This Week in FCPA

As we move to our first non-PG podcast and channel our inner Chauncy Gardner with signature line, “I like to watch”, Tom and Jay continue to brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week.

1. What is monitoring and oversight? Matt Kelly draws compliance inspiration from Jerry Falwell who (allegedly) likes to watch his wife having sex with another man.
2. What is risk-based due diligence? Financial regulators opine. Mengqi Sun in the WSJ.
3. Bank/government partnership to fight financial crime. Dylan Tokar in WSJ.
4. Why fraud matters, the Steve Bannon indictment. Mike Volkov.
5. Why does the Palantir S-1 appear to be like the children of Lake Wobegon — stronger, better-looking, and above average? Francine McKenna explains on The Dig. Lucenda Shen sees a flag-waving, in Term Sheet.
6. How bad was the sexual harassment on the Washington Football Club? Very Bad. Expose in the Washington Post.
7. Are we losing the war on AML? Martin Woods says yes.
8. More on McDonald’s suit against its former CEO? Fenwick West lawyers.
9. This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance. In Part 2, we discussed the qualities of a successful CCO. In Part 3, communication as a driver of compliance. In this month’s final episode Part 4, Sapirman takes a look at the CCO role down the road.
10. On Compliance and Coronavirus we had a week of Exiger. Tuesday had Brandon Daniels on Data Management and Data Security Moving out of Covid-19, Michael Beber on on M&A, IPOs and SPACs During and After Covid-19; and Anna Osborn on managed services and outsourced compliance.
11. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on the role of the Board in compliance. This week saw the following offerings: Monday– BOD and succession planning; Tuesday-incorporating compliance strategy into long-term BOD planning; Wednesday-areas of BOD inquiry into compliance; Thursday– special guest Vin DiCianni on 3 specific BOD inquiries on compliance; and Friday-20 questions. The month of August is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. Please join us in September where I take a deep dive into Internal Controls.
12. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here.
13. There’s a place where True Crime meets Compliance, and its name is Fraud Eats Strategy. Check out this new show by Scott Moritz of FTI consulting, and catch all the episodes, notes, resources and more on the Compliance Podcast Network! We’d love to hear what you think of the show, and we’d love it even more if you shared it with a friend, colleague or that one guy you think might be a secret oligarch. Check out this great new podcast series here.
14. This week on the FCPA Compliance Report, some of the top commentators in compliance have joined Tom to discuss some of the top developments in compliance over the past 10 years. The schedule for this week is as follows:

• Monday, Aug. 24 – Episode 495 – Mike Volkov on changes in FCPA enforcement;
• Tuesday, Aug. 25 – Episode 496 – Matt Kelly on changes in compliance from the business journalist perspective;
• Wednesday, Aug. 26 – Episode 497 – Jonathan Armstrong in changes in data protection/data privacy compliance;
• Thursday, Aug. 27 – Episode 498 – Jay Rosen in changes to proactive monitoring from the business development perspective; and
• Friday, Aug. 28 – Episode 499 – Jonathan Marks on how changes in internal audit both mirror and even foreshadow some of the changes he has seen in compliance.

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As the Trump Administration backtracks from its avowed goal to destroy the USPS, Tom and Jay brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week. 

1.     First DOJ Opinion Release in 6 years. What is the significance? Tom explains it all in the FCPA Compliance and Ethics Blog. 

2.     FCPA enforcement action involving international adoptions. Harry Cassin in the FCPA Blog.

3.     Bank/government partnership to fight financial crime.  Dylan Tokar in WSJ Risk and Compliance Journal. 

4.     Once a cheater, always a cheater? Daimler pays $2bn fine. Aaron Nicodemus in Compliance Week(sub req’d)

5.     At the one year anniversary of the Business Roundtable’s Statement on the Purpose of a Corporation, Mike Volkov reviews Board performance in a 4-part series on Corruption, Crime and Compliance. Part 1, Accountability. Part 2, diversity. Part 3, challenges for Board decision-making.  Part 4, steps to advance corp governance. 

