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FCPA Compliance Report

Eric Young on the Evolution of the CCO

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this special episode, I am joined by Eric Young from Guidepost Solutions. Young has worked at prestigious institutions like JPMorgan, General Electric, S&P Global Ratings, and BNP Paribas. He shares his expertise to empower employees looking to move ahead with processes, find solutions, and navigate compliance issues.

Tom and Eric talk about the highlights of the Monaco Memo, updates on the Corporate Enforcement Policy, a case study from ABB to showcase the role of the CCO, and how firms should interpret Department of Justice speeches. He further dives into the corporate culture, accountability, and role of the CCO within an organization. Finally, Eric sheds light on a case from McDonald’s involving the former CEO and their decision to claw back compensation. The discussion concluded with acknowledging the Delaware court’s holding that elevates the CCO’s corporate duties.

Key Topics:

[00:04:24] Process Improvement to Avoid Violations and Effect Positive Change in Company Culture

[00:09:19] The Effects of the Monaco Memorandum on Corporate Compliance Practice

[00:14:35] ABB’s Impressive Performance During an Investigation and Remediation Period

[00:18:42] The C-suite’s Responsibility in Organizations

[00:23:21] The Impact of Experiences on Assessing Business Decisions

[00:28:05] The SEC Inquiry on McDonald’s precipitated by Steve Easterbrook’s Removal

[00:32:24] The Significance of Delaware Courts in Regards to Corporate Law

[00:37:13] The Functions of Corporate Boards During Times of Crisis.

Tune in and listen to Eric as he educates us about the need to report extraordinary circumstances to the Department of Justice

 Resources:

Connect with Tom Fox

●      LinkedIn

Connect with Eric Young

●      Guidepost Solutions

●      LinkedIn

Categories
The Ethics Experts

Episode 075 – Eric Young

In this episode of The Ethics Experts, Nick welcomes Eric Young, adjunct professor of compliance at Fordham University School of Law and author of “Declaration of Independence-How Compliance and the Board Can Hold Management More Accountable,” to the show.

Categories
The Compliance Handbook

The Compliance Handbook – The Evolution of Controls with Eric Young


Effective controls are the lifeblood of what makes a compliance program work. In today’s episode of The Compliance Podcast, Thomas Fox sits down with for Global Chief Compliance Officer Eric Young and talks about internal controls, how human conscience overrides technology, and emphasizing the long-term benefits of running clean organizations in the compliance space.
Major takeaways discussed in the episode:

  • From financial institutions to public corporations — understand that compliance & ethics bridges enterprise risk management and a system of internal controls, including internal accounting controls. It also is the fabric that cuts across the E-S-G, which is not yet viewed enough this way.
  • Know that an effective system of internal controls is about people, processes, and technology. People are the most important of the three because, without people, functions won’t be clearly defined and assigned. Technology accelerates the flawed processes, gaps, and weaknesses leading to loss of data integrity and controls.
  •  The COVID-19 pandemic has created a shift and has become an important opportunity for compliance to be the drivers of ethics and to stand as owners of the code to shape the behavior of corporations, not just focusing on maximizing profits but responsibly safeguarding employees
  • Be constantly reminded that a robust set of controls can be the backbone for financial management, but compliance and ethics can help a company build more efficient business process systems.

Connect with Eric Young
A compliance practitioner for 40 years, Eric re-engineers & advises firms on how Compliance, Ethics, Conduct, and RegTech programs can enable safe, healthy, sustainable growth.
LinkedIn: linkedin.com/in/youngerict
The Compliance Handbook 
Thomas Fox, the Compliance Evangelist®, is one of the leading writers, thinkers, and commentators on anti-bribery and anti-corruption compliance. In this latest edition of The Compliance Handbook, he continues to arm seasoned compliance professionals and those new to the realm with the practical, actionable guidance and tools needed to design, create, implement and continually enhance a best practices compliance program.
The “Nuts and Bolts” for Creating a Comprehensive Compliance Plan
This chapter of this unique work lays out a succinct yet thorough one-month approach to operationalizing a company’s compliance regimen. Beginning with a section on what 2020 brought to the compliance landscape, each chapter methodically outlines best practices for everything from establishing policies, procedures, and internal controls, to assessing risk, training, handling investigations, and more. Each day ends with three key takeaways you can implement at little or no cost.
Understanding Compliance Responsibility Across the Organization
The Compliance Handbook also takes a close look at all professionals’ roles with compliance responsibility, from Compliance Officers and Boards of Directors to Human Resources, to Internal Audit and Internal Controls and Communications and Training professionals.
In-Depth Treatment of Hot Topics and Trends
The Handbook provides an in-depth look at the latest thinking and trends for the full range of critical compliance topics, including:

  • Compliance and business ventures
  • Third-party risk management
  • The Board’s Role in Compliance
  • Continuous improvement
  • Compliance innovation
  • And much more

Incorporating Current Government Pronouncements
The Second Edition incorporates the most current government pronouncements governing best practices compliance programs, including the 2019 Evaluation of Corporate Compliance Programs released by the Fraud Section of the Department of Justice, and its 2020 Update; the updated FCPA Resource Guide 2nd edition; the Framework for OFAC Compliance Commitments; and the 2019 DOJ Antitrust Division’s Evaluation of Corporate Compliance Programs in Criminal Antitrust.
eBooks, CDs, downloadable content, and software purchases are non-cancellable, non-refundable, and non-returnable. Click here for more information about LexisNexis eBooks. The eBook versions of this title may feature links to Lexis + for further legal research options. A valid subscription to Lexis + is required to access this content.
Order your copy OR copies of The Compliance Handbook: A Guide to Operationalizing Your Compliance Program. Save 25% off.
http://www.lexisnexis.com/fox25

Categories
FCPA Compliance Report

Eric Young on Key Compliance & Enforcement Changes 2010 to 2020


In this episode, I am joined by Eric Young, recently retired long-time compliance professional. In a continuing series on the FCPA Compliance Report, Eric joins me to explore some of the key changes he observed in compliance and enforcement in the financial industry over the decade of 2010 to 2020.
Some of the highlights include:

  • Greater and more visibility of bribery and corruption enforcement, particularly by the SEC against financial institutions.
  • Much lower regulator tolerance for poor data governance, self-governance and self-regulation.
  • An AML compliance program is a microcosm of what an enterprise-wide corporate compliance program should look like.

Resources
Eric Young on LinkedIn

Categories
FCPA Compliance Report

Eric Young on the Fed and DFS Components of the Goldman Sachs Corruption Enforcement


In this episode, I am joined by Eric Young, recently retired long-time compliance professional. We explore an under-looked aspect of the Goldman Sachs FCPA enforcement action; the independent enforcement actions by the Federal Reserve Bank and state of New York’s Department of Financial Services.
Some of the highlights include:

  • Why was the Fed involved in the Goldman Sachs FCPA resolution?
  • The Fed Order seemed critical of Goldman Sachs compliance function. Do you find this criticism warranted?
  • Is the ongoing oversight of the Fed typical for this type of case?
  • Why was the state the New York DFS involved in the Goldman Sachs FCPA resolution?
  • What were the separate reporting obligations of the Goldman Sachs compliance function discussed in the DFS Order? Do such obligations exist at the federal level?
  • Were the dates, timing and amounts of these 3 bond offerings red flags?
  • Were the money laundering allegations in funding equally as troubling as the bribery and corruption? 

Resources
Federal Reserve Cease and Desist Order
State of New York, Department of Financial Services Consent Order

Categories
FCPA Compliance Report

Eric Young on the Plumbing and Wiring of Compliance


In the Episode, I am joined by Eric Young. Eric has been in the compliance field longer than anyone I know and long before it was called Compliance. Eric graduated from Columbia University at the age of 20, with a degree in Economics and has securities licenses with FINRA and is ACAMS-certified. He started with the Fed in 1980 and has 40 years’ regulatory and Chief Compliance Officer experience with the Fed, JP Morgan Chase, General Electric, S&P Global Ratings, and four foreign banks including UBS and most recently, as CCO of BNP Paribas.
Some of the highlights include:
Young has been in compliance longer than anyone I know. He gives us a rundown of his professional career starting with the Fed.
Penn Square. At the time it was the largest bank failure since the Great Depression. What was the significance of Penn Square for the US banking industry and the regulators?
What are the three things Young is most proud of accomplishing in his career?
What are 3 pieces of advice Young would give a new CCO today?
Young tells us about the book he is writing.