Categories
Daily Compliance News

Daily Compliance News: July 13, 2019, the Facebook fined edition

In today’s edition of Daily Compliance News:

  • FTC proposes a $5 bn fine for Facebook. (NYT)
  • Epstein developments-(1) Feds allege witness tampering (NYT); (2) Acosta resigns. (WSJ)
  • Deutsche Bank pays $175MM to settle bribery allegations. (FT)
  • Head of Vatican’s Sistene Chapel choir resigns amid fraud allegations. (Reuters)
Categories
Trekking Through Compliance

Trekking Through Compliance-Episode 43 – Wolf in the Fold


In this episode of Trekking Through Compliance, we consider the episode Wolf in the Fold which aired on December 22, 1967, Star Date 3614.9.
Compliance Takeaways:

  1. Does your Board engage in active oversight of your compliance function?
  2. Do you perform due diligence on potential senior management hires?
  3. What should be the length of a suspension?
Categories
This Week in FCPA

This Week in FCPA-Episode 162 – the Halfway to ‘Take it Back’ edition

The All-Star Game has come and gone and the Astros are halfway back to returning the World Series trophy to Houston.  As Tom and Jay look forward to the second half of the baseball season,  they are back  to discuss some of this week’s top compliance and ethics stories which caught their collective eyes.
1.    GDPR week.
2.    Why do FCPA resolutions take so long? Matthew Stephenson considers through the lens of the Walmart FCPA enforcement action.
3.    What is suspension and debarment? Jay Rosen explains in Part 1 of a five-part series.
4.    The FBI is actively investigating in Latin America. Matt Ellis reports.
5.    What finance can learn about compliance from recent corporate scandals.
6.    Deutsche Bank now under scrutiny for its role in 1 MDB scandal. Dylan Toklar continues to nail.
7.    What is data maintenance and why is it so critical to compliance?
8.    CCOs and D&O coverage. Julie DeMauro and Janaya Moscony.
9.    Caremark is alive and well, at least when it comes to ice cream.
10. Have you checked in on Trekkng Through Compliance? If not sample of this week’s exploration of Star Trek-the Original Series and compliance. Check out the following: Monday-Metamorphosis; Tuesday-Journey to Babel; Wednesday-Friday’s Child; Thursday-The Deadly Years; and Friday-Obsession. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTubeSpotifyand Corporate Compliance InsightsCompliance Podcast Networkand now on the C-Suite Radio Network.
11. Tom and Jonathan Marks are joining Sean Freidlin (back from his honeymoon) on a Hanzo webinar on Wednesday, July 17 at 2 PM EDT. We discuss compliance research, trend and key enforcement actions from Q2. The event is free. For more information and registration details, click 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.
Categories
Popcorn and Compliance

Toy Story 4

In this podcast series, recovering screenwriter (and Mr. Monitor) Jay Rosen and Tom (the Compliance Evangelist) indulge in passion for the movies by looking at them through the lens of compliance. Jay is a contemporary movie fan and I am more of a classic movie maven so we present a well-rounded view of the movie fandom. If you want to indulge in your love for the movies with two guys who are passionate about Hollywood and get some ideas for your compliance program, this is the podcast series for you.For this  offering, we consider the recently released Toy Story 4.
Some of the highlights include:

  • Why did this movie seem to come from a place of revenue generation over emotion?
  • Where was the heart of the movie?
  • Why did the entire movie seem so contrived?
  • Lack of minor characters playing much of any role.
  • The introduction of ‘Forky’ and does this character work?
  • Jay gives the Inside Hollywood story of the production.
  • Jay gives the movie not only a half-full bucket of popcorn but a stale half-bucket as well. Tom joins with a half-bucket of popcorn as well but goes with fresh popcorn. Both were very disappointed in the film.

Some of the Compliance takeaways:

  1. How do you onboard new employees around compliance and ethics?
  2. What is your investigative protocol?
  3. Get out of the office and into the field.
Categories
Trekking Through Compliance

Trekking Through Compliance-Episode 42 – Obsession


In this episode of Trekking Through Compliance, we consider the episode Obsession which aired on December 15, 1967, Star Date 3619.2.
Compliance Takeaways:

  1. Sometimes a CCO must make a stand and speak truth to power.
  2. How is a root cause analysis different than an investigation?
  3. Why you should train for crisis management.
Categories
Daily Compliance News

Daily Compliance News: July 12, 2019, the tit-for-tat edition

In today’s edition of Daily Compliance News:
·       Export sanctions with Huawei change yet again. (FT)
·       US Reaches $1.4 Billion Opioid-Drug Settlement With Reckitt. (WSJ)
·       In a tit-for-tat exercise, France institutes digital tax on US companies.  (NYT)
·       No surprise here as Uber received more scrutiny from the SEC than Lyft during the IPO process. (MarketWatch)
Categories
Trekking Through Compliance

Trekking Through Compliance-Episode 41 – The Deadly Years


In this episode of Trekking Through Compliance, we consider the episode The Deadly Years which aired on December 8, 1967, Star Date 3478.2.
Compliance Takeaways:

  1. Just because research is discontinued does not mean it is invalid.
  2. Training-Why was Chekov’s reaction like that of a schoolboy?
  3. How do you show the quality, ability and competence of your compliance team?
Categories
Daily Compliance News

Daily Compliance News: July 11, 2019, the yet even more trouble for Deutsche Bank edition

In today’s edition of Daily Compliance News:
·       Deutsche Bank under investigation for its role in 1MDB scandal. (WSJ)
·       Harvard suspends star professor for sexual harassment claim. (NYT)
·       US House passes whistleblower law fix.  (Radical Compliance)
·       French ex-President questioned in Brazilian figher jet probe. (Reuters)
Categories
Life with GDPR

Life With GDPR: Episode 30- British Airways GDPR Enforcement Action

In this podcast, data privacy/data security expert Jonathan Armstrong and Compliance Evangelist Tom Fox use the framework of GDPR to discuss a wide range of issues relating to these topics. They consider what the US compliance and InfoSec security expert needs to know about what is happening in the UK, Europe and beyond. In this episode, we discuss the recently announced proposed fine by the UK Data Protection Regulator against British Airways (BA) after its data breach. She intends to fine the airline £183.39 million (approximately $230MM).
Some of the highlights in this episode include:
  1. This proposed fine represents the largest GDPR fine in the UK.
  2. As the fine is now open to comment by BA and other national data protection regulators, the amount of the final fine may change.
  3. The BA CEO comes out swinging against this fine.
  4. What was the role of the ICO as ‘lead regulator’?
  5. Will BA’s tone-deaf posturing hurt or help it with the final penalty?
  6. What did BA know and when did they know (yes that is the famous Watergate question) will be a critical analysis.
  7. What remedial measures did BA engage in after it became aware of the breach?
  8. What are the lessons to be learned by the data privacy officer?
For more information on Cordery Compliance, go their website here.
For additional reading see the Cordery Compliance article, “UK Data Protection Regulator Announces Intention to Fine BA after Data Breach”.
Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.
Categories
Trekking Through Compliance

Trekking Through Compliance-Episode 40 – Friday’s Child


In this episode of Trekking Through Compliance, we consider the episode Friday’s Child which aired on December 1, 1967, Star Date 3497.2.
Compliance Takeaways:

  1. The three C’s of leadership.
  2. How do you react when the leader goes off the deep end?
  3. Train your employees what to do when faced with a bribe demand.