2. The OFAC Framework mandates due diligence on not only third parties in the sales cycle but also vendors in the Supply Chain and customers as well.
    3. The Antitrust Division Compliance Evaluation adds a requirement for data analytics and statistical analysis in monitoring and continuous improvement.
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  • 2019 was a very significant year for every compliance practitioner...
  • Array ( [id] => 9e72ced8-2a6d-11ea-bc2b-a7b640090de0 [createdAt] => 2019-12-29T14:01:28.621-05:00 [updatedAt] => 2019-12-29T14:01:50.400-05:00 [title] => Karen Woody on the SEC year in FCPA Enforcement [pubdate] => 2019-12-30T00:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/9e72ced8-2a6d-11ea-bc2b-a7b640090de0/image/uploads_2F1577645632765-yrnv5xme24r-611b7bd22699efb518aff570587283f3_2FFCPAComplianceReport2.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In the Episode, I visit with Karen Woody, Assistant Professor of Law at Washington and Lee. We take a look at the most recent SEC year in FCPA enforcement and other issues facing the SEC. [summary] =>

    In the Episode, I visit with Karen Woody, Assistant Professor of Law at Washington and Lee. Karen was in private practice for many years before going into Academia. She specializes in the SEC and issues around the Commission. Some of the highlights include:

    • Karen moved this year from the Indiana University-Kelly School of Business to the Law School at Washington and Lee. We discuss some of the differences in teaching at a law school as opposed to a business school.
    • Karen assesses the SEC’s overall year in FCPA Enforcement.
    • Karen highlights some of the key SEC FCPA enforcement actions over the past year.
    • She provides insights into the upcoming Supreme Court consideration of Lui and Wang attack on profit disgorgement.
    • We consider SEC Chairman Clayton’s backing off on his attempt to cut whistleblower awards. Why did it fail?
    • Woody highlights some of the SEC enforcement areas she is paying the most attention to going forward.
    • We conclude with a look into the veiled land of the future and what Woody expects to see from the SEC in 2020.

    Resources

    Scholarly papers from Karen Woody, click here


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  • In the Episode, I visit with Karen Woody, Assistant Professor...
  • Array ( [id] => dbb929f4-187a-11ea-8c9b-4b514223f98f [createdAt] => 2019-12-06T17:50:53.953-05:00 [updatedAt] => 2019-12-06T17:51:07.408-05:00 [title] => Stacie Hartman on Whistleblowers, the CFTC and the FCPA [pubdate] => 2019-12-09T00:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/dbb929f4-187a-11ea-8c9b-4b514223f98f/image/uploads_2F1575671264834-i58f7vgymr-322f3c1555fef903d7c0059d1ca7d8f1_2FFCPAComplianceReport2.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 455 [subtitle] => In this Episode, I visit with Stacie Hartman, Partner at Steptoe and Johnson. We consider what these pieces of legislation overturn the SCt. decision in Digital Realty Trust might mean for the corporate compliance practitioner. [summary] =>

    In this episode I visit with Stacie Hartman, co-chair of the Financial Services Group at Steptoe & Johnson LLP. She offers insight in how this new appeal to whistleblowers could impact the type or volume of enforcement cases within the CFTC. Stacie leads major cases in courts around the country and in enforcement proceedings before the Commodity Futures Trading Commission (CFTC), Securities and Exchange Commission (SEC), and financial exchanges, as well as in investigations by the US Department of Justice (DOJ). She has a strong track record of helping her clients avoid prosecution completely or obtain settlements at record-low penalties.

     In July, the House passed the Whistleblower Protection Reform Act of 2019, which passed by a vote of 410-12. Last month the Senate introduced the Whistleblower Programs Improvement Act. In this podcast we consider what these pieces of legislation might mean for the corporate compliance practitioner.

    Some of the highlights include:

    • We consider if these pieces of legislation are in response to the Supreme Court decision in Digital Realty Trust?
    • If so, how do they remedy the Court’s decision?
    • Are there be ancillary issues involved?
    • Do they expand the definition of whistleblower?
    • What do they do for the timeframes for decisions on whistleblower awards at the SEC and CFTC?
    • Listeners are familiar with whistleblower process to the SEC. Have there been What if any are the differences in the process program run by to the CFTC?

     Resources

    Stacie Hartman firm profile

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  • In this episode I visit with Stacie Hartman, co-chair of...
  • Array ( [id] => dbb929f4-187a-11ea-8c9b-4b514223f98f [createdAt] => 2019-12-06T17:50:53.953-05:00 [updatedAt] => 2019-12-06T17:51:07.408-05:00 [title] => Stacie Hartman on Whistleblowers, the CFTC and the FCPA [pubdate] => 2019-12-09T00:00:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/dbb929f4-187a-11ea-8c9b-4b514223f98f/image/uploads_2F1575671264834-i58f7vgymr-322f3c1555fef903d7c0059d1ca7d8f1_2FFCPAComplianceReport2.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 455 [subtitle] => In this Episode, I visit with Stacie Hartman, Partner at Steptoe and Johnson. We consider what these pieces of legislation overturn the SCt. decision in Digital Realty Trust might mean for the corporate compliance practitioner. [summary] =>

    In this episode I visit with Stacie Hartman, co-chair of the Financial Services Group at Steptoe & Johnson LLP. She offers insight in how this new appeal to whistleblowers could impact the type or volume of enforcement cases within the CFTC. Stacie leads major cases in courts around the country and in enforcement proceedings before the Commodity Futures Trading Commission (CFTC), Securities and Exchange Commission (SEC), and financial exchanges, as well as in investigations by the US Department of Justice (DOJ). She has a strong track record of helping her clients avoid prosecution completely or obtain settlements at record-low penalties.

     In July, the House passed the Whistleblower Protection Reform Act of 2019, which passed by a vote of 410-12. Last month the Senate introduced the Whistleblower Programs Improvement Act. In this podcast we consider what these pieces of legislation might mean for the corporate compliance practitioner.

    Some of the highlights include:

    • We consider if these pieces of legislation are in response to the Supreme Court decision in Digital Realty Trust?
    • If so, how do they remedy the Court’s decision?
    • Are there be ancillary issues involved?
    • Do they expand the definition of whistleblower?
    • What do they do for the timeframes for decisions on whistleblower awards at the SEC and CFTC?
    • Listeners are familiar with whistleblower process to the SEC. Have there been What if any are the differences in the process program run by to the CFTC?

     Resources

    Stacie Hartman firm profile

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  • In this episode I visit with Stacie Hartman, co-chair of...
  • Array ( [id] => 9257a234-1624-11ea-8307-e70db06b1f16 [createdAt] => 2019-12-03T18:28:11.794-05:00 [updatedAt] => 2019-12-04T11:13:50.551-05:00 [title] => Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 5: Developments from Brazil with Salim Saud [pubdate] => 2019-12-04T11:13:46.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/9257a234-1624-11ea-8307-e70db06b1f16/image/uploads_2F1575415679405-ffuj81c6fg8-3738b94755a69df385407a2338940b78_2FHHRLogoDad2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 5 [subtitle] => In this Part 5, I visit with Salim Saud, Partner at Saud Advogados, in cooperation with Hughes, Hubbard & Reed LLP, on developments in anti-bribery enforcement from Brazil from over the past year. [summary] =>

    Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard & Reed 2019 FCPA and Anti-Bribery Alert. I visit with five firm lawyers involved in the preparation of the report, each of whom is a subject matter expert in an area of the FCPA and anti-corruption. In this Part 5, I visit with Salim Saud, Partner at Saud Advogados, in cooperation with Hughes, Hubbard & Reed LLP, on developments in anti-bribery enforcement from Brazil from over the past year.

    Some of the highlights include:

    • What is the key role the CGU has taken over the past year?
    • How is the CGU currently assessing compliance programs?
    • What were some of the setbacks in Brazil over the year?
    • How can a company obtain a Leniency Agreement?
    • What are some key lessons for the compliance practitioner?

    Resources

    Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, click here.

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  • Welcome to a special five-part podcast series from the Compliance...
  • Array ( [id] => d753d1ac-1622-11ea-b841-5f0c78317c8a [createdAt] => 2019-12-03T18:15:48.537-05:00 [updatedAt] => 2019-12-04T11:13:22.849-05:00 [title] => Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 3: Anti-Bribery Enforcement in France with Bryan Sillaman [pubdate] => 2019-12-04T11:13:16.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/d753d1ac-1622-11ea-b841-5f0c78317c8a/image/uploads_2F1575414925448-6z5sa4mcw5w-e3a4e0bf93faa59f3b8dee8127505dae_2FHHRLogoDad2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => In this Part 3, I visit with Bryan Sillaman, Managing Partner of the firm’s Paris office, on developments in France regarding anti-bribery enforcement over the past year. [summary] =>

    Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard & Reed 2019 FCPA and Anti-Bribery Alert. I visit with five firm lawyers involved in the preparation of the report, each of whom is a subject matter expert in an area of the FCPA and anti-corruption. In this Part 3, I visit with Bryan Sillaman, Managing Partner of the firm’s Paris office, on developments in France regarding anti-bribery enforcement over the past year.

    Some of the highlights include:

    • What were the anti-bribery prosecutions under Sapin II?
    • What were the first decisions by the AFA on compliance programs?
    • What were changes in whistleblower protection over the past year in France?
    • Why are the developments of a DPA equivalent so significant in France?
    • What the requirement for entering into a settlement agreement in France?

    Resources

    Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, click here.

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  • Welcome to a special five-part podcast series from the Compliance...
  • Array ( [id] => d753d1ac-1622-11ea-b841-5f0c78317c8a [createdAt] => 2019-12-03T18:15:48.537-05:00 [updatedAt] => 2019-12-04T11:13:22.849-05:00 [title] => Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 3: Anti-Bribery Enforcement in France with Bryan Sillaman [pubdate] => 2019-12-04T11:13:16.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/d753d1ac-1622-11ea-b841-5f0c78317c8a/image/uploads_2F1575414925448-6z5sa4mcw5w-e3a4e0bf93faa59f3b8dee8127505dae_2FHHRLogoDad2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => In this Part 3, I visit with Bryan Sillaman, Managing Partner of the firm’s Paris office, on developments in France regarding anti-bribery enforcement over the past year. [summary] =>

    Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard & Reed 2019 FCPA and Anti-Bribery Alert. I visit with five firm lawyers involved in the preparation of the report, each of whom is a subject matter expert in an area of the FCPA and anti-corruption. In this Part 3, I visit with Bryan Sillaman, Managing Partner of the firm’s Paris office, on developments in France regarding anti-bribery enforcement over the past year.

    Some of the highlights include:

    • What were the anti-bribery prosecutions under Sapin II?
    • What were the first decisions by the AFA on compliance programs?
    • What were changes in whistleblower protection over the past year in France?
    • Why are the developments of a DPA equivalent so significant in France?
    • What the requirement for entering into a settlement agreement in France?

    Resources

    Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, click here.

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  • Welcome to a special five-part podcast series from the Compliance...
  • Array ( [id] => c026d046-1623-11ea-b841-3bdd800d577e [createdAt] => 2019-12-03T18:22:19.151-05:00 [updatedAt] => 2019-12-03T18:22:28.925-05:00 [title] => Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 4: Developments from Multilateral Development Banks with Michael DeBernardis [pubdate] => 2019-12-04T09:06:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/c026d046-1623-11ea-b841-3bdd800d577e/image/uploads_2F1575415324753-md3y62o0o9m-be2a8f5660932516fdeef71d93a7376f_2FHHRLogoDad2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In this Part 4, I visit with Michael DeBernardis, on developments from Multilateral Development Banks in the fight against bribery and corruption over the past year. [summary] =>

    Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard & Reed 2019 FCPA and Anti-Bribery Alert. I visit with five firm lawyers involved in the preparation of the report, each of whom is a subject matter expert in an area of the FCPA and anti-corruption. In this Part 4, I visit with Michael DeBernardis, on developments from Multilateral Development Banks in the fight against bribery and corruption over the past year.

    Some of the highlights include:

    • What is the role of Multilateral Development Banks in the fight against bribery and corruption?
    • What were the key enforcement actions reported by the World Bank?
    • What were changes in whistleblower protection over the past year in France?
    • Why are these developments so significant?
    • What are some key lessons for the compliance practitioner?

    Resources

    Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, click here.

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  • Welcome to a special five-part podcast series from the Compliance...
  • Array ( [id] => c026d046-1623-11ea-b841-3bdd800d577e [createdAt] => 2019-12-03T18:22:19.151-05:00 [updatedAt] => 2019-12-03T18:22:28.925-05:00 [title] => Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 4: Developments from Multilateral Development Banks with Michael DeBernardis [pubdate] => 2019-12-04T09:06:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/c026d046-1623-11ea-b841-3bdd800d577e/image/uploads_2F1575415324753-md3y62o0o9m-be2a8f5660932516fdeef71d93a7376f_2FHHRLogoDad2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In this Part 4, I visit with Michael DeBernardis, on developments from Multilateral Development Banks in the fight against bribery and corruption over the past year. [summary] =>

    Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard & Reed 2019 FCPA and Anti-Bribery Alert. I visit with five firm lawyers involved in the preparation of the report, each of whom is a subject matter expert in an area of the FCPA and anti-corruption. In this Part 4, I visit with Michael DeBernardis, on developments from Multilateral Development Banks in the fight against bribery and corruption over the past year.

    Some of the highlights include:

    • What is the role of Multilateral Development Banks in the fight against bribery and corruption?
    • What were the key enforcement actions reported by the World Bank?
    • What were changes in whistleblower protection over the past year in France?
    • Why are these developments so significant?
    • What are some key lessons for the compliance practitioner?

    Resources

    Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, click here.

    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/c026d046-1623-11ea-b841-3bdd800d577e/stripped_cbbec71c3e8c718c9bc3f8746226560a.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN5881312150.mp3 [size] => 29188179 [duration] => 729.7 [uid] => CSN5881312150 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/c026d046-1623-11ea-b841-3bdd800d577e/id3/abfd34053e8a74dfff13a987626ec7fc.mp3 [id3FileProcessing] => [id3FileSize] => 180569 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Episode 4-Mike D on MDBs - 12_3_19, 3.41 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • Welcome to a special five-part podcast series from the Compliance...
  • Array ( [id] => a449bb0a-146f-11ea-8409-bb4d94f9459b [createdAt] => 2019-12-01T14:20:31.832-05:00 [updatedAt] => 2019-12-01T14:20:41.306-05:00 [title] => Mikhail Gordon on Aspects of Monitorships: Part 4, Cultural Differences in Int'l and Domestic US Monitorships [pubdate] => 2019-12-02T00:08:00.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/a449bb0a-146f-11ea-8409-bb4d94f9459b/image/uploads_2F1575227728302-ukiqwhpcz2-6f9df2ebfa690ed95dbe10e28bca6226_2FMG_Podcast_11.2019_square.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In this special five-part podcast series, I am joined by Mikhail Reider-Gordon, Managing Director of Global Affairs at Affiliated Monitors, Inc. (AMI). In Part 4, we consider the cultural differences between international and US domestic monitorships. [summary] =>

    In this special five-part podcast series, I am joined by Mikhail Reider-Gordon, Managing Director of Global Affairs at Affiliated Monitors, Inc. (AMI) the sponsor of this podcast series. In this series we discuss various aspects of monitorships, including why independence matters, the American Bar Association’s (ABA) Guidelines on Monitors, Gordon’s professorial career at the International Anti-Corruption Academy, cultural differences between international and US domestic monitorships and the continuing evolution in monitorships. In Part 4, we consider the cultural differences between international and US domestic monitorships. Highlights include:

    ·       How do cultural differences and legal process affect the structures a monitorship of an entity or individuals?

    ·       Differences between US and other countries related to dealing with Corporations and Individuals?

    ·       Why are cultural considerations important for a monitor working with multi-nationals?

    ·       How does working with foreign regulators impact the consideration for a monitor?

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  • In this special five-part podcast series, I am joined by...
  • Array ( [id] => a312c714-0a2d-11ea-85e9-5f131addc3d7 [createdAt] => 2019-11-18T13:02:51.381-05:00 [updatedAt] => 2019-11-18T13:03:38.409-05:00 [title] => Update on Varsity Blues [pubdate] => 2019-11-18T12:53:37.000-05:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/a312c714-0a2d-11ea-85e9-5f131addc3d7/image/uploads_2F1574100148707-qo4fwppw1h-279c52ea19b3f748043bf22925fe7850_2FFCPAComplianceReport2.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 453 [subtitle] => In this episode of the FCPA Compliance Report, I visit with Benjamin Brtiz, partner at Hughes Hubbard & Reed. We consider the current state of the Varsity Blues prosecutions, where they have been and where they may headed. [summary] =>

    In this episode I visit with Benjamin Britz, a partner at Hughes Hubbard & Reed. We review the current state of the Varsity Blues prosecutions, including the guilty pleas and those still maintaining their innocence. We consider the evidence presented and where the case may be heading.

    Britz advises clients on all aspects of corporate governance including government investigations, shareholder class action and derivative litigation, and corporate compliance matters. He has represented clients before all manner of domestic and international enforcement agencies, including the Department of Justice, Securities and Exchange Commission, UK Serious Fraud Office and the enforcement offices of the World Bank, Asian Development Bank and African Development Bank, among others. His practice particularly focuses on anti-corruption compliance, securities enforcement, and accounting and procurement fraud matters. He has performed internal investigations and due diligence exercises around the globe and across an array of different industries.

    Some of the highlights include:

    • What is the current state of prosecutions?
    • What evidence has been presented?
    • Might there be ancillary issues involved?
    • What will be the fallout for the cooperating witnesses?
    • Is money laundering a viable prosecution strategy?
    • Will the IRS become involved?


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  • In this episode I visit with Benjamin Britz, a partner...
  • Array ( [id] => 83a119d2-f1b7-11e9-b2ca-1fce92075666 [createdAt] => 2019-10-18T10:56:50.100-04:00 [updatedAt] => 2019-10-19T11:28:40.887-04:00 [title] => Francine McKenna with an update on the KPMG-PCAOB Scandal [pubdate] => 2019-10-21T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/83a119d2-f1b7-11e9-b2ca-1fce92075666/image/uploads_2F1571498905636-1ywhby7e2a3-72824d3ad607b3a22f273e59075c15bf_2FFCPAComplianceReport2.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 449 [subtitle] => In this episode I visit with Francine McKenna, a reporter at MarketWatch. We check in on the current developments in the KPMG-PCAOB scandal including recent guilty pleas, sentencing and where the matter might finally be headed. [summary] =>


    In this episode I visit with one of my favorite people, Francine McKenna, a reporter at MarketWatch. We check in on the current developments in the KPMG-PCAOB scandal including recent guilty pleas, sentencing and where the matter might finally be headed. Some of the highlights include:

    ·       A review of the Indictment and underlying facts.

    ·       A review of the horrendous facts about KPMG that came out during the March trial.  

    ·       What does it say about the PCAOB that two of its former Board members were witnesses for the defense in the trial? 

    ·       What did all this mean for KPMG head Lynne Doughtie? What does all this mean for audit independence, particularly in the Jay Clayton era at the SEC?

    ·       Where can listeners go for more information?

