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
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Hosts Tom Fox and Mike Volkov launch their new podcast series by talking about their favorite Marx Brothers movies and how it leads to a broader description of compliance. The title Why a Duck comes from a line in the famous 1929 Marx Brothers film Coconuts: “ Why a duck? Why no chicken? Why no horse?”
Duck Soup is Tom’s favorite Marx Brothers movie. The film depicts a series of farcical efforts where rivals try to overthrow Rufus T. Firefly. It is political chaos at its finest. Tom especially enjoys the mirror scene.
Mike’s favorite Marx Brothers movie is Day at the Races. Hugo Hackenbush is a vet posing at a doctor at Standish Sanatorium to take care of his wealthy patient Emily Upjohn. The sanatorium is in financial trouble. The film shows his hilarious schemes to get a horse to win a race so that he can pay off the sanatorium debts.
Mike shares a funny story of how the Marx brothers cornered Irving Thalberg into a meeting.
Resources Duck Soup – The Mirror Scene
Duck Soup is Tom’s favorite Marx Brothers movie. The film depicts a series of farcical efforts where rivals try to overthrow Rufus T. Firefly. It is political chaos at its finest. Tom especially enjoys the mirror scene.
Mike’s favorite Marx Brothers movie is Day at the Races. Hugo Hackenbush is a vet posing at a doctor at Standish Sanatorium to take care of his wealthy patient Emily Upjohn. The sanatorium is in financial trouble. The film shows his hilarious schemes to get a horse to win a race so that he can pay off the sanatorium debts.
Mike shares a funny story of how the Marx brothers cornered Irving Thalberg into a meeting.
Resources Duck Soup – The Mirror Scene
In this episode of Trekking Through Compliance, we consider the episode That Which Survives which aired on January 24, 1969, Star Date unknown.
Compliance Takeaways:
- What is your risk tolerance?
- How do you manage sales risk?
- How does your Board look at risk?
In today’s edition Sunday Book Review edition of Daily Compliance News:
- The Peterloo Massacre-Robert Reid
- Ballads and Songs of Peterloo-Allison Morgan
- Peterloo: The English Uprising– Robert Poole
- Peterloo: The Story of a Massacre-Jacqueline Riding
Richard Lummis and Tom Fox are back to continue our series of exploring leadership through the study of US Presidents. This episode begins a short series on Gilded Age Presidents, now largely forgotten. In this episode we take up James Garfield.Some of the highlights include:
- Educational and Professional Background.
- History as Radical Republican.
- Crédit Mobilier scandal of 1872.
- Nomination and Election of 1880.
- Presidency including the Tariff, Purging the Post Office, Supreme Court Nominations, Proposal for universal education and Assassination.
- Leadership Issues including the importance of strong ethics, a strong believer in education and Goldbug-a man for his times?
In today’s edition of Daily Compliance News:
In this episode of Trekking Through Compliance, we consider the episode The Mark of Gideon which aired on January 11, 1969, Star Date 5423.4.
Compliance Takeaways:
- Why is compliance needed at the Board level?
- How do you promote middle management up to senior management?
- What is your triage protocol?
Our hearts go out to the communities which have suffered gun-massacre tradgedies, the most recent being in El Paso TX and Dayton, OH. They consider this issue from the compliance perspective and turn their collective eyes to some of this week’s top compliance and ethics stories.
1. What is the corporate response to El Paso and Dayton? Tom and Matt Kelly explore in Compliance into the Weeds. Kristen Broughton considers corporate disclosures 2. Congress considers a anti-foreign extortion bill to supplement the FCPA. Dick Cassin reports. 3. Is a world free of corruption a dream of fools? The Basel Institute on Governance says no. 4. What is cognitive governance? James Bone begins a 5-part series. 5. AML and Sanctions Trends Under the Trump Administration. Lawyers from WilmerHale explain. 6. What it the federal extortion and blackmail statute? Sara Kropf begins a two-part series. 7. Does everyone want to do the right thing? Calvin London says maybe not in CCI. 8. How to make your Code of Conduct great. Ed Petry tells us. 9. Swiss bank ignores compliance officer; pays $10.7M for tax evasion. Jaclyn Jaeger reports.10. SFO issues guidance for corporate cooperation. 11. Join Jay Rosen and myself for a 5 part exploration of Everything You Always Wanted to Know about Monitors But Were Afraid to Ask. Sponsored by AMI, it is a special production of the Compliance Podcast Network. 12. Our colleague, Doug Cornelis successfully participated in the annual 2-day, 192 mile Pan-Mass Bike Challenge which raises money for the fight against cancer. I hope you will join me again in supporting Doug by donating to PMC. Information on Doug’s ride, why he rides and donation button are all found here.13. Looking for one of the top conferences around. Look no further than Converge19, which is being put on by Convercent on October 2-3. Listeners to this podcast can garner a complimentary pass by using the code “foxvip”. Registration and information can be found 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. For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.
In this episode of Trekking Through Compliance, we consider the episode Let That Be Your Last Battlefield which aired on January 10, 1969, Star Date 5730.2.
Compliance Takeaways:
- Why language translation is so important.
- The role of compliance in creating safe work places.
- Why should you do business with ethical companies?
We conclude our week of Sherlock Holmes-themed podcasts today. Over this week’s blog posts, I have been exploring the first five stories from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s concluding offering, I consider The Adventure of the Sussex Vampire and it informs a root cause analysis in any best practices compliance program. The concludes my initial exploration of The Casebook of Sherlock Holmes and its intersection with compliance and leadership. I hope you have enjoyed listening to it as much as I did researching and brining it to you. But do not worry as I will continue my exploration of the entire Holmes oeuvre in later podcast series.