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Daily Compliance News

Daily Compliance News: May 7, 2024 – The Ghost Flights Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network.

Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

In today’s edition of Daily Compliance News:

  • Just how badly can airlines treat customers. (BBC)
  • The corrupt dictator’s son has foreigners arrested. (WSJ)
  • Yet another F.A.A. investigation for Boeing. (NYT)
  • Goldman Sachs criminal case over 1MDB ends. (Reuters)

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: How Investigative Triage Can Drive Culture

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we consider how your investigative protocol and triage can drive and improve your corporate culture.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Everything Compliance - Shout Outs and Rants

Everything Compliance: Shout Outs and Rants – Episode 134, The AI Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows.

In this episode, we have the septet of shout-outs and rantors; Jonathan Armstrong, Jonathan Marks, Matt Kelly, Jay Rosen, and special guest Karen Moore; all hosted by Tom Fox.

1. Matt Kelly rants about Kristi Noem killing her dog and that APRA should be ARPA.

2. Jonathan Armstrong shouts out to Kate Middleton for the grace and dignity that she has shown throughout her cancer diagnosis.

3. Karen Moore shouts out to Travis Clayton for being the first Rugby Union player to be signed to the NFL and to the Buffalo Bills for doing so.

4. Jonathan Marks shouts out to Maureen Stanko for starting the So Much to Give Inclusive Cafe, a restaurant that utilizes people with special needs as employees.

5. Jay Rosen shouts out his favorite time of the sports year with the NBA and NHL playoffs, MLB in full swing and the start of the WNBA.

6. Host Tom Fox shouts out to the revival of the Rock Opera Tommy on Broadway and to Pete Townsend.

The members of the Everything Compliance are:

• Jay Rosen – Jay can be reached at Jay.r.rosen@gmail.com

• Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com

• Jonathan Armstrong – is our UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at windyridgehouse@gmail.com.

• Jonathan Marks can be reached at jtmarks@gmail.com.

Guest Karen Moore can be reached at Kmoore51@fordham.edu

The host, producer, and ranter (and sometimes panelist) of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.

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SBR - Authors' Podcast

SBR – Authors Podcast: Mary Ann Faremouth on Revolutionary Results

In this episode, Tom Fox sits down with Mary Ann Faremouth to take a deep dive into her new book, Revolutionary Results.

Mary Ann Faremouth is a certified personnel consultant with a distinguished career in recruiting dating back to the early eighties. Besides this, she has also ventured into writing, podcasting, and keynote speaking, all geared towards empowering individuals through sharing life lessons.

Her perspective on relationships, integrity, and contribution stems from her personal experiences and journey of self-discovery. Faremouth’s traumatic personal experience inspired her to use writing as a channel for healing, reflection, and ultimately, sharing her insights on maintaining integrity and making meaningful contributions.

This journey, coupled with her expansive professional pursuits, has further cemented her commitment to assisting others in becoming their best selves.

Key Highlights Include:

  • Self-expression’s Role in Professional Growth
  • Seizing Opportunities Through Meaningful Connections
  • Metaphors of Butterfly Transformations in Adversity
  • Authenticity, Ethics, and Impact: A Journey of Influence
  • NSA Encounter Sparks Professional Collaborations
  • Embracing Uncertainty for Personal Growth

Resources:

Mary Ann Faremouth on Linkedin

Faremouth & Company

Revolutionary Results on amazon.com

Podcast-Career Can Do

Tom Fox

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Blog

Transforming Culture: Part 2 – The Role of Leadership

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other myriad of corporate scandals where culture failed and created a toxic culture. The question for any organization in such a situation is how to transform its culture. Currently running on the Culture Crafters podcast on the Compliance Podcast Network is a 5–part of podcast series with myself and Sam Silverstein, the most trusted voice in America on accountability. (The Culture Audit™ is the sponsor of this blog post series.)

In this companion, 5-part blog post series, we look at how a company in the depths of such a toxic culture can begin to make a comeback by planning and taking concrete steps to turn around and rebuild its culture. In Part 2, we consider the role of leadership in any cultural transformation.

Exploring the pivotal role of senior leadership in driving cultural change underscores the top-down approach necessary for successful transformation. In organizational culture, the influence and accountability of senior management and the Board of directors cannot be overstated. Leaders at the helm of an organization must demonstrate unwavering commitment to shaping a positive culture by embodying the values and behaviors they wish to instill throughout the company.

But what are the implications of leadership beliefs and actions on cultural transformation? Leaders must consistently demonstrate their commitment to ethics, quality, and employee well-being. Leaders serve as the ultimate culture architects. Senior leaders set the tone for the entire organization through their decisions, communication, and actions, influencing every aspect of the workplace culture and employee behavior. This underscores the direct correlation between leadership effectiveness and the successful transformation of a toxic culture into one that thrives on trust and accountability.