    Resources

    Francine McKenna on MarketWatch

    MarketWatch website

    Re: The Auditors blogsite

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  • In this episode I visit with one of my favorite people,...
  • Array ( [id] => e1c6ef6c-edb3-11e9-b5a2-ef5b1d7aa8e1 [createdAt] => 2019-10-13T08:20:45.421-04:00 [updatedAt] => 2019-10-13T13:14:25.301-04:00 [title] => Parth Chanda on integrating data analytics into a compliance platform [pubdate] => 2019-10-14T00:10:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/e1c6ef6c-edb3-11e9-b5a2-ef5b1d7aa8e1/image/uploads_2F1570969185599-pz16ofbltuf-21599b6de11ec30cd1b042e0a9d0cf0d_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 448 [subtitle] => In this episode I visit with Parth Chanda, CEO of Lextegrity, a leading technology platform that combines the up-front due diligence approval of planned third-party spend with the analysis of actual spend — focused on fraud, corruption and conflicts of interest. [summary] =>

    In this episode I visit with Parth Chanda, CEO of Lextegrity, a leading technology platform that combines the up-front due diligence approval of planned third-party spend with the analysis of actual spend — focused on fraud, corruption and conflicts of interest. Some of the highlights include: ·       Professional background for Chanda, with nearly 20 years in compliance.·       Some of the problems the Lextegrity Integrity platform is addressing with for compliance professionals?  ·       What traditional challenges do CCO’s face when they try to deploy compliance monitoring solutions? They include:a.     Employees lacking sufficient tools to assess risk and take ownership of their own compliance.b.     Complex reports or analytics for the business users not user-friendly or intuitive.c.      Too few legal, compliance, IT and anti-fraud resources to support the business or continuous monitoring efforts.d.     Disorganized and disparate data stores.e.     Risks managed in multiple systems that don’t “talk to each other” or require duplicate entry or manual data input processes.f.      Not having real-time analytics, reporting or monitoring, which leads to missed anomalies and patterns.·       In September’s FRAUD Magazine innovation column authored by Vincent Walden he quoted you for the following, “Avoiding professional biases in your fraud risk management program”.  How does the Lextegrity platform help avoid bias and integrating typical compliance functions with traditional internal audit functions?·       How does the Lextegrity platform integrate both pre-approvals and monitoring?  What are the benefits to that as compared to what’s in the market?·       What’s the benefits to General Counsels and heads of investigations from the platform and about how the machine learning aspects help companies be more strategic and effective? ·       What advice do you have for CCOs and General Counsels when they are evaluating the use of data analytics into their compliance program?·       Where can listeners go for more information? ResourcesParth ChandaLextegrity websiteArticle “Avoiding Bias in Your Fraud Management Program” by Vince Walden in September/October issue of Fraud Magazine

    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/e1c6ef6c-edb3-11e9-b5a2-ef5b1d7aa8e1/stripped_9c95da5fc598526382a5c2bde15cb92a.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN1067874497.mp3 [size] => 69547362 [duration] => 1738.68 [uid] => CSN1067874497 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/e1c6ef6c-edb3-11e9-b5a2-ef5b1d7aa8e1/id3/6aef5ad97902e23c99d5de1c9d054b2d.mp3 [id3FileProcessing] => [id3FileSize] => 234095 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => 448.Parth Chandra - 10_13_19, 6.53 AM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • In this episode I visit with Parth Chanda, CEO of...
  • Array ( [id] => e1c6ef6c-edb3-11e9-b5a2-ef5b1d7aa8e1 [createdAt] => 2019-10-13T08:20:45.421-04:00 [updatedAt] => 2019-10-13T13:14:25.301-04:00 [title] => Parth Chanda on integrating data analytics into a compliance platform [pubdate] => 2019-10-14T00:10:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/e1c6ef6c-edb3-11e9-b5a2-ef5b1d7aa8e1/image/uploads_2F1570969185599-pz16ofbltuf-21599b6de11ec30cd1b042e0a9d0cf0d_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 448 [subtitle] => In this episode I visit with Parth Chanda, CEO of Lextegrity, a leading technology platform that combines the up-front due diligence approval of planned third-party spend with the analysis of actual spend — focused on fraud, corruption and conflicts of interest. [summary] =>

    In this episode I visit with Parth Chanda, CEO of Lextegrity, a leading technology platform that combines the up-front due diligence approval of planned third-party spend with the analysis of actual spend — focused on fraud, corruption and conflicts of interest. Some of the highlights include: ·       Professional background for Chanda, with nearly 20 years in compliance.·       Some of the problems the Lextegrity Integrity platform is addressing with for compliance professionals?  ·       What traditional challenges do CCO’s face when they try to deploy compliance monitoring solutions? They include:a.     Employees lacking sufficient tools to assess risk and take ownership of their own compliance.b.     Complex reports or analytics for the business users not user-friendly or intuitive.c.      Too few legal, compliance, IT and anti-fraud resources to support the business or continuous monitoring efforts.d.     Disorganized and disparate data stores.e.     Risks managed in multiple systems that don’t “talk to each other” or require duplicate entry or manual data input processes.f.      Not having real-time analytics, reporting or monitoring, which leads to missed anomalies and patterns.·       In September’s FRAUD Magazine innovation column authored by Vincent Walden he quoted you for the following, “Avoiding professional biases in your fraud risk management program”.  How does the Lextegrity platform help avoid bias and integrating typical compliance functions with traditional internal audit functions?·       How does the Lextegrity platform integrate both pre-approvals and monitoring?  What are the benefits to that as compared to what’s in the market?·       What’s the benefits to General Counsels and heads of investigations from the platform and about how the machine learning aspects help companies be more strategic and effective? ·       What advice do you have for CCOs and General Counsels when they are evaluating the use of data analytics into their compliance program?·       Where can listeners go for more information? ResourcesParth ChandaLextegrity websiteArticle “Avoiding Bias in Your Fraud Management Program” by Vince Walden in September/October issue of Fraud Magazine

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  • In this episode I visit with Parth Chanda, CEO of...
  • Array ( [id] => ae69d4c0-eb8a-11e9-abaf-9b7775608572 [createdAt] => 2019-10-10T14:20:47.553-04:00 [updatedAt] => 2019-10-13T05:39:20.058-04:00 [title] => Why Culture Matters-Episode 5, How is ethical culture a part of an overall ethics and compliance assessment? [pubdate] => 2019-10-14T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ae69d4c0-eb8a-11e9-abaf-9b7775608572/image/uploads_2F1570959548546-tr0y8jv322s-0d8b24f044148832a64dc1b9d8765c1d_2FOct.Culture.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In this five-part podcast series sponsored by AMI, I visit with Jay Rosen on why culture matters. In Episode 5, we consider how ethical culture is a part of an overall ethics and compliance assessment. [summary] =>

    Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists in the space between what an organization professes and what it does. In this series Jay and I will be exploring key aspects of corporate culture, including why it matters, what influences culture, the CCOs role in culture, assessing corporate culture and how to use that information to improve culture. In this concluding Part V, we consider how an ethical culture is a part of an overall ethics and compliance assessment.

     Highlights include:Begin with framework for such an assessment, usually the compliance program itself.Is your training both focused and effective?Is there institutional fairness in your promotion and compensation programs?Is there institutional justice around reporting, discipline and investigations?Is your compliance program a paper program or is it fully operationalized?Is there accountability in your organization?For more information see Jay’s blog post How is ethical culture a part of an overall ethics and compliance assessment? on Corporate Compliance Insights.

    For more information on Affiliated Monitors, Inc. check out their website here.

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  • Welcome to this special five-part podcast series with Jay Rosen,...
  • Array ( [id] => ae69d4c0-eb8a-11e9-abaf-9b7775608572 [createdAt] => 2019-10-10T14:20:47.553-04:00 [updatedAt] => 2019-10-13T05:39:20.058-04:00 [title] => Why Culture Matters-Episode 5, How is ethical culture a part of an overall ethics and compliance assessment? [pubdate] => 2019-10-14T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ae69d4c0-eb8a-11e9-abaf-9b7775608572/image/uploads_2F1570959548546-tr0y8jv322s-0d8b24f044148832a64dc1b9d8765c1d_2FOct.Culture.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In this five-part podcast series sponsored by AMI, I visit with Jay Rosen on why culture matters. In Episode 5, we consider how ethical culture is a part of an overall ethics and compliance assessment. [summary] =>

    Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists in the space between what an organization professes and what it does. In this series Jay and I will be exploring key aspects of corporate culture, including why it matters, what influences culture, the CCOs role in culture, assessing corporate culture and how to use that information to improve culture. In this concluding Part V, we consider how an ethical culture is a part of an overall ethics and compliance assessment.

     Highlights include:Begin with framework for such an assessment, usually the compliance program itself.Is your training both focused and effective?Is there institutional fairness in your promotion and compensation programs?Is there institutional justice around reporting, discipline and investigations?Is your compliance program a paper program or is it fully operationalized?Is there accountability in your organization?For more information see Jay’s blog post How is ethical culture a part of an overall ethics and compliance assessment? on Corporate Compliance Insights.

    For more information on Affiliated Monitors, Inc. check out their website here.

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  • Welcome to this special five-part podcast series with Jay Rosen,...
  • Array ( [id] => eab592ba-e861-11e9-9aff-8b90fa696e36 [createdAt] => 2019-10-06T13:51:25.857-04:00 [updatedAt] => 2019-10-06T13:51:44.192-04:00 [title] => Joe Gerard on Conducting Fraud Investigations with Case Management Software [pubdate] => 2019-10-07T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/eab592ba-e861-11e9-9aff-8b90fa696e36/image/uploads_2F1570383682740-hepdyqasx9q-411d0813ba2caadbf4c1f2b03e56ac57_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In this episode, I visit with Joe Gerard, CEO at I-Sight SW on how case management software improves your fraud and corruption investigations. [summary] =>

    In this episode I visit with Joe Gerard, CEO of i-Sight Software. We consider i-Sight’s recent eBook, Conducting Fraud Investigations with Case Management Software and how case management software facilitates the investigative process. Some of the highlights include: What is iSight Software and what are some of its services, products and tools. What is Case Management Software?How does it assist corporate fraud investigations? How does it help both accuracy and speed?Gerard provides an example of how case management SW works.How case management SW streamlines a pre-existing investigative process?What is the ROI of case management SW?What are some of the differences between homegrown case management solutions (or worse yet—spreadsheets) and case management SW?Where can listeners go for more information? ResourcesJoe Gerardi-Sight SoftwareeBook on Conducting Fraud Investigations with Case Management SW

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  • In this episode I visit with Joe Gerard, CEO of...
  • Array ( [id] => eab592ba-e861-11e9-9aff-8b90fa696e36 [createdAt] => 2019-10-06T13:51:25.857-04:00 [updatedAt] => 2019-10-06T13:51:44.192-04:00 [title] => Joe Gerard on Conducting Fraud Investigations with Case Management Software [pubdate] => 2019-10-07T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/eab592ba-e861-11e9-9aff-8b90fa696e36/image/uploads_2F1570383682740-hepdyqasx9q-411d0813ba2caadbf4c1f2b03e56ac57_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In this episode, I visit with Joe Gerard, CEO at I-Sight SW on how case management software improves your fraud and corruption investigations. [summary] =>

    In this episode I visit with Joe Gerard, CEO of i-Sight Software. We consider i-Sight’s recent eBook, Conducting Fraud Investigations with Case Management Software and how case management software facilitates the investigative process. Some of the highlights include: What is iSight Software and what are some of its services, products and tools. What is Case Management Software?How does it assist corporate fraud investigations? How does it help both accuracy and speed?Gerard provides an example of how case management SW works.How case management SW streamlines a pre-existing investigative process?What is the ROI of case management SW?What are some of the differences between homegrown case management solutions (or worse yet—spreadsheets) and case management SW?Where can listeners go for more information? ResourcesJoe Gerardi-Sight SoftwareeBook on Conducting Fraud Investigations with Case Management SW

    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/eab592ba-e861-11e9-9aff-8b90fa696e36/stripped_aa4994c1a096250b1deaf515c6bdd343.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN8414307474.mp3 [size] => 58074382 [duration] => 1451.86 [uid] => CSN8414307474 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/eab592ba-e861-11e9-9aff-8b90fa696e36/id3/765bc8e2462d003b21b9c46509cbb94d.mp3 [id3FileProcessing] => [id3FileSize] => 230953 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => 447.Joe Gerard - 10_6_19, 12.35 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • In this episode I visit with Joe Gerard, CEO of...
  • Array ( [id] => f85b9e14-e5cd-11e9-bcfc-e7c1552cfe0a [createdAt] => 2019-10-03T07:07:20.916-04:00 [updatedAt] => 2019-10-03T07:07:42.270-04:00 [title] => The Future of Financial Compliance-Challenging Accepted Wisdom [pubdate] => 2019-10-03T07:03:52.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f85b9e14-e5cd-11e9-bcfc-e7c1552cfe0a/image/uploads_2F1570100733639-0l8zzf2wk8r-e4f17e7c7ebcd7daf60f246f3ef5b494_2FVerint%2BPodcasts%2BArtwork.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Verint takes a unique approach to financial compliance. Verint does not accept that legacy solutions and methods are good enough for its client’s needs but challenges the conventional wisdom and accepted practices. In this Episode 1, we introduce the concept of the Verint Process. [summary] =>

    In this special five-part podcast series, I visit with Phil Fry, VP Go To Market at Verint, which is the sponsor of this podcast series. In this podcast series, we consider how Verint is changing the future of financial compliance by challenging the accept wisdom through capture, control, sustainability & oversight. I found this process as useful to think through a wide range and assortment of compliance issues for any compliance field: anticorruption compliance; trade compliance; AML compliance or any other type of compliance. Today in Part 1, we begin with an overview of the process.

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  • In this special five-part podcast series, I visit with Phil...
  • Array ( [id] => f85b9e14-e5cd-11e9-bcfc-e7c1552cfe0a [createdAt] => 2019-10-03T07:07:20.916-04:00 [updatedAt] => 2019-10-03T07:07:42.270-04:00 [title] => The Future of Financial Compliance-Challenging Accepted Wisdom [pubdate] => 2019-10-03T07:03:52.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f85b9e14-e5cd-11e9-bcfc-e7c1552cfe0a/image/uploads_2F1570100733639-0l8zzf2wk8r-e4f17e7c7ebcd7daf60f246f3ef5b494_2FVerint%2BPodcasts%2BArtwork.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Verint takes a unique approach to financial compliance. Verint does not accept that legacy solutions and methods are good enough for its client’s needs but challenges the conventional wisdom and accepted practices. In this Episode 1, we introduce the concept of the Verint Process. [summary] =>

    In this special five-part podcast series, I visit with Phil Fry, VP Go To Market at Verint, which is the sponsor of this podcast series. In this podcast series, we consider how Verint is changing the future of financial compliance by challenging the accept wisdom through capture, control, sustainability & oversight. I found this process as useful to think through a wide range and assortment of compliance issues for any compliance field: anticorruption compliance; trade compliance; AML compliance or any other type of compliance. Today in Part 1, we begin with an overview of the process.

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  • In this special five-part podcast series, I visit with Phil...
  • Array ( [id] => c14590aa-e236-11e9-bfdc-a38c539d18f0 [createdAt] => 2019-09-28T17:27:20.998-04:00 [updatedAt] => 2019-09-29T13:12:23.672-04:00 [title] => The Future of Financial Compliance: Control [pubdate] => 2019-10-02T10:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/c14590aa-e236-11e9-bfdc-a38c539d18f0/image/uploads_2F1569705952787-m4fdd1ptaz8-91dcc62f7daa989cdcc16dc4469cd8cb_2FVerint%2BPodcasts%2BArtwork.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => Today in Part 3, we discuss control. [summary] =>

    In this special five-part podcast series, I visit with Phil Fry, VP Go To Market at Verint, which is the sponsor of this podcast series. In this podcast series, we consider how Verint is changing the future of financial compliance by challenging the accept wisdom through capture, control, sustainability & oversight. I found this process as useful to think through a wide range and assortment of compliance issues for any compliance field: anticorruption compliance; trade compliance; AML compliance or any other type of compliance. Today in Part 3, we discuss control. (The Verint process is so innovative, I have cross-posted the entire series on Innovation in Compliance this week as well.)  Verint, a provider of reactive, active and proactive compliance solutions for the new regulatory environment.

    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/c14590aa-e236-11e9-bfdc-a38c539d18f0/stripped_15d8aae703dd62e9413db88ba116e7b1.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN4466241061.mp3 [size] => 6758400 [duration] => 563.2 [uid] => CSN4466241061 [originalUrl] => [bitrate] => 96 [samplerate] => 44100 [channelMode] => mono [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/c14590aa-e236-11e9-bfdc-a38c539d18f0/id3/573857cf3e8373a1f7f669e9944daa11.mp3 [id3FileProcessing] => [id3FileSize] => 229947 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Episode 3-Control - 9_29_19, 10.29 AM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • In this special five-part podcast series, I visit with Phil...
  • Array ( [id] => c14590aa-e236-11e9-bfdc-a38c539d18f0 [createdAt] => 2019-09-28T17:27:20.998-04:00 [updatedAt] => 2019-09-29T13:12:23.672-04:00 [title] => The Future of Financial Compliance: Control [pubdate] => 2019-10-02T10:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/c14590aa-e236-11e9-bfdc-a38c539d18f0/image/uploads_2F1569705952787-m4fdd1ptaz8-91dcc62f7daa989cdcc16dc4469cd8cb_2FVerint%2BPodcasts%2BArtwork.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => Today in Part 3, we discuss control. [summary] =>

    In this special five-part podcast series, I visit with Phil Fry, VP Go To Market at Verint, which is the sponsor of this podcast series. In this podcast series, we consider how Verint is changing the future of financial compliance by challenging the accept wisdom through capture, control, sustainability & oversight. I found this process as useful to think through a wide range and assortment of compliance issues for any compliance field: anticorruption compliance; trade compliance; AML compliance or any other type of compliance. Today in Part 3, we discuss control. (The Verint process is so innovative, I have cross-posted the entire series on Innovation in Compliance this week as well.)  Verint, a provider of reactive, active and proactive compliance solutions for the new regulatory environment.

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  • In this special five-part podcast series, I visit with Phil...
  • Array ( [id] => b2931f12-db1c-11e9-8a18-d3ab0f20321e [createdAt] => 2019-09-19T16:33:11.291-04:00 [updatedAt] => 2019-09-19T16:33:23.306-04:00 [title] => Episode 445- Shon Ramey on the Navex Global Acquisition of Lockpath [pubdate] => 2019-09-23T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/b2931f12-db1c-11e9-8a18-d3ab0f20321e/image/uploads_2F1568925138488-hvv65woymdm-ad0647c07de4798d844be91bd1a5c90d_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In this episode I visit with Shon Ramey, General Counsel at Navex Global. We discuss Navex’s recent acquisition of Lockpath. In addition to his discussion on how Lockpath fits into the strategic plan of Navex Global, Ramey discusses his approach to mergers and acquisitions. [summary] =>

    In this episode I visit with Shon Ramey, General Counsel at Navex Global. We discuss Navex’s recent acquisition of Lockpath. In addition to his discussion on how Lockpath fits into the strategic plan of Navex Global, Ramey discusses his approach to mergers and acquisitions. Highlights from the podcast include:Why did Navex Global see this acquisition of Lockpath as an opportunity?How does this acquisition provide Navex Global with a more holistic approach to GRC solutions?Cyber security and data breaches have become an important part of M&A pre-acquisition Due Diligence. Can you outline your approach to these issues?Why is it important to have a defined acquisition procedure, which details an acquisition from pre-contact of a target through full integration in place?As the top lawyer for an ethics and compliance software and risk management, you must be hyper-aware of the myriad threats facing companies these days. What, in your experience, are some of the threats most overlooked by businesses?For additional information, see Navex Global Press Release announcing the sale.

    See article by Phillip Bantz in Corporate Counsel entitled “NAVEX Global General Counsel Discusses M&A Due Diligence”.

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  • In this episode I visit with Shon Ramey, General Counsel...
  • Array ( [id] => b2931f12-db1c-11e9-8a18-d3ab0f20321e [createdAt] => 2019-09-19T16:33:11.291-04:00 [updatedAt] => 2019-09-19T16:33:23.306-04:00 [title] => Episode 445- Shon Ramey on the Navex Global Acquisition of Lockpath [pubdate] => 2019-09-23T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/b2931f12-db1c-11e9-8a18-d3ab0f20321e/image/uploads_2F1568925138488-hvv65woymdm-ad0647c07de4798d844be91bd1a5c90d_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In this episode I visit with Shon Ramey, General Counsel at Navex Global. We discuss Navex’s recent acquisition of Lockpath. In addition to his discussion on how Lockpath fits into the strategic plan of Navex Global, Ramey discusses his approach to mergers and acquisitions. [summary] =>

    In this episode I visit with Shon Ramey, General Counsel at Navex Global. We discuss Navex’s recent acquisition of Lockpath. In addition to his discussion on how Lockpath fits into the strategic plan of Navex Global, Ramey discusses his approach to mergers and acquisitions. Highlights from the podcast include:Why did Navex Global see this acquisition of Lockpath as an opportunity?How does this acquisition provide Navex Global with a more holistic approach to GRC solutions?Cyber security and data breaches have become an important part of M&A pre-acquisition Due Diligence. Can you outline your approach to these issues?Why is it important to have a defined acquisition procedure, which details an acquisition from pre-contact of a target through full integration in place?As the top lawyer for an ethics and compliance software and risk management, you must be hyper-aware of the myriad threats facing companies these days. What, in your experience, are some of the threats most overlooked by businesses?For additional information, see Navex Global Press Release announcing the sale.

    See article by Phillip Bantz in Corporate Counsel entitled “NAVEX Global General Counsel Discusses M&A Due Diligence”.

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  • In this episode I visit with Shon Ramey, General Counsel...
  • Array ( [id] => e2bb974e-cf5c-11e9-b857-373fc21cfab5 [createdAt] => 2019-09-04T17:42:25.925-04:00 [updatedAt] => 2019-09-04T17:42:42.962-04:00 [title] => James Koukios on the Morrison and Foerster Top 10 International Anti-Corruption Developments for April 2019 [pubdate] => 2019-09-09T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/e2bb974e-cf5c-11e9-b857-373fc21cfab5/image/uploads_2F1567633117451-5x5mae8ofjj-27b283b2a8655f238f79d443db360024_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 443 [subtitle] => In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for April 2019. We look at some of the key international developments.   [summary] =>

    In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for April 2019. We look at some of the key international developments.  Highlights from the podcast include:The debate Over Meaning of “Agent” Under FCPA Intensifies Ahead of Hoskins Trial.Federal Court Finds FCPA Investigation Documents Protected by Attorney-Client Privilege.International Maritime Organization (IMO) Sets Anti-Corruption Agenda.We take a deep dive into the new Evaluation of Corporate Compliance Programs, 2019 Guidance. What is new (if anything)? How does this assist the corporate compliance professional? Should it be read in conjunction with the Benczkowski Memo?To see a copy of the Morrison and Foerster Top 10 International Anti-Corruption Developments for April 2019, click here.

