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Trekking Through Compliance

Trekking Through Compliance-Episode 20-Court Martial

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:

  1. Have you tied down your documents before your investigation begins?
  2. Your investigation can change based upon facts on the ground.
  3. Never forget in a FCPA enforcement action, each lawyer represents his or her client.

 

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This Week in FCPA

Show Notes for This Week in FCPA-Episode 159, week ending June 21, 2019 – the KPMG Trainwreck and Walmart Settles edition

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.

  1. Wal-Mart settles. Harry Cassin breaks the story for the compliance community in the FCPA Blog.
  2. 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.
  3. What is the role of the WTO in global anti-corruption enforcement? Luciana Silveira explores.
  4. 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.
  5. NAVEX Global published a first-of-its-kind ethics and compliance benchmark report. Jaclyn Jaeger reviews.
  6. What are the data security/data privacy issues from using Slack? Jim Murphy explains.
  7. Designing an ethical company is easy. So says Jeff Kaplan.
  8. Why are negligence and willfulness different standards? Greg Morvillo and Christine Handley explore.
  9. Dylan Tokar joins the WSJ Risk and Compliance Journal. See his twitter You can reach him at dylan.tokar@wsj.com.
  10. Why does one size not fit all? Jay continues his series on working with monitors.
  11. 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.
  12. 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.

Categories
Daily Compliance News

Daily Compliance News: June 21, 2019 Walmart settles edition

In today’s edition of Daily Compliance News (all dedicated to the Walmart FCPA settlement):

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Trekking Through Compliance

Trekking Through Compliance-Episode 19-Tomorrow is Yesterday

In this episode of Trekking Through Compliance, we consider the episode Tomorrow is Yesterday which aired on January 26, 1967, Star Date 3113.2.
Compliance Takeaways:
  1. Sometimes unexpected developments can cause higher risk.
  2. What is your investigation protocol?
  3. How do you onboard new employees on your corporate culture?
Categories
Everything Compliance

Everything Compliance-Episode 49-Trump Administration and Compliance, Half-Year Report, Part 2

Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Armstrong and our newest colleague, Sarah Hadden. In this episode, we conclude a two-part episode where we consider the Trump Administration and Compliance, Part 2. In our prior episode, Part 1 Sarah Hadden, Mike Volkov and Matt Kelly as gave their views. This episode features Jay Rosen, Jonathan Armstrong and your host, Tom Fox.
Jay Rosen considers the evolution in the DOJ’s thinking about corporate compliance programs from the Benczkowski Memo in October 2019 to the Evaluation of Corporate Compliance Programs, 2019 Guidance, issued in April 2019. Jay shouts out on those who help out.
Jonathan Armstrong discusses the wild swings in US trade policy, and the administration’s overall antipathy to the EU and UK trade regimes, data protection laws and commerce in general. Jonathan rants on British politicians whose admissions of recreational drug use could keep them from entering the US.
Tom Fox considers what the three top enforcement actions from the first half of the year tell us where DOJ enforcement may be headed. Fox rants about the petty criticism of the DOJ’s Evaluation of Corporate Compliance Programs. Fox rants on 24-hour helplines which are not working numbers.
The members of the Everything Compliance are:
Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com
Mike Volkov– One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com.
Matt Kelly– Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com
Jonathan Armstrong–is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com
Sarah Hadden–Publisher at Corporate Compliance Insights. Hadden can be reached at Sarah@corporatecomplianceinsights.com.
The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. Now it is part of C-Suite Radio.
Check out Part 1 of this two-part series here.

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Great Women in Compliance

Great Women in Compliance-Andrea Bonime-Blanc

In this episode of Great Women in Compliance, Lisa speaks with Andrea BonimeBlanc, who has “done it all” during her career in compliance.  Andrea has been a leader in this area since the “greed is good” era in 1980s New York, has developed and implemented risk, ethics and compliance programs, and is currently the founder and CEO of  GEC Risk Advisory LLC.  She talks about her current appointment as the Ethics Advisor to the Financial Oversight and Management Board for Puerto Rico, her experiences as a member of a Board and some practical ideas for women (and men) in the ethics and compliance space to maximize their opportunities to become members of Boards.   She has also just completed a book “Gloom to Boom: How Leaders Transform Risk into Resilience and Value,” which provides a practical roadmap for managing environmental, social, governance and technology (ESGT) risk and opportunity and the critical role that high integrity leaders play in creating ethical and sustainable organizational resilience.

Categories
Daily Compliance News

Daily Compliance News: June 20, 2019 the kiss and make up edition

In today’s edition of Daily Compliance News:

  • Nissan and Renault agree to resolve corp governance dispute. (WSJ)
  • Swedebank suspends Estonian unit CEO and CFO. (New York Times)
  • Deutsche Bank may face criminal investigation for AML lapses. (NYT)
  • Ex-French President to stand trial for corruption. (com)
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Daily Compliance News

Daily Compliance News: June 19 2019, the more on KPMG edition

In today’s edition of Daily Compliance News:

  • The commentary continues on the SEC enforcement action against KPMG. (MarketWatch)
  • If doctors would not send their children to a hospital, should you? (New York Times)
  • FIFA on the lookout for match-fixing. (NYT)
  • Michael Platani detained in Qatar corruption probe. (NYT)
Categories
Trekking Through Compliance

Trekking Through Compliance-Episode 18-Arena

In this episode of Trekking Through Compliance, we consider the episode Arena which aired on January 19, 1967, Star Date 3045.6.

Compliance Takeaways:
  1. Get out, talk but most importantly listen.
  2. What causes a risk to grow into a high risk?
  3. Even with facts on the ground, all due diligence may be required.
Resources

Excruciatingly Detailed Plot Summary by Eric W. Weisstein for Arena

MissionLogPodcast.com-Arena
Categories
Trekking Through Compliance

Trekking Through Compliance-Episode 17- The Squire of Gothos

In this episode of Trekking Through Compliance, we consider the episode The Squire of Gothos which aired on January 12, 1967, Star Date 2124.5.
Compliance Takeaways:

  1. What to make when basic science is so wrong (Alternative facts?)
  2. What happens when everything is ‘too easy’?
  3. What is country manager risk?

Resources
Excruciatingly Detailed Plot Summary by Eric W. Weisstein for TheSquire of Gothos
MissionLogPodcast.com-The Squire of Gothos