Categories
Jamming with Jason

Getting Out of the Forest and Listening to Your Inner Self with Glenda Barber


As a responsible, practical adult, who you are now may not BE who you are authentic. Maybe you’ve found yourself in some difficult life situations and have fallen off your path down into a dark and cold ravine and want to get back to you. Maybe you are struggling and don’t feel aligned with your #authentic.
Learn how to listen to yourself and follow your heart again when listening to this #jammingwithjason #podcast episode. Chances are who you were as a child or seeker wants to come out again, and that’s why you don’t feel aligned.
Glenda is a Reiki Master and Provincially Registered Massage Therapist turned NLP practitioner and hypnotherapist who created the Sacred Harmony Method as a framework to help guide your hypnosis sessions and transformation. It helps open your deep inner blocks, removing limitations and getting you into alignment and flow. You’ll do this by learning to tap into your heart connection, creating heart-aligned goals and habits, and developing self-trust.
Learn more and connect with Glenda at: https://www.glendabarber.ca/ on Facebook and Instagram.
You can even join her Facebook Group – Unlock the Potency and Power of Heart & Mind Harmony:
https://www.facebook.com/groups/unlockthepotencyandpowerofheartmindharmony/
Tune into this episode at: https://www.jasonmefford.com/jammingwithjason255/

Categories
Compliance Kitchen

Treasury Study Re: AML and the Art Trade


Treasury study: Facilitation of Money-Laundering; Terror Finance Through the Trade in Art.

Categories
Greetings and Felicitations

The Science of Star Wars: Part 3, Mechanical Prosthetics

Star Wars continues to be the most successful movie franchise in history. The movies are great fun, the story telling is excellent, thoroughly based on the Hero’s Journey and the characters are some of the most beloved in cinema history. Whether your favorite scene is the from jump into hyperspace, the climactic lightsaber duel between Obi Wan Kenobi and Darth Vadar, Vadar intoning “I am your father”, or the destruction of the Death Star they all still resonate today. But what of the science of Star Wars. Are these great scenes and effects even possible? Do they violate the laws of physics and nature as we understand them today? Join Tom Fox and Dr. Ben Locwin, a healthcare executive, who in addition to his medical expertise is a degreed astrophysicist, as the look behind some of the most exciting scenes in Star Wars to look at the portrayal of science in Star Wars. In Episode 3, they discuss the mechanical prosthetics as used on Luke after his forearm is severed by Darth Vadar. Some of the topics covered are:

1. Sequential current must be deployed to detract muscles to create motion.

2.The role of artificial intelligence and machine learning in mechanical prosthetics.

3. Regenerative cell therapy for skin covering?

4. How are chambers powered?

Categories
Career Can D0

New Work World Advice for the Soul with Melanie Bragg


 
In this episode of Career Can Do, Mary Ann Faremouth chats with Melanie Bragg, who is an author, speaker, and coach. She is an attorney and mediator at Bragg Law PC, and the President of Legal Insight, Inc. She writes for the American Bar Association flagship division’s Defining Moments: Insights into the Lawyer’s Soul.
 

 
Melanie shares legal advice for listeners. As a business owner, having a good lawyer on your side from the beginning will save you money in the long run, especially if you encounter legal problems. The best thing to do is understand your provisions, duties, and responsibilities, and do them correctly from the get-go. Additionally, in certain states, it is against the law for recruiters to ask candidates how much money they usually make. 
 
If you invest in yourself every morning, you end up walking through the day as a successful person, Melanie adds. Many of the obstacles we perceive to be in our way are all in our heads.  If you tell yourself you can’t do it, then you’re not going to do it, but if you tell yourself you can, you’re going to achieve it. Your mindset plays a crucial role in your performance.
 
Resources
Faremouth.com
 
Melanie Bragg on LinkedIn | Twitter
MelanieBragg.com
BraggLawPC.com
 
 

Categories
The Hill Country Podcast

Louis Amestoy – Broadcasting Thru a Winter Storm

Welcome to The Hill Country Podcast. The Texas Hill Country is one of the most beautiful places on earth. In this podcast, recent Hill Country resident Tom Fox visits with the people and organizations that make this the most unique areas of Texas. Join Tom as he explores the people, places and their activities of the Texas Hill Country. In this episode, I visit with Louis Amestoy, Editor and Publisher of the Kerrville Lead, a daily source of news for Kerrville, Kerr County and the Texas Hill Country who talks about broadcasting live during a two-day winter storm.

