Tag: DOJ

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Daily Compliance News

Daily Compliance News: September 24, 2024 – The Revised ECCP Released Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network.

Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

In today’s edition of Daily Compliance News:

  • DOJ releases a 2024 update to the Evaluation of Corporate Compliance Programs. (FCPA Compliance & Ethics Blog)
  • Jackson Walker referred for disciplinary proceedings. (Reuters)
  • Singapore gears up for huge corruption trial. (Al Jazeera)
  • The UK government says flexible work is better for companies. (BBC)

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Blog

Argentieri Speech: 6 Key Takeaways for Compliance Programs

On Monday, Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. ( A copy of her remarks can be found here.) She reiterated the long-stated policy that compliance professionals play a critical role in ensuring companies comply with the law and foster a culture of ethics and integrity. She noted that the Department of Justice (DOJ) has made it clear that companies are the first line of defense against corporate crime, and compliance officers are on the front lines of this defense. The 2024 update to the DOJ’s Evaluation of Corporate Compliance Programs (ECCP) and the introduction of new pilot programs in 2024 underscore the increasing importance of the roles of compliance professionals. This blog post will review the highlights from her speech, the key lessons from this 2024 update to the ECCP, and how they should shape our approach to compliance programs in our organizations.

Lesson 1: Embrace Continuous Improvement in Compliance Programs

The DOJ’s emphasis on continuous improvement in compliance programs is a call to action for all of us. The updated ECCP highlights the need for companies to regularly review and update their compliance programs to account for emerging risks, such as those posed by disruptive technologies like artificial intelligence (AI). As the pace of technological advancement is rapid, and with it come new risks. AI, for example, can be a double-edged sword—while it offers efficiency and insights, it can also be exploited for fraudulent purposes, such as generating false documentation or approvals. The DOJ now explicitly expects companies to assess and manage these risks, which means we must stay ahead of the curve in understanding and mitigating the potential pitfalls of new technologies.

Action Steps for the Compliance Professional:

  • Conduct regular risk assessments that include emerging technologies.
  • Implement controls that address the risks associated with AI and other disruptive technologies.
  • Ensure your compliance program evolves alongside technological advancements with continuous testing and monitoring.

Lesson 2: Foster a “Speak Up” Culture

The DOJ’s updates to the ECCP also emphasize encouraging a culture where employees feel comfortable reporting misconduct. The newly integrated questions into the ECCP regarding whistleblower protection reflect the DOJ’s serious stance on this issue. A “speak up” culture is foundational to a strong compliance program. Employees on the ground are often the first to spot potential issues, and creating an environment where they feel safe to report without fear of retaliation is crucial. The DOJ will scrutinize how well companies protect whistleblowers, so we must ensure our organizations have robust policies and training.

Action Steps for the Compliance Professional:

  • Review and strengthen whistleblower protection policies.
  • Regularly train employees on reporting misconduct and reassuring them about the protections in place.
  • Monitor the effectiveness of your whistleblower program and make necessary adjustments to enhance reporting mechanisms.

Lesson 3: Data Access is Key to Compliance Effectiveness

Another critical area highlighted in the DOJ’s ECCP updates is the importance of data access for compliance personnel. The DOJ will now evaluate whether compliance teams have adequate access to the necessary data to assess the effectiveness of their programs.

Over the past 18 months, the DOJ has made it clear that accessing and analyzing relevant data is crucial for identifying risks and monitoring compliance. If compliance teams are siloed or cut off from important data sources, it hampers their ability to do their jobs effectively, and the DOJ will take notice.

Action Steps for the Compliance Professional:

  • Ensure that compliance personnel have access to all relevant data sources.
  • Invest in the necessary technology and resources for effective data analysis and monitoring.
  • Work closely with IT and other departments to break down silos and facilitate seamless data access.