6.     Is ‘Failure to Prevent’ the next big crime in the UK? Cordery Compliance alert. 

7.     When can you use a corruption defense in litigation?  VE lawyers in the State Bar of Texas Int’l Law Journal.

8.     Does the McDonald’s suit against its former CEO implicate D&O coverage? Kevin LaCroix opines in the D&O Diary. 

9.     This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance.  In Part 2, we discussed the qualities of a successful CCO. In this week’s Part 3, communication as a driver of compliance. 

10.  On Compliance and Coronavirus we had a week of AMI. Tuesday had Eric Feldman discussing culture and compliance during Covid-19, Vin DiCianni on using compliance ambassadors during Covid; and Deb Waugh on challenges in the health care profession. 

11.  On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on the role of the Board in compliance. This week saw the following offerings: Monday-what leads to a successful BOD investigation; Tuesday– Board metrics for compliance;Wednesday-BOD failures with special guest Vin Dicianni; Thursday– BOD & doing business in China; and Friday-the Board’s role in hiring. The month of August is being sponsored by Affiliated Monitors.  Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.  

12.  Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here. 

13.  Join Tom and Vince Walden (host of The Walden Pond) for a webinar on the ROI of Compliance, Tuesday August 25, 10 AM CT. Registration and Information here. 

14.  Join Tom and AMI’s Don Stern for a review of the 2020 Update to the Evaluation of Corporate Compliance Programs as a part of Navex Global’s quarterly MasterClass on Thursday, August 27. Information and registration here. 

15.  Join K2 Intelligence FIN’s Bernard Factor for a webinar entitled “Examining the Nuances of Correspondent Banking to Address BSA/AML Compliance Risk”. Registation and Information here. 

16.  Join Tom next week on the FCPA Compliance Report, as he leads up to the 500th episode. All next week some of the top commentators in compliance will join Tom to discuss some of the top developments in compliance over the past 8 year. It is all leading up to the 500th anniversary episode which will run Monday, August 31. 

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.

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Tom and Jay brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week. 

1. World Acceptance bribed with bags of cash. Mike Volkov in Crime Corruption & Compliance.
2. Implications from the end of Privacy Shield. Lawyers from Debevoise & Plimpton in NYU’s Compliance and Enforcement blog.
3. NRA shoots itself in foot over non-compliance? Kyle Brausser in Compliance Week. (sub req’d)
4. Using lessons learned. Jeff Kaplan and Rebecca Walker in CCI.
5. Dick Cassin asks ‘are agents ever legal under the FCPA?’ in the FCPA Blog.
6. Applying 2020 Updates to anti-trust compliance. Matt Kelly writing in Navex Global’s Ethics and Compliance Matters.
7. What is a metric’s inventory and why do you need one? Tom explains in the FCPA Complaince and Ethics Blog.
8. Follow on corruption litigation is expensive. Kevin LaCroix in the D&O Diary.
9. This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance. In this week’s Part 2, we discussed the qualities of a successful CCO.
10. On Compliance and Coronavirus this week, we had John Fanning discusses the increased need for due diligence during Covid-19, Andy Goldstrom on compliance adaptations during Covid; and Jed Gardner on business as usual.
11. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on the role of the Board in compliance. This week saw the following offerings: Monday-BOD’s inquiring up and down; Tuesday– the BOD’s role in internal controls; Wednesday-BOD as an internal control; Thursday– BOD governance and risk oversight; and Friday-what is your Board’s investigative protocol. The month of August is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. 
12. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here.

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

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How does Fahrenheit 451 foretell non-compliance regulation in Germany? Tom and Jay brave the surge in Covid cases by staying safe at home to tell the tale. They are back to look at top compliance articles and stories which caught their eye this week.

