Categories
FCPA Compliance Report

The EC Gang on the Monaco Doctrine

In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, we have the Award-Winning Everything Compliance quartet of Jonathan Marks, Jonathan Armstrong, Karen Woody, and Tom Fox on the Monaco Memo.

1. Tom Fox looks at the Monaco Memo through the monitorship language and answers a listener’s questions about compliance programs under the Monaco Memo.

2. Karen Woody reviews the Monaco Memo, the self-disclosure angle, and investigatory considerations and ponders the role of defense counsel going forward.

3. Jonathan Marks also looks at investigatory issues under the Monaco Memo, the role of the Board of Directors, and the role of the forensic auditor under the Monaco Memo.

4. Jonathan Armstrong’s self-disclosure from a UK angle joins Karen Woody in questioning how defense counsel should move forward.

Resources

Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog

1.     A Jolt for Compliance

2.     Timely Self-Disclosure

3.     Corporate Compliance Programs

4.     Monitors

5.     The Heat is On

Monaco Memo

Categories
Great Women in Compliance

Margarita Derelanko – She’s Going Places

Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.

In late 2018, Mary and Lisa began advertising the launch of the Great Women in Compliance podcast, which would air on 6 December 2018.  Margarita Derelanko was one of the people who saw the marketing collateral and grew excited about the incoming podcast.  She affords Lisa and Mary the opportunity to hear what the launch of the podcast was like from the other side of the fence – the to-date missing aspect of their origin story – what the listenership was thinking and how the podcast was received.  Margarita shares how the podcast has impacted her life, including her takeaways from having her first article published, and the benefits she has gained from the encouragement of the hosts and guests.

Unlike many of the GWIC and certainly unlike Mary and Lisa, Margarita had the opportunity to choose whether or not to be in Compliance and she shares what it’s like for the new generation to consider joining the field – spoiler alert, Compliance Destiny appears yet again!  It’s a real thing folks!

Margarita shares some advice for helping to overcome biases when you don’t look like you fit the part.  She is of very small stature and is lucky enough to have youthful looks – causing some to make unfair judgments.  Listen in for how she overcomes the biases and consider how you can turn some of your perceived greatest weaknesses into a strength.

Following on from Mia Reini’s tips for putting together an engaging line up for the The Home Depot’s Compliance Summit, Margarita lends some tips from her experience on the planning team for the Waud Capital Partner’s Compliance Symposium to have a successful event.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings.  If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it.  If you have a moment to leave a review at the same time, Mary and Lisa would be so grateful.

You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast.  Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.

Categories
Compliance Into the Weeds

Monaco Doctrine and Memo

Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced Monaco Doctrine as encapsulated in the Monaco Memo. Highlights include:

  1. Corporate accountability.
  2. Timeliness in turning over evidence of wrongdoing.
  3. Baby Carrots in evaluating the corporate history of misconduct.
  4. Additions to Evaluation of Corporate Compliance Programs.
  5. Tweaks to the Yates Memo formulation.
  6. Monitors and Monitorships.

 Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

  1. Introduction
  2. Self-Disclosure
  3. Corporate Compliance Programs
  4. Monitors
  5. The heat is on

Monaco Memo

Categories
The Compliance Life

Maria D’Avanzo – To Traliant and Beyond

The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Maria D’Avanzo. We discuss Maria’s journey from a real estate and small business lawyer to compliance, then CCO chair, and now as the Chief Evangelist Officer at Traliant.

In this concluding episode, Maria discussed how she used the tools and skills she learned to move to a Traliant, where she is well positioned to help compliance professionals gain insights into their programs and help them better appreciated how Traliant can support their efforts. She is working with  with Traliant’s executive team as we not only develop new products but also enhance our existing offerings by listening tours with customers,  customer advisory councils and expounding on training’s role in speak-up culture.

Resources

Maria D’Avanzo LinkedIn Profile

Traliant.com

Categories
Great Women in Compliance

Rebecca Walker on Developing and Using Risk Assessments-A Holistic Approach

Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.

One of the key components of a compliance program is a risk assessment.  However, how to develop the right one for your organization is an art, not a science, as is how to best use the findings and report the results.  In this episode, Rebecca Walker, one of the founders of Kaplan & Walker LLP, takes a deep dive into the subject.

