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Innovation in Compliance

A Conversation with Skillsoft and StoneTurn: Part 1 – Toby Ralston on Your Code of Conduct

Welcome to a special five-part podcast series, A Conversation with Skillsoft and StoneTurn: From the Code of Conduct to Risk Assessment to Continuous Improvement. This week’s podcast series is jointly sponsored by Skillsoft and StoneTurn Group, LLP. In this podcast series we will explore the recently released 2020 Update to the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (2020 Update). We focus on your Code of Conduct and how it is informed by your Risk Assessment, training on your Code of Conduct, performing a Risk Assessment and conclude with how all this ties to continuous monitoring and continuous improvement. Participants in this podcast series include: from Skillsoft, Charlie Voelker, Director, Compliance Products; John Arendes, Vice President and GM of Global Compliance Solutions; from StoneTurn, Toby Ralston, Managing Director, Jamen Tyler, Managing Director, and Stephen Martin, Partner. In this first episode, I visit with Toby Ralston on Code of Conduct.

Obviously, your Code of Conduct is viewed as a foundational document by the DOJ and Securities and Exchange Commission (SEC) as they laid out in the FCPA Resource Guide, 2nd edition. Yet many compliance practitioners struggle with how to benchmark a code of conduct. Ralston believes there are a number of ways that a compliance professional could potentially benchmark a Code of Conduct. He suggested “a matrix approach that uses a modified scorecard or a balanced scorecard where we measure objectives early and subjectively rank an individual Code. We then consider those components against the Codes of competitors and those recognized as best practice.” This can make such a benchmarking exercise a peer comparison, but that peer to peer comparison should not be limited to organizations in your industry. “We find that this approach helps us identify missing or underdeveloped topics as well as sections of a Code that likely need to be condensed or reorganized.”

Join us tomorrow where Charlie Voelker, Director, Compliance Products, Skillsoft, discusses how a Risk Assessment informs your Code of Conduct.

Webinar

If you enjoyed today’s podcast, I want to let you know about an upcoming webinar Skillsoft and StoneTurn are hosting. The webinar “Evolving Your Compliance Program” will be held on Wednesday Sept 23 and will explore how companies are leveraging data and information to improve and evolve their compliance programs. Information and Registration click here.

 Resources

For more information on Skillsoft’s compliance offerings, click here.
For more information on the Skillsoft/StoneTurn partnership, click here.

For more information on StoneTurn, click here.

Categories
FCPA Compliance Report

Eric Lorber on How the Trade Sanction Sausage is Made


Ever wonder how the sausage is made around economic and trade sanctions? What is the process for persons and companies to be put on the sanctioned lists? Then this is the podcast for you as I am joined by Eric Lorber.
Eric is a vice president at K2 Intelligence Financial Integrity Network, where he advises global financial institutions on issues related to sanctions and anti-money laundering/combating the financing of terrorism compliance. Prior to re-joining FIN, Eric was a senior advisor to the Under Secretary for Terrorism and Financial Intelligence at the United States Department of the Treasury, where he provided strategic guidance on U.S. sanctions and AML/CFT policies. He is also the senior director of the Center of Economic and Financial Power at the Foundation for Defense of Democracies.
Some of the highlights include:

  • What is the process for creation of economic sanctions?
  • How does an individual or corporation go on the economic sanctions list?
  • What is the role of the DOJ?
  • Who at Treasury leads the effort?
  • What is the process for enforcement?
  • Why does Treasury have such an ongoing educational effort around sanctions?
Categories
Daily Compliance News

August 17, 2020-the References Gone edition


In today’s edition of Daily Compliance News:

  • Nursing homes try to lobby their way out of negligence. (NYT)
  • Historical business benchmarks no long apply. (WSJ)
  • DOJ extends a ban. (WSJ)
  • Trump withdraws BLM nominee who wanted to sell federal land. (WaPo)
Categories
Sunday Book Review