Lesson 4: Leverage Compensation to Drive Compliance

The DOJ’s Compensation Incentives and Clawbacks Pilot Program introduced a new dimension to compliance—aligning compensation with ethical behavior. This initiative requires companies to include compliance-related criteria in their compensation and bonus systems. While it is certainly not new to align compensation with compliance goals, it sends a powerful message to employees and management that ethical behavior is non-negotiable, and the new emphasis on consequences in the form of clawbacks and holdbacks must be considered. The DOJ views this leveraging of positive incentives and negative outcomes as a tangible link between individual performance and the company’s commitment to integrity.

Action Steps for the Compliance Professional:

  • Integrate compliance metrics into performance evaluations and compensation structures.
  • Regularly assess the effectiveness of these incentives and make adjustments as needed.
  • Make sure you have the contractual right to clawback incentive awards or holdback bonuses for executives who are culpable or have buried their collective heads in the sand while corruption surrounds them.

Lesson 5: The Importance of Cooperation and Remediation

The DOJ’s approach to corporate resolutions underscores the importance of timely and effective cooperation and remediation. Companies that act quickly to cooperate with the DOJ and take meaningful steps to remediate misconduct are rewarded with significant penalty reductions. How a company responds can significantly affect the outcome in the unfortunate event of misconduct. The DOJ’s recent resolutions show that companies that move swiftly and decisively to address issues are viewed more favorably.

Action Steps for the Compliance Professional:

  • Develop a clear protocol for responding to potential misconduct, including timely self-disclosure to the DOJ.
  • Ensure that your company is prepared to cooperate fully with any investigation.
  • Focus on meaningful remediation efforts that address the root causes of misconduct and prevent future occurrences.

Lesson 6: Whistleblower Programs as a Strategic Tool

Launching the DOJ’s Corporate Whistleblower Awards Pilot Program (CWA) is a significant development for compliance professionals. This program incentivizes internal reporting and substantially rewards companies that self-disclose misconduct. Given the number of reports the DOJ received in its first month (100), the CWA adds a new layer of urgency for companies to establish strong internal reporting mechanisms. Companies that encourage and protect whistleblowers can benefit from the CWA, while those that fail to do so may face harsher penalties.

Action Steps for the Compliance Professional:

  • Strengthen your internal reporting systems and ensure they are well-publicized within the company.
  • Make sure that your whistleblower policies are aligned with the DOJ’s expectations.
  • Actively monitor and protect whistleblowers, ensuring there is no retaliation against those who report misconduct.

Now is the Time to Act

The DOJ’s updated policies and programs signal that corporate compliance expectations are higher than ever. Compliance professionals must take these developments seriously and use them as a roadmap to strengthen our programs. Do not wait. Whether embracing new technologies, fostering a “speak up” culture, or aligning compensation with ethical behavior, now is the time to make the necessary investments in compliance.

Remember, when misconduct does occur, it’s better to be proactive and call the DOJ before they call you. By taking these lessons to heart and implementing them in our organizations, we can meet the DOJ’s expectations and contribute to building a culture of integrity and accountability that will serve our companies well in the long run.

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FCPA Compliance Report

FCPA Compliance Report: Spotlight on Executive at Risk: Latest Updates on The DOJ, OFAC, FCPA, and AML

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this edition of the FCPA Compliance Report, Tom welcomes back Miller & Chevalier attorneys Executives at Risk team, including Lauren Briggerman, Katherine Pappas, Ian Herbert, and their newest colleague Laura Deegan.

We dive into key compliance and enforcement topics such as the new DOJ whistleblower initiative, recent OFAC sanctions and export controls, key FCPA enforcement actions focusing on individual liability, and notable AML developments, particularly within the cryptocurrency sector. The discussion highlights the evolving landscape of corporate compliance and the increased need for robust internal reporting and proactive compliance measures.

Highlights in this Episode:

  • DOJ Whistleblower Initiative
  • OFAC Sanctions and Export Controls
  • FCPA Enforcement Actions and Developments
  • AML Developments and Binance Case

 

Resources:

Miller & Chevalier Chartered

Lauren Briggerman

Katherine Pappas

Ian Herbert

Laura Deegan

Executives at Risk, Summer 2024

Tom Fox

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Compliance Into the Weeds

Compliance into the Weeds: The BCG Declination – Key Insights for Compliance

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the recent Department of Justice (DOJ) declination for the Boston Consulting Group (BCG).

