I have always loved the classic Universal monster movies from the 1930s. I am exploring one movie each week to mine it for leadership and compliance lessons this month. For this first entry in this short series on Popcorn and Compliance, I look at the original 1931 version of Mary Shelley’s seminal work, Frankenstein, which starred Boris Karloff as the Monster. Karloff embued the Monster with great pathos, but in this podcast, I want to consider the leadership lessons of Dr. Victor Frankenstein or the lack of leadership by the good doctor, which led to the deaths of a small child, his brother, and the rape of his wife-to-be on her wedding day. Of course, it also led to the unleashing of his Monster, technically called Frankenstein’s Monster, upon the movie-going world for years to come.
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In today’s edition of Daily Compliance News:
- FINRA spells out AML penalties. (WSJ)
- McKinsey and ex-partner added to the corruption case in South Africa. (Bloomberg)
- Somebody needs to be fired. (ESPN)
- Barclay’s fined (yet again). This time $361MM. (Reuters)
The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges. GOL entered into a three-year deferred prosecution agreement (“DPA”) with the DOJ in exchange for payment of a $17 million criminal penalty. DOJ credited $1.7 million of that penalty against a $3.4 million fine that GOL agreed to pay law enforcement authorities in Brazil to resolve charges in Brazil. In a separate resolution, GOL agreed to pay the SEC $24.5 million over two years. The SEC’s initial settlement calculation was for $70 million, but it was reduced to $24.5 million based on GOL’s financial condition. Michael Volkov reviews the DOJ and SEC FCPA settlement actions in this episode.
In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, we have the Award-Winning Everything Compliance quartet of Jonathan Marks, Jonathan Armstrong, Karen Woody, and Tom Fox on the Monaco Memo.
1. Tom Fox looks at the Monaco Memo through the monitorship language and answers a listener’s questions about compliance programs under the Monaco Memo.
2. Karen Woody reviews the Monaco Memo, the self-disclosure angle, and investigatory considerations and ponders the role of defense counsel going forward.
3. Jonathan Marks also looks at investigatory issues under the Monaco Memo, the role of the Board of Directors, and the role of the forensic auditor under the Monaco Memo.
4. Jonathan Armstrong’s self-disclosure from a UK angle joins Karen Woody in questioning how defense counsel should move forward.
Resources
Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog
1. A Jolt for Compliance
2. Timely Self-Disclosure
3. Corporate Compliance Programs
4. Monitors
5. The Heat is On
In this podcast series, two complete MCU fans, Tom Fox, founder of the Compliance Podcast Network, and Megan Dougherty, co-founder of One Stone Creative, indulge in a passion for all things in the Marvel Cinematic Universe. We previously reviewed all the movies, and now we have a series on WandaVision. If you want to indulge in your love for the MCU with two fans passionate about all things MCU, this is the podcast series for you. For this offering, we continue with Episode 8, Previously On.
Some of the highlights include:
Ø The story synopsis.
Ø What are the key plot points?
Ø What were some of our favorite cookies?
Next up in our series WandaVision, Episode 9 Series Finale.

In this episode of Career Can Do, Mary Ann Faremouth chats with Molly Rose Speed, owner and Director of Operations at CoPilot Consulting. Molly Rose is a talented strategic thinker with cultivated skills in online tech solutions, systems, and processes that improve company efficiencies. She went from a “corporate cubicle dweller” to becoming an entrepreneur and creator of the Virtual Assistant Academy. Molly Rose shares her story and gives insight into the virtual assistance industry.
Ten years ago, Molly Rose quit her corporate job cold-turkey when she realized that it was not how she wanted to live her life. She delved into virtual assistance, despite not quite knowing everything it entailed – but she quickly learned. Virtual assistants provide the professional support online business owners need to stay in their zone of genius.
The Virtual Assistant Academy founded by Molly Rose trains and certifies people to start virtual businesses. It’s a very flexible career path, especially for mothers. On the flip side, the Academy also provides virtual services for business owners or even stay-at-home mothers looking to outsource certain tasks.
Resources
In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, I am joined by Hughes Hubbard partner Laura Perkins to take a deep dive into the Monaco Memo. Some of the highlights include:
- Determination of Monitor Need.
- Roadmap to proa-active compliance.
- Timely self-disclosure as criteria for monitorship?
- Monitor selection criteria.
- Monitor review and oversight.
Resources
Laura Perkins on HughesHubbard.com
Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog
- A Jolt for Compliance
- Timely Self-Disclosure
- Corporate Compliance Programs
- Monitors
- Polite Speech
Jonathan Armstrong and Tom Fox return for another episode of Life with GDPR. In this episode, we discuss the changes in the UK Data Privacy regime currently proposed in the wake of Brexit. Some of the highlights include:
- Why these changes are so significant.
- Are things really more complicated now?
- What does it mean for compliance?
- What happens next?
- Will the new PM request any changes?
- Practical steps you can take now.
Resources
For more information on the issues raised in this podcast, check out the Cordery Compliance News Section. For more information on Cordery Compliance, go to their website here. Also, check out the GDPR Navigator, one of the top resources for GDPR Compliance, by clicking here.
Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. In 2021, Everything Compliance was honored by W3 as a top talk show in podcasting. In this episode, we have the quartet of Jonathan Marks, Jonathan Armstrong, Karen Woody, and Tom Fox on the Monaco Memo and antitrust enforcement going forward in Europe. We conclude with our fan Shout Outs and Rants section.
- Tom Fox looks at the Monaco Memo through the monitorship language and answers a listener’s questions about compliance programs under the Monaco Memo. He shouts out to Aaron Judge, who has a year for the ages.
- Karen Woody reviews the Monaco Memo, the self-disclosure angle, and investigatory considerations and ponders the role of defense counsel going forward. She shouts out to the HBO film Elvis and the movie portrayal of Presley.
- Jonathan Marks also looks at the Monaco Memo’s investigatory issues, the Board of Directors’ role, and the forensic auditor’s role under the Monaco Memo. He rants about compliance professionals and fraud examiners who have no idea what internal control is.
- Jonathan Armstrong looks at the EU communications around Facebook and antitrust enforcement and how things may change dramatically. He shouts out to King Charles III, who had a 70-year apprenticeship as the Heir Apparent to the British throne.
The members of Everything Compliance are:
- Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com
- Karen Woody – One of the top academic experts on the SEC. Woody can be reached at kwoody@wlu.edu
- Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com.
- Jonathan Armstrong is our UK colleague, an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com.
- Jonathan Marks is Partner, Firm Practice Leader – Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at marks@bakertilly.com.
The host and producer, ranter (and sometime 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.