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  • In this episode I visit with podcast favorite Morrison and...
  • Array ( [id] => e2bb974e-cf5c-11e9-b857-373fc21cfab5 [createdAt] => 2019-09-04T17:42:25.925-04:00 [updatedAt] => 2019-09-04T17:42:42.962-04:00 [title] => James Koukios on the Morrison and Foerster Top 10 International Anti-Corruption Developments for April 2019 [pubdate] => 2019-09-09T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/e2bb974e-cf5c-11e9-b857-373fc21cfab5/image/uploads_2F1567633117451-5x5mae8ofjj-27b283b2a8655f238f79d443db360024_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 443 [subtitle] => In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for April 2019. We look at some of the key international developments.   [summary] =>

    In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for April 2019. We look at some of the key international developments.  Highlights from the podcast include:The debate Over Meaning of “Agent” Under FCPA Intensifies Ahead of Hoskins Trial.Federal Court Finds FCPA Investigation Documents Protected by Attorney-Client Privilege.International Maritime Organization (IMO) Sets Anti-Corruption Agenda.We take a deep dive into the new Evaluation of Corporate Compliance Programs, 2019 Guidance. What is new (if anything)? How does this assist the corporate compliance professional? Should it be read in conjunction with the Benczkowski Memo?To see a copy of the Morrison and Foerster Top 10 International Anti-Corruption Developments for April 2019, click here.

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  • In this episode I visit with podcast favorite Morrison and...
  • Array ( [id] => daff07b8-c1b8-11e9-ab91-332ea49871cc [createdAt] => 2019-08-18T09:05:30.364-04:00 [updatedAt] => 2019-08-18T09:05:56.819-04:00 [title] => Episode 441- Compliance Training to Influence Behavior [pubdate] => 2019-08-19T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/daff07b8-c1b8-11e9-ab91-332ea49871cc/image/uploads_2F1566133358272-kjrmmqi1qho-9b06c2906662fe496c5c130893eacae1_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 441 [subtitle] => In this episode I visit with Matt Galvin, Vice President, Ethics & Compliance at Anheuser-Busch InBev and Peter Grossman, Co-Founder, Chief Strategist at Labyrinth Training about their work on compliance training to influence behavior at Ab-InBev [summary] =>

    In this episode I visit with Matt Galvin, Vice President, Ethics & Compliance at Anheuser-Busch InBev and Peter Grossman, Co-Founder, Chief Strategist at Labyrinth Training about their work on compliance training to influence behavior at Ab-InBev.  Highlights from the podcast include: 1.      How did they create some of the most innovative compliance training?2.     How can innovative training be effective training?3.     How can compliance training influence behavior?4.     Why does Galvin (and Ab-InBev) emphasis compliance training so robustly?5.     How can non-traditional approaches to compliance training be effective?6.     Why compliance officers should always be curious?7.     How did Matt and Peter come together to create this innovative training regime?  For more information on Peter Grossman, check out his LinkedIn profile here. For more information on his company Labyrinth Training, click here. For more on Labyrinth’s work with Ab-InBev on training, click here.

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  • In this episode I visit with Matt Galvin, Vice President,...
  • Array ( [id] => daff07b8-c1b8-11e9-ab91-332ea49871cc [createdAt] => 2019-08-18T09:05:30.364-04:00 [updatedAt] => 2019-08-18T09:05:56.819-04:00 [title] => Episode 441- Compliance Training to Influence Behavior [pubdate] => 2019-08-19T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/daff07b8-c1b8-11e9-ab91-332ea49871cc/image/uploads_2F1566133358272-kjrmmqi1qho-9b06c2906662fe496c5c130893eacae1_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 441 [subtitle] => In this episode I visit with Matt Galvin, Vice President, Ethics & Compliance at Anheuser-Busch InBev and Peter Grossman, Co-Founder, Chief Strategist at Labyrinth Training about their work on compliance training to influence behavior at Ab-InBev [summary] =>

    In this episode I visit with Matt Galvin, Vice President, Ethics & Compliance at Anheuser-Busch InBev and Peter Grossman, Co-Founder, Chief Strategist at Labyrinth Training about their work on compliance training to influence behavior at Ab-InBev.  Highlights from the podcast include: 1.      How did they create some of the most innovative compliance training?2.     How can innovative training be effective training?3.     How can compliance training influence behavior?4.     Why does Galvin (and Ab-InBev) emphasis compliance training so robustly?5.     How can non-traditional approaches to compliance training be effective?6.     Why compliance officers should always be curious?7.     How did Matt and Peter come together to create this innovative training regime?  For more information on Peter Grossman, check out his LinkedIn profile here. For more information on his company Labyrinth Training, click here. For more on Labyrinth’s work with Ab-InBev on training, click here.

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  • In this episode I visit with Matt Galvin, Vice President,...
  • Array ( [id] => fd85dd12-b9ec-11e9-b47a-1f0f05e26ebd [createdAt] => 2019-08-08T10:58:32.812-04:00 [updatedAt] => 2019-08-09T10:39:15.892-04:00 [title] => Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part IV-Considerations When Hiring a Monitor [pubdate] => 2019-08-12T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/fd85dd12-b9ec-11e9-b47a-1f0f05e26ebd/image/uploads_2F1565361270312-qh9n78holc8-77b32bbbd970bece3c4f1cc3580dfa5c_2FFCPA_Podcast_08.2019.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In this five-part podcast series, Jay Rosen and I consider some of the basic questions around monitors and monitorships. Today, in Part 4, we look at considerations when hiring a monitor. [summary] =>

    In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of independent integrity monitors and corporate monitorships; discuss both pre-settlement and post-resolution monitorships and their different applications; considerations a company should take in hiring a monitor and cost reflections for monitorships. Today, in Part 4, we look at considerations when hiring a monitor.

    Some of the highlights from this podcast include:Considering the type and style of the monitor in your selection process.What is the expertise of the monitor, not simply in the subject matter but concluding monitorships?Balancing the interests of the regulator, the company and other stakeholders.Making sure that the monitor is bringing value to the company.Why a Monitor must be independent and conflict-free.I hope you will join us tomorrow for Part 5, where we discuss the issue of costs when retaining a monitor.

    For additional reading see Jay Rosen’s article What Issues Should a Company Consider When Hiring a Corporate Monitor? on Corporate Compliance Insights.

    For more information on Affiliated Monitors, Inc. visit their website here.

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  • In this five-part podcast series, we consider some of the...
  • Array ( [id] => fd85dd12-b9ec-11e9-b47a-1f0f05e26ebd [createdAt] => 2019-08-08T10:58:32.812-04:00 [updatedAt] => 2019-08-09T10:39:15.892-04:00 [title] => Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part IV-Considerations When Hiring a Monitor [pubdate] => 2019-08-12T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/fd85dd12-b9ec-11e9-b47a-1f0f05e26ebd/image/uploads_2F1565361270312-qh9n78holc8-77b32bbbd970bece3c4f1cc3580dfa5c_2FFCPA_Podcast_08.2019.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In this five-part podcast series, Jay Rosen and I consider some of the basic questions around monitors and monitorships. Today, in Part 4, we look at considerations when hiring a monitor. [summary] =>

    In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of independent integrity monitors and corporate monitorships; discuss both pre-settlement and post-resolution monitorships and their different applications; considerations a company should take in hiring a monitor and cost reflections for monitorships. Today, in Part 4, we look at considerations when hiring a monitor.

    Some of the highlights from this podcast include:Considering the type and style of the monitor in your selection process.What is the expertise of the monitor, not simply in the subject matter but concluding monitorships?Balancing the interests of the regulator, the company and other stakeholders.Making sure that the monitor is bringing value to the company.Why a Monitor must be independent and conflict-free.I hope you will join us tomorrow for Part 5, where we discuss the issue of costs when retaining a monitor.

    For additional reading see Jay Rosen’s article What Issues Should a Company Consider When Hiring a Corporate Monitor? on Corporate Compliance Insights.

    For more information on Affiliated Monitors, Inc. visit their website here.

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  • In this five-part podcast series, we consider some of the...
  • Array ( [id] => f14dee46-b9eb-11e9-bda3-473bc2a9b76a [createdAt] => 2019-08-08T10:51:02.816-04:00 [updatedAt] => 2019-08-09T10:33:28.129-04:00 [title] => Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part III-the Power of a Pre-Settlement Monitorship [pubdate] => 2019-08-12T00:06:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f14dee46-b9eb-11e9-bda3-473bc2a9b76a/image/uploads_2F1565361196190-odg8ucxbml-d24de59e36c5e6e0e2a9a35bb50c7d5a_2FFCPA_Podcast_08.2019.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => In this five-part podcast series, Jay Rosen and I consider some of the basic questions around monitors and monitorships. Today, in Part 3, we consider the power of a monitorship in the pre-settlement phase of any matter.  [summary] =>

    In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of independent integrity monitors and corporate monitorships; discuss both pre-settlement and post-resolution monitorships and their different applications; considerations a company should take in hiring a monitor and cost reflections for monitorships. Today, in Part 3, we consider the power of a monitorship in the pre-settlement phase of any matter.

    Some of the highlights from this podcast include:

    1.    What is an Internal Cultural Assessment?2.    How can a pre-settlement monitorship be used as a (a) Pre-emptive Strike;  or (b) to prevent a suspension or debarment action?3.    What is the power of a pre-acquisition monitor in M&A Due Diligence?4.    How is an independent integrity monitor can be a powerful prescriptive tool?

    I hope you will join us tomorrow for Part 4, where we discuss considerations when hiring a monitor.

    For additional reading see Jay Rosen’s article What is the Power of a Pre-Settlement Monitorship?on Corporate Compliance Insights.

    For more information on Affiliated Monitors, Inc. visit their website here

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  • In this five-part podcast series, we consider some of the...
  • Array ( [id] => f14dee46-b9eb-11e9-bda3-473bc2a9b76a [createdAt] => 2019-08-08T10:51:02.816-04:00 [updatedAt] => 2019-08-09T10:33:28.129-04:00 [title] => Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part III-the Power of a Pre-Settlement Monitorship [pubdate] => 2019-08-12T00:06:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f14dee46-b9eb-11e9-bda3-473bc2a9b76a/image/uploads_2F1565361196190-odg8ucxbml-d24de59e36c5e6e0e2a9a35bb50c7d5a_2FFCPA_Podcast_08.2019.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => In this five-part podcast series, Jay Rosen and I consider some of the basic questions around monitors and monitorships. Today, in Part 3, we consider the power of a monitorship in the pre-settlement phase of any matter.  [summary] =>

    In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of independent integrity monitors and corporate monitorships; discuss both pre-settlement and post-resolution monitorships and their different applications; considerations a company should take in hiring a monitor and cost reflections for monitorships. Today, in Part 3, we consider the power of a monitorship in the pre-settlement phase of any matter.

    Some of the highlights from this podcast include:

    1.    What is an Internal Cultural Assessment?2.    How can a pre-settlement monitorship be used as a (a) Pre-emptive Strike;  or (b) to prevent a suspension or debarment action?3.    What is the power of a pre-acquisition monitor in M&A Due Diligence?4.    How is an independent integrity monitor can be a powerful prescriptive tool?

    I hope you will join us tomorrow for Part 4, where we discuss considerations when hiring a monitor.

    For additional reading see Jay Rosen’s article What is the Power of a Pre-Settlement Monitorship?on Corporate Compliance Insights.

    For more information on Affiliated Monitors, Inc. visit their website here

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  • In this five-part podcast series, we consider some of the...
  • Array ( [id] => 83a9d67c-b534-11e9-82d0-c75232ea798d [createdAt] => 2019-08-02T10:47:56.323-04:00 [updatedAt] => 2019-08-02T10:48:27.988-04:00 [title] => Jesse Caplan on the DOJ Evaluation of Corporate Compliance Programs for Antitrust [pubdate] => 2019-08-05T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/83a9d67c-b534-11e9-82d0-c75232ea798d/image/uploads_2F1564757105259-ymeeverqd5l-d9712b0d27df8c99e8ac41d408b094df_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 440 [subtitle] => In this episode of the FCPA Compliance Report, I visit with Affiliated Monitor’s Managing Director Jesse Caplan on the recently released DOJ Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations. [summary] =>

    In this episode I visit with Affiliated Monitor’s Managing Director Jesse Caplan on the recently released DOJ Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations.  Highlights from the podcast include:

    How does this change the Antitrust Division Leniency Program?Does your compliance program have an antitrust focus?How should compliance professionals consider using this Evaluation?How does this Evaluation fit in with Evaluation of FCPA Compliance Programs?For a copy of the DOJ Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations, click here.

    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/83a9d67c-b534-11e9-82d0-c75232ea798d/stripped_b224afb6b353a6eeb7f2cccf4ee780d2.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN1229445780.mp3 [size] => 42857533 [duration] => 1071.44 [uid] => CSN1229445780 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 1 [postCount] => 1 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/94b64056-c5b9-11e8-a148-137a19d11967/episodes/83a9d67c-b534-11e9-82d0-c75232ea798d/id3/5e9ce7acc663f5f67337f940d802e7fe.mp3 [id3FileProcessing] => [id3FileSize] => 230211 [parentId] => [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => 440.Caplan on New Antitrust Compliance Program Evalution - 7_24_19, 10.56 AM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • In this episode I visit with Affiliated Monitor’s Managing Director...
  • Array ( [id] => eb11842e-b19f-11e9-87f4-973b0fb3be9c [createdAt] => 2019-07-28T21:26:41.303-04:00 [updatedAt] => 2019-07-28T21:27:02.354-04:00 [title] => FCPA Compliance Report-Episode 439, James Koukios on the Morrison and Foerster Top 10 International Anti-Corruption Developments for March 2019 [pubdate] => 2019-07-29T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/eb11842e-b19f-11e9-87f4-973b0fb3be9c/image/uploads_2F1564363391899-fkx5hnnkh2s-7c3614265dbd052445fa17014030efc5_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 439 [subtitle] => In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for March 2019. [summary] =>

    In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for March 2019. We look at some of the key international developments.  Highlights from the podcast include:

    The MTS FCPA Settlement.Changes in FCPA Corporate Enforcement Policy-what is ‘De-Confliction’ and ephemeral messaging.OECD Working Group on Bribery Reports on the UK’s Foreign Bribery Enforcement Record.CFTC announces entry into FCPA enforcement.India appoints first anticorruption ombudsman.To see a copy of the Morrison and Foerster Top 10 International Anti-Corruption Developments for March 2019, click here.

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  • In this episode I visit with podcast favorite Morrison and...
  • Array ( [id] => eb11842e-b19f-11e9-87f4-973b0fb3be9c [createdAt] => 2019-07-28T21:26:41.303-04:00 [updatedAt] => 2019-07-28T21:27:02.354-04:00 [title] => FCPA Compliance Report-Episode 439, James Koukios on the Morrison and Foerster Top 10 International Anti-Corruption Developments for March 2019 [pubdate] => 2019-07-29T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/eb11842e-b19f-11e9-87f4-973b0fb3be9c/image/uploads_2F1564363391899-fkx5hnnkh2s-7c3614265dbd052445fa17014030efc5_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 439 [subtitle] => In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for March 2019. [summary] =>

    In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for March 2019. We look at some of the key international developments.  Highlights from the podcast include:

    The MTS FCPA Settlement.Changes in FCPA Corporate Enforcement Policy-what is ‘De-Confliction’ and ephemeral messaging.OECD Working Group on Bribery Reports on the UK’s Foreign Bribery Enforcement Record.CFTC announces entry into FCPA enforcement.India appoints first anticorruption ombudsman.To see a copy of the Morrison and Foerster Top 10 International Anti-Corruption Developments for March 2019, click here.

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  • In this episode I visit with podcast favorite Morrison and...
  • Array ( [id] => 746ab85e-af9c-11e9-8c76-ab5af7dc5b0c [createdAt] => 2019-07-26T07:56:51.425-04:00 [updatedAt] => 2019-07-26T07:57:25.204-04:00 [title] => Bonus Episode-Mike Volkov's Interviews the Compliance Evangelist for 100th Episode of Corruption Crime and Compliance [pubdate] => 2019-07-27T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/746ab85e-af9c-11e9-8c76-ab5af7dc5b0c/image/uploads_2F1564140489017-p01rqeu3nj-307fbd08fd03074a927d63f892d54f59_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => [subtitle] => This special bonus episode is a cross-post of Mike Volkov's 100th episode podcast, where he interviewed me. It was a ton of fun and Mike was gracious enough to allow me to post on the FCPA Compliance Report. [summary] =>

    This special bonus episode is a cross-post of Mike Volkov's 100th episode podcast, where he interviewed me. It was a ton of fun and Mike was gracious enough to allow me to post on the FCPA Compliance Report. Click here for the post on Corruption Crime and Compliance.

    Some of the highlights include:

    Where is the vast Compliance Podcast Network, and what is coming in the future?

    The genesis of for Trekking through Compliance and how were you able to pull together and synthesize all of the Star Trek episodes?

    My perspective on this recent DOJ and OFAC Guidance and how should compliance professionals use this guidance?

    Given all of this recent government guidance, where does the FCPA Guidance from 2012 fit into the picture?  Does it still have value to the compliance professional?

    What do you see, over the next five years, and how should compliance professionals prioritize compliance?

    We always hear about automation, blockchain, artificial intelligence, data analytics and machine learning – how do we sift through these, find valuable compliance applications and then prioritize the use of these technologies?

    When Trump first assumed the presidency there was concern about his commitment to FCPA enforcement.  What is my view of how this has turned out?

    Where DOJ will be over the next few years on enforcement and compliance?

    As compliance continues to evolve and increase its influence, where is the compliance profession growing?

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  • This special bonus episode is a cross-post of Mike Volkov's...
  • Array ( [id] => 8a8c0f92-af16-11e9-9d86-3fc8ade30154 [createdAt] => 2019-07-25T15:58:16.046-04:00 [updatedAt] => 2019-07-25T16:01:10.204-04:00 [title] => Bonus Episode-Sean Freidlin Interviews Elizabeth O'Keefe [pubdate] => 2019-07-26T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/8a8c0f92-af16-11e9-9d86-3fc8ade30154/image/uploads_2F1564084373209-1g15kjcywa4-e4556828670ee971e8338d30248c843e_2FHanzo-podcast-okeefe-1500.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => [subtitle] => In this special bonus episode, Sean Freidlin interviews Elizabeth O'Keefe Compliance Manager at KAYAK and Open Table. [summary] =>

    In this special bonus episode, In the newest episode of Hanzo's Profiles in Excellence series, Sean Freidlin interviews Elizabeth O'Keefe, Compliance Manager at KAYAK and OpenTable. Their conversation includes Elizabeth's career path from over a decade in the compliance space, what an average day as a compliance manager looks like, building a culture where compliance is seen as a collaborator within the organization, major trends impacting the compliance profession, and more. Tune in to listen to the full conversation, or head over to https://corporatecomplianceinsights.com to read the transcribed, edited version. 

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  • In this special bonus episode, In the newest episode of...
  • Array ( [id] => 7c47d3b0-abd5-11e9-8fcf-e3e6bf4b0290 [createdAt] => 2019-07-21T12:35:01.280-04:00 [updatedAt] => 2019-07-21T12:35:14.552-04:00 [title] => The Use of Monitors by State Attorneys General: Part V-The Road Ahead [pubdate] => 2019-07-22T00:10:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/7c47d3b0-abd5-11e9-8fcf-e3e6bf4b0290/image/uploads_2F1563726790515-t8ows9wga4s-acb6156f5dc04d401b7e70b6f61ed70d_2FStateAGs.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 5 [subtitle] => In this concluding Part 5 of our five-part podcast series, we consider the road ahead and the use of monitors by state Attorney Generals. [summary] =>

    In this five-part podcast series, I consider the use of monitors by state Attorneys General. I am joined in this podcast series by Jerry Coyne, the Managing Director of State Monitoring Services at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of state Attorneys Generals as enforcers of state law and bringers of civil litigation; the reaction to the big-tobacco settlement and the criticism of state Attorney Generals over that process; multi-state settlements in the post-tobacco era; challenges in multi-state litigation and the road ahead. Today, in this concluding Part 5, we consider the road ahead and the use of monitors by state Attorney Generals. For more information on Affiliated Monitors, Inc. visit their website here.