They highlight why this case garnered significant attention and dissect the substantive actions BCG took to avoid prosecution, including firing implicated employees and forcing equity forfeiture. The duo also explores the seven factors that led to the declination, such as timely self-reporting, full cooperation, and improved compliance measures. The episode provides a comprehensive analysis of the BCG case, offering crucial takeaways for compliance officers on how to handle potential corruption issues and DOJ expectations.

Key Highlights:

  • Overview of the Boston Consulting Group Declination
  • DOJ’s Factors for Declination
  • Full Cooperation, Timely Self-Disclosure and Employee Consequences
  • Remediation Efforts and Compliance Improvements

Resources:

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Tom 

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Blog

The Boston Consulting Group Declination: A Money Shot for Clawbacks

In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign Corrupt Practices Act (FCPA). Despite evidence of bribery involving BCG’s operations in Angola, the decision to forgo prosecution serves as a powerful reminder of the critical role that timely self-disclosure, cooperation, and effective remediation play in navigating the complexities of corporate compliance and, most significantly, clawbacks play in a decision to decline to prosecute. The decision was made public via a letter from the DOJ to BCG.

Between 2011 and 2017, BCG’s Lisbon, Portugal office engaged in a scheme to secure business contracts with Angolan government agencies, including the Ministry of Economy (MINEC) and the National Bank of Angola (BNA). BCG funneled approximately $4.3 million in commissions to an agent with close ties to Angolan government officials. These payments, made through offshore entities, helped BCG secure twelve contracts, resulting in revenues of $22.5 million and profits of $14.424 million.

The misconduct was serious: BCG employees in Portugal were aware of the agent’s ties to government officials and took deliberate steps to conceal the true nature of the agent’s work. This included backdating contracts and falsifying documents to cover up the corrupt activities. Such actions violated the FCPA, which prohibits U.S. companies from engaging in bribery of foreign officials to secure business advantages.

The money shot in this Declination was in the area of clawbacks. In the Wall Street Journal  (WSJ), Dylan Tokar wrote, “The consulting group’s disciplinary actions come amid pressure on companies by Justice Department officials to clawback compensation from employees involved in wrongdoing. Officials have said they want to shift the burden of penalties for corporate misconduct to those most responsible.” Mary Shirley, quoted by Tokar in the same article, noted, “That’s a strong message. While they’re not stated, the actual figures involved for individuals could be quite high.”

In his Radical Compliance piece on the Declination, Matt Kelly emphasized Shirley’s point: “That final point on surrendering equity — wow. That’s a punitive measure with real bite. Not only has BCG damaged the offenders’ future employment prospects by firing them and leaving a black mark on their records, but the loss of equity is a wallop to all their past employment with the firm. I have no idea how much that equity might have been worth, but BCG is a giant and prosperous business, so it’s entirely possible those offenders just lost millions of dollars.”

Given the severity of the misconduct, the DOJ’s decision to decline prosecution may seem surprising at first glance. However, more conduct was conducted by BSG after discovering the illegal conduct, which led to this superior result. The decline reveals that BCG’s response to finding the potential FCPA violation was exemplary, and equally importantly, it aligned with the DOJ’s Corporate Enforcement and Voluntary Self-Disclosure Policy. These factors included:

  • Timely and Voluntary Self-Disclosure: In a 2014 email, BCG uncovered evidence of the potential FCPA violation and promptly disclosed the misconduct to the DOJ. This proactive step is crucial in the DOJ’s assessment of whether to pursue prosecution, as it demonstrates the company’s commitment to transparency and accountability.
  • Full and Proactive Cooperation: BCG did not merely disclose the misconduct; the company fully cooperated with the DOJ’s investigation. This included providing all relevant facts, including information about the individuals involved in the bribery scheme. Cooperation of this magnitude significantly mitigates the risk of prosecution, as it aids the government in its investigation and potential prosecutions of individuals responsible for the wrongdoing.
  • Comprehensive Remediation: BCG’s response to the misconduct was swift and decisive. The company terminated the personnel involved, imposed compensation-based penalties, and required implicated partners to forfeit their equity in the company. BCG also denied these individuals the financial transitions typically accorded to departing employees, underscoring the seriousness of the misconduct.
  • Significant Compliance Improvements: Beyond addressing the immediate issue, BCG substantially enhanced its compliance program and internal controls. These improvements included formalized employee training, vendor and client screening protocols, and the establishment of local and global risk committees. Such measures demonstrate BCG’s commitment to preventing future misconduct and fostering a culture of compliance.
  • Absence of Aggravating Factors: The DOJ’s decision was also influenced by the absence of certain aggravating factors, such as executive management’s involvement in the misconduct, significant profit relative to the company’s size, or a history of criminal recidivism. These factors often weigh heavily in the decision to prosecute, but in BCG’s case, their absence worked in the company’s favor.
  • Disgorgement of Ill-Gotten Gains: BCG agreed to disgorge $14.424 million, representing the profits from the contracts secured through the corrupt scheme. This financial penalty further reinforced BCG’s commitment to addressing the consequences of its actions and aligning with legal and ethical standards.

The BCG case offers several critical lessons for compliance professionals. First and foremost, the importance of timely and voluntary self-disclosure cannot be overstated. When a company discovers potential misconduct, promptly bringing it to the authorities’ attention can significantly influence the outcome, potentially leading to a declination of prosecution.

Full cooperation with government investigations is essential. Compliance teams must be prepared to provide all relevant information, facilitate interviews, and support the investigation process. This cooperation demonstrates the company’s commitment to addressing the issue and helps build a collaborative relationship with the authorities.

Remediation is another crucial aspect. Companies must swiftly and meaningfully address the root causes of misconduct, including holding individuals accountable and implementing robust compliance measures to prevent future violations. A strong compliance program, reinforced by ongoing training and risk assessment, is vital in demonstrating a company’s commitment to ethical business practices.

Finally, the BCG case underscores the importance of avoiding aggravating factors. Companies should strive to cultivate a culture of integrity from the top down, ensuring compliance is embedded in every aspect of the organization. By doing so, they can reduce the likelihood of misconduct occurring in the first place and mitigate the impact if it does.

The DOJ’s decision to decline BCG’s prosecution is a powerful reminder of the value of self-disclosure, cooperation, and remediation in corporate compliance. For compliance professionals, the BCG case highlights the critical role they play in guiding their organizations through complex legal and ethical challenges. By fostering a culture of compliance, responding proactively to potential issues, and working closely with authorities, companies can navigate the difficult terrain of regulatory enforcement while upholding their commitment to ethical business practices.

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Daily Compliance News

Daily Compliance News: August 16, 2024 – The All Law360 Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network.

Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

In today’s edition of Daily Compliance News:

  • DOJ defends itself from Boeing victims’ families’ objections. (Law360)
  • Missouri anti-ESG rules for financial advisors are illegal. (Law360)
  • How to keep layoffs from going viral. (Law360)
  • Overstock Ex-CEO attorney DQ’d from the case. (Law360)

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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FCPA Compliance Report

FCPA Compliance Report: Exploring DOJ’s New Whistleblower Incentive Program with Mary Inman

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox welcomes back Mary Inman, Partner at Whistleblower Partners LLC, to discuss the new DOJ Whistleblower Incentive Program.

Tom and Mary discuss the DOJ’s New Whistleblower Incentive Program’s aim to fill gaps in existing reward programs and its focus areas, including financial institution violations, foreign and domestic corruption, and healthcare offenses. Mary highlights some criticisms of the program, such as lack of a reward floor and the cap on rewards, and the potential challenges and impacts on corporate compliance. They also talk about the interplay between whistleblowers, DOJ, and corporate investigations, and the potential for adaptation of the program based on stakeholder feedback.

