Tag: compliance programs

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Blog

Day 19 of 30 Days to a Better Compliance Program, Compliance Expertise on the Board

The Office of Inspector General (OIG) has called for greater compliance expertise at the Board level. The OIG said that a Board could raise its level of substantive expertise concerning regulatory and compliance matters by adding a compliance member to the Board. Such a compliance professional with subject matter expertise on the Board sends a strong message about the organization’s commitment to compliance, provides a valuable resource to other Board members, and helps the Board better fulfill its oversight obligations. Mike Volkov looked at it from both a practical and business perspective. He stated, “I have witnessed firsthand that companies with a board member with compliance expertise usually have a more aggressive and effective compliance program. In this situation, a Chief Compliance Officer has to answer to the board for the company’s compliance program while receiving the resources and support to accomplish compliance tasks.” Roy Snell sees it through the prism of the compliance profession and has said, “If you ask most companies if they have compliance expertise on their Board… most would say yes. When asked who the compliance expert is, they typically point to a lawyer, auditor, risk manager, or ethicist. None of these professions are automatically compliance experts. All lawyers have different specialties.” He goes on to state that what regulators want to see is specific compliance expertise at the Board level. He noted, “the government is looking for is not generic compliance expertise. They are looking for compliance program management expertise. Hui Chen, the DOJ Compliance Counsel, has continually talked about the need for companies to operationalize their compliance programs. She intones businesses must work to burn compliance into the fabric and DNA of their organization. Having a Board member with specific compliance expertise heading a Board level Compliance Committee can provide a level of oversight and commitment to achieving this goal. It will not be long before the DOJ and SEC require this step in any FCPA enforcement action resolution. This means that when your company is evaluated by Chen, under the factors set out in Prong Three of the FCPA Pilot Program, to retrospectively determine if your company had a best practices compliance program in place at the time of any violation, you need to have not only the structure of the Board level Compliance Committee but also the specific subject matter expertise on the Board and on that committee.

Key Takeaways

  1. Boards must have compliance expertise.
  2. Government regulators and shareholder groups have called for greater compliance expertise on the Board.
  3. Compliance expertise at the Board works up and down as such expertise can be a resource to the CCO and the compliance department.

For more information, check out my book Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program, which is available by clicking here. Both government regulators and shareholder groups have both called for greater compliance expertise at the Board.

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Everything Compliance

Episode 69, the Biden Administration


Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Jonathan Armstrong, Jay Rosen, Jonathan Marks, Matt Kelly and Mike Volkov for a deep dive into five key areas of law and enforcement and what they might look like under the Biden Administration. We end with a veritable mélange of rants and shouts outs.

  1. Jonathan Armstrong looks at the possibility of a fix to Privacy Shield under a Biden Administration. Armstrong shouts out to all retired trial lawyers who want to get back in the courtroom and now have Rudi Giuliani to demonstrate you are never too old to make a fool of yourself in court.
  1. Jay Rosen looks at the discontinuance of independent monitors under the Trump Administration and how this could change under the Biden Administration. Jay shouts out to our better angels to help rebuild the country after the hate and divisiveness of the Trump Administration.
  1. Matt Kelly considers the changes in enforcement, policy and focus in the SEC and other regulatory agencies under the Biden Administration. Matt shouts out to Georgia Secretary of State Brad Raffensperger who has withstood criminal actions by the Trump Administration to secure a fair vote from Georgia.
  1. Mike Volkov considers how antitrust enforcement might move forward under the Biden Administration. Volkov rants about the Trump Administration’s abandonment of the fight against Coronavirus and how its actions have caused untold more deaths.
  1. Jonathan Marks considers the increased importance of data and data analytics in compliance programs and how they will form the basis of enforcement under the Biden Administration. Marks shouts out to scientists working on the coronavirus vaccine in face of the Trump Administration’s abandonment of science and scientists for charlatans.
  1. Tom Fox gives a bittersweet shout out to Saul Turteltaub, father of our good friend Adam Turteltaub, who witnessed his beloved Los Angeles Dodgers lose in two consecutive World Series to teams that cheated and was denied seeing his Dodgers win their first pennant since 1987. Saul Turteltaub passed away last spring. 

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
  • Jonathan Marks is Partner, Firm Practice Leader – Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at marks@bakertilly.com

The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.

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This Week in FCPA

Episode 223 – the FinCen Papers edition


As the ICIJ releases some 2100 SARs from FinCen detailing over $2 trillion in illegal banking activity, the fires in California, Oregon and Washington finally abate. Tom and Jay are back to look at top compliance articles and stories which caught their eye this week.

