In today’s edition of Daily Compliance News:
- KPMG to pay $50MM fine. (MarketWatch)
- Corruption in China? Who knew? (NYT)
- Don’t talk about sick pigs and China. (FT)
- What is your corporate battle rhythm? (WSJ)
In this episode of Trekking Through Compliance, we consider the episode Balance of Terror which aired on December 15, 1966, Star Date 1709.1
Compliance Takeaways:
Compliance Takeaways:
- As a CCO, you must not allow racism in your organization.
- Does your speak up culture include training on how to listen?
- #MeToo means that if, as a by-stander you see something it is your responsibility to report it.Resources
With Tom and Jay together for a week in the City of Champions (Boston) and Tom finally getting to Fenway Park to sing Sweet Caroline, he and Jay to take a break to join discuss both events some of this week’s top compliance and ethics stories which caught their collective eyes.
- Who owns a bribe and why does it matter?
- What are the 6 hats of an AML compliance professional?
- Two prosecutors leave DOJ.
- What are some of the impacts of working with monitors?
- FBI skewered in another FCPA sting trial.
- Trump Tower in Moscow? What is the story?
- Italy enacts a law to provide credit for remediation during corruption investigations.
- Two top FCPA prosecutors leave DOJ and go into private practice.
- And you think you are having a bad day? Matt Kelly looks at an assination attempt on a CAE in South Africa.
- What is ghost money?
- Tom has a special 3-part podcast series this week, looking at leadership lessons from Harry Truman, Douglas MacArthur and Truman’s firing of MacArthur on 12 O’Clock High, a podcast on business leadership. Check out the following: Part 1-Leadership lessons from Harry Truman; Part 2-Leadership lessons from Douglas MacArthur; Part 3– Leadership lessons from Truman’s firing of MacArthur. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTube, Spotifyand Corporate Compliance Insights, Compliance Podcast Networkand now on the C-Suite Radio Network.
- The Everything Compliance gang begins a two-part podcast series looking at the Trump Administration’s first 6 months of 2019, from the compliance perspective. In Part 1, Matt Kelly, Sarah Hadden and Mike Volkov weigh in. In Part 2 (to be released June 27) Jay Rosen, Jonathan Armstrong and Tom Fox opine.
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.
In this episode of Trekking Through Compliance, we consider the episode The Conscience of the King which aired on December 8, 1966, Star Date 2817.6.
Compliance Takeaways:
Compliance Takeaways:
- When does a leader step over the line from business to personal?
- Can you ever be sure in an investigation absent a confession?
- What is the difference between an investigation and a root cause analysis?
Resources
In today’s edition of Daily Compliance News:
In this episode of Trekking Through Compliance, we consider the episode The Menagerie (Part Two) which aired on November 24, 1966, Star Date 3012.4.
Compliance Takeaways:
- What happens with your counter party refuses to comply with FCPA requirements?
- When the time comes will you as a CCO speak truth to power?
- Sometimes failure and being left behind are options.
Resources
Excruciatingly Detailed Plot Summary by Eric W. Weisstein for The Menagerie (Part Two)
MissionLogPodcast.com-The Menagerie (Parts 1 & 2)
In today’s edition of Daily Compliance News:
- Are high numbers of athletes at a university indicia of bribery? (Washington Post)
- Tesla shareholders fail to pass corporate governance improvements. (WSJ)
- Will Switzerland become a global courthouse? (FT)
- No water time for ex-Stanford sailing coach, at least for 6 months. (Reuters.com)
Welcome to the only roundtable podcast in compliance. In this episode, we begin a two-part episode where we consider the Trump Administration and Compliance, Part 1. This episode includes Sarah Hadden, Mike Volkov and Matt Kelly. Our next episode will feature Jay Rosen, Jonathan Armstrong and your host, Tom Fox.
- Sarah Hadden bemoans the death of privacy and explains how the Number 7 has come to haunt her in the modern world of advertising algorithms. Sarah shouts out to the resistance to the Surveillance State and Surveillance Capitalism.
- Matt Kelly considers both where the SEC has been and is headed in its rollback of SEC 404 protections and the SEC changes to its whistleblower provisions under Dodd-Frank. Matt treats us to a double shot of rants today as he cannot control himself on the subject of the Trump Administration calling sub-regulatory guidance from the DOJ worthless “paper” while continuing to issue Guidance such as the 2019 Guidance for Compliance Programs. He also rants about the Dutch Data Protection Authority who violated GDPR in a recent release of data and then failed to timely report said breach (to themselves).
- Mike Volkov goes hyperbolic in his discusses of the new OFAC compliance program and the current state of OFAC sanctions. Mike rants about the petty criticism of the DOJ’s Evaluation of Corporate Compliance Programs.
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.
In this episode of Excellence in Training, Shawn Rogers and I consider how you should envision your training.
Shawn begins his journey with the famous book, The Seven Habits of Highly Effective People, where Stephen R. Covey said, “All things are created twice. There’s a mental or first creation, and a physical or second creation to all things. Take the construction of a home, for example. You create it in every detail before you ever hammer the first nail into place. . . Then you reduce it to blueprint and develop construction plans. . . Begin with the end in mind. ”
This principle applies to creating a compliance training program. A common mistake is jumping right to the question if which courses you want and how to deploy them. However, there are several things you need to think about before you start building the program.
Here are the steps we followed at GM as we envisioned what our compliance training should look like:
Shawn begins his journey with the famous book, The Seven Habits of Highly Effective People, where Stephen R. Covey said, “All things are created twice. There’s a mental or first creation, and a physical or second creation to all things. Take the construction of a home, for example. You create it in every detail before you ever hammer the first nail into place. . . Then you reduce it to blueprint and develop construction plans. . . Begin with the end in mind. ”
This principle applies to creating a compliance training program. A common mistake is jumping right to the question if which courses you want and how to deploy them. However, there are several things you need to think about before you start building the program.
Here are the steps we followed at GM as we envisioned what our compliance training should look like:
- Decide on the program’s guiding principles
- Establish program design objectives
- Develop a style guide or set of course standards
- Determine the exact risks that will be addressed by the training program
- Set up a governance process to ensure stakeholder alignment, approve the program design, approve the budget, and monitor effectiveness.In Covey’s terms, these activities resulted in the blueprint — or the “first creation” — of our compliance training program. We did all of these before we selected our vendor and started building our training courses.
In this episode of Trekking Through Compliance, we consider the episode The Menagerie (Part One) which aired on November 17, 1966, Star Date 3012.4.
Compliance Takeaways:
Compliance Takeaways:
- A leader must take care of themselves as well as their crew.
- What does it mean if a deal is too good to be true?
- Trust but verify.
Resources