In today’s edition of Daily Compliance News:
In this special 5-part podcast series on the FCPA Compliance Report, I am considering the Airbus international anti-corruption enforcement action from a variety of perspectives from some of the top world’s top compliance practitioners and commentators on compliance. They include, Jay Rosen-Mr. Monitor; Mike Volkov-Editor of Corruption Crime and Compliance; Jonathan Armstrong-partner at Cordery Compliance in London; Cecilia Fellouse-Guenkel-Secretary General, The Circle of Compliance and Tom Fox-the Compliance Evangelist. In today’s Episode 1, Jay Rosen considers the FCPA enforcement involving Airbus.
Highlights include:
- What was the procedural history of the enforcement action?
- Why companies who do business with the government need robust compliance.
- Airbus was clearly incentivized to cooperate with the DOJ.
In today’s edition of Sunday Book Review:
- Past Master by RA Lafferty
- Picnic on Paradise by Joanna Russ
- Nova by Samuel Delaney
- Emphyrio by Jack Vance
We have been getting accountability all wrong in the compliance profession. It’s not a set of tasks – it’s a way of thinking and it has to come from the heart as well as the head. On Accountability: The Heart of Compliance Tom Fox and Sam Silverstein dig into what accountability means to the corporate compliance function and business organizations and most significantly, how to make it an integral part of your culture. In this episode Sam and I conclude our three-part series to considering the current disaster Boeing finds itself in from the accountability perspective and what it might do to crawl out of the deep hole it finds itself in. In this Part 3, we consider accountability to other stakeholders and what accountability means in a heavily regulated industry. Some of the highlights include:
- What is the role of honor in accountability?
- What are the three standards of an accountable legacy?
- The role of culture is well understood in the compliance community. What is the role of accountability in creating and sustaining a great culture?
For more information on Sam Silverstein and his work on accountability, click here.
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As the blowback on the Astros, MLB, Commisioner Rob Manfred continues to get worse, Jay and Tom are back to consider some of the top compliance articles and stories which caught our eye this week.
- Airbus still making news. Asher Miller provides 5 key takeaways for the compliance practitioner in the FCPA Blog. Dylan Tokar reports on more follow on investigations in the WSJ Risk & Compliance Journal. Joanne Taylor joins Tom on the FCPA Compliance Report to consider the UK perspective. Tom considers the French enforcement perspective in the FCPA Compliance and Ethics Blog.
- Another sentencing in the PdVSA ongoing bribery scandal. See the DOJ Press Release.
- What are WOW moments in compliance? Geert Vermeulen begins a 5-part series in Risk and Compliance Platform Europe.
- How do compliance officers show their worth? Dick Cassin explain in the FCPA Blog.
- Is it time to rebalance your 3rd party risk management strategy? Mike Volkov reports in Corruption Crime and Compliance. Mike writes about the importance of classifying your 3rd parties in Navex Global’s Ethics & Compliance Matters blog.
- Is the tide turning against whistleblowers? Aaron Nicodemus explores in Compliance Week. (sub req’d)
- Civil damages for corruption claims? Rick Messick considers on the Global Anti-Corruption Blog.
- New round of Alstom employee indictments. Dick Cassin reports in the FCPA Blog.
- What is a moral hazard moment? Jeff Kaplan explains on the Conflict of Interest blog.
- On the Compliance Podcast Network, Tom begins a one month look at the role of HR in compliance on 31 Days to a More Effective Compliance Program.This week saw the following offerings: Monday-succession planning and compliance; Tuesday-compliance performance appraisal review; Wednesday-Hiring a CCO: developing a job profile; Thursday-sales incentives and compliance;Friday-the exit interview. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.
- Join Tom to watch Jay on the panel with other compliance experts in the Dow Jones Refining Compliance Risk event in Hosuton on Tuesday, February 25 from 10 AM to 12 PM. For information and registration click here.
- Join Tom in NYC on Thursday, March 12 as Convercent is hosting an Innovation Forum from 3:30-7 PM at Sabrina. This event will allow you to network with like-minded individuals within the ethics and compliance space and hear from Thomas Fox and Philip Winterburn as well. 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.

Listen to the episode:
EPISODE NOTES
https://www.prearesourcecenter.org/
See Oklahoma’s PREA Guidelines for a good example of how the state applies the Act:
http://doc.ok.gov/Websites/doc/images/Documents/Policy/op030601.pdf
PREA Statistics:
https://www.themarshallproject.org/2018/07/25/prison-rape-allegations-are-on-the-rise
Welcome to the only roundtable podcast in compliance. We devote our entire episode to the Airbus international corruption enforcement actions. Today, we have a serving of Jonathan Armstrong, Jay Rosen, Matt Kelly and Mike Volkov with a potpourri of topics. Rants and shouts outs follow the commentary for this episode.
- Mike Volkov considers the enforcement action from the trade sanction/ITAR perspective.
- Jonathan Armstrong reviews the SFO’s role in this matter.
- Jay Rosen sets up the background facts under the US Deferred Prosecution Agreement and Criminal Information released by the DOJ and considers the FCPA angle of the case.
- Matt Kelly looks at some policy angles and compares Airbus to recent scandals involving Wells Fargo and Boeing.
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 data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.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.
Richard Lummis and I are back. Today, continue our annual review of Oscar winning Best Pictures and the leadership lessons drawn from them. Over the next four weeks we will consider the following movies: Casablanca, Rocky, The Greatest Show on Earth and Out of Africa. Today, we continue our series with one of the very all-time boxing movies, Rocky.
Highlights of this podcast include:
- What are our favorites scenes from the movie? No one who you anything, you owe yourself, get the work done and we are all underdogs.
- What are the leadership lessons from Rocky Balboa? Repetition will make you great, tech can be a great business advantage but never forget the human element and practice for the worst.
- What are the leadership lessons from Apollo Creed? The mind is the greatest muscle and pay attention to those behind you.
- What are the leadership lessons from Rocky’s trainer-Mick?
- What are the leadership lesson from the boxing ring? Go the distance and think long term, it’s not about how hard you punch but how hard a punch you can take and go back into the ring when it’s the toughest.
- Do these lessons hold up today?
Resources
Five Business Lessons I Learned from Rocky
4 dialogues from Rocky series that helped me become a better leader
Leaders as Storytellers
4 Motivational Lessons that Rocky Can Teach