1. OFAC focusing on screening errors. Mike Volkov with a 3-part series on Corruption Crime and Compliance. Part 1, Part 2 and Part 3
2. There is no single panacea for stopping corruption. Matthew Stephenson in GAB.
3. 5 top steps for data transfer after Schrems III. Neil Hodge in Compliance Week. (sub req’d)
4. What’s the cost of non-compliance? For Wells Fargo, a staggering $15.8 Billion. Matt Kelly explores on Radical Compliance.
5. Fahrenheit 451, compliance and German regulators? Rosemary Lark considers in the FCPA Blog.
6. Coronavirus Comeback planner. Navex Global’s Ethics and Compliance Matters.
7. A compliance approach to excessive force in policing. Joseph Murphy and Emil Moschella in NYU’s Compliance and Enforcement
8. Crisis preparedness and the BOD? Joydip Day explores in CCI.
9. This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance.
10. AMI week on Compliance and Coronavirus as Maurice Gilbert discusses the compliance hiring scene Covid-19, Andy Goldstrom on business sustainability; and Laura Petrolino on storytelling for communications.
11. On the Compliance Podcast Network, Tom begins a new month on 31 Days to a More Effective Compliance Program, this month focusing on the role of the Board in compliance. This week saw the following offerings: Monday-legal obligations of the BOD; Tuesday– prudent discharge of BOD obligations; Wednesday-BOD Compliance Committees; Thursday- OIG guidance for BODs; and Friday-Compliance expertise on the BOD. The month of July is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. 
12. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here.

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

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As the international fight against corruption took two small steps forward this week in the 1MDB case, Tom and Jay brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week. 

1. Goldman Sachs settles with Malaysia for nearly $4bn. Ben Otto and Chester Tay report in the WSJ. Former Malaysia PM convicted in 1MDB scandal, Harry Cassin reports in the FCPA Blog.
2. Mike Volkov reports on two big enforcement actions in Pharma. Indivior and illegal marketing of opioid products. Taro Pharma and price-fixing.
3. What are the shared elements in a best practices compliance program? Jaclyn Jaeger explores in Compliance Week. (sub req’d)
4. How can you test your hotline? Matt Kelly explores on Radical Compliance.
5. Why is Germany soft of corporate crime? Dick Cassin considers in the FCPA Blog.
6. Whistleblower management in the EU. Frank Staelens in CCI.
7. How can you audit AI? James Bone explores in CCI.
8. What should be the goal of effective internal controls? Alex Movchan interviews Edmund Sanders in Risk and Compliance Platform Europe.
9. This month on The Compliance Life, I am joined by Scott Sullivan, Chief Integrity and Compliance Officer at Newport Mining. In Part 1, we discussed the need for empathy in a CCO. In Part 2, we looked at reading the tea leaves and staying ahead of the (corp) wolf pack. In Part 3, we considered who a CCO needs on their compliance team. In this concluding Part 4, we look at the CCO and compliance function down the road.
10. AMI week on Compliance and Coronavirus as Jerry Coyne discusses telemedicine and Covid-19, Don Stern on how Covid-19 will impact federal prosecutors and Mikhail Reider-Gordon compliance issues during the business reopenings.
11. On the Compliance Podcast Network, Tom concludes the topic of 3rd party risk management. This week saw the following offerings: Monday-freight forwarders; Tuesday– risk ranking in the Supply Chain; Wednesday-data and 3rd party risk management (Vin DiCianni as guest); Thursday-enforcement actions; and Friday-wrap up. The month of July is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. Join us in August for the role of the Board of Directors.
12. Upcoming Webinars:

K2-FIN, Windward, and C4ADS Webinar—New Sanctions Developments in the Maritime Sector: UK Sanctions Shipping Guidance and Venezuelan Shipping in Focus, August 5, 2020 at 10:45 to 11:45 AM EST; with Juan Zarate and Eric Lorber. Registration and Information here.

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is      Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

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As the Chinese Consulate burns papers after its closure, Tom and Jay brave the surge in covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week.

1.     More compliance guidance from OFAC. Dick Cassin reports in the FCPA Blog.

2.     First ComEd fined $200MM in Illinois, then Speaker of Ohio House charged in massive state corruption probes. Matt Kelly in Radical Compliance on Illinois. Julie Wernau and Katherine Blunt in WSJ on Ohio.