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  • In this five-part podcast series, I consider the use of...
  • Array ( [id] => a77bfeea-abd4-11e9-a629-33c73bd91d32 [createdAt] => 2019-07-21T12:29:04.265-04:00 [updatedAt] => 2019-07-21T12:29:19.016-04:00 [title] => The Use of Monitors by State Attorneys General: Part IV-The Challenges of Multi-state in Today’s Litigation Environment [pubdate] => 2019-07-22T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/a77bfeea-abd4-11e9-a629-33c73bd91d32/image/uploads_2F1563726448499-krl10e0cxon-acdc82ccec8650894e4ee1efcd44ff07_2FStateAGs.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In Part 4 of our five-part podcast series, we consider the challenges for state Attorney Generals in today’s litigation environment. [summary] =>

    In this five-part podcast series, I consider the use of monitors by state Attorneys General. I am joined in this podcast series by Jerry Coyne, the Managing Director of State Monitoring Services at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of state Attorneys Generals as enforcers of state law and bringers of civil litigation; the reaction to the big-tobacco settlement and the criticism of state Attorney Generals over that process; multi-state settlements in the post-tobacco era; challenges in multi-state litigation and the road ahead. Today, in Part 4, we consider the challenges for state Attorney Generals in today’s litigation environment. I hope you will join us tomorrow for our concluding Part 5, where consider the road ahead for state AGs. For more information on Affiliated Monitors, Inc. visit their website here.

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  • In this five-part podcast series, I consider the use of...
  • Array ( [id] => 7a035ae0-abd3-11e9-854d-8771ba064860 [createdAt] => 2019-07-21T12:20:38.482-04:00 [updatedAt] => 2019-07-21T12:24:10.568-04:00 [title] => The Use of Monitors by State Attorneys General: Part III-Multistate Litigation in the Post-Tobacco Era [pubdate] => 2019-07-22T00:06:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/7a035ae0-abd3-11e9-854d-8771ba064860/image/uploads_2F1563725911493-eksv8cs9ux6-50511f48f975c8fb554e03b5eff76c82_2FStateAGs.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => in Part 3 of a five-part podcast series, we consider the role of state Attorney Generals in multi-state litigation in the post-tobacco era. [summary] =>

    In this five-part podcast series, I consider the use of monitors by state Attorneys General. I am joined in this podcast series by Jerry Coyne, the Managing Director of State Monitoring Services at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of state Attorneys Generals as enforcers of state law and bringers of civil litigation; the reaction to the big-tobacco settlement and the criticism of state Attorney Generals over that process; multi-state settlements in the post-tobacco era; challenges in multi-state litigation and the road ahead. Today, in Part 3, we consider the role of state Attorney Generals in multistate litigation in the post-tobacco era.

    I hope you will join us tomorrow for Part 4, where we discuss the challenges of multistate into today’s litigation environment. For more information on Affiliated Monitors, Inc. visit their website here.

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  • In this five-part podcast series, I consider the use of...
  • Array ( [id] => 91f262ac-abd0-11e9-bf2d-afe3c7318c7d [createdAt] => 2019-07-21T11:59:50.150-04:00 [updatedAt] => 2019-07-21T12:00:04.071-04:00 [title] => The Use of Monitors by State Attorneys General-Part I: The Role of State Attorneys General as Enforcers [pubdate] => 2019-07-22T00:02:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/91f262ac-abd0-11e9-bf2d-afe3c7318c7d/image/uploads_2F1563723916066-zjsxt5csbl-30228b552fa606098329660e8d56e7f5_2FStateAGs.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 1 [subtitle] => In this Part 1 of a five-part podcast series, we consider the role of state Attorneys Generals as enforcers of civil law and in bringing litigation to enforce consumer protect and related statutes. [summary] =>

    In this five-part podcast series, I consider the use of monitors by state Attorneys General. I am joined in this podcast series by Jerry Coyne, the Managing Director of State Monitoring Services at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of state Attorneys Generals as enforcers of state law and bringers of civil litigation; the reaction to the big-tobacco settlement and the criticism of state Attorney Generals over that process; multistate settlements in the post-tobacco era; challenges in multistate litigation and the road ahead. Today, in Part 1, we consider the role of state AGs as enforcers of civil law and in bringing litigation to enforce consumer protect and related statutes.

    I hope you will join us tomorrow for Part 2, where we discuss the reaction to the Big Tobacco settlement and the criticisms of state Attorney Generals for the process used. For more information on Affiliated Monitors, Inc. visit their website here.

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  • In this five-part podcast series, I consider the use of...
  • Array ( [id] => b5f95ea4-a670-11e9-9366-830ec3daba14 [createdAt] => 2019-07-14T15:51:03.078-04:00 [updatedAt] => 2019-07-14T15:51:19.005-04:00 [title] => FCPA Compliance Report-Episode 437, Kelly Leonard on The Second City Works and Compliance [pubdate] => 2019-07-15T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/b5f95ea4-a670-11e9-9366-830ec3daba14/image/uploads_2F1563133800266-2pejsvppdcp-ccc1477ecf87a19cf5faea8026f39cdc_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 437 [subtitle] => In this episode of the FCPA Compliance Report, I visit with Kelly Leonard, from The Second City Works to discuss how they approach compliance training and communications. [summary] =>

    In this episode of the FCPA Compliance Report, I visit Kelly Leonard, Executive Director, Insights and Applied Improvisation at The Second City Works. We discuss the compliance training which The Second City Works has developed and how they have incorporated storytelling into compliance training and communications.

    Some of the highlights include:Most folks are familiar with Second City but what is Second City Works?What are the service offerings of Second City Works?What is the Second Science Project and how does it inform your service offerings?Why is storytelling so important in training and ongoing communications?The book “Yes, And: How Improvisation Reverses "No, But" Thinking and Improves Creativity and Collaboration--Lessons from The Second City”.How do you mentor Millennials but sidestep the drama?As a company scales up or grows how can it keep its lines of communications open?Where can listeners go for more information?You can find more information on The Second City Works by checking out their website, here.

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  • In this episode of the FCPA Compliance Report, I visit...
  • Array ( [id] => b5f95ea4-a670-11e9-9366-830ec3daba14 [createdAt] => 2019-07-14T15:51:03.078-04:00 [updatedAt] => 2019-07-14T15:51:19.005-04:00 [title] => FCPA Compliance Report-Episode 437, Kelly Leonard on The Second City Works and Compliance [pubdate] => 2019-07-15T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/b5f95ea4-a670-11e9-9366-830ec3daba14/image/uploads_2F1563133800266-2pejsvppdcp-ccc1477ecf87a19cf5faea8026f39cdc_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 437 [subtitle] => In this episode of the FCPA Compliance Report, I visit with Kelly Leonard, from The Second City Works to discuss how they approach compliance training and communications. [summary] =>

    In this episode of the FCPA Compliance Report, I visit Kelly Leonard, Executive Director, Insights and Applied Improvisation at The Second City Works. We discuss the compliance training which The Second City Works has developed and how they have incorporated storytelling into compliance training and communications.

    Some of the highlights include:Most folks are familiar with Second City but what is Second City Works?What are the service offerings of Second City Works?What is the Second Science Project and how does it inform your service offerings?Why is storytelling so important in training and ongoing communications?The book “Yes, And: How Improvisation Reverses "No, But" Thinking and Improves Creativity and Collaboration--Lessons from The Second City”.How do you mentor Millennials but sidestep the drama?As a company scales up or grows how can it keep its lines of communications open?Where can listeners go for more information?You can find more information on The Second City Works by checking out their website, here.

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  • In this episode of the FCPA Compliance Report, I visit...
  • Array ( [id] => ed63fbc8-9b36-11e9-9736-032995542986 [createdAt] => 2019-06-30T08:59:42.466-04:00 [updatedAt] => 2019-06-30T09:00:02.311-04:00 [title] => FCPA Compliance Report-Episode 434, Brandon Daniels on Using Investigations to Drive Continuous Improvement [pubdate] => 2019-07-01T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ed63fbc8-9b36-11e9-9736-032995542986/image/uploads_2F1561899518322-mnopbl5jrh-d1abbbb64027f507838c461747ca6d98_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 434 [subtitle] => In this episode, I visit with Brandon Daniels from Exiger. We have a wide ranging discussion on using investigations to drive continuous improvement. [summary] =>

    In this episode of the FCPA Compliance Report, I visit with Brandon Daniels, who is the President of Global Technology Markets for Exiger. Daniels is regulatory expert and technology practitioner, bringing more than 15 years in senior management across the financial services, life sciences and energy sectors. He has a reputation for technological innovation in regulatory investigations and compliance management. Some of the highlights include:

    Daniels’ professional background, how he got to Exiger and his current role at the company.Some of the key technological innovations Daniels has recently seen in the way in which investigations are being handled?We discuss how can Exiger’s technological solutions help a CCO get their arms around the unstructured data which is available to them inside their organization?How can technology be used to create predictive models to rank offshore companies for potential tax and corruption risk?How can a technological solution can be used to help perform a compliance risk assessment?How do Exiger technological solutions assist compliance professionals to improve their corporate culture? For more information on Exiger, check out the firm’s website here. For more information on Brandon Daniels, check out his firm profile here.

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  • In this episode of the FCPA Compliance Report, I visit...
  • Array ( [id] => ed63fbc8-9b36-11e9-9736-032995542986 [createdAt] => 2019-06-30T08:59:42.466-04:00 [updatedAt] => 2019-06-30T09:00:02.311-04:00 [title] => FCPA Compliance Report-Episode 434, Brandon Daniels on Using Investigations to Drive Continuous Improvement [pubdate] => 2019-07-01T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ed63fbc8-9b36-11e9-9736-032995542986/image/uploads_2F1561899518322-mnopbl5jrh-d1abbbb64027f507838c461747ca6d98_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 434 [subtitle] => In this episode, I visit with Brandon Daniels from Exiger. We have a wide ranging discussion on using investigations to drive continuous improvement. [summary] =>

    In this episode of the FCPA Compliance Report, I visit with Brandon Daniels, who is the President of Global Technology Markets for Exiger. Daniels is regulatory expert and technology practitioner, bringing more than 15 years in senior management across the financial services, life sciences and energy sectors. He has a reputation for technological innovation in regulatory investigations and compliance management. Some of the highlights include:

    Daniels’ professional background, how he got to Exiger and his current role at the company.Some of the key technological innovations Daniels has recently seen in the way in which investigations are being handled?We discuss how can Exiger’s technological solutions help a CCO get their arms around the unstructured data which is available to them inside their organization?How can technology be used to create predictive models to rank offshore companies for potential tax and corruption risk?How can a technological solution can be used to help perform a compliance risk assessment?How do Exiger technological solutions assist compliance professionals to improve their corporate culture? For more information on Exiger, check out the firm’s website here. For more information on Brandon Daniels, check out his firm profile here.

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  • In this episode of the FCPA Compliance Report, I visit...
  • Array ( [id] => d59243ea-986d-11e9-bd99-2f2adc5fb2c0 [createdAt] => 2019-06-26T19:55:11.329-04:00 [updatedAt] => 2019-06-26T19:55:27.286-04:00 [title] => FCPA Compliance Report-Episode 433, Sean Freidlin on the Current State of Internal Investigations [pubdate] => 2019-06-27T00:04:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/d59243ea-986d-11e9-bd99-2f2adc5fb2c0/image/uploads_2F1561593255869-e5r2n1ktctj-7743c6275219fc7d013b3ef29ede676c_2FFox%2BPodcasting.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In tis episode Sean Freidlin and I discuss the current state of best practices for internal investigations. [summary] =>

    In this episode I visit with Sean Freidlin, the Senior Product Marketing Manager, Compliance at Hanzo. We take a deep dive into the state of compliance investigation in 2019, focusing on the impact of the Evaluation of Corporate Compliance Programs on investigations. For more information, Hanzo has published the following work, “THE 2019 GUIDE TO INTERNAL INVESTIGATIONS FOR COMPLIANCE-An eBook on Planning, Protocols, Data Collection, Triage, and Remediation” on which I collaborated. (The eBook was sponsored by Hanzo.) The eBook provides the compliance professional with multiple tools, strategies and tactics for the entire lifecycle of investigations; from initial intake through remediation. I know that you will find it incredibly useful. You can download it here.

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  • In this episode I visit with Sean Freidlin, the Senior...
  • Array ( [id] => d59243ea-986d-11e9-bd99-2f2adc5fb2c0 [createdAt] => 2019-06-26T19:55:11.329-04:00 [updatedAt] => 2019-06-26T19:55:27.286-04:00 [title] => FCPA Compliance Report-Episode 433, Sean Freidlin on the Current State of Internal Investigations [pubdate] => 2019-06-27T00:04:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/d59243ea-986d-11e9-bd99-2f2adc5fb2c0/image/uploads_2F1561593255869-e5r2n1ktctj-7743c6275219fc7d013b3ef29ede676c_2FFox%2BPodcasting.png?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In tis episode Sean Freidlin and I discuss the current state of best practices for internal investigations. [summary] =>

    In this episode I visit with Sean Freidlin, the Senior Product Marketing Manager, Compliance at Hanzo. We take a deep dive into the state of compliance investigation in 2019, focusing on the impact of the Evaluation of Corporate Compliance Programs on investigations. For more information, Hanzo has published the following work, “THE 2019 GUIDE TO INTERNAL INVESTIGATIONS FOR COMPLIANCE-An eBook on Planning, Protocols, Data Collection, Triage, and Remediation” on which I collaborated. (The eBook was sponsored by Hanzo.) The eBook provides the compliance professional with multiple tools, strategies and tactics for the entire lifecycle of investigations; from initial intake through remediation. I know that you will find it incredibly useful. You can download it here.

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  • In this episode I visit with Sean Freidlin, the Senior...
  • Array ( [id] => 8b692274-951c-11e9-95a3-ab44494c87af [createdAt] => 2019-06-22T14:35:44.190-04:00 [updatedAt] => 2019-06-22T14:35:58.221-04:00 [title] => The Current State of Compliance - Issues and Challenges: Part 5 - New Compliance Concerns in Healthcare [pubdate] => 2019-06-24T00:10:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/8b692274-951c-11e9-95a3-ab44494c87af/image/uploads_2F1561228475155-8i7g6zmg3zp-fc974329dcb7db35be2136e75a6359d0_2FKrollLogo-Series%2B1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 5 [subtitle] => In the concluding episode, Part V, we consider some of the latest challenges for healthcare compliance, including legislative changes and a recent corruption trial which Orr believes will be seen as a landmark event. [summary] =>

    Over this five-part podcast series, I have visited with Terry L Orr, a Managing Director at Kroll, a division of Duff & Phelps, and the sponsor of this podcast series. We have taken a comprehensive look at state of compliance at the half-year mark of 2019. In the concluding episode, Part V, we consider some of the latest challenges for healthcare compliance, including legislative changes and a recent corruption trial which Orr believes will be seen as a landmark event. There are some safe harbor exceptions but outside of those exceptions a broad interpretation of value is used. For more information on Kroll, a division of Duff & Phelps, click here. For more information on Terry Orr, click here.

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  • Over this five-part podcast series, I have visited with Terry...
  • Array ( [id] => e4438968-94ed-11e9-bcdb-bb6dbb2124ea [createdAt] => 2019-06-22T09:01:46.913-04:00 [updatedAt] => 2019-06-22T13:45:15.821-04:00 [title] => The Current State of Compliance - Issues and Challenges: Part 4 - Private Equity and Compliance [pubdate] => 2019-06-24T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/e4438968-94ed-11e9-bcdb-bb6dbb2124ea/image/uploads_2F1561225511686-7x3xydrscdx-16c4a5b92256937d92e3d71075e14217_2FKrollLogo-Series%2B1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In Part IV of this five-part podcast series with Terry Orr of Kroll, we consider unique challenges for private equity companies in compliance; both in their organizations and for their portfolio companies. [summary] =>

    In this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff & Phelps, the sponsor of this podcast series. We visit on the current state of compliance through the lens of recent Foreign Corrupt Practices Act (FCPA) enforcement actions and the Evaluation of Corporate Compliance Programs, 2019 Guidance, consider some of the specific issues in compliance for private equity and the increased importance of compliance in the healthcare industry. It is a comprehensive look at state of compliance at the half-year mark of 2019. We have previously considered how compliance programs might be updated based upon lessons learned in recent FCPA enforcement actions, then we considered the Department of Justice’s (DOJ’s) recent guidance on corporate compliance. In Part IV, we consider unique challenges for private equity companies in compliance; both in their organizations and for their portfolio companies.

    For more information on Kroll, a division of Duff & Phelps, click here. For more information on Terry Orr, click here. Join us for our final episode where take a deep dive into the burgeoning issues of healthcare and compliance.

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  • In this five-part podcast series, I visit with Terry L...
  • Array ( [id] => e4438968-94ed-11e9-bcdb-bb6dbb2124ea [createdAt] => 2019-06-22T09:01:46.913-04:00 [updatedAt] => 2019-06-22T13:45:15.821-04:00 [title] => The Current State of Compliance - Issues and Challenges: Part 4 - Private Equity and Compliance [pubdate] => 2019-06-24T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/e4438968-94ed-11e9-bcdb-bb6dbb2124ea/image/uploads_2F1561225511686-7x3xydrscdx-16c4a5b92256937d92e3d71075e14217_2FKrollLogo-Series%2B1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In Part IV of this five-part podcast series with Terry Orr of Kroll, we consider unique challenges for private equity companies in compliance; both in their organizations and for their portfolio companies. [summary] =>

    In this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff & Phelps, the sponsor of this podcast series. We visit on the current state of compliance through the lens of recent Foreign Corrupt Practices Act (FCPA) enforcement actions and the Evaluation of Corporate Compliance Programs, 2019 Guidance, consider some of the specific issues in compliance for private equity and the increased importance of compliance in the healthcare industry. It is a comprehensive look at state of compliance at the half-year mark of 2019. We have previously considered how compliance programs might be updated based upon lessons learned in recent FCPA enforcement actions, then we considered the Department of Justice’s (DOJ’s) recent guidance on corporate compliance. In Part IV, we consider unique challenges for private equity companies in compliance; both in their organizations and for their portfolio companies.

    For more information on Kroll, a division of Duff & Phelps, click here. For more information on Terry Orr, click here. Join us for our final episode where take a deep dive into the burgeoning issues of healthcare and compliance.

