As Texas’ Governor-Mr. Personal Responsibility-himself comes down with Covid after refusing to engage in ‘personal responsibility’, Tom and Jay are back to look at some of this week’s top compliance and ethics stories which caught their interest on This Week in FCPA in the Personal Responsibility edition.
Stories
- Corruption led to the fall of Afghanistan. Dick Cassin in the FCPA Blog.
- Does HSBC facilitate cybercrime. Elfriede Sixt in Risk and Compliance Journal Europe.
- The Pearson SEC enforcement action. Matt Kelly in Radical Compliance. Tom and Matt on Compliance into the Weeds. Kevin Lacroix in the D&O Diary.
- Trust and the CCO? Jeff Kaplan in Conflict of Interest
- Fraud during the pandemic. James Ruotolo in CCI.
- Inefficiency in AML enforcement. Maria Evstropova in CCI.
- SEC coming after cryptocurrencies. Aaron Nicodemus in Compliance Week.
- What Boards need to know before, during and after M&A. Maria Castanon Moats and Leah Malone in Harvard Law School Forum on Corporate Governance.
- Who is on your crisis management team? Eden Gillott in com.
- CFIUS publishes 2020 report. K2 Integrity Client Alert.
Podcasts and Events
- On Innovation in Compliance this week I interview Dennis Kucinich about his latest book, The Division of Light and Power. Check out the show here.
- On The Compliance Life, in August I visit with Kortney Nordrum CCO at Deluxe. In Episode 1, from Red Wing to Israel. In Episode 2, From Freddie Mac to the law.
- How do the Greek Eumenes and the Roman Sertorius inform compliance leadership today? Find out as Tom and Richard Lummis continue their exploration of Plutarch’s Lives in this episode of 12 O’Clock High, a podcast on business leadership.
- Compliance Week is having an open house this month as they have dropped their firewall. You can check out the entire publication for no charge. Check it out here.
- Breaking News features The Compliance Handbook, 2nd edition. Check out the Breaking News feature here. Purchase The Compliance Handbook, 2nd edition here. Find out more about The Compliance Handbook, 2nd edition in an upcoming Zoom webinar, on Wednesday, September 1 at 8:30 AM ET; hosted by the Azevedo Sette law firm and Charles River Associates. To RSVP email tcintra@azevedosette.br
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.

Korrine Kohm is CSS’s Director of Retail Wealth Manager Services. Prior to CSS, Korrine was the Chief Compliance Officer and Head of Operations at Estabrook Capital Management where she was responsible for all compliance functions of this SEC-registered, $2.1B investment advisory firm. Korrine began her regulatory career while working at Allied Irish Bank (NY) in the Operations Department where she was a key member of AIB’s Compliance Committee, responsible for ensuring compliance with Federal and State regulations. An active member of the National Society of Compliance Professionals for over 10 years, Korrine earned her Investment Adviser Certified Compliance Professional (IACCPTM ) designation in 2006, is a member of the Association of Certified Fraud Examiners, and obtained her Certified Fraud Examiner designation. In addition to her experience in compliance and banking, Korrine began the 16-week intensive training course in Quantico, Virginia, to become a Special Agent with the Federal Bureau of Investigation. She has particular experience in crafting customized policies and procedures, developing and implementing compliance programs, conducting on-site compliance reviews, acquisition due diligence reviews, risk assessments and mock SEC examinations. She routinely counsels clients on various regulatory matters, including SEC registration issues, social media and advertising, policies related to diminished financial capacity, disclosures and the annual review process.

John Gentile is responsible for overseeing various types of broker-dealer and investment adviser consulting engagements, including conducting SEC/FINRA internal control reviews, anti-money laundering testing, written supervisory policy and procedures testing, and other consultation services. John is a frequent speaker at industry conferences on various compliance topics, including “Effective Supervision,” “Large Firm Testing,” FINRA Supervisory Control Rules” and “Anti Money Laundering Requirements for Broker Dealers under the PATRIOT Act.” In 1987 John joined the SEC as a Securities Compliance Examiner, becoming a Branch Chief in 1991. He became Assistant Regional Director in 1993, supervising a team of 20 broker-dealer managers and examiners. He also planned and conducted financial, operational, and sales practice examinations of the largest broker dealers and was among those responsible for a review of hedge funds’ impact on broker dealer internal controls. Before joining the SEC, John was a Financial Damage Analyst with PaineWebber Inc. Most recently from 2000-2007 John was an Executive Consultant, Broker-Dealer Services, at National Regulatory Services. John has an MBA from Fordham University and a BS in Finance from Central Connecticut State University. From 1995 to 2002, John was also a member of the Securities Industry Continuing Education East Coast Content Committee.
Adam DiPaolo CISA, CRISC is a Section 13 Reporting Manager, Senior Consultant and Associate General Counsel at CSS. Adam designs practical solutions to manage regulatory challenges faced by hedge funds, private equity funds, funds of funds, and other investment advisers. In addition to providing compliance services such as annual compliance program reviews, risk assessments and acquisition due diligence, Adam established Section 13 reporting capabilities and EDGAR filing agent services for CSS’s Compliance Services division. He drafts and maintains corporate filings ranging from Forms ADV and PF to Forms 13F and 13H. Adam also provides cybersecurity risk management services to CSS clients – ranging from network vulnerability scanning to onsite cybersecurity risk assessments to assistance in implementing the NIST cybersecurity framework. He is a Certified Information Systems Auditor (CISA®), and Certified in Risk and Information Systems Control (CRISC™). Adam practiced corporate law prior to joining CSS and has an extensive background in both the public and private sectors. Adam served as Assistant General Counsel at Capgemini – one of the world’s largest providers of Consulting, Technology and Outsourcing services. As in-house counsel to a global consulting business, he implemented pragmatic strategies to resolve complex legal and regulatory issues. Adam earned his B.A. from Pitzer College, his J.D. degree from UC Berkeley – Boalt Hall School of Law, and his LL.M. in Taxation from New York University School of Law. He is a member of the New York State Bar.


