During this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff & Phelps, the sponsor of this podcast series. We visit on the current state of compliance through the lens of recent Foreign Corrupt Practices Act (FCPA) enforcement actions and the Evaluation of Corporate Compliance Programs, 2019 Guidance, consider some of the specific issues in compliance for private equity and the increased importance of compliance in the healthcare industry. It is a comprehensive look at state of compliance at the half-year mark of 2019. In Part III, we consider the recently released Department of Justice (DOJ) 2019 Guidance and what it means for compliance professionals.
Which will be the topic of our next Podcast. For more information on Kroll, a division of Duff & Phelps, click here. For more information on Terry Orr, click here. Join us for our next episode where take a deep dive into the unique issues of Private Equity and compliance.
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In this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff & Phelps, the sponsor of this podcast series. We visit on the current state of compliance through the lens of recent Foreign Corrupt Practices Act (FCPA) enforcement actions and the Evaluation of Corporate Compliance Programs, 2019 Guidance, consider some of the specific issues in compliance for private equity and the increased importance of compliance in the healthcare industry. It is a comprehensive look at state of compliance at the half-year mark of 2019. In Part II, we consider what can be learned from recent FCPA investigations and settlements.
Which will be the topic of our next Podcast. For more information on Kroll, a division of Duff & Phelps, click here. For more information on Terry Orr, click here. Join us for our next episode where take a deep dive into DOJ’s recent Evaluation of Corporate Compliance Programs, 2019 Guidance.
Categories
Walmart FCPA Settlement
In this special bonus podcast, I am joined by Jay Rosen to discuss the stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the FCPA enforcement action against the world’s largest retailer–Walmart. Some of the highlights include:
- The background facts;
- How significant is the case;
- Is the penalty too low (or too high)?
- Response of Walmart;
- Lessons learned for the compliance professional;
- Was there self-disclosure and full cooperation?
- How should we analyze the monitor requirement under the Benczkowski Memo?
Resources:
The documents for this matter include:
From the Department Of Justice
From the SEC, aCease and Desist Order and Press Release.
See also Tom’s Blog Post Walmart Enforcement Action-Part 1: Introduction. Tom will have multiple blog posts on the Walmart enforcement action so keep abreast on the FCPA Compliance Report.
In this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff & Phelps, the sponsor of this series. We visit on the current state of compliance through the lens of recent Foreign Corrupt Practices Act (FCPA) enforcement actions and the Evaluation of Corporate Compliance Programs, 2019 Guidance, consider some of the specific issues in compliance for private equity and the increased importance of compliance in the healthcare industry. It is a comprehensive look at state of compliance at the half-year mark of 2019. We begin this series by introducing Orr, how he came into focus in the compliance space and where he sees compliance headed down the road.
For more information on Kroll, a division of Duff & Phelps, click here. For more information on Terry Orr, click here. Join us for our next episode where take a deep dive into lessons learned for the compliance practitioner from recent key FCPA enforcement actions.
In this episode of Trekking Through Compliance, we consider the episode Space Seed which aired on February 16, 1967, Star Date 3141.9.
Compliance Takeaways:
Compliance Takeaways:
- How do you manage 3rd parties after the contract is signed?
- Interview questioning is as much art as science.
- What crisis management program do you have in place?
In today’s edition of Daily Compliance News:
- War and Peace: FDR’s Final Odyssey, D-Day to Yalta, 1943 -1945 by Nigel Hamilton
- The Capital by Robert Menasse
- Loonshots: How to Nurture the Crazy Ideas That Win Wars, Cure Diseases, and Transform Industries by Safi Bahcal
- Conviction by Denise Mina
In this episode of Trekking Through Compliance, we consider the episode Return of the Archons which aired on February 9, 1967, Star Date 3156.2
Compliance Takeaways:
- Is the Prime Directive absolute or is there room for flexibility?
- Groupthink can kill off a civilization or corporation.
- AI will always be enhanced by human interactions and interpretations.
In this episode of Trekking Through Compliance, we consider the episode Court Martial which aired on February 2, 1967, Star Date 2947.3.
Compliance Takeaways:
- Have you tied down your documents before your investigation begins?
- Your investigation can change based upon facts on the ground.
- Never forget in a FCPA enforcement action, each lawyer represents his or her client.
With KPMG in the news for one of the biggest ethical trainwrecks in recent memory (or since the last biggest ethical trainwreck-Walmart) Tom and Jay return to discuss both events some of this week’s top compliance and ethics stories which caught their collective eyes.
- Wal-Mart settles. Harry Cassin breaks the story for the compliance community in the FCPA Blog.
- The KPMG ethical trainwreck catapults off the tracks with a SEC enforcement action. Francine McKenna with the most comprehensive reporting. Tom and Matt Kelly explore in separate blog posts.
- What is the role of the WTO in global anti-corruption enforcement? Luciana Silveira explores.
- Banks behaving badly (Part 1,304,555). Swedebank suspends execs from its Estonia branch. Dominic Chopping reports in WSJ. Deutsche Bank under criminal investigation for AML violation. David Enrich, Ben Protess and William K. Rashbaum report.
- NAVEX Global published a first-of-its-kind ethics and compliance benchmark report. Jaclyn Jaeger reviews.
- What are the data security/data privacy issues from using Slack? Jim Murphy explains.
- Designing an ethical company is easy. So says Jeff Kaplan.
- Why are negligence and willfulness different standards? Greg Morvillo and Christine Handley explore.
- Dylan Tokar joins the WSJ Risk and Compliance Journal. See his twitter You can reach him at dylan.tokar@wsj.com.
- Why does one size not fit all? Jay continues his series on working with monitors.
- This week Tom had a special 5-part podcast series sponsored by Assent Compliance on the emerging regulatory challenges in Supply Chain management. Check out the following: Part 1-Ithe HTS Landscape; Part 2-instituting a broader Risk Management Program; Part 3– CSR value proposition; Part 4-Conflict Minerals/Responsible Minerals; Part 5-scaling up to meet challenges. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTube, Spotifyand Corporate Compliance Insights. The Compliance Podcast Networkjoins C-Suite Radio.
- Tom is keynoting next week (June 28) at the University of Miami conference “Compliance Across Borders”. For information and registration click here. In Europe and want to attend a great compliance conference? Tom will be keynoting at Circle of Compliance forum on July 3 and 4 in Paris. For more information and registration, 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.
