In today’s edition of Sunday Book Review:
- Whose Body by Dorothy L. Sayers
- Murder is Easy by Agatha Christie
- The Big Sleep by Raymond Chandler
- Strangers on a Train by Patricia Highsmith
Author: admin
Prior to the 2012 FCPA Guidance, the DOJ issued two 2007 Opinion Releases which offered guidance to companies considering whether, and if so how, to incur travel and lodging expenses for government officials. Both Opinion Releases laid out the specific representations made to the DOJ, which led to them to approve the travel to the U.S. by foreign governmental officials. These facts provided strong guidance to any company which seeks to bring such governmental officials to the U.S. for a legitimate business purpose. In Opinion Release 07-01, the company was desired to cover the domestic expenses for a trip to the U.S. for a six-person delegation of the government of an Asian country for an educational and promotional tour of one of the requestor’s U.S. operations sites. In 07-02, the Company desired to pay certain domestic expenses for a trip within the U.S. by approximately six junior to mid-level officials of a foreign government for an educational program at the Requestor’s US headquarters, prior to the delegates attendance at an annual six-week long internship program for foreign insurance regulators sponsored by the National Association of Insurance Commissioners (NAIC).
When Walmart Inc., Hewlett-Packard Company (HP) or GSK are in the news for alleged FCPA violations, it provides you a good reminder to review your compliance program. Not only from your compliance procedures perspective, but to test to determine if the policies and procedures are being followed or if there are issues which you might need to look at more closely.
Three key takeaways:
- Travel for foreign officials continues to plague companies for compliance violations.
- The key is being reasonable in your costs.
- Always remember to record travel expenses correctly based upon documented costs.
As federal judge Emmet Sullivan reminded the Justice Department that he, not they, run his court this week, self-distancing Tom and Jay are back to consider some of the top compliance articles and stories which caught their collective eye this week.
- Former Wal-Mart lawyer sues for allegedly refusing to change internal investigation report on FCPA. Matt Kelly in Radical Compliance. Dylan Tokar in the WSJ Risk & Compliance Journal.
- How to mobilize for an internal investigation. In the WSK Risk & Compliance Journal.
- What is trade based money laundering? Jon Rausch in Dipping Through Geometries.
- Moving towards a more agile compliance and internal audit. Alex Movchan interviews Alkistis Gkiosi for the Risk and Compliance Platform Europe.
- What steps can you take to safeguard a compliance program during Covid-19? Kara Brockmeyer, Andrew M. Levine and Philip Rohlikin opine in NYU’s Compliance and Enforcement Blog.
- Should the role of the CCO be expanded? Klaus Moosemeyer says yes in the FCPA Blog.
- Using data analytics in a compliance regime. Szilvia Andriasik in the FCPA Blog.
- A new cyber-compliance playbook? Rod Rosenstein & Sumon Dantiki in Compliance Week. (sub req’d)
- How to handle an internal investigation in during Covid-19? Lara Burke & Dominique Strieder in Compliance Week. (sub req’d)
- Interested in moving to the CCO chair? Check in on this month’s edition of The Compliance Life where Tom visits with Ellen Hunt, CCO at AARP. In this Part 2, Hunt relates how to move towards the CCO chair. New episodes appear each Tuesday in May at 1 PM CST. The Compliance Life is now available on iTunes.
- On Compliance and Coronavirus this week: Megan Dougherty explains why you should be pod-curious; Andrew Rawson on the new normal of employee relations during and after Covid-19; JohnPetrovski and Jim Belin on how the economy may reopen and the markets play out. Compliance and Coronavirus.
- On the Compliance Podcast Network, this month topic: written standards; all on 31 Days to a More Effective Compliance Program. This week’s offerings: Monday-Operationalization of your Code of Conduct; Tuesday-Introduction to policies and procesures; Wednesday-Revising your policies and procedures; Thursday– Policies and procedures on gifts and business entertainment; Friday– Policies and procedures on travel. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel.
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.
Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. As the Voice of Compliance, I wanted to start a podcast which will help to bring both clarity and sanity to the compliance practitioner and compliance profession during this worldwide health and healthcare crisis. In this episode, I am joined by Jim Belin, as self-styled ‘contrarian investor’ and John Petrovski, a long time commercial real estate specialist in the lending arena. We take a deep dive into the reopening of the economies of the states in which we reside and where the economy may be going into 2012 and beyond. They are both speaking for themselves and not any former or current employers.
Categories
Verbal Reporting under GDPR
In this episode I visit with Jonathan Armstrong are back to discuss issues relating to data privacy, data protection and GDPR. Today, we consider the issue of verbal reporting under GDPR, in the context of the case of Scott v. LGBT Foundation. Some of the highlights are:
- What were the issues and interests involved in this case?
- What is a relevant filing system for automated data under GPDR?
- When does the public health and safety outweigh data privacy?
- Was Scott’s data processed by the LGBT Foundation?
- What is the necessity test?
Check out the Cordery Compliance, client alert on the case of Scott v. LGBT Foundation, click here. For more information on Cordery Compliance, go their website here. Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.
Richard Lummis and I are back with more business leadership lessons. In this episode of 12 O’Clock High, a podcast on business leadership, we take a look at leadership lessons from William Howard Taft, the 27th President, who had the misfortune to follow one of America’s greatest and most popular Presidents, Theodore Roosevelt. Taft was a mountain of a man, weighing over 300 lbs. He is also the only President to become Chief Justice of the US Supreme Court after he left the office of the Presidency.
Highlights of this podcast include:
- Background of Taft.
- Education and early professional life in Ohio.
- Move to Washington, role of Nellie and work in the Philippines.
- Work in the Roosevelt Administration.
- Presidential Term.
- 1912 Presidential election.
- Final thoughts on leadership lessons.
Resources
- National Park Service article on his home and upbringing.
- Taft as good-hearted
- Taft, TR and the Bully Pulpit-Forbes
- General Review of Taft
In today’s edition of Daily Compliance News:
- Old foods make comeback. (WaPo)
- Dos Santos says evidence of fraud is fake. (YaHoo News)
- Alstom accused of corruption yet again. (The Guardian)
- Judge handling Flynn conviction says not so fast. (WSJ)