3.     Was Willie Nelson or Patsy Cline crazy? Bill Steinmann says it’s the FCPA year 2020 in the FCPA Blog.

4.     Mike Volkov goes Old Testament about Amazon OFAC sanctions. In Corruption Crime and Compliance.

5.     From 3 Lines of Defense to the 3 Lines Model as the IIA updates its model. Matt Kelly back with a rare double double for This Week in FCPA in Radical Compliance.

6.     Compliance really is a journey. Mary Shirley in CCI.

7.     How is Covid-19 impacting compliance? Jennifer Sun explores in CCI.

8.     The Ethical Revolution in Business. Philip Winterburn and Jane Mitchell in Converge.

9.     This month on The Compliance Life, I am joined by Scott Sullivan, Chief Integrity and Compliance Officer at Newport Mining. In Part 1, we discussed  the need for empathy in a CCO. In Part 2, we looked at reading the tea leaves and staying ahead of the (corp) wolf pack. This week in Part 3, we considered who a CCO needs on their compliance team.

10.  On the Compliance Podcast Network, Tom continues the topic of 3rd party risk management this month.This week saw the following offerings: Monday-the ROI of 3rd party compliance (Linda Justice as guest); Tuesday– 3rd parties as innovation partners (Eric Feldman as guest), Wednesday-3rd party risk expansion; Thursday-termination of 3rd parties; and Friday-distributor compensation. The month of July is being sponsored by Affiliated Monitors.  Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.

11.  Great Upcoming Webinars:

K2 Intelligence Fin Webinar with AIBACP: Pandemics to Recession—Finding AML and ABC Synergies in Tough Times, July 30, 2020 at 1:30 PM – 2:30 PM EST; with JoAnn Taylor and Adam Frey. Registration and Information here.

ECI’s Best Practice Forum, a Q&A Session with Brian Rabbitt, Acting Assistant Attorney General for the Criminal Division on the FCPA Resource Guide, 2nd edition, Thursday, July 30, 2:00 – 4:00 p.m. EDT. Registration and Information here.

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

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As the SFO finally garners convictions at trial, Tom and Jay brave the surge in covid cases to stay safe they are back to look at top compliance articles and stories which caught their eye this week.

1.  SFO finally garners convictions. Susan Hawley reports in the FCPA Blog. Did the SFO get played? Kristen Ridley considers in Reuters.
2. EU Court of Justice invalidates Privacy Shield. Catherine Stupp in WSJ Risk and Compliance Journal. Cordery Compliance with a client alert.
3. The SEC and its China Problem. Francine McKenna in The Dig.
4. The biggest gold scandal ever? Jon Rausch in Dipping Through Geometries.
5. UK imposes Magnitsky sanctions. Dick Cassin in the FCPA Blog.
6. SEC has $3.8MM whistleblower payout. SEC Press Release.
7. Is compliance in the need for a digital transformation? Adam Shinder shows the way in CCI.
8. How to conduct an audit engagement in a high risk region. Alex Movchan in Risk and Compliance Platform Europe.
9. How much did ego and greed lead to Wirecard scandal? Michael Tobee in CCI.
10. This month on The Compliance Life, I am joined by Scott Sullivan, Chief Integrity and Compliance Officer at Newport Mining. In Part 1, we discussed the need for empathy in a CCO. In Part 2, we look at reading the tea leaves and staying ahead of the (corp) wolf pack.
11. On the Compliance Podcast Network, Tom started the topic of 3rd party risk management this month.This week saw the following offerings: Monday-the how question in due diligence; Tuesday-metrics on 3rd party management, Wednesday-managing 3rd parties; Thursday-auditing of 3rd parties; and Friday-ongoing monitoring of 3rd parties. The month of July is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.
12. Great Upcoming Webinars:

Navigating the Risks of Prescribing Opioids for Chronic Pain in the COVID-19 Era, Wednesday, July 22, 2020 12:00 PM EDT; with Jesse Caplan, Deb Waugh and Amy Fogelman, M.D. Registration and Inforamtion here.