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  • In this five-part podcast series, I visit with Terry L...
  • Array ( [id] => bf24a048-891e-11e9-81f6-f7ba8d96222a [createdAt] => 2019-06-07T08:21:16.025-04:00 [updatedAt] => 2019-06-07T12:05:30.707-04:00 [title] => Impacts of Emerging Regulations: Part 4- the Current State of Responsible Minerals [pubdate] => 2019-06-17T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/bf24a048-891e-11e9-81f6-f7ba8d96222a/image/uploads_2F1559909982626-0btcnc1whdno-2f03e5e95e70be2ecad4fc64cd533841_2FAssent3.1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In this fourth episode of a 5-part podcast series, I visit with Jared Connors, subject matter expert for Assent Compliance on Corporate Social Responsibility on the current state of conflict minerals/responsible minerals.  [summary] =>

    In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery  supply chain risk management programs, Corporate Social Responsibility (CSR) value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this fourth episode, I visit with Jared Connors, subject matter expert for Assent Compliance on CSR on the current state of conflict minerals/responsible minerals. Join us tomorrow where we wrap us this series on emerging regulatory areas in a conversation with Jonathan Hughes. You can check out more about Assent Compliance Inc. at their website, by clicking here

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  • In this five-part podcast series, sponsored by Assent Compliance Inc....
  • Array ( [id] => bf24a048-891e-11e9-81f6-f7ba8d96222a [createdAt] => 2019-06-07T08:21:16.025-04:00 [updatedAt] => 2019-06-07T12:05:30.707-04:00 [title] => Impacts of Emerging Regulations: Part 4- the Current State of Responsible Minerals [pubdate] => 2019-06-17T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/bf24a048-891e-11e9-81f6-f7ba8d96222a/image/uploads_2F1559909982626-0btcnc1whdno-2f03e5e95e70be2ecad4fc64cd533841_2FAssent3.1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In this fourth episode of a 5-part podcast series, I visit with Jared Connors, subject matter expert for Assent Compliance on Corporate Social Responsibility on the current state of conflict minerals/responsible minerals.  [summary] =>

    In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery  supply chain risk management programs, Corporate Social Responsibility (CSR) value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this fourth episode, I visit with Jared Connors, subject matter expert for Assent Compliance on CSR on the current state of conflict minerals/responsible minerals. Join us tomorrow where we wrap us this series on emerging regulatory areas in a conversation with Jonathan Hughes. You can check out more about Assent Compliance Inc. at their website, by clicking here

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  • In this five-part podcast series, sponsored by Assent Compliance Inc....
  • Array ( [id] => b7058a8c-891c-11e9-bede-73abd84c2fe2 [createdAt] => 2019-06-07T08:06:43.403-04:00 [updatedAt] => 2019-06-07T12:03:44.311-04:00 [title] => Impacts of Emerging Regulations: Part 2- Instituting a Broader Risk Management Program [pubdate] => 2019-06-17T00:02:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/b7058a8c-891c-11e9-bede-73abd84c2fe2/image/uploads_2F1559909097564-9bffw1om2sm-82643c8a4cc20f802b5132fb36e10fc3_2FAssent3.1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 2 [subtitle] => In Part 2 of a 5-part podcast series, I visit with Jared Connors, subject matter expert for Assent Compliance on Corporate Social Responsibility (CSR) on how to institute a broader supply chain risk management program. [summary] =>

    In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, CSR value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this second episode, I visit with Jared Connors, subject matter expert for Assent Compliance on Corporate Social Responsibility (CSR) on how to institute a broader supply chain risk management program. Join us tomorrow where we ask, ‘what’s your CSR value proposition’? You can check out more about Assent Compliance Inc. at their website, by clicking here

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  • In this five-part podcast series, sponsored by Assent Compliance Inc....
  • Array ( [id] => b7058a8c-891c-11e9-bede-73abd84c2fe2 [createdAt] => 2019-06-07T08:06:43.403-04:00 [updatedAt] => 2019-06-07T12:03:44.311-04:00 [title] => Impacts of Emerging Regulations: Part 2- Instituting a Broader Risk Management Program [pubdate] => 2019-06-17T00:02:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/b7058a8c-891c-11e9-bede-73abd84c2fe2/image/uploads_2F1559909097564-9bffw1om2sm-82643c8a4cc20f802b5132fb36e10fc3_2FAssent3.1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 2 [subtitle] => In Part 2 of a 5-part podcast series, I visit with Jared Connors, subject matter expert for Assent Compliance on Corporate Social Responsibility (CSR) on how to institute a broader supply chain risk management program. [summary] =>

    In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, CSR value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this second episode, I visit with Jared Connors, subject matter expert for Assent Compliance on Corporate Social Responsibility (CSR) on how to institute a broader supply chain risk management program. Join us tomorrow where we ask, ‘what’s your CSR value proposition’? You can check out more about Assent Compliance Inc. at their website, by clicking here

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  • In this five-part podcast series, sponsored by Assent Compliance Inc....
  • Array ( [id] => d9bc1748-83f5-11e9-8e55-575601796f98 [createdAt] => 2019-05-31T18:32:15.885-04:00 [updatedAt] => 2019-05-31T18:45:56.226-04:00 [title] => Life With GDPR: Episode 29- GDPR Year 1 Review-Part II, the Issues [pubdate] => 2019-06-06T00:03:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 29 [subtitle] => [summary] =>

    In this podcast, data privacy/data security expert Jonathan Armstrong and Compliance Evangelist Tom Fox use the framework of GDPR to discuss a wide range of issues relating to these topics. They consider what the US compliance and InfoSec security expert needs to know about what is happening in the UK, Europe and beyond. This episode is the first of a two-part series where  Jonathan Armstrong and myself consider some of the highlights from the first year of GDPR implementation and enforcement. In this Part I we considered some of the enforcement numbers. In this Part II, we discuss some of the substantive issues. Some of the highlights in this episode include: Security issues-multiple regulators for large breaches and questions of whether TOMs are adequate. 6 Principles of GDPR-highest is around transparency.Data Subject Rights are seen as the biggest corporate pain points.DPIAs have been embraced by many companies and are seen by regulators as the backbone of a corporate compliance program around data security/data privacy. Industry sweeps are beginning to occur. Mixed quality of legal advice is hurting many companies in their compliance efforts. Some significant cases are headed to trial and then appeal. GDPR is here to stay. For more information on Cordery Compliance, go their website here.For additional reading see the Cordery Compliance article, “GDPR One Year On”.Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.

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  • In this podcast, data privacy/data security expert Jonathan Armstrong and...
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    In this podcast, data privacy/data security expert Jonathan Armstrong and Compliance Evangelist Tom Fox use the framework of GDPR to discuss a wide range of issues relating to these topics. They consider what the US compliance and InfoSec security expert needs to know about what is happening in the UK, Europe and beyond. This episode is the first of a two-part series where  Jonathan Armstrong and myself consider some of the highlights from the first year of GDPR implementation and enforcement. In this Part I we considered some of the enforcement numbers. In this Part II, we discuss some of the substantive issues. Some of the highlights in this episode include: Security issues-multiple regulators for large breaches and questions of whether TOMs are adequate. 6 Principles of GDPR-highest is around transparency.Data Subject Rights are seen as the biggest corporate pain points.DPIAs have been embraced by many companies and are seen by regulators as the backbone of a corporate compliance program around data security/data privacy. Industry sweeps are beginning to occur. Mixed quality of legal advice is hurting many companies in their compliance efforts. Some significant cases are headed to trial and then appeal. GDPR is here to stay. For more information on Cordery Compliance, go their website here.For additional reading see the Cordery Compliance article, “GDPR One Year On”.Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.

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  • In this podcast, data privacy/data security expert Jonathan Armstrong and...
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    Over the course of this podcast series, sponsored by Affiliated Monitors, Inc. (AMI), I have visited with Eric Feldman, Senior Vice President of AMI. We have considered the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. We are exploring what the 2019 Guidance changes are from the Evaluation of Corporate Compliance Program (2017 Guidance), released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In this concluding Episode, we bring together our final thoughts through a consider of the question “What does it all mean for your compliance practice?” For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor at www.affiliatedmonitors.com

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  • Over the course of this podcast series, sponsored by Affiliated...
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    Over the course of this podcast series, sponsored by Affiliated Monitors, Inc. (AMI), I have visited with Eric Feldman, Senior Vice President of AMI. We have considered the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. We are exploring what the 2019 Guidance changes are from the Evaluation of Corporate Compliance Program (2017 Guidance), released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In this concluding Episode, we bring together our final thoughts through a consider of the question “What does it all mean for your compliance practice?” For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor at www.affiliatedmonitors.com

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  • Over the course of this podcast series, sponsored by Affiliated...
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    Over the course of this podcast series, sponsored by Affiliated Monitors, Inc. (AMI), I am visiting with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. We are exploring what the 2019 Guidance changes are from the Evaluation of Corporate Compliance Program (2017 Guidance), released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In Episode 4, we consider the question “Does your compliance program work in practice?” Join us tomorrow when we conclude our deep dive into the 2019 Guidance by putting it all together with final thoughts and observations.  For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor at www.affiliatedmonitors.com.

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  • Over the course of this podcast series, sponsored by Affiliated...
  • Array ( [id] => c5214068-82ee-11e9-9554-875b131a840b [createdAt] => 2019-05-30T11:22:43.248-04:00 [updatedAt] => 2019-05-30T11:34:15.744-04:00 [title] => DOJ 2019 Guidance: Part III – Is It Being Effectively Implemented? [pubdate] => 2019-06-03T00:06:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/c5214068-82ee-11e9-9554-875b131a840b/image/uploads_2F1559229627055-src4qdoage-b55acd844da325443a80cf5376f69071_2FAMi-2019%2BGuidance.2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => This week, in a podcast series sponsored by Affiliated Monitors, Inc., I am visiting with Eric Feldman. We look at the DOJ Evaluation of Corporate Compliance Programs. In Episode 3, we consider the question “Is it being effectively implemented?” [summary] =>

    This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I am visiting with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. Over this series we are exploring the 2019 Guidance changes from the Evaluation of Corporate Compliance Program (2017 Guidance), released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In Episode 3, we consider the question “Is it being effectively implemented?” Join us tomorrow when begin a deep dive into the 2019 Guidance in considering the third question, “Does your compliance program work in practice?” For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor at www.affiliatedmonitors.com.

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  • This week, in a podcast series sponsored by Affiliated Monitors,...
  • Array ( [id] => c5214068-82ee-11e9-9554-875b131a840b [createdAt] => 2019-05-30T11:22:43.248-04:00 [updatedAt] => 2019-05-30T11:34:15.744-04:00 [title] => DOJ 2019 Guidance: Part III – Is It Being Effectively Implemented? [pubdate] => 2019-06-03T00:06:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/c5214068-82ee-11e9-9554-875b131a840b/image/uploads_2F1559229627055-src4qdoage-b55acd844da325443a80cf5376f69071_2FAMi-2019%2BGuidance.2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => This week, in a podcast series sponsored by Affiliated Monitors, Inc., I am visiting with Eric Feldman. We look at the DOJ Evaluation of Corporate Compliance Programs. In Episode 3, we consider the question “Is it being effectively implemented?” [summary] =>

    This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I am visiting with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. Over this series we are exploring the 2019 Guidance changes from the Evaluation of Corporate Compliance Program (2017 Guidance), released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In Episode 3, we consider the question “Is it being effectively implemented?” Join us tomorrow when begin a deep dive into the 2019 Guidance in considering the third question, “Does your compliance program work in practice?” For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor at www.affiliatedmonitors.com.

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  • This week, in a podcast series sponsored by Affiliated Monitors,...
  • Array ( [id] => 87e16a80-82ed-11e9-a7b3-9b71baf68766 [createdAt] => 2019-05-30T11:13:50.993-04:00 [updatedAt] => 2019-05-30T11:32:22.451-04:00 [title] => DOJ 2019 Guidance: Part II – Is Your Program Well Designed? [pubdate] => 2019-06-03T00:02:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/87e16a80-82ed-11e9-a7b3-9b71baf68766/image/uploads_2F1559230325058-1ez2xox53p5-b5aad221816c0c55643cfb6c7fa4289f_2FAMi-2019%2BGuidance.2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 2 [subtitle] => This week, in a podcast series sponsored by Affiliated Monitors, I am visiting with Eric Feldman, SVP of AMI. We look at the DOJ Evaluation of Corporate Compliance Programs. In Episode 2, we consider the question “Is your program well designed?” [summary] =>

    This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I am visiting with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. Over the next five podcasts we will explore what the 2019 Guidance changes are from the Evaluation of Corporate Compliance Program (2017 Guidance), released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In Episode 2, we consider the question “Is your program well designed?” Join us tomorrow when begin a deep dive into the 2019 Guidance in considering the second question, “Is your program being implemented effectively?” For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor at www.affiliatedmonitors.com.

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  • This week, in a podcast series sponsored by Affiliated Monitors,...
  • Array ( [id] => b12df370-8579-11e9-b2db-ab67a9aeb7db [createdAt] => 2019-06-02T17:00:35.881-04:00 [updatedAt] => 2019-06-02T18:36:14.155-04:00 [title] => Daily Compliance News: June 3, 2019, the more lessons from Boeing edition [pubdate] => 2019-06-03T00:01:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for June 3, 2019? Check in with Tom Fox on the Daily Compliance News to find out. [summary] =>

    In today’s edition of Daily Compliance News:Lengthy detail of Boeing miss-steps in 737 Max software issue. (NYT)What price did a whistleblower pay in tennis for reporting match fixing? (NYT)UK freezes home ownership for 3 homes purchased with unexplained wealth. (BBC)Jamie Diamond criticizes Wells Fargo for having no CEO succession plan. (FT)

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  • In today’s edition of Daily Compliance News:Lengthy detail of Boeing...
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    In today’s edition of Daily Compliance News:Lengthy detail of Boeing miss-steps in 737 Max software issue. (NYT)What price did a whistleblower pay in tennis for reporting match fixing? (NYT)UK freezes home ownership for 3 homes purchased with unexplained wealth. (BBC)Jamie Diamond criticizes Wells Fargo for having no CEO succession plan. (FT)

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  • In today’s edition of Daily Compliance News:Lengthy detail of Boeing...
  • Array ( [id] => 9497a6c0-82ea-11e9-991f-4fe62e81f80d [createdAt] => 2019-05-30T10:52:43.829-04:00 [updatedAt] => 2019-05-30T11:30:53.307-04:00 [title] => DOJ 2019 Guidance: Part I - Introduction [pubdate] => 2019-06-03T00:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/9497a6c0-82ea-11e9-991f-4fe62e81f80d/image/uploads_2F1559230236722-thtpq80dtyk-42e82291ae9a2b51d7df40bf353c3a0e_2FAMi-2019%2BGuidance.2.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 1 [subtitle] => This week, in a podcast series sponsored by AMI, I visit with Eric Feldman. We look at the DOJ Evaluation of Corporate Compliance Programs. In Episode 1, we begin with some of Feldman’s observations on the 2019 Guidance. [summary] =>

    This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. Over the next five podcasts we will explore what the 2019 Guidance changes are from the Evaluation of Corporate Compliance Program (2017 Guidance), released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward. In Episode 1, we begin with some of Feldman’s observations on the 2019 Guidance. Join us tomorrow when begin a deep dive into the 2019 Guidance in considering the first question, “Is the program well designed?” For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor at www.affiliatedmonitors.com.

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  • This week, in a podcast series sponsored by Affiliated Monitors,...
  • Array ( [id] => b0c817ce-83b9-11e9-b643-17756fcaeef2 [createdAt] => 2019-05-31T11:30:00.266-04:00 [updatedAt] => 2019-05-31T11:35:17.126-04:00 [title] => Daily Compliance News: June 1, 2019-the Management Incentives edition [pubdate] => 2019-06-01T00:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for June 1, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

    In today’s edition of Daily Compliance News:What are management incentives?(Huffington Post)Vale employees warned of dam collapse and were ignored. (WSJ)Think meetings are bad? Just wait until you can’t have any.(FT)Claus von Bülow dies. (NYT)

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  • In today’s edition of Daily Compliance News:What are management incentives?(Huffington...
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    In today’s edition of Daily Compliance News:What are management incentives?(Huffington Post)Vale employees warned of dam collapse and were ignored. (WSJ)Think meetings are bad? Just wait until you can’t have any.(FT)Claus von Bülow dies. (NYT)

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  • In today’s edition of Daily Compliance News:What are management incentives?(Huffington...
  • Array ( [id] => ad4a553c-83b2-11e9-9041-63b82c32052a [createdAt] => 2019-05-30T16:56:17.609-04:00 [updatedAt] => 2019-05-31T10:45:05.273-04:00 [title] => Daily Compliance News: May 31, 2019-the May is done edition [pubdate] => 2019-05-31T00:04:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for May 31, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

    In today’s edition of Daily Compliance News:CITGO now part of PdVSA/Venezuelan corruption scandal. (Houston Chronicle)Who else did Chuck Blazer bribe? (NYT)Who is in your supply chain? (FT)Former head of Pemex charged with bribery and tax fraud? (NYT)

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  • In today’s edition of Daily Compliance News:CITGO now part of...
  • Array ( [id] => ad4a553c-83b2-11e9-9041-63b82c32052a [createdAt] => 2019-05-30T16:56:17.609-04:00 [updatedAt] => 2019-05-31T10:45:05.273-04:00 [title] => Daily Compliance News: May 31, 2019-the May is done edition [pubdate] => 2019-05-31T00:04:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for May 31, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

    In today’s edition of Daily Compliance News:CITGO now part of PdVSA/Venezuelan corruption scandal. (Houston Chronicle)Who else did Chuck Blazer bribe? (NYT)Who is in your supply chain? (FT)Former head of Pemex charged with bribery and tax fraud? (NYT)

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  • In today’s edition of Daily Compliance News:CITGO now part of...
  • Array ( [id] => 88ace648-8152-11e9-8e94-d77e77a45c46 [createdAt] => 2019-05-28T10:07:19.953-04:00 [updatedAt] => 2019-05-28T10:11:58.134-04:00 [title] => Life With GDPR: Episode 28- GDPR Year 1 Review-Part I, the Numbers [pubdate] => 2019-05-30T00:10:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 28 [subtitle] => In this episode Jonathan Armstrong and myself begin a two-part podcast series where we review the first year of GDPR. In this episode we consider the numbers from Year 1. [summary] =>

    In this podcast, data privacy/data security expert Jonathan Armstrong and Compliance Evangelist Tom Fox use the framework of GDPR to discuss a wide range of issues relating to these topics. They consider what the US compliance and InfoSec security expert needs to know about what is happening in the UK, Europe and beyond. This episode is the first of a two-part series where  Jonathan Armstrong and myself consider some of the highlights from the first year of GDPR implementation and enforcement. In this Part I of this two-part series we consider some of the enforcement numbers. In Part II, we will consider some of the substantive issues. Some of the highlights in this episode include: EDPB says just over 150,000 complaints files EU under GDPR. Robust enforcement by both regulators and private bodies/citizens.UK leads with the largest number of complaints filed, followed by Germany then France.Around 950 complaints have reach courts. Italy is the country which has seen the largest number of court cases. Several countries are increasing inspections which could lead to enforcement actions.  For more information on Cordery Compliance, go their website here. Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.

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  • In this podcast, data privacy/data security expert Jonathan Armstrong and...
  • Array ( [id] => e82a1572-8252-11e9-a7db-7bd8cd95a90c [createdAt] => 2019-05-29T16:45:50.280-04:00 [updatedAt] => 2019-05-29T16:47:01.156-04:00 [title] => Daily Compliance News: May 30, 2019-is a spanking is coming edition [pubdate] => 2019-05-30T00:05:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for May 30, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

    In today’s edition of Daily Compliance News:

    Is the SEC useless? Mark Cuban thinks so. (Yahoo Finance)Monitor orderd for Wynn Casinos in Massachusettes. (WSJ)Frederick Pierucci continues his crusade against the DOJ and FCPA enforcement.(Shine)What will happen to Carnival Cruise Lines? (Miami Herald)

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  • In today’s edition of Daily Compliance News:Is the SEC useless?...
  • Array ( [id] => e82a1572-8252-11e9-a7db-7bd8cd95a90c [createdAt] => 2019-05-29T16:45:50.280-04:00 [updatedAt] => 2019-05-29T16:47:01.156-04:00 [title] => Daily Compliance News: May 30, 2019-is a spanking is coming edition [pubdate] => 2019-05-30T00:05:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for May 30, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

    In today’s edition of Daily Compliance News:

    Is the SEC useless? Mark Cuban thinks so. (Yahoo Finance)Monitor orderd for Wynn Casinos in Massachusettes. (WSJ)Frederick Pierucci continues his crusade against the DOJ and FCPA enforcement.(Shine)What will happen to Carnival Cruise Lines? (Miami Herald)

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  • In today’s edition of Daily Compliance News:Is the SEC useless?...
  • Array ( [id] => 8459e82e-7fd2-11e9-a012-bbdbe1f1d34f [createdAt] => 2019-05-26T12:19:50.661-04:00 [updatedAt] => 2019-05-26T12:22:55.459-04:00 [title] => Everything Compliance-Episode 47, the Potpourri edition [pubdate] => 2019-05-30T00:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 47 [subtitle] => In this episode, the Everything Compliance gang presents a potpourri of topics and resources for your consideration. [summary] =>

    Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Armstrong and our newest colleague, Sarah Hadden. In this episode, we present a potpourri of topics.    

    Sarah Hadden considers the behavioral side of ethics and how this needs to be incorporated more fully into a compliance regime. Sarah shouts out to the University of Texas, McCombs School of Business (Hook ‘Em) and its online video series entitled Ethics Unwrapped.Matt Kelly considers the current state of whistleblower programs. He asks if corporate legal departments will support the fix to Dodd- Frank after the Digital Realty Trust ruling? Matt shouts out to smaller law firms and companies having more focused compliance events.Jay Rosen tells you everything you wanted to know about monitors but were afraid to ask. Jay shouts out to House Speaker Nancy Pelosi for her slap down of AG William Barr.Mike Volkov discusses the new OFAC compliance program and the current state of OFAC sanctions. Mike shouts to the recently concluded ECI national conference Impact 2019.The members of the Everything Compliance are:Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.comMike Volkov– One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com.Matt Kelly– Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.comJonathan Armstrong–is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.comSarah Hadden–Publisher at Corporate Compliance Insights. Hadden can be reached at Sarah@corporatecomplianceinsights.comThe host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network.