  1. The FinCen Papers. Banks and SARs. (NYT) HSBC allowed Ponzi scheme. (BBC) Cache of FinCen docs made public. (BBC) Aaron Nicodemus says it puts compliance in a bad light in Compliance Week (Sub Req’d). Martin Woods on the breach of trust in Compliance Week (Sub Req’d). Jaclyn Jaeger says look at the banks, In Compliance Week (Sub req’d). Matt Kelly weighs in on Radical Compliance.
  2. More data analytics tools for compliance. Dylan Tokar in the WSJ Risk and Compliance Journal.
  3. What makes a ‘Great Woman in Compliance’. Mary Shirley reports on her journey as co-host of #GWIC in CCI.
  4. What does doing more with less mean for compliance? Matthew McFillin and Amanda Rigby in the FCPA Blog.
  5. What are the 7 sins of ESG Management? FTI in the Harvard Law School Forum on Corporate Governance.
  6. The largest AML case in Hong Kong history. Jon Rausch in Dipping Through Geometries.
  7. Oil trader cops to FCPA violation. Harry Cassin breaks the story on the FCPA Blog
  8. Why the Board needs a separate Compliance Committee. Mike Volkov in Corruption Crime and Compliance.
  9. This month on The Compliance Life, I am joined by DeAnna Nwankwo. In this week’s Part 3, DeAnna talks about building trust as a CCO.
  10. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on internal controls. This week saw the following offerings: Monday– Objective I; Tuesday– Objective II;Wednesday– Objective III; Thursday– Objective IV; and Friday– Objective 5. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.
  11. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here.
  12. Join K2 Intelligence FIN, on September 30 for a webinar with the AIBACP, “Strategies for Surviving an Offsite Regulatory Examination,” featuring Koby Bambilia, K2 FIN Managing Director, and a panel of experts, from banks to regulators. Registration and information 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.

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This Week in FCPA

Episode 222 – the Trees Gone Bad edition


As Donald Trump blames the California and Oregon forest fires on ‘trees gone bad’; Tom and Jay continue to brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week.

  1. How does Bluebell apply to cyber claims against a Board of Directors? Paul Ferllio, Bob Zukis and Christophe Veltsos in the Harvard Law School forum on Corp Governance.
  2. VW Monitor closes out monitorship. Jack Ewing in the NYT. Mengqi Sun in the WSJ Risk and Compliance Journal.
  3. Tom takes a deep dive into Herbalife. Part 1, Part 2, Part 3 and Part 4.
  4. The intersection of anti-human trafficking and ABC compliance. Vanessa Hans in the FCPA Blog.
  5. Does the DOJ have to turn in SEC investigative material in a criminal FCPA trial? Matt Kelly goes legal in Radical Compliance.
  6. The intersection of compliance and internal audit? Mike Volkov in Corruption Crime and Compliance.
  7. Who is a PEP? Dick Cassin considers a plethora of definitions in the FCPA Blog.
  8. Has Covid-19 changed the relationship between senior management and the Board? Dottie Schindlinger and Kira Ciccarelli in CCI.
  9. This month on The Compliance Life, I am joined by DeAnna Nwankwo. In this week’s Part 2, DeAnna talks about some of the skills she needed in the CCO chair.
  10. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on internal controls. This week saw the following offerings: Monday– Internal controls for 3rd parties; Tuesday– Internal controls for GTE; Wednesday– BOD oversight as an internal control; Thursday– Code of Conduct as an internal control; and Friday– What is the COSO Internal Controls Framework. The month of August is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.
  11. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here.
  12. Join a great upcoming K2 Intelligence FIN webinar. Robin Henry on how investigators can use social media, Thursday, 9-24 at 1600 GMT. Registration and information here.
  13. Join Tom, Charlie Voelker, Legal Compliance Solutions, Skillsoft and Stephen Martin, Partner, StoneTurn for a joint Skillsoft/StoneTurn webinar on evolving your compliance program under the 2020 Update to the Evaluation of Corporate Compliance Programs. Wednesday, September 23, from 12 PM – 1 PM EDT. Information and registration 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.