Rebecca has been in the compliance field for over 20 years, and has always been an advocate for a holistic and well-rounded view of compliance.  She speaks regularly on many topics, and here, Lisa and Rebecca talk about various aspects of risk assessments including how to tailor your risk assessment to your organization, or if you know there is a risk, do you need to then do an assessment.  They also touch on the distinction between risk assessments and program assessments.

Rebecca also talks about the beginning of her career in a large law firm, and the challenges of starting her own firm, both in general and as a woman.  She recounts a story about her 1st day that illustrates both the fear and excitement of starting out.

The Great Women in Compliance podcast is excited to look at topics like this one, and we are always open to suggestions for guests.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings.  If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it.  If you have a moment to leave a review at the same time, Mary and Lisa would be so grateful.

You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast.  Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.

Categories
Compliance Into the Weeds

Polite Speech-A Jolt for Compliance

Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at Assistant Attorney General Kenneth A. Polite’s recent speech at the University of Texas Law School. The speech focused on corporate and individual accountability in FCPA enforcement actions. Highlights and questions posed include:

·      What are clawbacks, and how would they work in practice?

·      Does a lack of corporate clawbacks lead to aggravating factors?

·      How much credit will a company receive by instituting clawbacks?

·      CCO certifications are here to stay.

·      How does the Polite Speech relate to the Monaco Memo?

Resources

Matt in Radical Compliance

Text of Polite Speech

Categories
The Compliance Life

Maria D’Avanzo – Moving into the CCO Chair

The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Maria D’Avanzo. We discuss Maria’s journey from a real estate and probate lawyer to compliance, then CCO chair, and now as the Chief Evangelist Officer at Traliant.

After for 2.5 years at AIG, Maria moved to Cushman & Wakefield where she became the Chief Ethics and Compliance Officer and Chief Data Privacy Officer. In this role, she led an innovative and commercially focused global compliance and privacy team to support ethical decision-making and risk management needs of Cushman & Wakefield, a global leader in commercial real estate services with 53,000+ employees worldwide, where she learned that compliance is one of the hardest jobs (if not the hardest) in any company.  To be effective, employees need to know who you are, trust and have faith in you, and see your “human side”.  One of Cushman & Wakefield’s CEOs taught me that the best way to accomplish this is to go to where the employees are and listen to them over a cup of coffee.

Resources

Maria D’Avanzo LinkedIn Profile

Traliant.com

Categories
FCPA Compliance Report

Tomell Ceasar and the Middle East and Africa Compliance Association

In this episode of the FCPA Compliance Report, I am joined by Tomell Ceasar. He is the Group Head of Ethics and Compliance at Careem (An Uber Company). He is one of the founders of the Middle East and Africa Compliance Association (MEACA). Some of the highlights include:

1.     What is it like practicing compliance in EAME?

2.     EAME is a huge amount of territory to cover with many different countries and cultures.

3.     How does that play into compliance for the region?

4.     Training in EAME.

5.    Genesis of MEACA.

6.    What do you and the other founders hope to accomplish through MEACA?

 7.    What are the requirements for membership?

Resources

Tomell Ceasar on LinkedIn

The Middle East and Africa Compliance Association

Categories
Compliance Into the Weeds

Suicide Prevention Hotline and a Speak Up Culture

Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the implementation of a national suicide prevention hotline, 988, and consider what it might teach compliance professionals. Highlights and questions posed include:

·      What is the new national Suicide Prevention hotline?

·      How does it inform your corporate hotline and speak up culture?

·      How do you teach the trait of listening?

·      Engaged employees are more effective employees.

·      How easy are the mechanics of your hotline to navigate?

Resources

Matt in Radical Compliance

Categories
The Compliance Life

Maria D’Avanzo – Move to Compliance

The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Maria D’Avanzo. We discuss Maria’s journey from a real estate and probate lawyer to compliance,  then CCO chair, and now as the Chief Evangelist Officer at Traliant.  

The 2008 financial crisis caused a downturn in real estate work so Maria sold her law practice. This precipitated her move into the compliance field. Maria began her first compliance role at a real estate focused private equity shop. Here she registered investment adviser and broker dealer entities and obtained series 7, 63 and 24 licenses.  After four years, Maria moved to Deputy Chief Compliance Officer at AIG Asset Management where she led a team of compliance professionals handling regulatory compliance matters on behalf of both registered investment advisers and broker dealer entities in North America.

Resources

Maria D’Avanzo LinkedIn Profile

Traliant.com