Highlights in this Episode:

  • DOJ Whistleblower Incentive Program Overview
  • Four Focus Areas of the New Program
  • Challenges and Criticisms of the Program
  • Concerns About Reward Mechanisms
  • Race to DOJ: Whistleblowers vs. Corporations
  • Implications for Corporate Compliance

Resources:

Mary Inman on LinkedIn

Whistleblower Partners

Tom Fox

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Compliance Into the Weeds

Compliance into the Weeds: The DOJ Whistleblower Incentive Program

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the recently announced Department of Justice (DOJ) Whistleblower Incentive Program.

Last week, the DOJ announced a whistleblower pilot program, offering monetary rewards to whistleblowers who report corporate misconduct. Whistleblowers can receive up to 30% of the net proceeds of a settlement resulting from their tip. The program covers various types of corporate crime, including bribery, healthcare fraud, and Foreign Corrupt Practices Act (FCPA) violations.

This program puts pressure on compliance programs to quickly investigate and address reported misconduct. It also raises questions about how whistleblowers will be rewarded in cases where there is a declination or non-prosecution agreement. The SEC case involving a whistleblower award highlights the importance of handling whistleblower reports effectively.

Key Highlights:

  • DOJ Announces Whistleblower Pilot Program
  • Covering Various Types of Corporate Misconduct
  • Tension Between Self-Reporting and Whistleblower Reporting
  • Recent SEC whistleblower award as a cautionary tale

Resources:

Matt in Radical Compliance 

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DOJ Whistleblower Pilot Program: Transforming the Compliance Landscape

In a world where corporate integrity and accountability are more crucial than ever, the Department of Justice (DOJ) ‘s Whistleblower Pilot Program announcement marks a pivotal moment for compliance professionals. This initiative promises to reshape how we approach whistleblowing, corporate misconduct, and organizational culture. Let’s dive into the details and implications of this program, focusing on how it impacts compliance officers, whistleblowers, and corporate governance.

Deputy Attorney General Lisa Monaco said of the Whistleblower Pilot Program, “With this program, we’re doubling down on a proven strategy to ferret out criminal activity that might otherwise go unreported. Law enforcement has long offered rewards to coax tipsters to report crimes — from the “Wanted” posters of the Old West to the reforms in Dodd-Frank that created whistleblower programs at the SEC and the CFTC.” However, she cautioned, “those programs — by their very nature — are limited in scope. They only cover misconduct within those agencies’ jurisdictions. The same is true for similar programs run by the IRS and FinCEN. And qui tam actions, which offer whistleblowing incentives, are available only for fraud against the government.” The DOJ “corporate enforcement program is rooted in using carrots and sticks. Today’s announcement builds on our other efforts to incentivize reporting of corporate misconduct to the government.” Part of those carrots is to reward those “under these disclosure programs — both our corporate voluntary self-disclosure programs and the whistleblower initiative we’re announcing today — you have to tell us something we didn’t already know. With few exceptions, you must be first in the door.”

The Whistleblower Pilot Program incentivizes individuals to report corporate misconduct directly to the authorities. It offers financial rewards similar to existing programs at agencies like the Securities and Exchange Commission (SEC). Under the Whistleblower Pilot Program, whistleblowers are now eligible for a financial award. The award may be up to 30% of the first $100 million in net proceeds forfeited and up to 5% of any net proceeds forfeited between $100 million and $500 million. This framework encourages individuals to come forward with information about corporate wrongdoing, particularly in areas such as the Foreign Extortion Prevention Act (FEPA) and the Foreign Corrupt Practices Act (FCPA).

From the whistleblower’s perspective, the Whistleblower Pilot Program provides a powerful incentive to report misconduct. The promise of financial rewards and legal protections can motivate individuals who might otherwise fear retaliation or lack confidence in their employer’s internal reporting mechanisms. The program is designed to cover various types of corporate crime, ensuring that potential whistleblowers have a direct channel to report wrongdoing, even when internal channels might fail.

For compliance officers, the Whistleblower Pilot Program introduces new dynamics into the compliance landscape. On the one hand, it underscores the importance of robust internal compliance programs that can effectively handle whistleblower reports. On the other hand, it creates potential challenges, as employees might need help to bypass internal reporting mechanisms in favor of direct reporting to the DOJ, mainly when financial incentives are involved. The Whistleblower Pilot Program raises an interesting dilemma for compliance officers and corporate management: How do you maintain a solid internal reporting culture when employees have a lucrative alternative in external reporting?

