In today’s edition of Daily Compliance News:
Tag: corruption
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.
In today’s edition of Daily Compliance News:
- What is ethics? Pimco and Rick Singer (WSJ)
- Big changes coming to Corporate Leniency Program? (DOJ Press Release)
- France seeks trial of former IAAF head. (Financial Times)
- Former South Africa President wants corruption charges thrown out. (Bloomberg)
In today’s edition of Daily Compliance News:
- So many myths, so little time. The FT lunches with Codruta Kövesi. (FT)
- Red flags on Trump and Kushner? I’m shocked. (New York Times)
- Government official demands he stay at his company’s hotel to visit Irish government. Is it extortion? (Washington Post)
- Compliance Week 2019 kicks off (it’s not too late to attend). (Compliance Week)
In today’s edition of Daily Compliance News:
- Four more banks named in London bribery suit. (Bloomberg)
- Can blockchain help in the fight against corruption? (World Economic Forum)
- South African President appoints new head of bribery unit. (Reuters)
- FBI targets Johnson & Johnson, Siemens, GE, Philips in Brazilian graft case. (Reuters)
In today’s edition of Daily Compliance News:
- SW Airlines not told of deactivated safety feature on Boeing 737 Max. (Wall Street Journal)
- Sexual harassment claims hit the energy industry. (I’m shocked) (Wall Street Journal)
- Welcome to my Tweet-Up, as Musk/SEC settlement twitter imbroglio. (Wall Street Journal)
- Power, corruption and duplicity in Alabama over a superfund site. (Washington Post)
APRIL 11, 2019 BY TOM FOX
In today’s edition of Daily Compliance News:
- New enforcement around Petrobras scandal ramping up. (Reuters)
- Is something is rotten at Airbus? (Reuters)
- How do you evaluate ‘Uber’ risk? (Financial Times)
- Trump Building Condo Tied to Scandal-Scarred Foreign Leader. (Financial Times)
I recently saw the performance of King Lear with Glenda Jackson as the mad king. It was a magnificent production and if you have the chance to see, I would certainly urge you to do so. The production had many interesting features and interpretations which seemed to be great entrees into several compliance topics. The play was directed by Sam Gold and it was scored by Phillip Glass but the star power was derived from Jackson as King Lear. It was a fabulous take on the story and one that will resonate directly to our turbulent times. Therefore, inspired by octogenarian Jackson and her performance, I am going to use King Lear as a deep dive into several compliance topics this week. In this episode, I want to discuss the opening scene where Lear bids his daughters express the breadth and scope of their love for him.
Lear has called a conference to divide his kingdom between his three daughters, Goneril, Regan and Cordelia, his youngest who is clearly is favorite. Goneril professes her love is more than words alone can convey, saying “A love that makes . . . speech unable / Beyond all manner of so much I love you”. Regan professes, “Myself an enemy to all other joys, Which the most precious square of sense possesses, And find I am alone felicitate in your dear Highness’ love.” However, Cordelia refuses to play the flattering fool. Her father twice gives her the opportunity to redress this decision but she holds firm saying “Nothing, my lord”. This leads to the break in the family, the deaths of the sisters and the fullest scope of tragedy.
Why do you need to engage your audience? I thought about this in the context of the Foreign Corrupt Practices Act, compliance and regime change. This is not Saddam Hussain regime change where the US government invades a country to throw out the old boss. This is a democratically elected-peaceful transfer of power. However, it now appears that regime change now means corruption investigations which impact not only the FCPA but also US companies. Every compliance officer needs to aware of this new reality. Take three recent regime changes, together with what they have meant; and perhaps one to come.
- South Africa
- Malaysia
- Brazil
- Venezuela
The bottom line is that every Chief Compliance Officer (CCO) must now watch local politics much more closely. If you are doing business in a high-risk country and there are new leaders brought in through democratically elected regime change, your company had better be ready for a robust corruption investigation. Certainly if Malaysia, South Africa and Brazil are any indication, prosecutors from nations with new regimes may well share their findings with the US Department of Justice (DOJ). This means that regime change could lead directly to a FCPA investigation, where the disclosure was by a foreign government and not the company self-disclosing. If there is no self-disclosure, a company is not eligible for the declination under the 2017 FCPA Corporate Enforcement Policy.
APRIL 9, 2019 BY TOM FOX
In today’s edition of Daily Compliance News:
- First round of guilty pleas in Varsity Blues. (Huffington Post)
- How can you tell if a company is overpaying its CEO? (MarketWatch)
- Dirty money and Scandinavian banks. (New York Times)
- Nissan shareholders erupt at annual meeting. (Wall Street Journal)
APRIL 3, 2019 BY TOM FOX
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In today’s edition of Daily Compliance News:
- Trial of ex-Malaysian PM Najib Razak to begin. (The Guardian)
- Shocked, just shocked to find out drug company pushed opioids. (NPR)
- Former Colombia official convicted of bribing government officials on behalf of Odebrecht. (Colombia Reports)
- UK’s Financial Reporting Council will examine KPMG. (Wall Street Journal)