Sam Silverstein encapsulated the essence of the discussion: “Well, everything rises and falls on leadership.” This highlights the significant impact that leadership has on organizational culture and success. This simple yet profound statement encapsulates how influential leaders set the tone for organizational culture. Whether steering the ship toward a new direction or reinforcing existing values, senior leadership is the guiding force that shapes the managerial ethos.

The Board’s strategic imperative is upholding and championing organizational culture and its transformation. A Board must protect and defend the culture as the first point in its strategic plan. A committed board can set the tone for a culture transformation that attracts and retains top talent while fostering sustained success.

Aligning corporate beliefs with action is critical as well.  There is a stark contrast between leaders who merely pay lip service to values like quality and ethics and those who actively embody and champion these principles. True leadership requires a deep commitment to values that resonate throughout the organization. A CEO must engage in trust-building and fostering accountability within an organization. This includes demonstrating an unwavering commitment to their people, earning their trust, and enabling them to perform at their best.

One way to do so is the cascade effect of organizational cultural change. Leaders at every level must uphold and prioritize a company’s defined values. By holding everyone accountable and ensuring alignment with the organization’s cultural ethos, leaders can drive meaningful change from the top down and engender trust. Trust catalyzes organizational success. When leaders prioritize building trust with their teams, they empower individuals to move forward confidently and speedily, ultimately driving higher productivity and engagement.

Key takeaways for leaders include the well-worn maxim that Actions Speak Louder Than Words. This means they must not simply state their values but actively demonstrate them through their actions. Leaders must visibly display actions and make decisions that connect to and support them. This authenticity and consistency in behavior are essential in fostering a culture of trust and accountability.

CEOs are accountable for fostering cultural change by prioritizing their people and standing up for values such as quality and ethics. The accountability is to his people or her people and for their people. This accountability involves being accessible, listening to employees, and taking decisive action to uphold the desired culture.

In conclusion, effective cultural transformation requires strong leadership commitment, visible actions aligned with values, and a cascading effect of cultural priorities from the top down. Organizations can create a positive workplace environment that drives success and employee satisfaction by prioritizing ethics, valuing people, and fostering a culture of trust. As Sam Silverstein aptly puts it, “When your people fully trust you, they can go forward at a much faster speed.”

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Culture Crafters

Culture Crafters – Turning Around a Toxic Culture: Part 1 – The Problem

Boeing has recently seen one of the most public meltdowns over corporate culture. In 2024 alone, there have been multiple incidents, allegations, and reports about the company in the public arena. The company is under investigation by numerous governmental agencies. Several news organizations have reported a ‘toxic’ culture at the company, and there are ripples throughout the worldwide aviation industry. In such a situation, the question for any organization is how it thinks about turning around its culture. In this special five-part podcast series, Sam Silverstein, the most trusted voice in America on accountability, and Tom Fox, the Voice of Compliance, look at the ways a company in the depths of such a situation can plan out and take concrete steps to turn around and rebuild its culture. In Part 1, we consider the steps that led Boeing to the current state of its corporate culture.

A culture does not go toxic overnight. There are always multiple steps, roads taken (or perhaps not taken), and sometimes years for the toxicity to manifest itself. The cultural problems of Boeing can be traced back to its 1997 merger with McDonnell Douglas, which has since manifested in significant safety and quality issues. This issue highlights the importance of prioritizing quality over stock performance, a lesson to be learned for the future of the commercial airline industry. The root of Boeing’s problems lies in this shift in culture post-merger, from a quality-driven ethos to a profit-centered one, leading to a compromising situation for safety and quality. The company needs a cultural transformation that values quality, safety, and employee feedback for an improved company reputation. Silverstein highlights that the company’s cultural problem stems from a shift towards short-term financial gains after the merger. Drawing on his expertise in accountability, Silverstein underlines the importance of a culture that values quality, safety, and open communication, which is vital for attracting top talent, enhancing productivity, and, ultimately, maximizing profitability.

Key Highlights:

  • Shift in Boeing’s Prioritization Towards Stock Performance
  • Impact of Culture on Mergers and Acquisitions
  • Workplace Culture’s Influence on Business Outcomes

Resources:

 Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

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Corruption, Crime and Compliance

Deep Dive into SCG Plastics’ $20 Million Settlement with OFAC to Resolve Violations of Iran Sanctions Program

OFAC is capable of extending a long arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws.

If you need to find an example of this long reach, look no further than OFAC’s recent settlement with SCG Plastics (“SCG”).

