Categories
Jamming with Jason

Are You Really a Trusted Advisor?

Many support functions in organizations want to be seen as a “trusted advisor” to the business, and internal audit is no exception. There is an aspiration to provide value, so we work really hard proving to ourselves that we are adding value, but other don’t see it and tend to runaway.
“And I wonder, I wo, wo, wo, wo, wonder, why,” we aren’t seen as trusted advisors. Maybe it’s because we don’t really understand what “trust” and “advice” really mean.

Jason Mefford is a Rock Star – Internal Audit, Risk Management and Compliance. He helps Chief Audit Executives (CAE) and professionals with technical & soft-skills training and coaching to navigate the minefields of audit, risk and compliance in organizations. http://www.jasonmefford.com/ and http://www.meffordassociates.com
Apple Podcast: https://itunes.apple.com/us/podcast/jamming-with-jason-mefford/id1456660699
PodBean: https://jammingwithjason.podbean.com/
#trustedadvisor #internalaudit #cae #chiefauditexecutive

Categories
This Week in FCPA

This Week in FCPA-Episode 147 – the Spring has Sprung edition

As the St. Patrick’s Day weekend is past and Spring has sprung all over Tom and Jay are back to take a look at some of this week’s top compliance and ethics stories which caught their collective eyes this week.

  1. What are some of the lessons for compliance professionals from the college admissions scandal? Bob Conlin and Carrie Penman lay them out in Navex’s Ethics and Compliance Matters. 
  2. How did the FCPA Corporate Enforcement Policy change for messaging apps? Nate Lankford and Dawn E. Murphy-Johnson spell it out for you in the FCPA Blog.
  3. What’s the difference between concurrent, consecutive and stacked? Sara Kropf explains it all her great blog, Grand Jury Target.
  4. Even the big dogs can be defrauded. Kristen Broughton reports on fraud which cost Google and Facebook over $100MM in the WSJ Risk and Compliance Journal.
  5. Training wheels will continue to be useful in the future. Ken Wielerstein explains in the Analysts Syndicate.
  6. The business response leads to better compliance through FinTech. Matthew Epstein and Robert Werner discuss in NYU’s Compliance and Enforcement Blog. Sonny Singh in Corporate Compliance Insights.
  7. Cyber breach disclosures are a mess. Matt Kelly reports in Radical Compliance.
  8. The Editor speaks on insider threats. Compliance Week Editor Dave Lefort discusses what he learned at Compliance Week West, in Compliance Week. (sub req’d)
  9. Jaclyn Jaeger looks inside the FBI Office of Integrity, in Compliance Week. (sub req’d)
  10. Following up on his blog post series on the MTS FCPA settlement, Tom moves to the audio format for a podcast series on the enforcement action.Check out the following: Part 1-background;Part 2-bribery schemes; Part 3– missed red flags; Part 4-the individual indictments; and Part 5-lessons learned. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Panoplyand YouTube. The Compliance Podcast Network is now also on Spotifyand Corporate Compliance Insights.
  11. In Houston on Tuesday? Join Tom and Katie Smith at Convercent’s Roundtable Lunch. Registration and information are here. If you are not in Houston, then join Tom, Louis Sapirman and Katelyn Conlyn for a Convercent webinar on how to better engage with your employees. Registration and information for the webinar found here. Best of all, both events are FREE.
  12. Check out the latest edition of Popcorn and Compliancewhere Tom and Jay looked at Captain Marvel from the compliance perspective.
  13. Join Tom and AMI’s Jesse Caplan next week for a 5-part exploration of emerging issues in healthcare compliance and monitoring. The podcast will be available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Panoply, YouTube, Spotify and Corporate Compliance Insights.

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: March 23, 2019-the who’s on your Board edition

MARCH 23, 2019 BY TOM FOX


In today’s edition of Daily Compliance News:

  • Should safety be a ‘nice to have’? (New York Times)
  • Boeing loses first contract for 737 MAX jets. (Wall Street Journal)
  • Unrepentant Rujat Gupta says jury got it wrong, he never violated the law. (New York Times)
  • What is his compliance experience? Shaq joins the Papa John Board of Directors (Business Insider)
Categories
FCPA Compliance Report

IMPACT 2019- Sam Silverstein on Accountability

In this episode I visit with Sam Silverstein about his upcoming keynote speech at IMPACT 2019, entitled “Inspiring Accountability at Every Level”. Some of the highlights from the podcast include:

  1. Why Silverstein believes that “Accountability is the Highest Form of Leadership”.
  2. The problems he sees with the way companies talk about “accountability”.
  3. How accountability can create impact and influence for your organization through a leader’s values.
  4. How accountability enhances corporate culture and improves the organization.
  5. Information on why you should attend ECI’s IMPACT 2019.

Resources:
Sam Silverstein bio here
Sam Silverstein website, on how to lead with accountability here
Registration and Information on IMPACT 2019 here.