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  • Welcome to the only roundtable podcast in compliance. Today, we...
  • Array ( [id] => a939826c-819e-11e9-8b21-674519818734 [createdAt] => 2019-05-28T19:15:02.074-04:00 [updatedAt] => 2019-05-28T19:16:45.700-04:00 [title] => Daily Compliance News: May 29, 2019-the Workers Unite edition [pubdate] => 2019-05-29T00:02:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for May 29, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

     In today’s edition of Daily Compliance News:Braskem Board OK’s $101MM for corruption settlement. (Reuters)Mexican steel company shut down by Mexican government for AML violations. (FT)Workers of America unite? (Washington Post)The long road ahead for Fiat-Chrysler/Renault. (NYT)

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  •  In today’s edition of Daily Compliance News:Braskem Board OK’s $101MM...
  • Array ( [id] => 85291ee6-819e-11e9-bef6-1381ea0a3a2b [createdAt] => 2019-05-28T19:15:02.074-04:00 [updatedAt] => 2019-05-28T19:15:45.656-04:00 [title] => Daily Compliance News: May 29, 2019-the Workers Unite edition [pubdate] => 2019-05-29T00:02:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for May 29, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

     In today’s edition of Daily Compliance News:Braskem Board OK’s $101MM for corruption settlement. (Reuters)Mexican steel company shut down by Mexican government for AML violations. (FT)Workers of America unite? (Washington Post)The long road ahead for Fiat-Chrysler/Renault. (NYT)

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  •  In today’s edition of Daily Compliance News:Braskem Board OK’s $101MM...
  • Array ( [id] => ed1d0098-7f10-11e9-a759-3f8e9befd790 [createdAt] => 2019-05-25T13:17:08.566-04:00 [updatedAt] => 2019-05-30T16:30:55.779-04:00 [title] => Leveraging AI in Compliance Investigation: Part 5 – Where are investigations headed? [pubdate] => 2019-05-27T00:09:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ed1d0098-7f10-11e9-a759-3f8e9befd790/image/uploads_2F1558804376592-wm82ds50nf-4654aca22e586db3520f7b086f5e5744_2FHanzo-Investigations.JPG?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 5 [subtitle] => Where are investigations headed? How will the dynamic use of data improve not only compliance internal investigations but also make a compliance program more effective? Find out in this Part 5 of a five-episode series. [summary] =>

    Today we conclude a five-part podcast series sponsored by Hanzo, where we have considered how to leverage Artificial Intelligence (AI) in compliance investigations. I have been joined by several members of the Hanzo team as we explored the current best practices around investigations and how your compliance function can take investigations to a level of cost efficiency and operational proficiency. Our explorations include considering the current Department of Justice (DOJ) guidance on investigations, the use of AI in the Hanzo Investigator, how Hanzo technology can help a company overcome common investigative challenges and Hanzo’s specific approach to finding and managing data across the entire lifecycle of an investigation. In Part 5, I am once again joined by Keith Laska to consider how the company’s specific approach to finding and managing data across the entire lifecycle of an investigation improves the efficiency of a compliance investigation in a cost-effective manner.  For more information check out Hanzo.co. 

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  • Today we conclude a five-part podcast series sponsored by Hanzo,...
  • Array ( [id] => ed1d0098-7f10-11e9-a759-3f8e9befd790 [createdAt] => 2019-05-25T13:17:08.566-04:00 [updatedAt] => 2019-05-30T16:30:55.779-04:00 [title] => Leveraging AI in Compliance Investigation: Part 5 – Where are investigations headed? [pubdate] => 2019-05-27T00:09:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ed1d0098-7f10-11e9-a759-3f8e9befd790/image/uploads_2F1558804376592-wm82ds50nf-4654aca22e586db3520f7b086f5e5744_2FHanzo-Investigations.JPG?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 5 [subtitle] => Where are investigations headed? How will the dynamic use of data improve not only compliance internal investigations but also make a compliance program more effective? Find out in this Part 5 of a five-episode series. [summary] =>

    Today we conclude a five-part podcast series sponsored by Hanzo, where we have considered how to leverage Artificial Intelligence (AI) in compliance investigations. I have been joined by several members of the Hanzo team as we explored the current best practices around investigations and how your compliance function can take investigations to a level of cost efficiency and operational proficiency. Our explorations include considering the current Department of Justice (DOJ) guidance on investigations, the use of AI in the Hanzo Investigator, how Hanzo technology can help a company overcome common investigative challenges and Hanzo’s specific approach to finding and managing data across the entire lifecycle of an investigation. In Part 5, I am once again joined by Keith Laska to consider how the company’s specific approach to finding and managing data across the entire lifecycle of an investigation improves the efficiency of a compliance investigation in a cost-effective manner.  For more information check out Hanzo.co. 

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  • Today we conclude a five-part podcast series sponsored by Hanzo,...
  • Array ( [id] => a81f1fb6-7e5d-11e9-b1c8-cb8def9b25e8 [createdAt] => 2019-05-24T15:53:52.906-04:00 [updatedAt] => 2019-05-30T16:30:24.318-04:00 [title] => Leveraging AI in Compliance Investigation: Part 4-Improving Investigative Efficiencies [pubdate] => 2019-05-27T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/a81f1fb6-7e5d-11e9-b1c8-cb8def9b25e8/image/uploads_2F1558727450693-fxi5vjlbs7n-be81d98e68d91f845b3aafc2f4b09862_2FInvestigations%2BLogo.JPG?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => In this episode four of a 5-part podcast series learn how AI can not improve your investigation efficiency. [summary] =>

    I am on a five-part podcast series sponsored by Hanzo. In this series we consider how to leverage artificial intelligence (AI) in compliance investigations. In this series I am joined by several members of the Hanzo team as we explore the current best practices around investigations and how your compliance function can take investigations to a level of cost efficiency and operational proficiency. Our explorations includes considering the current Department of Justice (DOJ) guidance on investigations, the use of AI in the Hanzo Investigator, how Hanzo technology can help a company overcome common investigative challenges and Hanzo’s specific approach to finding and managing data across the entire lifecycle of an investigation. In this Part 4 I am joined by Keith Laska, Chief Commercial Officer at Hanzo to consider how the use of AI in investigations improves the workflow and processes around solving complex problems that compliance professionals experience when work around data. For more information, check out the Hanzo Dynamic Investigator in more detail and how it will assist you moving forward. For more information visit Hanzo.co.

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  • I am on a five-part podcast series sponsored by Hanzo....
  • Array ( [id] => 732994e2-7e5a-11e9-ab48-67f736784a6f [createdAt] => 2019-05-24T15:30:55.560-04:00 [updatedAt] => 2019-05-24T15:31:08.382-04:00 [title] => Leveraging AI in Compliance Investigation: Part 2-Using AI and Web-Based Evidence [pubdate] => 2019-05-27T00:02:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/732994e2-7e5a-11e9-ab48-67f736784a6f/image/uploads_2F1558726013714-tuwg6qcswr-fc784f950ba2f16031ac75fcfc44efcd_2FInvestigations%2BLogo.JPG?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 2 [subtitle] => In this episode two of a 5-part podcast series learn how AI can not only improve your investigation efficiency but also drive down costs. [summary] =>

    This week I embark on a five-part podcast series sponsored by Hanzo. In this series we consider how to leverage artificial intelligence (AI) in compliance investigations. In this series I am joined by several members of the Hanzo team as we explore the current best practices around investigations and how your compliance function can take investigations to a level of cost efficiency and operational proficiency. Our explorations includes considering the current Department of Justice (DOJ) guidance on investigations, the use of AI in the Hanzo Investigator, how Hanzo technology can help a company overcome common investigative challenges and Hanzo’s specific approach to finding and managing data across the entire lifecycle of an investigation. We begin today with Part 2 where I am joined by Jim Murphy, VP for Products at Hanzo to consider how to conduct more conclusive compliance investigations with AI and web-based evidence. For more information, check out the Hanzo Dynamic Investigator in more detail and how it will assist you moving forward. For more information visit Hanzo.co.

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  • This week I embark on a five-part podcast series sponsored...
  • Array ( [id] => 9864fe80-7d89-11e9-9167-b3c0be328423 [createdAt] => 2019-05-23T14:32:30.255-04:00 [updatedAt] => 2019-05-23T19:43:24.026-04:00 [title] => Daily Compliance News: May 24, 2019-the Memorial Day Weekend edition [pubdate] => 2019-05-24T00:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for May 23, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

    In today’s edition of Daily Compliance News:BeIN Media Group CEO charged in corruption scandal. (FoxNews)Deutche Bank finds flaw in reporting system. (Wall Street Journal)Whose in your supply chain? (NYT)Compliance staff for banks tough to find? (Wall Street Journal)

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  • In today’s edition of Daily Compliance News:BeIN Media Group CEO...
  • Array ( [id] => fae56c34-7d48-11e9-819b-6bcc09f2a28e [createdAt] => 2019-05-23T06:52:36.165-04:00 [updatedAt] => 2019-05-23T06:53:21.831-04:00 [title] => Daily Compliance News: May 23, 2019-the life or death [pubdate] => 2019-05-23T06:46:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for May 23, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

    In today’s edition of Daily Compliance News:

    Guyana Investigating Leases Controlled by Exxon & Tullow (Bloomberg)In EU 75% of those who observe illegal corp activity afraid to report it. (FT)KPMG to be hit by massive fine in UK. (Reuters)What is risk management (as in when its life or death)? (Wall Street Journal)

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  • In today’s edition of Daily Compliance News:Guyana Investigating Leases Controlled...
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    In today’s edition of Daily Compliance News:

    Guyana Investigating Leases Controlled by Exxon & Tullow (Bloomberg)In EU 75% of those who observe illegal corp activity afraid to report it. (FT)KPMG to be hit by massive fine in UK. (Reuters)What is risk management (as in when its life or death)? (Wall Street Journal)

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  • In today’s edition of Daily Compliance News:Guyana Investigating Leases Controlled...
  • Array ( [id] => f3feef9c-7822-11e9-9d4e-f3e8db71bf79 [createdAt] => 2019-05-16T17:38:32.917-04:00 [updatedAt] => 2019-05-16T17:38:46.300-04:00 [title] => Maintaining Market Access: Part 4 - FARs flow downs [pubdate] => 2019-05-20T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f3feef9c-7822-11e9-9d4e-f3e8db71bf79/image/uploads_2F1558042588318-rpu0f7d397p-6900726d7606c3f34f5ec5da48ddd903_2FAssent2.1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => [summary] =>

    Over this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I have been exploring market access for supply chain data. I have visited with several Assent team members to introduce the topic, consider what market access is, provide an overview of trade compliance, Federal Acquisition Register (FAR) flow downs, the value of continuous monitoring and the origins of laws impacting market access. In episode four, Travis Miller, General Counsel (GC), and I discuss how the regulatory requirements of the Federal Acquisitions Regulations (FARs) impact access to markets and supply chain compliance. Join us tomorrow for our final episode where I visit with James Calder on Chemical and Product Compliance. You can check out more about Assent Compliance Inc. at their website, by clicking here

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  • Over this five-part podcast series, sponsored by Assent Compliance Inc....
  • Array ( [id] => f3feef9c-7822-11e9-9d4e-f3e8db71bf79 [createdAt] => 2019-05-16T17:38:32.917-04:00 [updatedAt] => 2019-05-16T17:38:46.300-04:00 [title] => Maintaining Market Access: Part 4 - FARs flow downs [pubdate] => 2019-05-20T00:08:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f3feef9c-7822-11e9-9d4e-f3e8db71bf79/image/uploads_2F1558042588318-rpu0f7d397p-6900726d7606c3f34f5ec5da48ddd903_2FAssent2.1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 4 [subtitle] => [summary] =>

    Over this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I have been exploring market access for supply chain data. I have visited with several Assent team members to introduce the topic, consider what market access is, provide an overview of trade compliance, Federal Acquisition Register (FAR) flow downs, the value of continuous monitoring and the origins of laws impacting market access. In episode four, Travis Miller, General Counsel (GC), and I discuss how the regulatory requirements of the Federal Acquisitions Regulations (FARs) impact access to markets and supply chain compliance. Join us tomorrow for our final episode where I visit with James Calder on Chemical and Product Compliance. You can check out more about Assent Compliance Inc. at their website, by clicking here

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  • Over this five-part podcast series, sponsored by Assent Compliance Inc....
  • Array ( [id] => ab66524e-7821-11e9-a037-e36b0dc755cd [createdAt] => 2019-05-16T17:29:21.619-04:00 [updatedAt] => 2019-05-16T17:29:45.678-04:00 [title] => Maintaining Market Access: Part 2 - Trade Compliance [pubdate] => 2019-05-20T00:03:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ab66524e-7821-11e9-a037-e36b0dc755cd/image/uploads_2F1558042018741-449lerk7ko6-8d5bf84c10fa86b93595480e6cf51436_2FAssent2.1.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 2 [subtitle] => Why is trade compliance critical to maintaining market access? [summary] =>

    In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market access for supply chain data. In this series, I visit with several Assent team members to introduce the topic, consider what market access is, provide an overview of trade compliance, Federal Acquisition Register (FAR) flow downs, the value of continuous monitoring and the origins of laws impacting market access. In episode two, I continue the conversation with Travis Miller, General Counsel (GC). We introduce the topic of trade compliance and how this new era of trade wars has created such challenges. Join us tomorrow where consider the value of continuous monitoring in trade compliance and the Supply Chain. You can check out more about Assent Compliance Inc. at their website, by clicking here

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  • In this five-part podcast series, sponsored by Assent Compliance Inc....
  • Array ( [id] => f6c27d30-773b-11e9-84c4-03941b54365f [createdAt] => 2019-05-15T14:05:03.812-04:00 [updatedAt] => 2019-05-15T14:05:23.645-04:00 [title] => FCPA Compliance Report-Episode 430, Scott Moritz on a Forensic Response to Varsity Blues [pubdate] => 2019-05-20T00:01:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f6c27d30-773b-11e9-84c4-03941b54365f/image/uploads_2F1557943323006-g3mvar6dfvq-c78414ff9c0b0114c251d0ea3bccf9ea_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 430 [subtitle] => In this episode I visit with Scott Moritz, the Global Lead, Protiviti Forensics. We discuss the Varsity Blues scandal from the forensic perspective. [summary] =>

    In this episode I visit with Scott Moritz, the Global Lead, Protiviti Forensics. We discuss the Varsity Blues scandal from the forensic perspective. Some of the highlights from the podcast include: Ø  What would a root cause analysis show?Ø  Every college and university need to do a full analysis of its admissions process. From soup to nuts, a complete review. Ø  With so much in the public domain, there is a clear road map to do so.Ø  How should you pressure test your control environment?Ø  What is the curriculum around business ethics? These words must also mean for each institution to look inward. Ø  What will you do when the government comes knocking? 

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  • In this episode I visit with Scott Moritz, the Global...
  • Array ( [id] => f6c27d30-773b-11e9-84c4-03941b54365f [createdAt] => 2019-05-15T14:05:03.812-04:00 [updatedAt] => 2019-05-15T14:05:23.645-04:00 [title] => FCPA Compliance Report-Episode 430, Scott Moritz on a Forensic Response to Varsity Blues [pubdate] => 2019-05-20T00:01:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f6c27d30-773b-11e9-84c4-03941b54365f/image/uploads_2F1557943323006-g3mvar6dfvq-c78414ff9c0b0114c251d0ea3bccf9ea_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 430 [subtitle] => In this episode I visit with Scott Moritz, the Global Lead, Protiviti Forensics. We discuss the Varsity Blues scandal from the forensic perspective. [summary] =>

    In this episode I visit with Scott Moritz, the Global Lead, Protiviti Forensics. We discuss the Varsity Blues scandal from the forensic perspective. Some of the highlights from the podcast include: Ø  What would a root cause analysis show?Ø  Every college and university need to do a full analysis of its admissions process. From soup to nuts, a complete review. Ø  With so much in the public domain, there is a clear road map to do so.Ø  How should you pressure test your control environment?Ø  What is the curriculum around business ethics? These words must also mean for each institution to look inward. Ø  What will you do when the government comes knocking? 

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  • In this episode I visit with Scott Moritz, the Global...
  • Array ( [id] => 93b78e3a-7973-11e9-b7e4-eb9813fbcef0 [createdAt] => 2019-05-17T18:34:11.803-04:00 [updatedAt] => 2019-05-18T09:48:12.093-04:00 [title] => Daily Compliance News: May 19, 2019-the Sunday Book Review-con men edition [pubdate] => 2019-05-19T00:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => In this Sunday Book Review edition of the Daily Compliance News for May 19, 2019, I take a look at five books dealing with con men. [summary] =>

    In today’s edition of Daily Compliance News:King Con by Paul WillettsChasing Phil by David HowardUltimate Folly by Henry MacroryDuped by Abbe EllinThe Confidence Game by Maris KonnikovaAdditional resources-Golden Age of the Grift

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  • In today’s edition of Daily Compliance News:King Con by Paul...
  • Array ( [id] => da82feb4-78c7-11e9-b5de-f32b2146d6b1 [createdAt] => 2019-05-16T16:17:27.053-04:00 [updatedAt] => 2019-05-17T13:18:57.790-04:00 [title] => This Week in FCPA-Episode 154 - the Take It Back edition [pubdate] => 2019-05-17T12:26:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 154 [subtitle] => The Astros continue their inexorable march back to the World Series (Take It Back) as the Red Sox hover at .500. Never one to gloat, Tom takes a break to join Jay to discuss both events some of this week’s top compliance and ethics stories which caught their collective eyes. [summary] =>

    This week's highlights include:

    1.    Uber stumbles at going IPO. What role did its culture, lack of compliance and ethics play? 2.    Belying those who advocate a paper program compliance defense, DOJ/SEC require compliance programs which actually works. 3.    What is up with Ephemeral Messaging for Businesses? Avi Gessner, Daniel Foerster and Mengyi Xu consider. 4.    What criteria should be used to make reparations to victims of corruption? Sam Hickey explores. 5.    Hong Kong criminally indicts ex-JP Morgan banker in Princeling case. Harry Cassin reports.6.     FCPA Unit head Dan Kahn discusses evolution in FCPA enforcement. Clara Hudson reports. 7.How should you repay victims of corruption? Sam Hickey. 8.    Federal judge lambastes SEC for filing on VW nearly 4 years after emissions-testing scandal erupted. David Shepardson reports.10.  What is the fraud risk for non-profits? 11.  Join Tom and Jay at Compliance Week 2019. It is one of the top compliance and ethics conferences of the year. This year, Tom is joined by Jonathan Marks in leading a pre-conference workshop on Sunday afternoon about handling internal investigations and performing a root cause analysis. Monday will include a keynote address from the always popular Hui Chen, Tuesday Preet Bharara. As a listener, you are eligible for a discount on the conference cost. Enter code “TOM300” at checkout to save $300 from your registration. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.  For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com

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  • This week's highlights include:1.    Uber stumbles at going IPO....
  • Array ( [id] => da82feb4-78c7-11e9-b5de-f32b2146d6b1 [createdAt] => 2019-05-16T16:17:27.053-04:00 [updatedAt] => 2019-05-17T13:18:57.790-04:00 [title] => This Week in FCPA-Episode 154 - the Take It Back edition [pubdate] => 2019-05-17T12:26:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 154 [subtitle] => The Astros continue their inexorable march back to the World Series (Take It Back) as the Red Sox hover at .500. Never one to gloat, Tom takes a break to join Jay to discuss both events some of this week’s top compliance and ethics stories which caught their collective eyes. [summary] =>

    This week's highlights include:

    1.    Uber stumbles at going IPO. What role did its culture, lack of compliance and ethics play? 2.    Belying those who advocate a paper program compliance defense, DOJ/SEC require compliance programs which actually works. 3.    What is up with Ephemeral Messaging for Businesses? Avi Gessner, Daniel Foerster and Mengyi Xu consider. 4.    What criteria should be used to make reparations to victims of corruption? Sam Hickey explores. 5.    Hong Kong criminally indicts ex-JP Morgan banker in Princeling case. Harry Cassin reports.6.     FCPA Unit head Dan Kahn discusses evolution in FCPA enforcement. Clara Hudson reports. 7.How should you repay victims of corruption? Sam Hickey. 8.    Federal judge lambastes SEC for filing on VW nearly 4 years after emissions-testing scandal erupted. David Shepardson reports.10.  What is the fraud risk for non-profits? 11.  Join Tom and Jay at Compliance Week 2019. It is one of the top compliance and ethics conferences of the year. This year, Tom is joined by Jonathan Marks in leading a pre-conference workshop on Sunday afternoon about handling internal investigations and performing a root cause analysis. Monday will include a keynote address from the always popular Hui Chen, Tuesday Preet Bharara. As a listener, you are eligible for a discount on the conference cost. Enter code “TOM300” at checkout to save $300 from your registration. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.  For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com

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  • This week's highlights include:1.    Uber stumbles at going IPO....
  • Array ( [id] => e0dbcc7a-7708-11e9-913c-471f05ec756a [createdAt] => 2019-05-15T07:57:16.744-04:00 [updatedAt] => 2019-07-18T12:29:53.055-04:00 [title] => Everything Compliance-Episode 46, the Justice Department's 2019 Guidance for FCPA Compliance Programs [pubdate] => 2019-05-15T07:52:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 46 [subtitle] => This entire episode is dedicated to the recently released Evaluation of Corporate Compliance Programs-2019 Guidance [summary] =>

    Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Armstrong and our newest colleague, Sarah Hadden. We take on one topic which the panelist explores from their expertise. The topic is the Justice Department’s Evaluation of Corporate Compliance Programs-2019 Guidance which was recently released.