Some of the highlights include:
·      Broadcasting live during winter Storm .
·      How did these broadcasts help fuel the growth of the Kerrville Lead?
·      Water Rights to Fuel Growth in the Hill Country.
·      Housing development in Kerrville and Kerr County.
·      Dramatic growth in the Kerrville Lead since October.
Resources
Kerrville Lead Bulletin
Kerrville Lead on Facebook
Louis Amestoy on LinkedIn

Categories
Great Women in Compliance

Debra Sabitini Hennelly, Part 1: Psychological Safety, Burnout and Culture


Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
In Part 1 of a two-part series with Debra Sabitini Hennelly, we focus on three major themes of psychological safety, burnout and culture.  In Google studies, psychological safety has been the number one factor of successful teams.  It’s therefore important that we cultivate cultures with psychological safety as a critical part of our culture of integrity.  Environments of psychological safety are safe places where stakeholders know that they can share their views without fear or retribution – that it is a safe place to speak freely.  There also needs to be inclusiveness and a sense of belonging by members of the community and we discuss this in further detail in this episode.
Deb shares some thoughts on burnout and we emphasize that feelings of burnout do not just occur when you’re overworked and overtired.  Burnout can occur when you’re going through very traumatic situations at work or at home so we keep in mind the moral injury aspect of feelings that can be present sometimes with burnout, as well as the sheer exhaustion.
These topics naturally touch on culture as a critical aspect in terms of whether you are surrounded by psychological safety or burnout and we talk about culture from many different angles in this episode from how you can own and embrace it as a population to the recent brave move of Rio Tinto making their culture survey results public as an example of courage and accountability.
The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings to listen in to.  If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it.  You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast.  Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020).
You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.
Join the Great Women in Compliance community on LinkedIn here.

Categories
Compliance Into the Weeds

Corrupt Culture and Bags of Cash-the KT Corp. FCPA Enforcement Action


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. This week, Matt and Tom turn to the recent FCPA enforcement action brought by the SEC involving the Korean company KT Corp. Some of the issues we consider

  • Background facts and a corrupt culture, literally from the top.
  • How does the SEC have jurisdiction over KT Corp?
  • Why you need a flow chart of the bribery schemes and a scorecard of the players.
  • Corruption leading to the Korean Blue House.
  • Bags of cash delivered and kept in office safes.
  • Was the resolution an interim step before a monitor is employed?

Resources
Tom with a 3-part series in the FCPA Compliance and Ethics Blog
Matt in Radical Compliance

Categories
Daily Compliance News

February 23, 2022 the Russia Invades Edition


In today’s edition of Daily Compliance News:
·      Biden Administration pivots to anticorruption in Asia.  (Asia Times)
·      Carl Icahn and pig welfare.   (WaPo)
·      Texas winter storm trial begins. (Reuters)
·      Biden orders next round of sanctions. (NYT)

Categories
Blog

KT Corp. FCPA Enforcement Action: Part 2 – The Bribery Schemes – Flow Charts and Scorecards