Computer Say ‘No’: Mitigating Legal & Ethical Risks in Public Agency Use of Automated Decision-Making Tools, Tuesday, July 28, 2020 12:00 PM EDT; with David Shonka, Mikhail Reider-Gordon and Jonathan Redgrave. Registration and Information here.

ECI’s Best Practice Forum, a Q&A Session with Brian Rabbitt, Acting Assistant Attorney General for the Criminal Division on the FCPA Resource Guide, 2nd edition, Thursday, July 30, 2:00 – 4:00 p.m. EDT. Registration and Information here.

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

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The DOJ/SEC drop the 2nd edition to the FCPA Resource Guide at 5 PM on July 2. As Tom and Jay brave the surge in covid cases to stay safe they are back to look at top compliance articles and stories which caught their eye this week.

1.  FCPA Resource Guide, 2nd edition released. Tom takes a deep dive in a 5-part blog post series on the FCPA Complinace and Ethics Blog. Part 1-The New Hallmark, Part 2-FCPA Corporate Enforcement Policy, Part 3– the Accounting Provisions, Part 4– Policy and Case Law Updates, Part 5-What does it all mean? Jonathan Marks on Borad and Fraud. Tom and Matt Kelly in Compliance into the Weeds.
2. After its FCPA settlement, Novatris pays another $678MM for corruption inside the US. Mike Volkov in Corruption Crime and Compliance.
3. A plan to restore trust in South Africa ABC enforcement. Larry Kirsch guest posts in GAB.
4. A reassessment of due diligence in China? Jenny Liang opines in the FCPA Blog.
5. Venezuela can’t get its gold out of England. Jon Rausch in Dipping Through Geometries.
6. Amazon settles OFAC sanctions enforcement action. Mengqui Sun in the WSJ Risk and Compliance Journal.
7. How can you make a risk management committee effective? Jim DeLoach shows the way in CCI.
8. Is Deutsche Bank the world’s most corrupt? Matt Kelly digs in on Radical Compliance.
9. Going from disaster recovery to business continuity? Carrie Penman in Ethics and Compliance Matters.
10. On Compliance and Coronavirus, I was joined this week by Paul Mueller on how to reset, restart and accelerate your business in the era of Coronavirus; Ian Denis on employment and communication during Covid-19 and Breeda Miller on caregiving in the era of Covid-19.
11. On the Compliance Podcast Network, Tom started the topic of 3rd party risk management this month.This week saw the following offerings: Monday-Questionniare; Tuesday-Due Diligence,Wednesday-levels of DD; Thursday-evaluating DD and clearing red flags; and Friday-compliance terms and conditions. The month of July is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.
12. Great Upcoming Webinars:

Navigating the Risks of Prescribing Opioids for Chronic Pain in the COVID-19 Era, Jul 22, 2020 12:00 PM in Eastern Time (US and Canada); with Jesse Caplan, Deb Waugh and Amy Fogelman, M.D. Registration and Inforamtion here.

Computer Say ‘No’: Mitigating Legal & Ethical Risks in Public Agency Use of Automated Decision-Making Tools, Jul 28, 2020 12:00 PM in Eastern Time (US and Canada); with David Shonka, Mikhail Reider-Gordon and Jonathan Redgrave. Registration and Information here.

ECI’s Best Practice Forum, a Q&A Session with Brian Rabbitt, Acting Assistant Attorney General for the Criminal Division on the FCPA Resource Guide, 2nd edition, Thursday, July 30 2:00 – 4:00 p.m. EDT. Registration and Information here.

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

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As President Trump allows Russia to pay bounties for the Taliban to kill American soldiers, self-isolating (again) Jay and Tom have a special Thursday July 4th edition to look at top compliance articles and stories which caught their eye this week.

