In this episode of Trekking Through Compliance, we consider the episode The Lights of Zetar which aired on January 31, 1969, Star Date 5725.3.
Compliance Takeaways:
This week, over a five-part podcast series, we have considered some of the basic questions around monitors and monitorships. I have been joined in this exploration 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 introduced the role of independent integrity monitors and corporate monitorships; discussed both pre-settlement and post-resolution monitorships and their different applications; and listed out some of the considerations a company should take in hiring a monitor. Today, in our concluding Part 5, we look at cost issues when hiring a monitor and how a company can work to ameliorate them.
Some of the highlights from this podcast include:
For additional reading see Jay Rosen’s article How Much Will a Corporate Monitorship Cost? on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. visit their website here.
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:
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.
In today’s edition of Daily Compliance News:
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:
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.
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 1, introduce the role of independent integrity monitors and corporate monitorships.
Some of the highlights from this podcast include:
I hope you will join us tomorrow for Part 2, where we discuss post-settlement monitorships.
For additional reading see Jay Rosen’s article Corporate Monitorship 101: Who Are They, and What Can You Expect?on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. visit their website here.
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 2, we consider the use of monitors in the post-resolution phase.
Some of the highlights from this podcast include:
I hope you will join us tomorrow for Part 3, where we discuss the power of a pre-settlement monitorship.
For additional reading see Jay Rosen’s article What is a Post-Resolution Monitorship? on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. visit their website here.
Mike’s favorite Marx Brothers movie Day at the Races is a fitting analogy for the race to effective compliance. Mike shares his favorite lines from the movie after which the discussion focuses on 3 Best Practices Compliance programs from the Criminal Division of the Department of Justice and OFAC.
Tom points out that each guidance document has a different focus depending on who released it. The Antitrust Guidance for example, is focused on criminal antitrust behavior: that is, the intention to defraud the market based on market fixing, cartel behavior or other intentional acts by more than one group or person. Each one of the documents gives greater insight to anti-corruption practitioners to incorporate into their compliance program.
There are elements that are common to all three documents. Mike says this emphasizes the importance of operationalizing your program to cut through the silos that exist in compliance. Compliance now has a reason to bring together all these elements into one comprehensive training program.
The Criminal Division of the Department of Justice asks for continuous monitoring of the compliance program. We need to take the data and loop it back into the compliance program to continually improve. Antitrust monitoring takes a statistical look at contract data over long periods of time to discover indications of cartel or price-fixing behavior. Anti-corruption monitoring shows the need for overall transaction monitoring from a compliance perspective so that red flags or anomalies are detected early on.
Once you have a database of contracts you can now have effective business analysis. You can analyze discounts given to customers over time and compare and contrast profit margins of contracts by geographical area or business unit. This is going to put the Compliance at the table for business discussions going forward. Compliance now becomes part of the business plan.
Resources OFAC Compliance documentCriminal Division Compliance documentAntitrust Division Compliance document
