In today’s edition of Daily Compliance News:
Tag: compliance
Highlights include:
- Have you checked out the new OFAC compliance program? If not see Mike Volkov’s 5-part series on Corruption, Crime and Compliance. (Part 1, Part 2, Part 3, Part 4) For those who prefer the podcast format, you can list to his podcast on the topic here.
- Hui Chen and Pam Davis weigh in on the 2019 DOF FCPA Guidance. In Bloomberg.
- Noose tighten around Credit Suisse and Privinvest in Mozambique tuna boat scandal? Rick Messick explores in Global Anti-Corruption
- What are the compliance lessons from a messy and very public food fight? Matt Kelly explores in two postings on Radical Compliance. (hereand here)
- How does scape-goating come into play in cross-border anti-corruption enforcement? Laurent Cohen-Tanugi discusses on NYU’s Compliance and Enforcement Blog.
- Jay continues his exploration of using a monitor, in his Corporate Compliance Insights
- What do dawn raids have in common with fires (at least in the UK)? Barry Vitou explores on com.
- Is Equifax about to settle for its massive data breach? Jon Rusch explores on Dipping Through Geometries.
- Why should compliance training start with a smile? Ronnie Feldman explains on Corporate Compliance Insights.
- What are the compliance lessons for hospitality around major sporting events? Tom explores in a white paper on Corporate Compliance Insights.
- This week Tom had a special 5-part podcast series sponsored by Assent Compliance on the issue of maintaining market access. Check out the following: Part 1-Introduction to Market Access; Part 2-Trade Compliance; Part 3– Continuous Monitoring; Part 4-FARs and flow downs; Part 5-Chemical and Product Compliance. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTube, Spotifyand Corporate Compliance Insights. The Compliance Podcast Network
- 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.
On this episode of Great Women in Compliance, Lisa Fine speaks with Stacey Hanna, General Counsel, Ethics & Compliance at Lonza, which is an integrated solutions provider in the areas of pharma and biotech, and is headquartered in Switzerland. While Stacey started as an attorney, she was in the mergers and acquisition world, and how this influences her approach to ethics and compliance. She discusses the evolution of her organization’s compliance program and how she works to promote business growth, discussing some real-life examples and strategies to build relationships as a compliance officer. Stacey also discusses evolution in other areas, including work and life complimenting one another and in the compliance space as a whole.
In today’s edition of Daily Compliance News:
- What is data security? Ask Jonathan Armstrong. (Financial Times)
- Uber tanks at IPO opening. What did compliance have to do with it? (WSJ)
- SEC Thursday fined Telefônica Brasil S.A. $4.125MM for World Cup tickets. (FCPABlog)
- What to do when the boss tells you to lie to the feds? Ask Don McGahn. (New York Times)
Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Armstrong and our newest colleague, Sarah Hadden. We take on one topic which the panelist explores from their expertise. The topic is the Justice Department’s Evaluation of Corporate Compliance Programs-2019 Guidance which was recently released.
- Sarah Hadden puts on her journalist hat to consider the 2019 Guidance in the context of transparency by DOJ in releasing this information critical for compliance going forward. Sarah rants on all those in the Everything Compliance gang who attended the ECI Impact 2019 conference in her hometown of Dallas and did not reach out to connect with her. (And we know who we are)
- Matt Kelly considers some different questions such as: Is there anything new? Does it mean any difference in practice? Is it simply a way to wipe out one of the core legacies of Hui Chen? Matt rants on the Trump Administration which said only a couple of weeks ago said it was cracking down on Agency and Department Guidance and literally turns around and issues the 2019 Guidance. Which is it guys?
- Jay Rosen discuss the original Benczkowski Memo as a precursor to the new 2019 Guidance and how the Benczkowski Memo lays out a roadmap to avoid a monitor by using pro-active assessments. Jay shouts out to the Boston Red Sox for reaching .500. (Matt chastises Jay for now jinxing the Sox)
- Mike Volkov discusses how the Justice Department is using the state of compliance programs not only at time of violation but also at time of conclusion to reward companies with lower penalties. Mike shouts out to both Brian Benczkowski/DOJ for this new FCPA Compliance Guidance and the Department of Treasury for OFAC guidance around money-laundering and trade sanctions compliance programs.
- Jonathan Armstrong compares and contrasts the 2019 Guidance document with the information released by SFO on compliance programs. He then considers what a ‘good’ compliance program looks like in his search for a ‘good’ recipe for the perfect Tikka Masala. He rants about the first UK data privacy regulatory action under GDPR, where the UK data protection agency sanctioned the UK government for violation of GDPR.
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–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.
In today’s edition of Daily Compliance News:
- Regulatory capture, regulatory ineptitude or just don’t care? (Washington Post)
- 1MDB diamonds headed to US. (Reuters)
- Boeing knew about safety issue for 1 year before informing FAA. (Wall Street Journal)
- Why compliance needs a seat at the grown-ups table. (Wall Street Journal)
In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 3, we consider many CECO’s concern that Boards do not dedicate sufficient time and priority to compliance nor go into sufficient depth into compliance programs and potential outcomes . Some of the highlights from the podcast include:
- Why don’t Boards put in more time around E&C programs?
- Why is compliance often the last item on the Board agenda and equally as often, left off for later?
- CECOs want to be challenged by their Boards but often are not.
- Does your Board have a compliance game plan?
- Why don’t BODs go deeper into E&C programs? How would they do so?
- Are Boards even asking the right questions?
Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.
Over this special 5-part podcast series, I have visited with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In this fifth and final episode, we look at the road ahead. The White Paper stated, “Over time, the gulf between CECOs and boards should be bridgeable. We believe the bridge should be built quickly. The sooner that CECOs have the board’s ear – and that directors are fully aware of what CECOs and the initiatives they lead can bring to the table –the stronger and more resilient their companies will be.
Some of the highlights from the podcast include:
- What practical steps should be taken to engage the board more actively and effectively in ethics and compliance oversight?
- More time, higher priority, stronger signals from boards in ethics and compliance oversight.
- Boards need to question whether ethics and compliance are genuinely integral to business operations.
- Elevate the CECO and establish direct and confidential reporting lines?
- What lays on the road ahead?
Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.
In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 2, we consider the average Board of Director’s knowledge of compliance and your game plan going forward. Some of the highlights from the podcast include:
- Why don’t Boards have a better understanding of the compliance function within their organization?
- Why do BOD’s have such little knowledge of the CECO role?
- Why does the BOD tend to focus on what has passed rather forward looking?
- Does your Board have a compliance game plan?
- Why does a BOD need to develop a framework for discussing, evaluating, and measuring ethics and compliance?
- Why should BODs relate ethics and compliance to their companies’ core strategy and be able to have a sufficient point of view to guide and oversee it?
Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.
In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We are taking a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 4, we look metrics which a BOD should consider and how a Board should oversee senior management around ethics, compliance and culture.
Some of the highlights from the podcast include:
- CECOs want their boards will send stronger signals to executive management about the importance of embedding ethics and compliance in the company’s business.
- CECOs want boards to hold management more accountable for ethics and compliance
- A BOD should ask management ‘What have you done to assure compliance. Show me.’
- Why should a Board be concerned about metrics around culture?
- What measures should a Board employ for culture and ethics?
Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.