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FCPA Compliance Report

Matt Kelly on Changes Seen by the 4th Estate

The FCPA Compliance Report is the longest running podcast in compliance, premiering on July 31, 2015. This week begins a series of podcasts leading up to the 500th anniversary episode of the FCPA Compliance Report, which will post on Monday, August 31. Over the next five episodes, I will post podcasts of 5 top FCPA and compliance commentators. Over this week, I will be joined by Mike Volkov, Matt Kelly, Jonathan Armstrong, Jay Rosen and Jonathan Marks. Each will speak about the evolution of compliance from their own unique perspective. In this episode, I visit with Matt Kelly, founder of Radical Compliance. Kelly is a business journalist who was one of the first to gravitate to compliance. We take a look back at the evolution compliance over the past 10 years from the perspective of the 4th Estate.
Some of the highlights include:

  • How compliance has moved into the mainstream of business news and the discussions about business.
  • How social media has led to a more robust discussion about corporate ethics and democratized other people’s ability to hold companies accountable to ethical standards.
  • The significance of the COSO 2013 Internal Controls Framework.
  • Kelly sees FCPA enforcement as fundamentally different than corporate scandals which led to SOX and Dodd-Frank.
  • The convergence of compliance & ethics and audit & risk management.
  • The increased use of data in compliance as emphasized in the 2020 Update to the Evaluation of Corporate Compliance Program.

Lineup
I hope you will listen in to each episode over this week. The lineup will be:
Monday, August 24-Episode 495-Mike Volkov on changes in FCPA enforcement.
Wednesday 26, August Episode 497-Jonathan Armstrong in changes in data protection/data privacy compliance.
Thursday August 27-, August Episode 498-Jay Rosen in changes in compliance from the business development perspective.
Friday August 28-, August Episode 499-Joanthan Marks on changes compliance mirroring those from internal audit.
Monday, August Episode 500-the Anniversary Episode.

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31 Days to More Effective Compliance Programs

Inquiring up and down

Where does “tone at the top” start? With any public and most private U.S. companies, it is at the Board of Directors. But what is the role of a company’s Board in compliance? First a Board should not engage in management but should engage in oversight of a CEO and senior management. The Board does this through asking hard questions, risk assessment and identification.
Initially it must be important that the Board receive direct access to such information on a company’s policies on this issue. The Board must have quarterly or semi-annual reports from a company’s CCO to either the Audit Committee or the Compliance Committee. Every Board should create a Compliance Committee to deal with compliance issues, as an Audit Committee may more appropriately deal with financial audit issues. A Board Compliance Committee can devote itself exclusively to non-financial compliance. The Board’s oversight role should be to receive such regular reports on the structure of the company’s compliance program, its actions and self-evaluations. From this information the Board can give oversight to any modifications to managing FCPA risk that should be implemented. CCO reporting to the Compliance Committee must be structured carefully to promote ethics and compliance.
Three key takeaways:

  1. A Board Compliance Committee should provide oversight not management.
  2. A CCO should use multiple reports to communicate with the Board Compliance Committee.
  3. Board Compliance Committee oversight makes companies more efficient and at the end of the day more profitable.
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This Week in FCPA

Episode 216 – the 1MDB Moves Towards Resolution edition

 
As the international fight against corruption took two small steps forward this week in the 1MDB case, Tom and Jay brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week.

  1. Goldman Sachs settles with Malaysia for nearly $4bn. Ben Otto and Chester Tay report in the WSJ. Former Malaysia PM convicted in 1MDB scandal, Harry Cassin reports in the FCPA Blog.
  2. Mike Volkov reports on two big enforcement actions in Pharma. Indivior and illegal marketing of opioid products. Taro Pharma and price-fixing.
  3. What are the shared elements in a best practices compliance program? Jaclyn Jaeger explores in Compliance Week. (sub req’d)
  4. How can you test your hotline? Matt Kelly explores on Radical Compliance.
  5. Why is Germany soft of corporate crime? Dick Cassin considers in the FCPA Blog.
  6. Whistleblower management in the EU. Frank Staelens in CCI.
  7. How can you audit AI? James Bone explores in CCI.
  8. What should be the goal of effective internal controls? Alex Movchan interviews Edmund Sanders in Risk and Compliance Platform Europe.
  9. This month on The Compliance Life, I am joined by Scott Sullivan, Chief Integrity and Compliance Officer at Newport Mining. In Part 1, we discussed the need for empathy in a CCO. In Part 2, we looked at reading the tea leaves and staying ahead of the (corp) wolf pack. In Part 3, we considered who a CCO needs on their compliance team. In this concluding Part 4, we look at the CCO and compliance function down the road.
  10. AMI week on Compliance and Coronavirus as Jerry Coyne discusses telemedicine and Covid-19, Don Stern on how Covid-19 will impact federal prosecutors and Mikhail Reider-Gordon compliance issues during the business reopenings.
  11. On the Compliance Podcast Network, Tom concludes the topic of 3rd party risk management. This week saw the following offerings: Monday-freight forwarders; Tuesday– risk ranking in the Supply Chain; Wednesday-data and 3rd party risk management (Vin DiCianni as guest); Thursday-enforcement actions; and Friday-wrap up. The month of July is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.  Join us in August for the role of the Board of Directors.
  12. Upcoming Webinars:

K2-FIN, Windward, and C4ADS Webinar—New Sanctions Developments in the Maritime Sector: UK Sanctions Shipping Guidance and Venezuelan Shipping in Focus, August 5, 2020 at 10:45 to 11:45 AM EST; with Juan Zarate and Eric Lorber. Registration and Information 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.

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This Week in FCPA

Episode 210 – the Bostock edition


As Trump has trouble drinking a glass of water and walking (Note-not at the same time), Covid-19 cases spike, the US Supreme Court hands down a landmark decision on protections for the LGBTQ community in the workplace, self-distancing Tom and Jay are back to consider some of the top compliance articles and stories over the past week.

  1.  Mike Volkov takes the chickens out to roost in a 3-part series on the DOJ Antitrust Division charges of price-fixing and bid-rigging conspiracy. In Corruption Crime & Compliance. Jon Rausch weighs in on Dipping Through Geometries.
  2. How will WFH change business? Alison Taylor opines on the World Economic Forum
  3. What are the three ‘R’s’ of a speak up culture? Lloydette Bai-Marrow on the FCPA Blog.
  4. GOP stymies data privacy/data protection legislation yet again. Dave Uberti reports in the WSJ.
  5. It’s your culture stupid. Jim Nortz in CCI.
  6. How is Covid-19 changing internal audit. Matt Kelly explores in Radical Compliance.
  7. Viva La France. Dylan Tokar reports in the WSK Risk and Compliance Journal.
  8. Making sure compliance is not marginalized during financial dislocation. A plethora of authors contribute on NYU’s Compliance and Enforcement Blog.
  9. The ethical upside to WFH. In the Center for Ethical Leadership
  10. Interested in moving to the CCO chair? Check out my latest podcast series The Compliance Lifewhere I interview one CCO type for a month on their journey to the CCO chair and beyond. In on this month’s edition I visit with Ryan Rabalais. In this Part 3, he details some of key skills of a CCO. The Compliance Life is now available on iTunes.
  11. On Compliance and Coronavirus this week,: Scott Price on cyber security risks going forward; Gabe Gumbs data privacy and data protection during the economic dislocation and Covid-19; David McLaughlin joins me to discuss increasing automation to enhance compliance. Compliance and Coronavirus is available on iTunes here.
  12. On the Compliance Podcast Network, this month topic: internal reporting and investigations; all on 31 Days to a More Effective Compliance Program. This week’s offerings: Monday-The Investigative Team; Tuesday-investigative challenges; Wednesday-the witness interview; Thursday– issues in cross-border investigations; Friday– who and when to suspend. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel.
  13. How does the Hundred Acre Wood inform compliance? Check out Tom’s 5-part blog post series on the FCPA Compliance and Ethics Blog. Monday-Tigger and Sales; Tuesday-Kanga, Roo & Ombudsman; Wednesday-Eeyore and corp legal; Thursday-Piglet and Finance; Friday-Winnie the Pooh as CECO.

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.

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This Week in FCPA

Episode 209 – the George Floyd is Buried edition


As Trump goes back into hiding in his bunker, the rest of the country continues to reopen. Self-Tom and Jay are back to consider some of the top compliance articles and stories over the past week.

