Categories
All Things Investigations

All Things Investigations – Beyond the DPA: Maintaining an Effective Compliance Culture Post-Release

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, Hughes Hubbard & Reed LLP partner Mike Huneke and I speak with Mei Li Zhen, Head of Ethics & Compliance, Commercial Operations & Subsidiaries, Airbus, about her role in the organization’s compliance department.

Mei Li Zhen and Michael Huneke are two accomplished professionals with extensive backgrounds in compliance programs and company culture, having both transitioned from external counsel to in-house counsel roles at Airbus. With her experience working with diverse international backgrounds, Zhen believes that a strong, company-wide, embraced compliance program is not just about avoiding fines but is a competitive advantage that attracts young talent and gains the trust of investors and governments. She sees integrity as beneficial for the bottom line and emphasizes the importance of everyone in the organization feeling responsible for behaving with integrity. Huneke, a US-qualified lawyer working in France, shares a similar perspective. He sees a strong compliance program as a self-reinforcing cycle that attracts the right talent and enhances the business’s reputation and reliability. Like Zhen, Huneke believes that compliance should permeate the entire company culture, with every employee feeling accountable for maintaining integrity in their daily activities.

Key Highlights:

  • Airbus’ Global Commitment to Compliance and Trust
  • Ethics Ambassadors Shaping Airbus Compliance Culture
  • Enhancing Team Trust through Transparent Communication
  • Establishing Trust Through Empathetic Communication Practices
  • Ethical Compliance Leadership in the Aerospace Industry

Resources:

Hughes Hubbard & Reed LLP Website

Mei Li Zhen on LinkedIn

Categories
10 For 10

10 For 10: Top Compliance Stories For the Week Ending September 30, 2023

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings to you, the compliance professional the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes, hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  • Menendez was indicted for accepting bribes. (NYT)
  • Polish visa selling scandal. (FT)
  • FTC going after PE for serial acquisitions. (FT)
  • FCA to crack down on firms bullying their employees. (WSJ)
  • Cognizant execs trial delayed.  (Law360)
  • Indonesia vows to sue UK over Airbus settlement. (FT)
  • McKinsey to pay another $230MM for opioid settlement. (FT)
  • The US warns advisory services in China. (WSJ)
  • Chinese Deputy Bank head accused of bribery.  (Reuters)
  • SBF looking at a ‘very long’ sentence. (Reuters)

You can check out the Daily Compliance News for four curated compliance and ethics-related stories each day, here.

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Daily Compliance News

Daily Compliance News: September 28, 2023 – The Cognizant Trial Delay Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

·       Prosecution seeks delay in Cognizant execs trial.   (Law360)

·       Indonesia vows to sue UK over Airbus settlement.  (FT)

·       McKinsey to pay another $230MM for opioid settlement. (FT)

·       US warns advisory services in China. (WSJ)

Categories
Daily Compliance News

May 10, 2022 the Did UK Gov Approve Bribes Edition


In today’s edition of Daily Compliance News:

  • China-Taiwan risk insurance. (WSJ)
  • Airbus defendants claim UK government approved bribe payments. (Bloomberg)
  • Is government investigation hurting US solar industry? (WaPo)
  • SEC extends comment period on climate Change risk reporting. (Reuters)
Categories
FCPA Compliance Report

Airbus-Part 5, Tom Fox with some final thoughts on Airbus


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 concluding Episode 5, Tom Fox provides his perspective with some final thoughts about what it all means.
Highlights include:

  • The significance of the largest international anti-corruption enforcement action of all time.
  • Why a complete sweep of Airbus was required and did it achieve one?
  • What are the three key takeaways for the compliance professional?
  • How this enforcement action will be the model for international cooperation in investigations and enforcement going forward.
  • At the end of the day, what does it all mean?
Categories
FCPA Compliance Report

Airbus-Part 3, Jonathan Armstrong on the UK-SFO Enforcement


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 3, Jonathan Armstrong considers the UK’s Serious Fraud Office role in the enforcement involving Airbus.
Highlights include:

  • The transparency in the UK-Deferred Prosecution Agreement process allows greater information to for the compliance professional.
  • What are the key differences in the UK and US DPA process?
  • The breadth and scope of the UK investigation.
  • The UK-DPA is not the end of the story as there may well be significant individual enforcement actions going forward.
  • What does Airbus mean for the new SFO style of anti-bribery enforcement action?

Resources
Cordery Compliance Client Alert on the Airbus enforcement action here.

Categories
FCPA Compliance Report

Airbus-Part 2, Mike Volkov on ITAR and Trade Sanction Enforcement


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 2, Mike Volkov considers that US trade sanction enforcement involving Airbus.
Highlights include:

  • How was Airbus subject to US trade sanction jurisdiction?
  • This is one of the few cases where the DOJ focused on anti-corruption and trade sanctions.
  • Airbus had complete absence of commitment to compliance.
  • Airbus had a completely broken culture.
  • What were the three categories of ITAR violation identified by the DOJ?

Resources
Mike Volkov’s review of the ITAR portion of the US enforcement action here.
 

Categories
FCPA Compliance Report

Airbus, Part 1-Jay Rosen on the FCPA Enforcement


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.
Categories
Everything Compliance

Episode 57-the Airbus edition


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.

  1. Mike Volkov considers the enforcement action from the trade sanction/ITAR perspective.
  2. Jonathan Armstrong reviews the SFO’s role in this matter.
  3. 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.
  4. 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.

Categories
FCPA Compliance Report

Joanne Taylor on the UK Airbus Enforcement Action


In the Episode, I visit with Joanne Taylor, Managing Director at K2, an industry leading investigative, compliance and cyber defense services firm. Joanne joined K2 Intelligence with 20 years of experience in legal, investigations, and financial crime compliance. This includes fraud risk management, anti-bribery and corruption, regulatory enforcement, and fraud investigations within leading international financial and legal services industries. Prior to joining K2 Intelligence, Joanne led global anti-fraud, bribery and corruption strategy and was previously responsible for the global whistleblowing program and cross-border investigations related to fraud, bribery and corruption for a European bank. In this podcast we discuss the UK portion of the Airbus anti-corruption enforcement action.
Some of the highlights include:

  1. The Airbus international corruption settlement is so massive that many compliance professionals might have trouble getting their arms around it. What are there some key takeaways you see from your perspective?
  2. Can you describe the extensive cooperation noted by the UK Court by Airbus after the investigation began in earnest?
  3. What is the significance of the French/UK/US taking the lead in different aspects of the investigation?
  4. The UK Court provided a detailed look at the economic consequences of a trial and guilty verdict. Why was this analysis so critical to the Court?
  5. What do you see as the significance of the international cooperation by investigating agencies and enforcement agencies?
  6. What does the UK Judgment say about or do for the SFO?