    Sarah Hadden puts on her journalist hat to consider the 2019 Guidance in the context of transparency by DOJ in releasing this information critical for compliance going forward. Sarah rants on all those in the Everything Compliance gang who attended the ECI Impact 2019 conference in her hometown of Dallas and did not reach out to connect with her. (And we know who we are)Matt Kelly considers some different questions such as: Is there anything new? Does it mean any difference in practice? Is it simply a way to wipe out one of the core legacies of Hui Chen? Matt rants on the Trump Administration which said only a couple of weeks ago said it was cracking down on Agency and Department Guidance and literally turns around and issues the 2019 Guidance. Which is it guys?Jay Rosen discuss the original Benczkowski Memo as a precursor to the new 2019 Guidance and how the Benczkowski Memo lays out a roadmap to avoid a monitor by using pro-active assessments. Jay shouts out to the Boston Red Sox for reaching .500. (Matt chastises Jay for now jinxing the Sox)Mike Volkov discusses how the Justice Department is using the state of compliance programs not only at time of violation but also at time of conclusion to reward companies with lower penalties. Mike shouts out to both Brian Benczkowski/DOJ for this new FCPA Compliance Guidance and the Department of Treasury for OFAC guidance around money-laundering and trade sanctions compliance programs.Jonathan Armstrong compares and contrasts the 2019 Guidance document with the information released by SFO on compliance programs. He then considers what a ‘good’ compliance program looks like in his search for a ‘good’ recipe for the perfect Tikka Masala. He rants about the first UK data privacy regulatory action under GDPR, where the UK data protection agency sanctioned the UK government for violation of GDPR.

    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/e762ea3c-d30d-11e8-91bc-f3f4945d6803/episodes/95c3f578-7708-11e9-8f18-dbb15c35f14c/stripped_77fd8bc155f007f9c8cdc7d3833917d7.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN3226326737.mp3 [size] => 130476407 [duration] => 3261.91 [uid] => CSN3226326737 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 2 [postCount] => 2 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/e762ea3c-d30d-11e8-91bc-f3f4945d6803/episodes/95c3f578-7708-11e9-8f18-dbb15c35f14c/id3/6b3f700eeb377ec592c5a7df73675dbf.mp3 [id3FileProcessing] => [id3FileSize] => 184762 [parentId] => 95c3f578-7708-11e9-8f18-dbb15c35f14c [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Episode 46 - 5_5_19, 12.06 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • Welcome to the only roundtable podcast in compliance. Today, we...
  • Array ( [id] => e0dbcc7a-7708-11e9-913c-471f05ec756a [createdAt] => 2019-05-15T07:57:16.744-04:00 [updatedAt] => 2019-07-18T12:29:53.055-04:00 [title] => Everything Compliance-Episode 46, the Justice Department's 2019 Guidance for FCPA Compliance Programs [pubdate] => 2019-05-15T07:52:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 46 [subtitle] => This entire episode is dedicated to the recently released Evaluation of Corporate Compliance Programs-2019 Guidance [summary] =>

    Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Armstrong and our newest colleague, Sarah Hadden. We take on one topic which the panelist explores from their expertise. The topic is the Justice Department’s Evaluation of Corporate Compliance Programs-2019 Guidance which was recently released.

    Sarah Hadden puts on her journalist hat to consider the 2019 Guidance in the context of transparency by DOJ in releasing this information critical for compliance going forward. Sarah rants on all those in the Everything Compliance gang who attended the ECI Impact 2019 conference in her hometown of Dallas and did not reach out to connect with her. (And we know who we are)Matt Kelly considers some different questions such as: Is there anything new? Does it mean any difference in practice? Is it simply a way to wipe out one of the core legacies of Hui Chen? Matt rants on the Trump Administration which said only a couple of weeks ago said it was cracking down on Agency and Department Guidance and literally turns around and issues the 2019 Guidance. Which is it guys?Jay Rosen discuss the original Benczkowski Memo as a precursor to the new 2019 Guidance and how the Benczkowski Memo lays out a roadmap to avoid a monitor by using pro-active assessments. Jay shouts out to the Boston Red Sox for reaching .500. (Matt chastises Jay for now jinxing the Sox)Mike Volkov discusses how the Justice Department is using the state of compliance programs not only at time of violation but also at time of conclusion to reward companies with lower penalties. Mike shouts out to both Brian Benczkowski/DOJ for this new FCPA Compliance Guidance and the Department of Treasury for OFAC guidance around money-laundering and trade sanctions compliance programs.Jonathan Armstrong compares and contrasts the 2019 Guidance document with the information released by SFO on compliance programs. He then considers what a ‘good’ compliance program looks like in his search for a ‘good’ recipe for the perfect Tikka Masala. He rants about the first UK data privacy regulatory action under GDPR, where the UK data protection agency sanctioned the UK government for violation of GDPR.

    [audioFile] => https://megaphone-prod.s3.amazonaws.com/podcasts/e762ea3c-d30d-11e8-91bc-f3f4945d6803/episodes/95c3f578-7708-11e9-8f18-dbb15c35f14c/stripped_77fd8bc155f007f9c8cdc7d3833917d7.mp3 [downloadUrl] => http://traffic.megaphone.fm/CSN3226326737.mp3 [size] => 130476407 [duration] => 3261.91 [uid] => CSN3226326737 [originalUrl] => [bitrate] => 320 [samplerate] => 44100 [channelMode] => stereo [vbr] => [audioFileProcessing] => [podcastId] => 94b64056-c5b9-11e8-a148-137a19d11967 [preCount] => 2 [postCount] => 2 [insertionPoints] => Array ( ) [id3File] => https://megaphone-prod.s3.amazonaws.com/podcasts/e762ea3c-d30d-11e8-91bc-f3f4945d6803/episodes/95c3f578-7708-11e9-8f18-dbb15c35f14c/id3/6b3f700eeb377ec592c5a7df73675dbf.mp3 [id3FileProcessing] => [id3FileSize] => 184762 [parentId] => 95c3f578-7708-11e9-8f18-dbb15c35f14c [guid] => [pubdateTimezone] => Eastern Time (US & Canada) [originalFilename] => Episode 46 - 5_5_19, 12.06 PM.mp3 [preOffset] => 0.0 [postOffset] => 0.0 [spotifyIdentifier] => [expectedAdhash] => [audioFileUpdatedAt] => [draft] => [externalId] => [customFields] => )
  • Welcome to the only roundtable podcast in compliance. Today, we...
  • Array ( [id] => 7f4a4de2-768b-11e9-895f-7374c4eea573 [createdAt] => 2019-05-14T16:53:27.373-04:00 [updatedAt] => 2019-05-14T17:02:12.001-04:00 [title] => Compliance into the Weeds: Episode 123-Whistleblower Protection [pubdate] => 2019-05-15T00:05:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 123 [subtitle] => In this episode, Matt and I take a deep dive into the House Financial Services bill, HR 2515, which amends the Dodd-Frank Act to clarify that whistleblowers who report misconduct to their employers and not to the SEC also have protections against retaliation under the law. [summary] =>

    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 Kelly (the coolest guy in compliance) and I take a deep dive into the House Financial Services bill, HR 2515, which amends the Dodd-Frank Act to clarify that whistleblowers who report misconduct to their employers and not to the SEC also have protections against retaliation under the law. This bill fixes the US Supreme Court decision in Digital Realty Trust which mandated that whistleblowers had to go to the SEC to obtain Dodd-Frank anti-retaliation protection. Some of the highlights include: Some of the highlights include: Ø What was the ruling in Digital Realty Trust?Ø Why did it negatively impact whistleblowers, companies and the SEC?Ø What has made whistleblowers and internal reporting so significant?Ø How does the proposed fix benefit whistleblowers, companies and the SEC?Ø Why should businesses get behind this proposed fix?Ø What are the chances it actually is signed into law? For more reading check out Matt’s blog post “Progress on Whistleblower Fix” 

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  • Compliance into the Weeds is the only weekly podcast which...
  • Array ( [id] => 97dbdfc6-75d5-11e9-876b-83a5a4316eb9 [createdAt] => 2019-05-13T19:16:09.523-04:00 [updatedAt] => 2019-05-13T19:19:45.390-04:00 [title] => Daily Compliance News: May 14, 2019-the from bad to worser edition edition [pubdate] => 2019-05-14T00:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => What are some of the top compliance and corruption stories for May 14, 2019? Check in on the Daily Compliance News with Tom Fox. [summary] =>

    In today’s edition of Daily Compliance News:Judge scolds SEC over VW lawsuit. (WSJ)With friends like this? (Corporate Counsel)Bombadier faces World Bank debarment. (org.cn)Things go from bad to terrible for Bayer. (WSJ)

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  • In today’s edition of Daily Compliance News:Judge scolds SEC over...
  • Array ( [id] => cd7751e6-7513-11e9-9198-0bd3d77e26cd [createdAt] => 2019-05-12T20:11:05.740-04:00 [updatedAt] => 2019-05-12T20:12:32.974-04:00 [title] => Daily Compliance News: May 13, 2019-the regime change edition [pubdate] => 2019-05-13T00:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: May 13, 2019-the regime change edition [summary] =>

    In today’s edition of Daily Compliance News:DOJ asks Judge to remove lead defense counsel for Huawei. (NYT)Did cost cutting cause Boeing 737 Max crashes? (Bloomberg)House Financial Services approves bill to overturn Digital Trust Realty. (Radical Compliance)States allege generic drug makers obstructed justice in cartel probe. (Washington Post)

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  • In today’s edition of Daily Compliance News:DOJ asks Judge to...
  • Array ( [id] => cd7751e6-7513-11e9-9198-0bd3d77e26cd [createdAt] => 2019-05-12T20:11:05.740-04:00 [updatedAt] => 2019-05-12T20:12:32.974-04:00 [title] => Daily Compliance News: May 13, 2019-the regime change edition [pubdate] => 2019-05-13T00:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: May 13, 2019-the regime change edition [summary] =>

    In today’s edition of Daily Compliance News:DOJ asks Judge to remove lead defense counsel for Huawei. (NYT)Did cost cutting cause Boeing 737 Max crashes? (Bloomberg)House Financial Services approves bill to overturn Digital Trust Realty. (Radical Compliance)States allege generic drug makers obstructed justice in cartel probe. (Washington Post)

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  • In today’s edition of Daily Compliance News:DOJ asks Judge to...
  • Array ( [id] => 8a05dbda-70f4-11e9-a5d4-a788e262d11b [createdAt] => 2019-05-07T14:15:46.225-04:00 [updatedAt] => 2019-05-07T14:18:40.688-04:00 [title] => Daily Compliance News: May 8, 2019-the Is He or Isn’t He edition [pubdate] => 2019-05-08T01:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: May 8, 2019-the Is He or Isn’t He edition [summary] =>

    In today’s edition of Daily Compliance News:

    Judge says Roger Ng in negotiations with the DOJ, although his lawyer denies it. (New York Times)Colleges in ‘Willful Ignorance’ of corruption, say it ain’t so. (Law360)It’s a bad day when the FT Editorial Board spanks you. (Financial Times)Former Danske bank CEO charged in money-laundering scandal? (Reuters)

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  • In today’s edition of Daily Compliance News:Judge says Roger Ng...
  • Array ( [id] => b5eb9390-7048-11e9-8e46-479323e7e58c [createdAt] => 2019-05-06T17:46:57.699-04:00 [updatedAt] => 2019-05-06T17:56:05.833-04:00 [title] => Daily Compliance News: May 7, 2019-the Welcome to the US edition [pubdate] => 2019-05-07T01:01:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: May 7, 2019-the Welcome to the US edition [summary] =>

    In today’s edition of Daily Compliance News:

    ·       Roger Ng extradited to US. (New York Times)·       Closing arguments made in NCAA bribery scandal case. (ESPN)·       Hell hath no fury like a competitor scorned. (Financial Times)·       What happens when safety is ‘just a given’ at the Board level? (Washington Post)

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  • In today’s edition of Daily Compliance News:·       Roger...
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    In today’s edition of Daily Compliance News:

    ·       Roger Ng extradited to US. (New York Times)·       Closing arguments made in NCAA bribery scandal case. (ESPN)·       Hell hath no fury like a competitor scorned. (Financial Times)·       What happens when safety is ‘just a given’ at the Board level? (Washington Post)

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  • In today’s edition of Daily Compliance News:·       Roger...
  • Array ( [id] => e4aab618-6e93-11e9-8137-0f445c556bde [createdAt] => 2019-05-04T13:41:48.700-04:00 [updatedAt] => 2019-05-04T13:42:03.915-04:00 [title] => Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 3, Case Studies of Working with 3rd Party Independents [pubdate] => 2019-05-06T01:05:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/e4aab618-6e93-11e9-8137-0f445c556bde/image/uploads_2F1556991572041-aloffcyxbll-d7a522ae1443515d505dcc993fe529b7_2FAMI-Defense%2BCounsel.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 3, Case Studies of Working with 3rd Party Independents [summary] =>

    In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent monitors to help clients who may have sustained an ethical or compliance violation or are under government scrutiny for allegations of illegal misconduct in a wide variety of industries, disciplines and corporate settings. In this third episode, we look at some case studies. Case studies are something every lawyer and compliance practitioner responds to because it presents real facts and events that the corporate compliance discipline can learn from and hopefully incorporate these lessons learned into their organizations. 

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  • In this five-part podcast series, sponsored by Affiliated Monitors, Inc....
  • Array ( [id] => e4aab618-6e93-11e9-8137-0f445c556bde [createdAt] => 2019-05-04T13:41:48.700-04:00 [updatedAt] => 2019-05-04T13:42:03.915-04:00 [title] => Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 3, Case Studies of Working with 3rd Party Independents [pubdate] => 2019-05-06T01:05:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/e4aab618-6e93-11e9-8137-0f445c556bde/image/uploads_2F1556991572041-aloffcyxbll-d7a522ae1443515d505dcc993fe529b7_2FAMI-Defense%2BCounsel.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 3 [subtitle] => Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 3, Case Studies of Working with 3rd Party Independents [summary] =>

    In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent monitors to help clients who may have sustained an ethical or compliance violation or are under government scrutiny for allegations of illegal misconduct in a wide variety of industries, disciplines and corporate settings. In this third episode, we look at some case studies. Case studies are something every lawyer and compliance practitioner responds to because it presents real facts and events that the corporate compliance discipline can learn from and hopefully incorporate these lessons learned into their organizations. 

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  • In this five-part podcast series, sponsored by Affiliated Monitors, Inc....
  • Array ( [id] => 95d8df76-6e91-11e9-bd6f-97718bb6afe5 [createdAt] => 2019-05-04T13:25:17.469-04:00 [updatedAt] => 2019-05-04T13:29:33.536-04:00 [title] => Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 1, Introduction [pubdate] => 2019-05-06T01:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/95d8df76-6e91-11e9-bd6f-97718bb6afe5/image/uploads_2F1556990444227-oqi42j4pdzp-6334fe0f25aed93d63cf366ce636aef7_2FAMI-Defense%2BCounsel.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => bonus [seasonNumber] => [episodeNumber] => 1 [subtitle] => Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 1, Introduction [summary] =>

    In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent monitors to help clients who may have sustained an ethical or compliance violation or are under government scrutiny for allegations of illegal misconduct in a wide variety of industries, disciplines and corporate settings. In this first episode, we introduce the concept of defense counsel working with independent monitors. Join us in our next episode where we dive into the weeds by looking at the nuts and bolts of working with a third-party independent monitor. Find out more about Affiliated Monitors Inc. by checking out their website here

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  • In this five-part podcast series, sponsored by Affiliated Monitors, Inc....
  • Array ( [id] => ddb5e7e4-683d-11e9-a784-0b49a4c90f60 [createdAt] => 2019-04-26T12:10:53.336-04:00 [updatedAt] => 2019-04-26T12:11:17.452-04:00 [title] => FCPA Compliance Report-Episode 429, James Koukios on MoFo’s February Anti-Corruption Newsletter [pubdate] => 2019-05-06T01:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ddb5e7e4-683d-11e9-a784-0b49a4c90f60/image/uploads_2F1556294800239-rz333s3j2h-bf741c8772164309cd3009e5bf1ee049_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 429 [subtitle] => FCPA Compliance Report-Episode 429, James Koukios on MoFo’s February Anti-Corruption Newsletter [summary] =>

    In this episode I have back with me, fan favorite James Koukios, partner at Morrison and Foerster.  This is Part 2 of a two-part series where we discuss the firm’s always great Top 10 International Anti-Corruption Developments newsletter. In this episode, we take a look at some of the key highlights from the February newsletter. In the most recent episode, we detailed some of the key developments from the January newsletter. We also have a special segment on the FCPA Opinion Release Procedure. Some of the highlights from the podcast include:

    DOJ Files $38 Million Civil Forfeiture Action in Connection with Malaysia Sovereign Wealth Fund ScandalWhat is the role of civil forfeiture in anti-corruption enforcement?9thCircuit Court of Appeals Vacates Federal Whistleblower Retaliation Verdict Against Bio-Rad. What does this mean for whistleblower cases going forward?UK Serious Fraud Office Closes Two Foreign Bribery Cases. Gutless move on the part of the new director or is something else going on?What is the Opinion Release Procedure? How a company can use it? What happens on the DOJ side once a request comes into the DOJ?For further reading, see the Morrison and Foerster Top 10 International Anti-Corruption Developments for February 2019, by clicking here.

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  • In this episode I have back with me, fan favorite...
  • Array ( [id] => ddb5e7e4-683d-11e9-a784-0b49a4c90f60 [createdAt] => 2019-04-26T12:10:53.336-04:00 [updatedAt] => 2019-04-26T12:11:17.452-04:00 [title] => FCPA Compliance Report-Episode 429, James Koukios on MoFo’s February Anti-Corruption Newsletter [pubdate] => 2019-05-06T01:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/ddb5e7e4-683d-11e9-a784-0b49a4c90f60/image/uploads_2F1556294800239-rz333s3j2h-bf741c8772164309cd3009e5bf1ee049_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 429 [subtitle] => FCPA Compliance Report-Episode 429, James Koukios on MoFo’s February Anti-Corruption Newsletter [summary] =>

    In this episode I have back with me, fan favorite James Koukios, partner at Morrison and Foerster.  This is Part 2 of a two-part series where we discuss the firm’s always great Top 10 International Anti-Corruption Developments newsletter. In this episode, we take a look at some of the key highlights from the February newsletter. In the most recent episode, we detailed some of the key developments from the January newsletter. We also have a special segment on the FCPA Opinion Release Procedure. Some of the highlights from the podcast include:

    DOJ Files $38 Million Civil Forfeiture Action in Connection with Malaysia Sovereign Wealth Fund ScandalWhat is the role of civil forfeiture in anti-corruption enforcement?9thCircuit Court of Appeals Vacates Federal Whistleblower Retaliation Verdict Against Bio-Rad. What does this mean for whistleblower cases going forward?UK Serious Fraud Office Closes Two Foreign Bribery Cases. Gutless move on the part of the new director or is something else going on?What is the Opinion Release Procedure? How a company can use it? What happens on the DOJ side once a request comes into the DOJ?For further reading, see the Morrison and Foerster Top 10 International Anti-Corruption Developments for February 2019, by clicking here.

