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EMBARGOED!

EMBARGOED! Episode 4: It’s the End of the World as We Know It (& I Feel Like Podcasting About Sanctions) EMBARGOED! Episode 4

In this episode of EMBARGOED!, hosts Brian Fleming and Tim O’Toole tackle the only topic that really matters right now, the COVID-19 pandemic, and break down some of the most significant ways trade-based restrictions are impacting the global crisis. They also discuss practical considerations for companies dealing with compliance, due diligence, and investigations demands under the cloud of COVID-19. Our first social distancing Lightning Round also features some thoughts on the Sadr verdict in SDNY, the latest provocative actions by the U.S. targeting Venezuela and Nicaragua, and, finally, a few words on extradition.

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Questions? Contact us at podcasts@milchev.com.
EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
EMBARGOED! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike, hosted by Miller & Chevalier Members Brian Fleming and Tim O’Toole. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe for new bi-weekly episodes so you don’t miss out!
Timestamps:
0:14 Introduction
The Rundown: COVID-19 Crisis
3:36 Global Trade Policy Survey
4:46 How are trade policies around the world making things better and (mostly) worse for global supply chains in disarray?
20:55 A Tale of Two Sanctions Programs: Iran and North Korea
32:00 Practical Challenges in the Trade Space
47:35 Lightning Round
48:20 Sadr Verdict
56:36 Venezuela + More Rosneft
1:04:21 Designation of Nicaraguan National Police
1:09:48 A Word About Extraditions: Travel Carefully (if you’re Iranian and under indictment by the U.S. DOJ)
1:14:36 Final Thoughts
***Stay sanctions free.***

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31 Days to More Effective Compliance Programs

What does innovation in compliance look like?


With the DOJ Evaluation’s emphasis on operationalizing your compliance regime, innovation is an important tool for you to use in this journey, yet one that is too often overlooked.We have considered a variety of innovations in compliance; from innovations in structure, use of social media tools and concepts, to new and different ways to consider your internal resources as ways to innovate in your compliance regime. The DOJ has consistently said that a compliance program must evolve. It must evolve to meet new or updated risks, new opportunities or different regulations. Innovation is one of the best ways to evolve. Finally, and perhaps most importantly as a compliance practitioner, always remember that you are only limited by your imagination.
 Three key takeaways:

  1. Innovation is one of the most overlooked and under-utilized tools in compliance.
  2. Operationalizing your compliance program will require innovation in your compliance program going forward.
  3. As with most CCO initiatives, you are only limited by your imagination.
Categories
Compliance and Coronavirus

Jared Connors on Supply Chain During Coronavirus


Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. As the Voice of Compliance, I wanted to start a podcast which will help to bring both clarity and sanity to the compliance practitioner and compliance profession during this worldwide health and healthcare crisis. In this episode, I am joined by Jared Connor, Subject Matter Expert on CSR for Assent Compliance. We discuss how expectations of compliance will continue during this health crisis.
This year marks the transition period as companies prepare for expanded Responsible Minerals initiative. While key events that were scheduled for this spring have now been cancelled, that does not mean that Responsible Minerals reporting expectations are going away.  How can companies understand these changes in reporting and enhanced due diligence expectations without the education and key stakeholder engagement these events provide?  The winter of 2021 may well have companies all over the globe scrambling to play catch up and taking some all too costly reputational hits in the market.
This podcast is sponsored by SAI Global. To learn how you can protect your business operations and workforce during these uncertain times, visit saiglobal.com/risk for free resources, expert guidance, and industry-leading technology.

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Innovation in Compliance

Going Beyond DDQs with Jed Gardner


Tom Fox chats with Senior Vice President of Linedata Technology Services, Jed Gardner in this week’s show. They talk about how Linedata’s solution protects companies within the financial sector from cybersecurity risk and how this leads to increased productivity and profitability.

Mitigating Cybersecurity Risk
Jed says that LineData addresses three main challenges within the financial sector. They provide 1) cloud computing solutions to investment firms; 2) cybersecurity that is SEC- and FINRA- compliant; and 3) 24/7 managed support services that are both remote and on premises from their security operations center.
Tom asks Jed to explain how Linedata helps investment firm senior executives address cybersecurity risk. Jed replies that his company is “…providing a level of confidence to senior executives within investment firms that they are protected on a day-to-day, week-to-week, month-to-month basis… The way we’ve been addressing that is by providing levels of service and reporting that do meet the SEC and FINRA requirements, but really push beyond that.” He says that Linedata’s reporting capabilities allow them to use their tool sets to provide a day-to-day view.
Jed comments that categorizing data and defining its locations are important considerations in providing their services to clients. He points out that regulated businesses, in particular, should classify their data and understand where it is, understand the risks, and its impact on the business and stakeholders. As such, businesses should have prevention technologies and policies in place to protect their live and archived data. 
360° Risk Analysis
Jed and Tom discuss Linedata’s approach to cybersecurity with vendors down the supply chain. Jed comments that senior executives want to know all the risks to their business since they ultimately become personally responsible for it. A proper risk analysis, like the 360° risk analysis Linedata offers its clients, can unearth hidden risks. Jed describes the 360° risk analysis process. He remarks, “Being able to implement that for businesses and provide feedback on a regular basis allows us to correctly protect them as much as we possibly can, but also gives the senior executives confidence…” 
Beyond DDQs
Tom asks, “…can a compliance solution increase business efficiency and productivity leading to an increase in profitability?” Jed responds that using managed services such as Linedata add value by giving time back to key members of staff, who are then able to provide value back into the business. This increased productivity is what leads to increased profitability. He explains how Linedata gives time back to investment firms by taking away the tedious due diligence questionnaire (DDQ) process. He adds that his clients now have time “to look at how to enable the business to be more productive through the more efficient implementation of security and compliance and then, in turn, utilizing that knowledge to then allow the business to operate more freely and more efficiently.” 
Resources
Linedata.com

Categories
Daily Compliance News

March 31, 2020-the Let Them Eat Cake edition


In today’s edition of Daily Compliance News:

  • GE employees demand to mfg ventilators? (com)
  • Compliance Officer whistleblower awarded $450K by SEC. (RadicalCompliance)
  • DOJ investigates lawmakers for insider trading. (WSJ)
  • CEOs need to take pay cuts. (Houston Chronicle)