1.  The Novartis FCPA settlement. Tom has a 5 part series Part 1-Introduction, Part 2-the Bribery Schemes,Part 3-Internal Controls, Part 4-Fines, Penalties and Recidivism; Part 5-Data Analytics. Matt Kelly with Radical Compliance. Mike Volkov has a 3 part series on Corruption Crime and Compliance. Matt and Tom take a deep dive on Compliance into the Weeds. After all this Novatris pays another $678MM for corruption inside the US, see DOJ Press Release.
2. Why you need a plan for distributors under the FCPA. Bill Steinman opines in the FCPA Blog.
3. Alexion settles FCPA enforcement action. Dick Cassin breaks the story in the FCPA Blog.
4. Banks facing increased compliance risks. Mengqi Sun in the WSJ Risk and Compliance Journal.
5. The DOJ 2020 Update to the Evaluation of Corporate Compliance Programs with a new emphasis on middle management. Dylan Tokar and Jack Hegal in the WSJ Risk and Compliance Journal.
6. How badly did EY botch the Wirecard audit? Michael Rapaport guest posts on Francine McKenna’s The Dig.
7. CCPA went live on July 1. Were you ready? Jessica Wilburn on Navex Global’s Ethics Matters.
8. What is the role of compliance in the future of work? Neta Meidav in CCI.
9. On Compliance and Coronavirus, I was joined this week by Ryan Schonfeld to discuss IT and physical security in the era of Coronavirus; Cindy Flynn on employment law issues and Bill Sanderson business change in the era of Covid-19.
10. On the Compliance Podcast Network, Tom concluded his one month look at the role of HR in compliance on 31 Days to a More Effective Compliance Program and started a new month of looking at 3rdThis week saw the following offerings: Monday-the parameters of attorney/client privilege; Tuesday-Miranda warnings in internal investigations. On July 1, the new month brought the new topic of 3rd party risk management. Wednesday-the 3rdParty risk management process; Thursday-the business rationale. The month of July is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

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As Wirecard seems to be missing $2bn, Texas Covid-19 cases explode as self-isolating Tom and self-distancing Jay are back to consider some of the week’s top compliance articles and stories on This Week in FCPA.

1.  Supreme Court rules on profit disgorgement. Harry Cassin breaks the story in the FCPA Blog. Tom and Matt Kelly discuss in this week’s Compliance into the Weeds. Mengqi Sun opines it could shrink whistleblower awards, on the WSJ Risk and Compliance Journal.
2. What are 5 ways to use a risk assessment? Jeff Kaplan in the FCPA Blog.
3. Is the SEC on a rampage around internal controls? Bill Steinman thinks so, in the FCPA Blog.
4. What are some of the problems with foreign issuers? Alissa Kole Amico on the Harvard Law School Forum on Corporate Governance.
5. Covid-19 issues and compliance, all on CCI. David England on 3rd Party Risk Management; Chris Jeffrey on your control environment; and Casey Pozarowszczky on fraud risk.
6. What do global ABC enforcement agencies look like? Jon Rausch explores on Dipping Through Geometries.
7. Wirecard is the first and biggest fraud of the 20’s. Reports in the WSJ-CEO Arrested & Missing $2bn, NYT-CEO Resigns, FT-the Reckoning.
8. Novartis settles massive FCPA enforcement action. WSJ Risk and Compliance Journal.
9. Interested in moving to the CCO chair? Check out my latest podcast series The Compliance Lifewhere I interview one CCO type for a month on their journey to the CCO chair and beyond. In on this month’s edition I visit with Ryan Rabalais. In this concluding Part 4, he reflects on the role of coprorate culture. The Compliance Life is now available on iTunes.
10. On Compliance and Coronavirus this week, a week of AMI: Rod Grandon on government bailouts and PPP compliance issues; Jesse Caplan on health care issues during crisis; Dionne Lomax joins me to M&A issues that may be coming down the road. Compliance and Coronavirus is available on iTunes here.
11. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month’s topic has been internal reporting and investigations. This week’s offerings: Monday-How an investigation informs remediation; Tuesday-Asking some tough questions; Wednesday-Board investigative protocols; Thursday– how to have a successful Board investigation; Friday– how the Yates Memo changed investigations. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel.
12. Join Tom and Convercent’s Philip Winterburn to look at hotline reporting data during Covid-19 and what it means for compliance practitioners going forward. Tuesday June 30 at 10 AM CT. Registration and information are available here. It’s free.

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.

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