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  • In this episode I have back with me, fan favorite...
  • Array ( [id] => cbef6316-6e6c-11e9-b604-5b0369312f31 [createdAt] => 2019-05-04T08:58:54.116-04:00 [updatedAt] => 2019-05-04T09:01:57.130-04:00 [title] => Daily Compliance News: May 5, 2019-the Sunday Book Review edition [pubdate] => 2019-05-05T01:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: May 5, 2019-the Sunday Book Review edition [summary] =>

    In today’s edition of Daily Compliance News:

    ·       New David McCullough book. (Wall Street Journal)·       How streaming changed music and us. (Financial Times)·       The Lord Lucan Murder case still fascinates. (Financial Times)·       Harper Lee lives on. (New York Times)

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  • In today’s edition of Daily Compliance News:·       New...
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    In today’s edition of Daily Compliance News:

    ·       New David McCullough book. (Wall Street Journal)·       How streaming changed music and us. (Financial Times)·       The Lord Lucan Murder case still fascinates. (Financial Times)·       Harper Lee lives on. (New York Times)

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  • In today’s edition of Daily Compliance News:·       New...
  • Array ( [id] => d1c47d30-6e62-11e9-81bb-47c927a81716 [createdAt] => 2019-05-04T07:47:53.346-04:00 [updatedAt] => 2019-05-04T07:50:32.012-04:00 [title] => Daily Compliance News: May 4, 2019-the Enter Slow, Exit fast edition [pubdate] => 2019-05-04T07:44:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: May 4, 2019-the Enter Slow, Exit fast edition [summary] =>

    In today’s edition of Daily Compliance News:What to do when the founder is toxic? (New York Times)Michael Senna informs 3rdparty risk management. (Wall Street Journal)Exxon sues Cuban companies for expropriation. (Wall Street Journal)Model airplane enthusiasts stop drone delivery. (Financial Times)

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  • In today’s edition of Daily Compliance News:What to do when...
  • Array ( [id] => d1c47d30-6e62-11e9-81bb-47c927a81716 [createdAt] => 2019-05-04T07:47:53.346-04:00 [updatedAt] => 2019-05-04T07:50:32.012-04:00 [title] => Daily Compliance News: May 4, 2019-the Enter Slow, Exit fast edition [pubdate] => 2019-05-04T07:44:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: May 4, 2019-the Enter Slow, Exit fast edition [summary] =>

    In today’s edition of Daily Compliance News:What to do when the founder is toxic? (New York Times)Michael Senna informs 3rdparty risk management. (Wall Street Journal)Exxon sues Cuban companies for expropriation. (Wall Street Journal)Model airplane enthusiasts stop drone delivery. (Financial Times)

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  • In today’s edition of Daily Compliance News:What to do when...
  • Array ( [id] => a4eca17e-6cc9-11e9-8df3-0be9e7f227ec [createdAt] => 2019-05-02T06:58:31.905-04:00 [updatedAt] => 2019-05-02T07:01:32.569-04:00 [title] => Daily Compliance News: May 2, 2019-the Evaluation edition [pubdate] => 2019-05-02T06:55:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: May 2, 2019-the Evaluation edition [summary] =>

    In today’s edition of Daily Compliance News:

    ·      Wall Street Journal·      Radical Compliance·      FCPA Compliance and Ethics Blog (Part 1)·       Board and Fraud

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  • In today’s edition of Daily Compliance News:·      Wall...
  • Array ( [id] => b74fde46-69e8-11e9-9c99-1373b1b8a8fb [createdAt] => 2019-04-28T15:05:05.727-04:00 [updatedAt] => 2019-04-28T15:06:24.418-04:00 [title] => Life With GDPR: Episode 26- The Importance of Passwords [pubdate] => 2019-05-02T01:03:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 26 [subtitle] => Life With GDPR: Episode 26- The Importance of Passwords [summary] =>

    In this episode, I visit with Jonathan Armstrong a topic which does not seem to garner the attention that it deserves in data protection; that being passwords. Some of the issues and highlights are: What is two-factor authentication? How, when and where should your use it?What are the most common passwords still in use?Why are passwords one of the most basic forms of data security protection?What are the lessons to be learned? For more information on Cordery Compliance, go their website here. Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.

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  • In this episode, I visit with Jonathan Armstrong a topic...
  • Array ( [id] => b74fde46-69e8-11e9-9c99-1373b1b8a8fb [createdAt] => 2019-04-28T15:05:05.727-04:00 [updatedAt] => 2019-04-28T15:06:24.418-04:00 [title] => Life With GDPR: Episode 26- The Importance of Passwords [pubdate] => 2019-05-02T01:03:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 26 [subtitle] => Life With GDPR: Episode 26- The Importance of Passwords [summary] =>

    In this episode, I visit with Jonathan Armstrong a topic which does not seem to garner the attention that it deserves in data protection; that being passwords. Some of the issues and highlights are: What is two-factor authentication? How, when and where should your use it?What are the most common passwords still in use?Why are passwords one of the most basic forms of data security protection?What are the lessons to be learned? For more information on Cordery Compliance, go their website here. Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.

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  • In this episode, I visit with Jonathan Armstrong a topic...
  • Array ( [id] => b3f048f6-6869-11e9-b3df-7bab6fb2ea80 [createdAt] => 2019-04-26T17:21:20.676-04:00 [updatedAt] => 2019-04-26T17:24:41.221-04:00 [title] => Across the Board – Episode 4: Metrics and Senior Management [pubdate] => 2019-04-29T01:10:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 4 [subtitle] => Across the Board – Episode 4: Metrics and Senior Management [summary] =>

    In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We are taking a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 4, we look metrics which a BOD should consider and how a Board should oversee senior management around ethics, compliance and culture. Some of the highlights from the podcast include: Ø  CECOs want their boards will send stronger signals to executive management about the importance of embedding ethics and compliance in the company’s business.Ø  CECOs want boards to hold management more accountable for ethics and complianceØ  A BOD should ask management ‘What have you done to assure compliance. Show me.’ Ø  Why should a Board be concerned about metrics around culture?Ø  What measures should a Board employ for culture and ethics? Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.

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  • In this special 5-part podcast series, I am visiting with...
  • Array ( [id] => b3f048f6-6869-11e9-b3df-7bab6fb2ea80 [createdAt] => 2019-04-26T17:21:20.676-04:00 [updatedAt] => 2019-04-26T17:24:41.221-04:00 [title] => Across the Board – Episode 4: Metrics and Senior Management [pubdate] => 2019-04-29T01:10:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 4 [subtitle] => Across the Board – Episode 4: Metrics and Senior Management [summary] =>

    In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We are taking a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 4, we look metrics which a BOD should consider and how a Board should oversee senior management around ethics, compliance and culture. Some of the highlights from the podcast include: Ø  CECOs want their boards will send stronger signals to executive management about the importance of embedding ethics and compliance in the company’s business.Ø  CECOs want boards to hold management more accountable for ethics and complianceØ  A BOD should ask management ‘What have you done to assure compliance. Show me.’ Ø  Why should a Board be concerned about metrics around culture?Ø  What measures should a Board employ for culture and ethics? Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.

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  • In this special 5-part podcast series, I am visiting with...
  • Array ( [id] => bb7ed692-6868-11e9-b36a-f3fb69f6023d [createdAt] => 2019-04-26T17:15:20.034-04:00 [updatedAt] => 2019-04-26T17:17:44.759-04:00 [title] => Across the Board – Episode 3: Not Enough Time/Not Enough Depth [pubdate] => 2019-04-29T01:08:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 3 [subtitle] => Across the Board – Episode 3: Not Enough Time/Not Enough Depth [summary] =>

    In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 3, we consider many CECO’s concern that Boards do not dedicate sufficient time and priority to compliance nor go into sufficient depth into compliance programs and potential outcomes . Some of the highlights from the podcast include:Why don’t Boards put in more time around E&C programs?Why is compliance often the last item on the Board agenda and equally as often, left off for later?CECOs want to be challenged by their Boards but often are not.Does your Board have a compliance game plan?Why don’t BODs go deeper into E&C programs? How would they do so?Are Boards even asking the right questions?Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.

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  • In this special 5-part podcast series, I am visiting with...
  • Array ( [id] => 7809460a-69d4-11e9-bafd-57b8cc7c0ea7 [createdAt] => 2019-04-28T12:39:28.540-04:00 [updatedAt] => 2019-04-28T12:41:28.063-04:00 [title] => Daily Compliance News: April 29, 2019-the Welcome to my Tweet-Up edition [pubdate] => 2019-04-29T01:06:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: April 29, 2019-the Welcome to my Tweet-Up edition [summary] =>

    In today’s edition of Daily Compliance News:SW Airlines not told of deactivated safety feature on Boeing 737 Max. (Wall Street Journal)Sexual harassment claims hit the energy industry. (I’m shocked) (Wall Street Journal)Welcome to my Tweet-Up, as Musk/SEC settlement twitter imbroglio. (Wall Street Journal)Power, corruption and duplicity in Alabama over a superfund site. (Washington Post)

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  • In today’s edition of Daily Compliance News:SW Airlines not told...
  • Array ( [id] => c08bb762-6869-11e9-94e5-a78804af146a [createdAt] => 2019-04-26T16:35:47.547-04:00 [updatedAt] => 2019-04-26T17:25:02.395-04:00 [title] => Across the Board – Episode 1: What’s the Tone at the Very Top [pubdate] => 2019-04-29T01:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 1 [subtitle] => Across the Board – Episode 1: What’s the Tone at the Very Top [summary] =>

    In this special 5-part podcast series, I visit with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 1 we introduce the topic of what’s the tone at the very top of your organization. Some of the highlights from the podcast include: Ø  What’s the role of the Board around compliance and ethics?Ø  Why is it important for the Board to actively oversee a C&E program?Ø  What is the biggest disconnect between the BOD and the compliance function?Ø  Board members should think of compliance as beyond FCPA and Sarbanes-Oxley, yet there understanding is members’ fuzzy at best. Ø  Board members understand what auditors do, but they often do not understand compliance enough to ask intelligent questions.” Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.

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  • In this special 5-part podcast series, I visit with David...
  • Array ( [id] => f7ab83fc-6833-11e9-b909-17fb83f4c22d [createdAt] => 2019-04-26T11:00:01.919-04:00 [updatedAt] => 2019-04-26T11:00:17.935-04:00 [title] => FCPA Compliance Report-Episode 428, James Koukios on MoFo’s January Anti-Corruption Newsletter [pubdate] => 2019-04-29T01:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f7ab83fc-6833-11e9-b909-17fb83f4c22d/image/uploads_2F1556290562986-rvmzbblwemh-e535314c87c474f11bcfd543dac860a1_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 428 [subtitle] => Episode 428, James Koukios on MoFo’s January Anti-Corruption Newsletter [summary] =>

    In this episode I have back with me, fan favorite James Koukios, partner at Morrison and Foerster.  This is Part 1 of a two-part series where we discuss the firm’s always great Top 10 International Anti-Corruption Developments newsletter. In this episode, we take a look at some of the key highlights from the January newsletter. Next week we conclude with some of the key developments from the February newsletter. Some of the highlights from the podcast include: Ø  Former Bankers Arrested on FCPA Charges in Mozambique Tuna Boat Scandal. Ø  Japan’s Olympics Chief Faces Corruption Charges in France. Ø  Two European Countries Take Steps to Strengthen Anti-Corruption Efforts.Ø  Italy Publishes New “Bribe Destroyer” Law. Ø  The UK Establishes Financial-Industry Task Force. For further reading, see the Morrison and Foerster Top 10 International Anti-Corruption Developments for January 2019, by clicking here.

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  • In this episode I have back with me, fan favorite...
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    In this special 5-part podcast series, I visit with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 1 we introduce the topic of what’s the tone at the very top of your organization. Some of the highlights from the podcast include: Ø  What’s the role of the Board around compliance and ethics?Ø  Why is it important for the Board to actively oversee a C&E program?Ø  What is the biggest disconnect between the BOD and the compliance function?Ø  Board members should think of compliance as beyond FCPA and Sarbanes-Oxley, yet there understanding is members’ fuzzy at best. Ø  Board members understand what auditors do, but they often do not understand compliance enough to ask intelligent questions.” Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.

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  • In this special 5-part podcast series, I visit with David...
  • Array ( [id] => f7ab83fc-6833-11e9-b909-17fb83f4c22d [createdAt] => 2019-04-26T11:00:01.919-04:00 [updatedAt] => 2019-04-26T11:00:17.935-04:00 [title] => FCPA Compliance Report-Episode 428, James Koukios on MoFo’s January Anti-Corruption Newsletter [pubdate] => 2019-04-29T01:00:00.000-04:00 [author] => [imageFile] => https://megaphone.imgix.net/podcasts/f7ab83fc-6833-11e9-b909-17fb83f4c22d/image/uploads_2F1556290562986-rvmzbblwemh-e535314c87c474f11bcfd543dac860a1_2FFCPA%2BCompliance%2BReport.jpg?ixlib=rails-2.1.2 [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 428 [subtitle] => Episode 428, James Koukios on MoFo’s January Anti-Corruption Newsletter [summary] =>

    In this episode I have back with me, fan favorite James Koukios, partner at Morrison and Foerster.  This is Part 1 of a two-part series where we discuss the firm’s always great Top 10 International Anti-Corruption Developments newsletter. In this episode, we take a look at some of the key highlights from the January newsletter. Next week we conclude with some of the key developments from the February newsletter. Some of the highlights from the podcast include: Ø  Former Bankers Arrested on FCPA Charges in Mozambique Tuna Boat Scandal. Ø  Japan’s Olympics Chief Faces Corruption Charges in France. Ø  Two European Countries Take Steps to Strengthen Anti-Corruption Efforts.Ø  Italy Publishes New “Bribe Destroyer” Law. Ø  The UK Establishes Financial-Industry Task Force. For further reading, see the Morrison and Foerster Top 10 International Anti-Corruption Developments for January 2019, by clicking here.

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  • In this episode I have back with me, fan favorite...
  • Array ( [id] => fc262fce-69d0-11e9-a2d2-d3147c3d206f [createdAt] => 2019-04-28T12:15:27.592-04:00 [updatedAt] => 2019-04-28T12:20:25.729-04:00 [title] => Daily Compliance News: April 28, 2019-the Sunday Book Review edition [pubdate] => 2019-04-28T12:11:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: April 28, 2019-the Sunday Book Review edition [summary] =>

    In today’s edition of Daily Compliance News:

    ·      What was behind “Our Man in Havana? (Financial Times)·      Why Ovid is still an inspiration. (New York Times)·       Life of John Hersy. (Wall Street Journal)·      The Best Five. Allison Lurie on heroines over 50. (Wall Street Journal)

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  • In today’s edition of Daily Compliance News:·      What...
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    In today’s edition of Daily Compliance News:

    ·      What was behind “Our Man in Havana? (Financial Times)·      Why Ovid is still an inspiration. (New York Times)·       Life of John Hersy. (Wall Street Journal)·      The Best Five. Allison Lurie on heroines over 50. (Wall Street Journal)

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  • In today’s edition of Daily Compliance News:·      What...
  • Array ( [id] => bcb446dc-686d-11e9-9dad-4baaee12a205 [createdAt] => 2019-04-26T17:52:44.037-04:00 [updatedAt] => 2019-04-26T17:53:33.931-04:00 [title] => Daily Compliance News: April 27, 2019-the Havlicek stole the ball edition [pubdate] => 2019-04-27T01:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => [subtitle] => Daily Compliance News: April 27, 2019-the Havlicek stole the ball edition [summary] =>

    In today’s edition of Daily Compliance News:

    ·      What hath Zion wrought? (NY Post)·      Petrobras revisiting its ill treatment of whistleblowers. (Reuters.com)·       Glencore under CFTC investigation for FCPA violations.(Bloomberg)·       Who owns Huawei? (The company says it’s the workers.)(New York Times)

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  • In today’s edition of Daily Compliance News:·      What...
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    In today’s edition of Daily Compliance News:

    ·      What hath Zion wrought? (NY Post)·      Petrobras revisiting its ill treatment of whistleblowers. (Reuters.com)·       Glencore under CFTC investigation for FCPA violations.(Bloomberg)·       Who owns Huawei? (The company says it’s the workers.)(New York Times)

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  • In today’s edition of Daily Compliance News:·      What...
  • Array ( [id] => b247e5b6-6785-11e9-8d1d-bfb8b6582d8a [createdAt] => 2019-04-24T21:09:25.133-04:00 [updatedAt] => 2019-04-25T14:12:33.396-04:00 [title] => This Week in FCPA-Episode 151 – the World Domination edition [pubdate] => 2019-04-26T01:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 151 [subtitle] => This Week in FCPA-Episode 151 – the World Domination edition [summary] =>

    Is the US utilizing FCPA enforcement for world domination? Recovering screenwriter Jay Rosen and frustrated novelist Tom Fox consider this while they also take a look at some of this week’s top compliance and ethics stories which caught their collective eyes this week. 

    1.    Does the statute of limitations run while Trump is in office? Sara Kropf opines. 2.    What is the compliance response to the Varsity Blues scandal? Sandra Erez reports. 3.    NYDFS cybersecurity requirements are live, is your organization ready? Michael McGrath. 4.    Matt Kelly has a twitter storm on Boeing, sales strategy and ethics. Tom and Matt take a deep dive into the imbroglio. 5.    Is the US using FCPA to garner world domination? Henry Astier opines.6.    What are the best practices for managing employee hotline reports? Jaclyn Jaeger reports.7.    What do the WME companies have in common? Aarti Maharaj. 8.    Transparency challenges in CSR. Dunstan Allison-Hope. 9.    Tom is speaking at ECI’s IMPACT 2019 next week in Dallas about the importance of measuring the quality and maturity of your high quality E&C program. Regisration and information is available here. 10.  Join Tom and Jay at Compliance Week 2019 on May 20-22, in Washington DC. Listeners to this podcast can receive a $300 discount by using the code TOM300. You can check out the full agenda, see who’s speaking, and review registration information. 11. Sarah Hadden joins the Everything Compliance as our latest panelist. Listen in on Episode 45, the Drinkin’ the Kool-Aidedition.  Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com

    For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com

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  • Is the US utilizing FCPA enforcement for world domination? Recovering...
  • Array ( [id] => b247e5b6-6785-11e9-8d1d-bfb8b6582d8a [createdAt] => 2019-04-24T21:09:25.133-04:00 [updatedAt] => 2019-04-25T14:12:33.396-04:00 [title] => This Week in FCPA-Episode 151 – the World Domination edition [pubdate] => 2019-04-26T01:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 151 [subtitle] => This Week in FCPA-Episode 151 – the World Domination edition [summary] =>

    Is the US utilizing FCPA enforcement for world domination? Recovering screenwriter Jay Rosen and frustrated novelist Tom Fox consider this while they also take a look at some of this week’s top compliance and ethics stories which caught their collective eyes this week. 

    1.    Does the statute of limitations run while Trump is in office? Sara Kropf opines. 2.    What is the compliance response to the Varsity Blues scandal? Sandra Erez reports. 3.    NYDFS cybersecurity requirements are live, is your organization ready? Michael McGrath. 4.    Matt Kelly has a twitter storm on Boeing, sales strategy and ethics. Tom and Matt take a deep dive into the imbroglio. 5.    Is the US using FCPA to garner world domination? Henry Astier opines.6.    What are the best practices for managing employee hotline reports? Jaclyn Jaeger reports.7.    What do the WME companies have in common? Aarti Maharaj. 8.    Transparency challenges in CSR. Dunstan Allison-Hope. 9.    Tom is speaking at ECI’s IMPACT 2019 next week in Dallas about the importance of measuring the quality and maturity of your high quality E&C program. Regisration and information is available here. 10.  Join Tom and Jay at Compliance Week 2019 on May 20-22, in Washington DC. Listeners to this podcast can receive a $300 discount by using the code TOM300. You can check out the full agenda, see who’s speaking, and review registration information. 11. Sarah Hadden joins the Everything Compliance as our latest panelist. Listen in on Episode 45, the Drinkin’ the Kool-Aidedition.  Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com

    For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com

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  • Is the US utilizing FCPA enforcement for world domination? Recovering...
  • Array ( [id] => f0029fb4-6626-11e9-a94e-ff25016e3886 [createdAt] => 2019-04-23T15:42:15.136-04:00 [updatedAt] => 2019-04-23T20:21:43.417-04:00 [title] => Everything Compliance-Episode 45, the Drink the Kool-aid edition [pubdate] => 2019-04-25T01:00:00.000-04:00 [author] => [imageFile] => [explicit] => [episodeType] => full [seasonNumber] => [episodeNumber] => 45 [subtitle] => Everything Compliance-Episode 45, the Drink the Kool-aid edition [summary] =>

    Welcome to the only roundtable podcast in compliance. Today, in Episode 45 we celebrate our newest addition to the Everything Compliance gang; Sarah Hadden. Sarah is the Publisher at Corporate Compliance Insights, taking the helm from founder Maurice Gilbert earlier this year. She is a journalist by profession and has been working in the compliance space, largely at CCI for the past six years. She brings a wealth of talent, knowledge and perspective to our happy band of commentators and help us to 'drink the Kool-Aid.    Sarah Hadden discusses experiential learning. She uses that as a basis to consider what is effective training and how interactive training can lead to a new level of not simply effectiveness but awareness to recency bias which can cloud decision making. Sarah shouts out to internet service providers everywhere who were able to make the Mueller report available as soon as it was released.Matt Kelly discusses best practices around disclosing reporting data and using interactive technologies to improve Codes of Conduct, compliance policies and procedures. Matt rants on former White House Ethics Counsel, Stefan Passantino who urged Mazars USA not to comply with a subpoena that House Oversight Committee issued for Trump’s financial documents. That is ethics for you in TrumpWorld.Jay Rosen talks about repositioning compliance as a business generator. He discusses companies which see compliance as a business advantage and details how they do so. Jay shouts out to former White House counsel Don McGahn for being a “real lawyer” because he takes notes.Tom Fox, sitting in on this episode, uses the top three FCPA settlements of 2019 (MTS, Cognizant and Fresenius) to illustrate how the FCPA Corporate Enforcement Policy, announced in 2017 is being used in practice. He compares the three different types of resolutions used by the Justice Department and what it might mean for compliance going forward. Tom rants about Charles Van Doren and the quiz show scandals from the late 1950s.The members of the Everything Compliance panelist are:Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.comMike Volkov– One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com.Matt Kelly– Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.comJonathan Armstrong–is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.comSarah Hadden– the newest addition to our panel. Sarah is the Publisher at Corporate Compliance Insights. Hadden can be reached at Sarah@corporatecomplianceinsights.com 

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  • Welcome to the only roundtable podcast in compliance. Today, in...
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