August 16, 2020, the European Noir edition


In today’s edition of Sunday Book Review:

Categories
Daily Compliance News

August 15, 2020-the Illegal Officials edition


In today’s edition of Daily Compliance News:

  • Top DHS officials appointed illegally. (WaPo)
  • Boeing in more trouble. (WSJ)
  • Sec. of Labor alleged to have personally intervened in Oracle case. (WSJ)
  • Was Beirut blast corruption or negligence. (FT)
Categories
Innovation in Compliance

A Conversation with Convercent and StoneTurn: Stephen Martin on Evaluating Compliance Programs


Welcome to a special five-part podcast series, A Conversation with Convercent and StoneTurn: From the Code of Conduct to Risk Assessment to Continuous Improvement. This week’s podcast series is jointly sponsored by Convercent and StoneTurn. Over the course of the series we have explored the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (2020 Update). We focus on investigations, data analytics, evaluating compliance programs, internal reporting and corporate culture. Participants in this podcast series include: Asha Palmer, Convercent Chief Ethics and Compliance Officer (CECO) and Executive Vice President (EVP) of CONVERGE; Rex Homme, Michele Edwards, and Stephen Martin, all Partners at StoneTurn. In this fifth and final episode, I am joined by Martin for a discussion of evaluating compliance programs.
Resources
For more information on StoneTurn, check out their website, here.
For more information on Convercent, check out their website, here.
To download a copy of the Convercent Interactive Self-Assessment based on the 2020 Update to the Evaluation of Corporate Compliance Programs, click here.

Categories
This Week in FCPA

Episode 218 – the Bags of Cash edition

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.

Categories
Daily Compliance News

August 14, 2020-the Will Danny Sell edition


In today’s edition of Daily Compliance News:

  • Marketers begin to scrutinize beyond Facebook. (WSJ)
  • Can Dan Snyder be forced to sell? (WSJ)
  • US try again to seize Iranian vessels on high seas. (WSJ)
  • Hunt for ex-Wirecard COO goes public. (WSJ)
Categories
Innovation in Compliance

A Conversation with Convercent and StoneTurn: Asha Palmer on Corporate Culture

Welcome to a special five-part podcast series, A Conversation with Convercent and StoneTurn: From the Code of Conduct to Risk Assessment to Continuous Improvement. This week’s podcast series is jointly sponsored by Convercent and StoneTurn. Over the course of the series we are exploring the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (2020 Update). We focus on investigations, data analytics, evaluating compliance programs, internal reporting and corporate culture. Participants in this podcast series include: Asha Palmer, Convercent Chief Ethics and Compliance Officer (CECO) and Executive Vice President (EVP) of CONVERGE; Rex Homme, Michele Edwards, and Stephen Martin, all Partners at StoneTurn. In this fourth episode, we take a deep dive with Palmer into corporate culture.

Join us tomorrow, as Stephen Martin, Partner at StoneTurn discusses evaluating compliance programs.
Resources
For more information on StoneTurn, check out their website, here.
For more information on Convercent, check out their website, here.
To download a copy of the Convercent Interactive Self-Assessment based on the 2020 Update to the Evaluation of Corporate Compliance Programs, click here.

Categories
Compliance and Coronavirus

Andy Goldstrom on Pivoting Compliance into the New Normal


Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. In this episode, I have back Andy Goldstrom, founder of Midcourse Advisors. Andy is a  two-time Inc 500 executive and his team help companies grow profitably and do it fast. On a previous episode, he called about business adaptation in the time of Coronavirus. He rejoins me to focus on what a corporate compliance function can do in the New Normal of Covid-19.
Some of the highlights include:

  • What does corporate governance look like in the time of Covid-19?
  • How can a compliance function focus on consistently ethical behavior?
  • How can compliance be done at the speed of business?
  • What is the New Normal in the age of Coronavirus?

For more information on Andy Goldstrom or Midcourse Advisors, click here.
Check out Exchanges at Goldman Sachs podcast here.