In today’s edition of Daily Compliance News:
Today we will visit the UK and take a look at the new UK anti-corruption sanctions program and the UK guidance to certain export licenses.
In this Episode of the FCPA Compliance Report, I am joined by fan fav James Koukios, partner at Morrison & Foerster and editor of the firm’s great monthly International Anti-Corruption Developments Newsletter. In this episode we look back to some of the key developments from the January and February newsletters.
Highlights include:
- 2021 TI-CPI released. What value do you see in it? Do compliance professionals rely too greatly on it to determine an appropriate level of due diligence?
- Samir Khoury denied cert. How or why could an indictment go unsealed for 10 years?
- Daniel Comoretto pleads guilty. Follow on from Sargeant Marine FCPA enforcement action.
- KBR decision. What does it mean for the SFO?
- Samsung Industries resolves corruption matter thru Leniency Agreement.
- Paul Bond convicted on retrial.
- Spain extradited Alonso Ancira to Mexico. What if any is the significance to this action?
- Car Wash ends. How would you assess its overall impact on the global fight against bribery and corruption?
Resources
January International Anti-Corruption Developments
February International Anti-Corruption Developments
James Koukios on MoFo
In today’s edition of Sunday Book Review:
- Origins of Hijacking. Violence in the Skies by Philip Baum
- Move to terrorism. The Skies Belong to Us: Love and Terror in the Golden Age of Hijacking by Brendan I. Koerner
- DB Cooper. DB by Elwood Reid
- 9/11. The Eleventh Day: The Full Story of 9/11 by Anthony Summers and Robyn Swan
Welcome to a special five-part podcast series sponsored by K2 Integrity. In this series, we have considered the intersection of compliance, diligence and mergers & acquisitions (M&A). I have been joined by Hannah Coleman, Managing Director in K2 Integrity’s Investigations and Risk Advisory practice. She specializes in fast-moving, complex, and specialized research assignments in a variety of areas including investigative due diligence, corporate contests, intellectual property investigations, media transparency assessments, and litigation support. Also joining this series is Tom Pannell, Managing Director in K2 Integrity’s Investigations and Risk Advisory practice. With a focus on financial investigations, Tom leads multi-disciplinary teams working with corporate clients and their legal advisors responding to crisis events, including multi-jurisdictional white-collar crime, misconduct, financial statement fraud, anti-bribery and corruption incidents, and compliance risk advisory work. In this concluding episode, I visit with Tom about integration issues after deal closure.
I hope you have enjoyed this special K2 Integrity sponsored series on compliance, diligence and M&A. For more on K2 Integrity, check out their website, here.
Bitcoin goes on a wild ride this week with its buddy, Elon Musk. With Jay podcasting from a still undisclosed location, he and Tom take a look at this week’s stories top compliance and ethics stories which caught their interest on This Week in FCPA in the Musk and Bitcoin edition.
Stories
1. Of Elon Musk, Bitcoin and Uturns. Matt Kelly in Radical Compliance. Tom and Matt in Compliance into the Weeds. Andrew Ross Sorkin in Dealbook. On SNL here.
2. Benchmark with the Walmart Global ABC policy. Harry Cassin in the FCPA Blog.
3. Closing the moral hazard gap. Jeff Kaplan in the FCPA Blog.
4. Boards and cybersecurity oversight. Wachtell lawyers, John F. Savarese, Sarah K. Eddy, and Sabastian Niles in the NYU Corruption and Enforcement Blog.
5. You are ready for th EU Whistleblower Directive? Neil Hodge in in Compliance Week (sub req’d)
6. Are companies serious about Diversity & Inclusion? Henry Kronk in CCI.
7. Who are a CCOs most important resource (Hint: it’s customers). Steve Chapman in Navex Global’s Ethics and Compliance Matters Blog.
8. What happens when whistleblowers joust over an award? Matt Kelly in Radical Compliance.
9. Do you have a mindset of respect? Sam Silverstein in the Accountability Blog.
10. How does ESG serve investors? Lawrence Heim in PracticalESG.com.
Podcasts and Events
11. Check out the 5-part podcast series this week sponsored by K2 Integrity. We consider the intersection of Compliance, Diligence and M&A. Part 1-Core Diligence, Part 2-Current state of M&A; Part 3-Avoiding Reputational Issues, Part 4-Global M&A issues, Part 5-Post-acquistion integration.
12. In the most recent episode of Integrity Through Compliance, Jesse Caplan, Dionne Lomax and Jim Anilot discuss “From Business Opportunities to Compliance Risks: Health Expectations in 2021”. Check it out here.
13. In a special two-part series, Tom visits with Joey Seeber, CEO of Level Legal. They discuss alternative legal services providers and the Baylor Bears 2021 NCAA Men’s Basketball Championship. Part 1 and Part 2.
14. CCI releases a new eBook, The FCPA Year in Review by the Compliance Evangelist, Tom Fox. You can obtain a copy here. Best of all its available at no charge.
15. Tom announces his latest book, The Compliance Handbook, 2nd edition is available for presale purchase. Use the code FOX25 and go here. The Compliance Handbook 2nd edition will be available in both print and eBook editions. This week on The Compliance Handbook podcast, Eric Young joins Tom for a deep dive into the role of internal controls in a best practices compliance program.
Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.
We are long overdue for a deep dive on the latest enforcement actions, so we’re covering the DOJ-led joint resolution with SAP, OFAC settlements with MoneyGram and Alliance Steel, DDTC’s consent agreement with Honeywell, and, last but not least, Luokung Technology’s successful court challenge to its CCMC listing. Then, in the Lightning Round, we check in on JCPOA 2.0, the U.S. approach to Venezuela and Cuba, and the winding down of an important general license for Belarus.
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Questions? Contact us at podcasts@milchev.com.
EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
Timestamps:
0:10 Introduction and Roadmap
The Rundown
4:27 SAP NPA and OFAC Settlement
21:38 MoneyGram OFAC Settlement
28:28 Alliance Steel OFAC Settlement
33:25 Honeywell DDTC Settlement
40:46 Luokung Takes Another Bite Out of the CCMC List
58:00 Lightning Round
58:12 JCPOA 2.0
1:11:26 Signals on Venezuela and Cuba
1:16:43 Belarus GL 2H
1:20:52 Final Thoughts
***Stay sanctions free.***