Tag: AML

Categories
FCPA Compliance Report

Mikhail Reider-Gordon on AML and Wirecard, Part 1

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors.  Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and international law.  She is accustomed to working on extremely sensitive and high-profile matters, both nationally and internationally. In this episode, we continue our multipart series on the Wirecard accounting fraud. Today, we begin a two-part exploration of the role of money-laundering in the Wirecard saga.

Some of the highlights include:

·       How money laundering works?

·       What is threat finance?

·       Other examples of German corporate fraud?

·       Why 2006 was such an important year in anti-money laundering?

·       How Wirecard made money through money laundering.

·       The risk related business model used by Wirecard.

Categories
Daily Compliance News

August 11, 2020-the Big Mac edition


In today’s edition of Daily Compliance News:

  • Kodak shares plummet. (WSJ)
  • McDonald’s sues former CEO. (Click2Houston)
  • Interactive Brokers to pay for AML violations. (WSJ)
  • Follow on corruption litigation is expensive. (D&O Diary)
Categories
This Week in FCPA

This Week in FCPA-Episode 156 – the Farewell to May edition

As the lads wish a fond farewell to May, enjoy the Astros still leading the MLB with the best record and looking forward to the start of summer, they return to discuss both events some of this week’s top compliance and ethics stories which caught their collective eyes.

  1. Dave Lefort’s Top 10 takeaways from Compliance Week 2019. (sub req’d) Tom, Mary Shirley, Lisa Fine and Amii Bernard-Bahn provide their reflections on a cross-posted podcast.
  2. Why ethics matters at the top.
  3. Can UNCAC help Mozambique recover funds stolen through corruption? Rick Messick explores.
  4. What is cooperation and remediation? Matt Kelly explores.
  5. Why is pre-acquistion DD from the compliance perspective now critical in France? Antoine F. Kirry, Frederick T. Davis, and Alexandre Bisch discuss.
  6. How much does a monitorship cost? Jay continues his multipart series on monitorships .
  7. How do you audit your investigative protocol? Mike Volkov explains in a 3-part series on his blog site Corruption, Crime and Compliance.
  8. Why is visibility key for compliance? Elsa Chan explores.
  9. CITGO now part of PdVSA/Venezuelan corruption scandal. Dick Cassin reports. Marissa Luck.
  10. Is there a legal duty to set the right ‘tone at the top?”
  11. This week Tom had a special 5-part podcast series sponsored by Hanzo on using AI and data analytics in compliance investigations. Check out the following: Part 1-Current State of Investigations; Part 2-Using AI and Web-Based Evidence; Part 3– Overcoming Investigative Challenges; Part 4-Improving Investigative Efficiencies; Part 5-Where are investigations headed? The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTube,  Spotifyand Corporate Compliance Insights. The Compliance Podcast Networkjoins C-Suite Radio.
  12. Join Tom in Boston for industry leading Compliance Master Class at the offices on AMI on June 11 & 12. Listeners who attend will receive a complimentary copy of The Compliance Handbook. Registration and Information is here. Join Tom, Eric Feldman, Vin DiCianni and Jay at the AMI Roundtable in Boston on June 13 for a deep dive into the DOJ’s new Evaluation of Corporate Compliance Programs-2019 Guidance. Information and registration is 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.
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: May 16, 2019-the CEOs and ethical lapses edition

In today’s edition of Daily Compliance News:

  • More business leaders forced out for ethical lapses than for poor financial performance in 2019. (Washington Post)
  • Do large companies fear legal violations? (New York Times)
  • Nordic/Baltic countries agree to share AML information. (Wall Street Journal)
  • Anti-corruption measures as KPIs for government ministers. What a novel idea. (Yahoo Business News)AML
Categories
Daily Compliance News

Daily Compliance News: May 1, 2019-the May Day edition

In today’s edition of Daily Compliance News:

Categories
Everything Compliance

Everything Compliance-Episode 45, the Drinkin’ the Kool-Aid edition

Welcome to the only roundtable podcast in compliance. Today, in Episode 45 we celebrate our newest addition to the Everything Compliance gang; Sarah Hadden. Sarah is the Publisher at Corporate Compliance Insights, taking the helm from founder Maurice Gilbert earlier this year. She is a journalist by profession and has been working in the compliance space, largely at CCI for the past six years. She brings a wealth of talent, knowledge and perspective to our happy band of commentators and help us to ‘drink the Kool-Aid’.

  1. Sarah Hadden discusses experiential learning. She uses that as a basis to consider what is effective training and how interactive training can lead to a new level of not simply effectiveness but awareness to recency bias which can cloud decision making. Sarah shouts out to internet service providers everywhere who were able to make the Mueller report available as soon as it was released.
  1. Matt Kelly discusses best practices around disclosing reporting data and using interactive technologies to improve Codes of Conduct, compliance policies and procedures. Matt rants on former White House Ethics Counsel, Stefan Passantino who urged Mazars USA not to comply with a subpoena that House Oversight Committee issued for Trump’s financial documents. That is ethics for you in TrumpWorld.
  1. Jay Rosen talks about repositioning compliance as a business generator. He discusses companies which see compliance as a business advantage and details how they do so. Jay shouts out to former White House counsel Don McGahn for being a “real lawyer” because he takes notes.
  1. Tom Fox, sitting in on this episode, uses the top three FCPA settlements of 2019 (MTS, Cognizant and Fresenius) to illustrate how the FCPA Corporate Enforcement Policy, announced in 2017 is being used in practice. He compares the three different types of resolutions used by the Justice Department and what it might mean for compliance going forward. Tom rants about Charles Van Doren and the quiz show scandals from the late 1950s.