  1. Final thoughts on the DOJ 2020 Update to the Evaluation of Corporate Compliance Programs. Tom summarizes the highlights on the FCPA Compliance and Ethics Blog. Mike Volkov gives his five top takeaways.
  2. Want to see examples of ham-fisted leadership. Matt Kelly on Radical Compliance. Tom and Matt take a deep dive in Compliance into the Weeds.
  3. Why does WFH raise compliance risks? Vera Cherapanova on the FCPA Blog.
  4. How did Jho Low use Kuwait to continue his fraud? Reporting in the WSJ.
  5. Common features of corruption and police brutality. Matthew Stephenson opines in GAB.
  6. How can you sharpen your cyber security? Jim DeLoach in CCI.
  7. How can you build a listen up culture? Bob Conlin on Navex Global’s Ethics and Compliance Matters
  8. Managing risk in compliance staffing. Kathryn Reimann on NYU’s Compliance and Enforcement Blog.
  9. Brian Benczkowski bails the DOJ. Dylan Tokar on the WSJ Risk and Compliance Journal.
  10. Interested in moving to the CCO chair? Check out my latest podcast series The Compliance Lifewhere I interview one CCO type for a month on their journey to the CCO chair and beyond. In on this month’s edition I visit with Ryan Rabalais. In this Part 2, he details why the corp compliance function can be seen as a Black Box. The Compliance Life is now available on iTunes.
  11. On Compliance and Coronavirus this week, I feature three podcasts from the folks at K2 Intelligence FIN: Gabe Hidalgo on lessons for financial institutions during the time of Covid-19; Sepideh Rowland on PPP and changing risks for financial institutions; Ray Dookhie joins me to discuss evolving fraud risk during the time of Covid-19. Compliance and Coronavirus is available on iTunes here.
  12. On the Compliance Podcast Network, this month topic: internal reporting and investigations; all on 31 Days to a More Effective Compliance Program. This week’s offerings: Monday-internal reporting and whistleblowers during layoffs; Tuesday-triage of allegations; Wednesday-the investigation protocol; Thursday– preparing for an investigation; Friday– selection of investigative counsel. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel.
  13. Join Tom and Jonathan Marks for a webinar on the 2020 Update to the Evaluation of Corporate Compliance Programs. Thursday, June 18 at noon CT. Registration and information available here.
  14. Join Jay’s AMI colleagues Dionne Lomax and Jesse Caplan for a webinar entitled, “The DOJ’s New Guidance for Antitrust Compliance Programs + Special Considerations During the COVID Pandemic”. This webinar will discuss the U.S. Department of Justice Antitrust Division’s recently announced initiative to encourage corporations to develop and implement effective antitrust compliance programs. Our panel will discuss the new guidance and special considerations during the COVID pandemic and provide practical tips for developing a comprehensive program, including tips on how to handle a federal and/or state antitrust investigations. The event will be held next Tuesday, June 16th, at 12P EST/9A PST. Registration and information can be found 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.

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This Week in FCPA

Episode 208 – the Trump Administration Attacks Americans edition


As peaceful protesters are attacked by the Army on the order of the Trump Administration, Tom and Jay ask “now that Trump has his wall around the White House, will Mexico pay for it?” Self-distancing Tom and Jay are back to consider some of the top compliance articles and stories on the new 2020 Update to the 2019 DOJ Evaluation of Corporate Compliance Programs.

  1. Tom Fox goes through a multipart deep dive. Part 1-Overall Themes, Part 2-Data and Continuous Improvement, Part 3-Third parties and M&A, Part 4-CCO and the Complaince Function, Part 5-Conclusion.
  2. Matt Kelly explores on Radical Compliance.
  3. Matt Kelly goes Pizza Pizza with another article in Navex Global’s Ethics and Compalince Matters.
  4. Dylan Tokar reports in WSJ Risk and Compliance Journal.
  5. Mike Volkov has a 3-part exploration on Corruption Crime and Compliance. Part 1, Part 2 and Part 3.
  6. Dick Cassin explores organizational justice in the FCPA Blog.
  7. Jonathan Marks looks at it from the forensic perspective in Board and Fraud.
  8. Interested in moving to the CCO chair? Check out my latest podcast series The Compliance Lifewhere I interview one CCO type for a month on their journey to the CCO chair and beyond. In on this month’s edition I visit with Ryan Rabalais. In this Part 1, he details his journey into compliance and the winding road which took him to the CCO Chair. The Compliance Life is now available on iTunes.
  9. On Compliance and Coronavirus this week: David Wolf on using podcasting and audio white papers as communication tools during the time of Covid-19; James Green on operationalizing risk management during this health crisis; Eden Gillott joins me to discuss crisis communication during the time of Covid-19. Compliance and Coronavirus is available on iTunes here.
  10. On the Compliance Podcast Network, this month topic: internal reporting and investigations; all on 31 Days to a More Effective Compliance Program. This week’s offerings: Monday-intro to internal reporting and investigations; Tuesday-Advantages of an internal reporting system; Wednesday-Internal reporting case study; Thursday– Internal Reporting Best Practices; Friday- Answering DOJ questions on internal reporting. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel.

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.