Tag: compliance

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Trekking Through Compliance

Trekking Through Compliance-Episode 25-Errand of Mercy

In this episode of Trekking Through Compliance, we consider the episode Errand of Mercy which aired on March 16, 1967, Star Date 3194.8.
Compliance Takeaways:

  1. In an investigation, trust but verify.
  2. If your subsidiary’s financial statements are too complicated to decipher, you have a problem.
  3. Do you know how far down your TPIs extend?
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Trekking Through Compliance

Trekking Through Compliance-Episode 24-Devil in the Dark

In this episode of Trekking Through Compliance, we consider the episode Devil in the Dark which aired on March 9, 1967, Star Date 3196.1.
Compliance Takeaways:

  1. What is your root cause analysis?
  2. Have you analyzed your internal controls from the compliance perspective?
  3. Simply because something is different doesn’t means its wrong or illegal. Is there a business justification?
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Trekking Through Compliance

Trekking Through Compliance-Episode 23-This Side of Paradise

In this episode of Trekking Through Compliance, we consider the episode This Side of Paradise which aired on March 2, 1967, Star Date 3417.3.
Compliance Takeaways:

  1. What are the unknown talents of your staff?
  2. Failure to continuously monitor can lead to disaster.
  3. What is the role of all your team members?
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FCPA Compliance Report

The Current State of Compliance – Issues and Challenges: Part 3 – Evaluation of Corporate Compliance Programs

During this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff & Phelps, the sponsor of this podcast series. We visit on the current state of compliance through the lens of recent Foreign Corrupt Practices Act (FCPA) enforcement actions and the Evaluation of Corporate Compliance Programs, 2019 Guidance, consider some of the specific issues in compliance for private equity and the increased importance of compliance in the healthcare industry. It is a comprehensive look at state of compliance at the half-year mark of 2019. In Part III, we consider the recently released Department of Justice (DOJ) 2019 Guidance and what it means for compliance professionals.
Which will be the topic of our next Podcast. For more information on Kroll, a division of Duff & Phelps, click here. For more information on Terry Orr, click here. Join us for our next episode where take a deep dive into the unique issues of Private Equity and compliance.

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Trekking Through Compliance

Trekking Through Compliance-Episode 22-Space Seed

In this episode of Trekking Through Compliance, we consider the episode Space Seed which aired on February 16, 1967, Star Date 3141.9.
Compliance Takeaways:
  1. How do you manage 3rd parties after the contract is signed?
  2. Interview questioning is as much art as science.
  3. What crisis management program do you have in place?
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Trekking Through Compliance

Trekking Through Compliance-Episode 21-Return of the Archons

In this episode of Trekking Through Compliance, we consider the episode Return of the Archons which aired on February 9, 1967, Star Date 3156.2
Compliance Takeaways:
  1. Is the Prime Directive absolute or is there room for flexibility?
  2. Groupthink can kill off a civilization or corporation.
  3. AI will always be enhanced by human interactions and interpretations.
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Trekking Through Compliance

Trekking Through Compliance-Episode 20-Court Martial

In this episode of Trekking Through Compliance, we consider the episode Court Martial which aired on February 2, 1967, Star Date 2947.3.
Compliance Takeaways:

  1. Have you tied down your documents before your investigation begins?
  2. Your investigation can change based upon facts on the ground.
  3. Never forget in a FCPA enforcement action, each lawyer represents his or her client.

 

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This Week in FCPA

Show Notes for This Week in FCPA-Episode 159, week ending June 21, 2019 – the KPMG Trainwreck and Walmart Settles edition

With KPMG in the news for one of the biggest ethical trainwrecks in recent memory (or since the last biggest ethical trainwreck-Walmart) Tom and Jay return to discuss both events some of this week’s top compliance and ethics stories which caught their collective eyes.

  1. Wal-Mart settles. Harry Cassin breaks the story for the compliance community in the FCPA Blog.
  2. The KPMG ethical trainwreck catapults off the tracks with a SEC enforcement action. Francine McKenna with the most comprehensive reporting. Tom and Matt Kelly explore in separate blog posts.
  3. What is the role of the WTO in global anti-corruption enforcement? Luciana Silveira explores.
  4. Banks behaving badly (Part 1,304,555). Swedebank suspends execs from its Estonia branch. Dominic Chopping reports in WSJ. Deutsche Bank under criminal investigation for AML violation. David Enrich, Ben Protess and William K. Rashbaum report.
  5. NAVEX Global published a first-of-its-kind ethics and compliance benchmark report. Jaclyn Jaeger reviews.
  6. What are the data security/data privacy issues from using Slack? Jim Murphy explains.
  7. Designing an ethical company is easy. So says Jeff Kaplan.
  8. Why are negligence and willfulness different standards? Greg Morvillo and Christine Handley explore.
  9. Dylan Tokar joins the WSJ Risk and Compliance Journal. See his twitter You can reach him at dylan.tokar@wsj.com.
  10. Why does one size not fit all? Jay continues his series on working with monitors.
  11. This week Tom had a special 5-part podcast series sponsored by Assent Compliance on the emerging regulatory challenges in Supply Chain management. Check out the following: Part 1-Ithe HTS Landscape; Part 2-instituting a broader Risk Management Program; Part 3– CSR value proposition; Part 4-Conflict Minerals/Responsible Minerals; Part 5-scaling up to meet challenges.  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. Tom is keynoting next week (June 28) at the University of Miami conference “Compliance Across Borders”. For information and registration click here. In Europe and want to attend a great compliance conference? Tom will be keynoting at Circle of Compliance forum on July 3 and 4 in Paris. For more information and registration, click 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.

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Trekking Through Compliance

Trekking Through Compliance-Episode 19-Tomorrow is Yesterday

In this episode of Trekking Through Compliance, we consider the episode Tomorrow is Yesterday which aired on January 26, 1967, Star Date 3113.2.
Compliance Takeaways:
  1. Sometimes unexpected developments can cause higher risk.
  2. What is your investigation protocol?
  3. How do you onboard new employees on your corporate culture?
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Everything Compliance

Everything Compliance-Episode 49-Trump Administration and Compliance, Half-Year Report, Part 2

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. In this episode, we conclude a two-part episode where we consider the Trump Administration and Compliance, Part 2. In our prior episode, Part 1 Sarah Hadden, Mike Volkov and Matt Kelly as gave their views. This episode features Jay Rosen, Jonathan Armstrong and your host, Tom Fox.
Jay Rosen considers the evolution in the DOJ’s thinking about corporate compliance programs from the Benczkowski Memo in October 2019 to the Evaluation of Corporate Compliance Programs, 2019 Guidance, issued in April 2019. Jay shouts out on those who help out.
Jonathan Armstrong discusses the wild swings in US trade policy, and the administration’s overall antipathy to the EU and UK trade regimes, data protection laws and commerce in general. Jonathan rants on British politicians whose admissions of recreational drug use could keep them from entering the US.
Tom Fox considers what the three top enforcement actions from the first half of the year tell us where DOJ enforcement may be headed. Fox rants about the petty criticism of the DOJ’s Evaluation of Corporate Compliance Programs. Fox rants on 24-hour helplines which are not working numbers.
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 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. Now it is part of C-Suite Radio.
Check out Part 1 of this two-part series here.