The members of the Everything Compliance panelist 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– the newest addition to our panel. Sarah is the 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.
For additional reading, check out the follow resources:
Matt Kelly’s blog post, Three Ideas on Codes, Policies, and Tech in Radical Compliance.
For additional reading on the 3 top FCPA cases and how they were handled under the FCPA Corporate Enforcement policy, see Tom’s blog post FCPA Enforcement Going Forwardin the FCPA Compliance Report.
Jay Rosen’s article How to Reposition Compliance as a Revenue Generator on Corporate Compliance Insights.

Categories
This Week in FCPA

This Week in FCPA-Episode 149 – the White Privilege edition

After a week hiatus, the lads are back. While debating white privilege and the Varsity Blues scandal, they also take a look at some of this week’s top compliance and ethics stories which caught their collective eyes this week.

  1. Guilty pleas begin in the Varsity Blues scandal. Antonio Blumberg report in the Huffington Post. For those who did not plead guilty, additional charges filed. Melissa Korn reports in the Wall Street Journal. Jay interviews Justin Paperny about the Varsity Blues sting, in Corporate Compliance Insights. For one of the best and fullest explanations of the white privilege component, see Caitlan Flanagan’s article in The Atlantic.
  2. Does your company lack integrity? Mike Volkov gives 5 signs which show it does, on Corruption, Crime and Compliance.
  3. Standard Chartered joins the $1 bn fine club. Emily Flitter reportsin the New York Times. Jon Rusch takes a deep dive in Dipping Through Geometries.
  4. What is the intersection of DD and AI? Merritt Smith considers in the FCPA Blog.
  5. OFAC enforcement action demonstrates need for pre-acquisition due diligence? Lawyers from Paul, Weiss in the NYU Compliance and Enforcement Blog.
  6. What is ethical AI? Tom Austin explores on the Analyst Syndicate.
  7. What are the shifting reasons for FCPA enforcement? Kevin Keller on the Global Anti-corruption Blog.
  8. What are the risks to investors in Uber? Shannon Bond reports in the Financial Times. (sub req’d)
  9. This week Tom explores the intersection of Shakespeare and Compliance through the lens of King Lear. Check out the following: Part 1-Innovation;Part 2– Changing Your Focus; Part 3– Engaging Your Audience; Part 4-a Different Interpretation; and Part 5-The Fool.The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Panoplyand YouTube. The Compliance Podcast Network is now also on 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 30, 2019-the Sackler family sued edition

MARCH 30, 2019 BY TOM FOX


In today’s edition of Daily Compliance News:

Categories
This Week in FCPA

This Week in FCPA-Episode 148 – the Hope Springs Eternal edition

As Opening Day near and the Astros are predicted to unseat Jay’s Red Sox to win the 2019 World Series, both lads are eternally hopeful for their hometown heroes. While debating this issue, they also take a look at some of this week’s top compliance and ethics stories which caught their collective eyes this week.

  1. Former Hong Kong official sentenced for FCPA violations. Harry Cassin reports in the FCPA Blog. Matthew Goldstein reports on how to reduce your FCPA sentence in the New York Times.
  2. SEC awards two whistleblowers $50MM. Kristin Broughton in the WSJ Risk and Compliance Journal. Matt Kelly takes a deep dive in Radical Compliance. Doug Cornelius gets snarky in Compliance Building. Jonathan Marks weighs in on Board and Fraud.
  3. Jonathan Ruschand William Weaver debate whether corruption can be measured. Both on the FCPA Blog.
  4. Was it fraud or was it incompetency? The HP v. Autonomy civil trial begins in London. The BBC
  5. What is the difference in whistleblowing and extortion? Joe Mont explains in Compliance Week. (sub req’d)
  6. What are your supply chain risks? Russ Berland explores in Part 1 of a two-part blog post series on Corporate Compliance Insights.
  7. Looking at enforcement of financial market crimes in Canada and UK. Anita Anand reports in NYU’s Compliance and Enforcement Blog.
  8. What steps can you take to reduce whistleblower retaliation? Matt Kelly opines in Navex Global’s Ethics and Compliance Matters
  9. OECD slams Canadian government for interfering in SNC-Lavalin corruption investigation. Jonathan Rausch reports in Dipping Through Geometries.
  10. Join Tom and AMI’s Jesse Caplan for a 5-part exploration of emerging issues in healthcare compliance and monitoring. Check out the following: Part 1-Opioid Crisis-Legal issue; Part 2– Opioid Crisis-compliance solution; Part 3– the regulators; Part 4-the monitoring healthcare organizations; and Part 5-proactive monitoring. 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 April 11? Join the Greater Houston Business and Ethics Roundtable for a presentation for one year look back on GDPR. Registration and information are here.
  12. Check out the latest edition of Great Women in Compliance where Mary Shirley visits with Marianne Ibrahim.

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 29, 2019-the out like a lamb edition

MARCH 29, 2019 BY TOM FOX


In today’s edition of Daily Compliance News:

  • JPMorgan under fire for bribery in Nigeria. (New York Times)
  • Black and Decker settle Iranian sanctions case. (Wall Street Journal)
  • Having failed to change its culture, Wells Fargo CEO quits, effective immediately. (NPR)
  • Swedbank President fired over money-laundering scandal. (Wall Street Journal)