Matt Kelly and I did an episode on our podcast, Compliance into the Weeds, about the KT Corporation settlement Foreign Corrupt Practices Act (FCPA) with the Securities and Exchange Commission (SEC) via a Cease and Desist Order (the Order) for “disgorgement of $2,263,821, prejudgment interest of $536,457, and a civil money penalty in the amount of $3,500,000” bringing the total fine and penalty to just over $6.3 million. One of the most prescient lines that came out of the podcast was that you need a flow chart to follow all the bribery schemes and you needed a scorecard to follow all the persons and entities involved in those schemes. In today’s post we will look at the bribery schemes in some detail.
I. South Korea
a. Getting Cash
As I mentioned yesterday, the bribery schemes used by KT Corp. harkened back to some older FCPA enforcement actions in one respect as one of the key bribery schemes used involved cash. The cash was garnered to fund a series of bribes from 2009-2017. The Order noted, “high-level executives of KT maintained slush funds, comprised of both off-the-books accounts and physical stashes of cash, in order to provide items of value to government officials, among others. These included gifts, entertainment and, ultimately, illegal political contributions to members of the Korean National Assembly serving on committees relevant to KT’s business.”
The cash was obtained in two distinct ways. In the first scheme, 2009-2013,  the Chief Executive Officer (CEO) and another senior approved inflated bonuses to other executive officers and executives. The recipients laundered the bonus payments into cash and next returned the cash to the CEO. This generated a slush fund of approximately $1 million. Some of the funds were held in another executive’s personal bank account, while the cash was stored in a safe in the corporate offices. The CEO then used the cash as a slush fund for gifts and payments to Korean government officials with the ability to influence KT Corp.’s business. There was no accompanying spreadsheet recordation’s of the gift recipients, although these payments were apparently common knowledge within the executive ranks. In a massive accounting fraud, the company “booked the slush fund amounts as executive bonuses, even though the money was used for gifts and for payments to government officials.”
Eventually this bribery scheme was uncovered, and the CEO was criminally charged on this matter. This did not deter KT Corp. in moving forward to continue to engage in bribery and corruption. From 2014 to 2017, the company’s Corporate Relations (“CR”) Group was brought in as the funding mechanism to create the pot of money to pay bribes. However, this vendor did not deliver gift cards to the CR Group but cash. The corrupt vendor even kept a percentage of the overall amount of cash as a fee. To facilitate the accounting fraud, the company used the phrase “CR Case Benchmarking,” in the company purchasing system as the purported purpose for the purchase.
But the cloak and dagger style used by KT Corp. continued as the vendor would meet a representative from the CR Group outside the KT office building where the vendor would give the CR Group representative “a paper bag containing a large manila envelope of cash, corresponding to the value of the gift cards purchased, less a commission for Vendor.” The cash was kept locked in the CR Group offices.
Unlike the first bribery scheme which was run directly by the CEO, in this second phase the cash was provided “to KT officers and managers, with the understanding that they would transfer the funds electronically to the contributions accounts for various Korean lawmakers. Once the transfer was made, a CR employee would inform the particular lawmaker’s aide that the contribution came from KT. This scheme was used to evade Korea’s Political Funds Act, which prohibits corporations from making political contributions. Most of the funds went to lawmakers in the National Assembly who sat on committees with the ability to impact the telecommunications industry and KT’s business.”
b. Hiring of Princelings
Here we saw a variety of the Princelings scandal that engulfed JPMorgan and other entities in bogus hiring’s of sons, daughters and other family members to provide illegal benefits to foreign government officials. Yet another scheme involved hiring individuals, as KT Corp. employees, with personal connections to the South Korean White House and ruling party, (the “Blue House”). Once they were hired these individuals were given even more cushy jobs in the company. In a derivation of the Princelings hiring schemes, the company also hired an entire advertising agency which did not meet KT Corp. criteria for retention as a vendor. In addition to hiring this unqualified advertising agency, “KT paid the two individuals a total of $454,009 in salaries and the advertising firm a total of $5.88 million in fees.”
II. Vietnam
a. Solar Power Project
In this project, KT Corp. used a sophisticated business venture, which was not a formal partnership or Joint Venture (JV) partnership. Under this bribery scheme, KT Corp. had another company involved in the project wire some $95,000 to KT Corp, who then would facilitate the payment of the bribe. The money was wired to a KT Corp. employee’s personal bank account, who then withdrew as cash. The employee and a construction company subcontractor representative met the corrupt government official and he was paid the money. Internally, the payment was described as “a rebate to the project owner.”
However, that did not end the matter for KT Corp. as they had to repay the construction company for the $95K. The construction company billed KT Corp. for the bribe, describing it as “expenses for engaging in sales activities with the ordering organization . . . ($95K),” as well as other expenses. KT Corp. paid the construction company approximately $200,000 to settle all the claims, including reimbursement for the bribe payment, and it booked the payment as “Support/consulting for performance of the business (completed).”
b. Vocational College Project
KT Corp. participated with a consortium to bid on the Vocational Colleges Project. KT Corp. learned from its original consortium partner (“Partner 1”), which was to pay the agent fee, that 10% of the project cost would go to the agent, who would pass on 7% of the project cost to Official 1. However, Partner 1 informed KT Corp. that it did not want to be responsible for the agent’s fee due to the risk involved. KT Corp. agreed to reorganize the consortium and assume responsibility for paying the agent’s fee. KT Corp. and a corrupt agent agreed that the fee would be 8.5%, which included $550,000 for Official 1.
KT Corp. then arranged for a subcontractor in the consortium to become a consortium partner (“Partner 2”) and KT Corp. “tasked Partner 2 with the responsibility of paying the agent fee. The purpose of the arrangement was to distance KT from the agent, as well as to conceal the agent from KT’s agent review process. While the agent review process was a financial risk review, not an anticorruption review, the KT managers involved preferred to avoid any questions about KT’s relationship with the agent. Paying the agent through Partner 2 enabled KT managers to bypass the review.”
As I said at the start of this post, you need a flow chart to follow the bribery schemes and a scorecard to follow the players.
Join us tomorrow where we look at some lessons learned for the compliance professional.