Categories
FCPA Compliance Report

MTS Foreign Corrupt Practices Act Enforcement Action: Part V – Lessons Learned

We are on Episode V of a five-part exploration of the recent the Department of Justice and Securities Exchange Commission resolution of a Foreign Corrupt Practices Act enforcement action against the Russian telecom company, MTS. In this episode,  I conclude with the lessons learned for the compliance professional. Today we focus on four key lessons: (1) due diligence, (2) business justification, (3) business valuation and (4) the long road of bribery.
The documents which are the subject of this series are:
  1. MTS Deferred Prosecution Agreement (DPA);
  2. MTS Criminal Information (MTS Information);
  3. SEC Cease and Desist Order (Order);
  4. Karimova and Akhmedov Indictment (Indictment);
  5. Kolorit Dizayn Ink LLC Plea Agreement (Plea Agreement); and
  6. Kolorit Dizayn Ink Information (Kolorit Information);
  7. DOJ Press Release and
  8. SEC Press Release.
For additional reading see the blog post, “MTS FCPA Settlement and Karimova Indictment: Part V – Lessons Learned”
Categories
Daily Compliance News

Daily Compliance News: March 22, 2019-the my bracket is already blown edition

MARCH 22, 2019 BY TOM FOX


In today’s edition of Daily Compliance News:

Categories
FCPA Compliance Report

IMPACT 2019, Tony Brigmon on Joy and Laughter

In this episode I visit with Tony Brigmon about his upcoming keynote speech at IMPACT 2019, entitled “The Funomenal Workplace: Energizing People & Culture with the Positive Power of Fun”. Some of the highlights from the podcast include:

Tony’s professional history at SW Airlines as the “Ambassador of Fun”. SW is generally recognized as one of the most fun places to work in the US.

  1. Why joy and laughter are keys to a great corporate culture.
  2. Some thoughts from his book “The FUNOMENAL WORKPLACE: Energizing People & Culture with the Positive Power of Fun!”
  3. How a fun workplace enhances corporate culture and improves the organization.
  4. Information on why you should attend ECI’s IMPACT 2019.

Resources:
Tony Brigmon website here
Registration and Information on IMPACT 2019 here.

Categories
FCPA Compliance Report

MTS Foreign Corrupt Practices Act Enforcement Action: Part IV – the Individual Indictments

We are on Episode IV of a five-part exploration of the recent the Department of Justice and Securities Exchange Commission resolution of a Foreign Corrupt Practices Act enforcement action against the Russian telecom company, Mobile TeleSystems PJSC (MTS). In this episode,  I look at the individual indictments, which charged Gulnara Karimova, daughter of the former President of Uzbekistan, with one count of conspiracy to commit money laundering and Bekhzod Akhmedov, a former MTS executive based in Uzbekistan with FCPA violations of one count of conspiracy to violate the FCPA, two counts of violating the FCPA, and one count of conspiracy to commit money laundering.
The indictment discussed the three companies who paid bribes to Karimova, who then laundered the money on the international stage. They were VimpelCom Ltd. (now VEON Ltd.), Telia Company AB (formerly TeliaSonera AB) (Telia) and MTS. The schemes Karimova used were so similar as to be almost identical. The only thing that changed was the name of the company she was shaking down money from in her march towards receiving over $1 billion in ill-gotten payments.
The documents which are the subject of this series are:
  1. MTS Deferred Prosecution Agreement (DPA);
  2. MTS Criminal Information (MTS Information);
  3. SEC Cease and Desist Order (Order);
  4. Karimova and Akhmedov Indictment (Indictment);
  5. Kolorit Dizayn Ink LLC Plea Agreement (Plea Agreement); and
  6. Kolorit Dizayn Ink Information (Kolorit Information);
  7. DOJ Press Release and
  8. SEC Press Release.
For additional reading see the blog post, “MTS FCPA Settlement and Karimova Indictment: Part IV – the Individual Indictments“
Categories
Life with GDPR

Life With GDPR: Episode 23- Looking into the 2019 Crystal Ball

In this episode, I visit with Jonathan Armstrong consider some of his predictions for the rest of 2019. Even if these predictions do not become fully formed, you should consider them in light of your data privacy/data protection policies and protocols. Some of the issues and highlights are:

  1. Drones-what are the GDPR implications.
  2. The number of data breach notifications under GDPR. Through the end of January there were over 42,000 in the EU alone.
  3. Will AI and self-driving cars follow the rules on safe driving standards, or will there be new rules for the road?
  4. What will be the effects of data, big data and AI in elections going forward? What will be the fallout from Cambridge Analytica going forward?
  5. How will businesses respond to the industrialization of internet crime? What happens when there is a Zero-Day exploit?
  6. Cybersecurity insurance. Will standard insurance rules and regulations apply, or will new policy language be drafted for such coverage?

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.

Categories
Daily Compliance News

Daily Compliance News: March 21, 2019-the Google spanked edition

MARCH 21, 2019 BY TOM FOX


In today’s edition of Daily Compliance News:

  • Chuck Pearson pleads guilty. (com)
  • USC goes after the students fraudulently admitted. (NPR)
  • EU spank Google to the tune of $1.5bn for anti-trust violations. (Financial Times)
  • Bayer stock plummets. (Washington Post)