The answer lies in strengthening internal reporting mechanisms and fostering a culture of trust and transparency. Companies must ensure that their whistleblower hotlines and reporting channels are accessible, confidential, and effective. Employees should feel confident that their reports will be taken seriously and addressed promptly without fear of retaliation. It also reiterates that investing in anti-retaliation training and policies is crucial. Employees must know that the organization values their input and that speaking up will have no negative consequences. Training managers and supervisors to handle reports sensitively and ensuring that whistleblowers receive feedback on the status of their reports can reinforce this trust.

With the potential for whistleblowers to report externally, companies must act quickly and decisively when handling internal reports. The Whistleblower Pilot Program highlights the need for efficient triage and investigation processes to swiftly assess and address misconduct allegations. This requires clear protocols and collaboration among compliance, legal, and HR departments to ensure timely resolutions.

The Whistleblower Pilot Program also addresses the tension between whistleblower reports and voluntary self-disclosure by companies. The DOJ has adjusted its policies to allow companies to receive credit for voluntary self-disclosure, even if a whistleblower has already reported the matter to the authorities. However, this requires that companies disclose the misconduct within 120 days of the internal report. This adjustment emphasizes the importance of timely action and reinforces the value of self-reporting as part of an effective compliance program.

The recent SEC whistleblower award case is a cautionary tale for companies navigating this new landscape. In this case, a whistleblower who reported misconduct internally was ignored, leading them to report the issue to the SEC. The company eventually self-disclosed but lacked cooperation, highlighting the risks of inadequate internal handling of whistleblower reports. This scenario underscores the need for companies to take internal reports seriously and proactively investigate and address issues before they escalate externally.

The Whistleblower Pilot Program reinforces organizations’ need for a robust speak-up culture. Compliance officers play a crucial role in fostering this culture by promoting open communication, ensuring that employees understand the importance of reporting misconduct, and providing them with the tools and support they need to do so safely.

Compliance officers must also engage senior management and the board of directors to ensure alignment on the importance of a strong compliance culture. This includes advocating for the necessary resources and support to maintain effective reporting mechanisms and demonstrating the value of proactive compliance efforts in mitigating risks and enhancing corporate reputation.

Compliance officers must continuously assess and improve their programs in this evolving landscape. This includes staying informed about regulatory developments, analyzing whistleblower reports to identify trends and areas for improvement, and adapting strategies to address emerging risks and challenges. The Whistleblower Pilot Program marks a significant step in promoting corporate accountability and transparency. It presents challenges and opportunities for compliance professionals to strengthen internal programs and foster a culture of integrity. By prioritizing trust, transparency, and effective reporting mechanisms, companies can successfully navigate this new era, ensuring they are well-prepared to address misconduct and protect their reputations. As compliance officers, embracing these changes and championing a culture of accountability will be key to thriving in this dynamic environment.

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FCPA Compliance Report

FCPA Compliance Report: The Boeing Plea Agreement – Culture is The Key

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. We take things in a different direction today as Tom Fox reposts the recent webinar with Sam Silverstein and Mike Volkov, where we took a deep dive into the Boeing Plea Agreement, the Monitorship, and why culture is the key to a Boeing turnaround.

We explore the recent plea agreement filed by Boeing, the outrage among victims’ families over the proposed penalties, and the appointment of an independent compliance monitor. Key issues discussed include the necessity of a culture overhaul at Boeing, the implications of excluding court jurisdiction over the monitorship, and the role of the board in fostering a culture of compliance and safety. The discussion highlights the critical need to focus on values, accountability, and transparent processes to rebuild trust and ensure long-term organizational integrity.

Highlights of this episode:

  • Details of the Plea Agreement
  • Compliance Monitor Appointment and Transparency
  • The Importance of Culture
  • The Role of Compliance Monitors
  • Board Involvement and Accountability
  • Victims’ Families and Organizational Accountability

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Sam Silverstein

Mike Volkov

The Culture Audit

Tom Fox

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