In this settlement, SCG, a Thai company that sells plastic resins, agreed to pay $20 million for violations of the Iran Sanctions Program.

In this episode, Michael Volkov explores the series of actions that led to that $20 million dollar settlement and the consequences.

  • In a recent enforcement action, SCG Plastics paid OFAC $20 million to resolve violations of the Iran sanctions program, showcasing OFAC’s far-reaching jurisdiction.
  • SCG Plastics caused U.S. financial institutions to process $291 million in wire transfer sales of High-Density Polyethylene Resin (HDPE) of Iranian origin from 2017 to 2018, which violated the Iran sanctions program.
  • SCG Plastics voluntarily disclosed 10 violations but did not disclose 457, which led to OFAC determining all 467 violations as egregious.
  • The size of the settlement was due to multiple aggravating factors: SCG Plastics willingly engaged in a multi-year pattern of conduct designed to circumvent the Iran sanctions program, causing significant harm to OFAC sanction policy objectives while earning substantial revenues.
  • Importantly, commercial activity that may fall outside the jurisdiction of OFAC sanctions can still result in a violation when the financial transactions related to the activity are processed through or involve U.S. financial institutions.
  • OFAC emphasized the risks for non-U.S. companies engaging in conduct that causes U.S. persons to violate sanctions, in this case processing the transactions, which would not have been done with adequate disclosure, highlighting the importance of compliance with U.S. sanctions and export control laws.

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

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FCPA Compliance Report

FCPA Compliance Report: Mary Inman on The DOJ Whistleblower Incentive Initiative

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this special edition of the FCPA Compliance Report, we welcome back fan favorite Mary Inman, now at her new firm, Whistleblower Partners LLP, a firm dedicated to assisting whistleblowers navigate various reward programs.

Mary joins Tom Fox to discuss what we know so far about the DOJ Whistleblower Incentive Initiative.

Mary has a positive perspective on the Department of Justice’s (DOJ) White Collar Whistleblower Program. She acknowledges the gaps in existing whistleblower reward programs across multiple agencies and sees the DOJ program as a crucial opportunity to fill these lacunae. Inman’s expertise, particularly in the SEC program, allows her to identify specific gaps, such as the lack of financial protections for whistleblowers reporting Foreign Corrupt Practices Act violations involving companies not publicly listed on US exchanges.

From her perspective, the DOJ program will address serious financial crimes, including domestic corruption. Inman also anticipates that the DOJ will establish its own office of the whistleblower, mirroring similar initiatives in other agencies, hence providing both confidential and anonymous reporting avenues.

Topics Covered in This Episode:

  • Specialized Law Firm for Whistleblower Reward Programs
  • Financial Crime Reporting Enhancement Initiative
  • Establishing a Central Office for Whistleblowers
  • Championing Transparency: Grassley’s Whistleblower Advocacy
  • Wellness Fund Support for Whistleblowers

Resources:

Mary Inman on LinkedIn

Whistleblower Partners LLP

Tom Fox

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Compliance Tip of the Day

Compliance Tip of the Day: Non-Retaliation to Improve Culture

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we discuss why retaliation against a person who speaks up not only creates a toxic work environment but also discourages victims from reporting incidents.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Adventures in Compliance

The Return of Sherlock Holmes: Investigative Lessons and Data Analytics Insights from The Adventure of the Abbey Grange

Welcome to a review of all the Sherlock Holmes stories that are collected in the work “The Return of Sherlock Holmes.

It is a collection of thirteen detective stories written by Sir Arthur Conan Doyle, marking the reappearance of the brilliant detective Sherlock Holmes after his apparent death in “The Final Problem.” The collection spans various intriguing cases and mysteries that Holmes and his loyal friend, Dr. Watson tackle.

Today we consider some investigative lessons and data analytics insights from The Adventure of the Abbey Grange.

The Adventure of the Abbey Grange is a riveting Sherlock Holmes story that intricately weaves together a murder mystery with Holmes’ shrewd investigative techniques. The narrative not only showcases Holmes’ astute data collection and interpretation skills but also raises pertinent ethical questions related to privacy, consent, and data protection.

Tom Fox offers an insightful analysis of the story, emphasizing its ethical implications. His views stem from a deep examination of Holmes’ methods and the moral dilemmas they encapsulate. Fox’s perspective underscores the tightrope walk between seeking justice and revenge, urging readers to contemplate the ethical dimensions of detective work.

Key Highlights:

  • The Story
  • Uncovering confidential information
  • Detective Skills: Uncovering Clues with Precision
  • Privacy and Confidentiality: Ethical Dilemmas in Investigation
  • Data Analytics lessons learned

 Resources:

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ

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