Tag: ethical leadership

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FCPA Compliance Report

FCPA Compliance Report-Episode 350, Linda Justice and Her Nancy Drew Approach

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Everything Compliance

Everything Compliance-Episode 14

Show Notes for Everything Compliance-Episode 14 

Topics from Matt:

  1. Trump Administration & FCPA enforcement— we have two declinations now; maybe a compare-and-contrast and speculation on what a tough Trump Admin enforcement WOULD look like;
  2. EU’s GDPR— Do EU regulators know what they want to do with the enforcement of this law; if they follow the lead of the anti-competition people whacking Google, it could be a big deal;
  3. Hui Chen’s departure from the Justice Department, both her public rebuke of Trump and the substance of how she believes her guidance has been misinterpreted; and
  4. Ethical leadership and the lack thereof; the menace of abusing perks and privilege, connecting my posts about Uber’s leaders and Chris Christie vacationing on a closed beach.

Topics from Jay:

  1. How do the Campaign Finance Laws mirror/or differ from the FCPA?
  2. Will the Russian Collusion Investigation reveal the ultimate FCPA violation?
  3. Regarding Walter Shaub’s departure from the Office of Governmental Ethics (OGE), does it matter? What is OGE supposed to do, and why did it work for the past 40+ years but fall on deaf ears with the Trump administration?
  4. Dovetailing with Matt’s question about a slow H1 for FCPA enforcement and in light of the just-released Gibson Dunn FCPA Mid-Year Report, does the current climate (and lack of vigorous enforcement) provide a perfect storm for companies to look the other way if they fall off the E&C wagon, or do we think that companies are still being vigilant despite a perception of decreased enforcement?

Rants follow this week’s episode. What do the two declinations in 2017 mean? The Everything Compliance panel of experts weighs in.

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This Week in FCPA

This Week in FCPA-Episode 56

  • The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit disgorgement. For what it means to the compliance practitioner, see Tom’s piece in the FCPA Compliance & Ethics Blog. For a legal review of the decision, see Miller & Chevalier client alert authored by Saskia Zandieh. Marc Bohn considered the case in the FCPA Blog. Marc and I discuss the case on the FCPA Compliance Report, Episode 332.
  • Trevor McFadden to leave the DOJ for federal bench. See article by Matt Kelly in Radical Compliance. Hui Chen’s contract not to be renewed, her position is posted for job applicants. Apply for the position here. Andrew Weissman leaves as head of the Fraud Section to go Special Prosecutor’s staff.
  • Former PetroTiger General Counsel Gregory Weismann is banned from SEC practice. See article in the FCPA Blog.
  • Matthew Stephenson considers what a Wal-Mart settlement might look like. See his article in the Global Anti-Corruption Blog.
  • The federal judge who sentenced Samuel Mebiame, the bag man for Och-Ziff; criticized the DOJ for its lack of prosecution of any individuals from the company. See article by Sam Rubenfeld in WSJ Risk and Compliance Report.
  • Jay previews his weekend report.
  • Tom continues to talk about the release of his new book 2016 – The Year in Corporate FCPA Enforcement. For more information and to purchase, click here.

    •  
    [tweet_box design=”default” url=”http://wp.me/p6DnMo-3kx” float=”none”]
    When do Mike & Mike agree on anything? Find out on This Week in FCPA. [/tweet_box]
    Jay Rosen can be reached:
    Mobile (310) 729-6746
    Toll Free (866)-201-0903
    JRosen@affiliatedmonitors.com
    Tom Fox can be reached:
    Phone: 832-744-0264
    Email: tfox@tfoxlaw.com]]>

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    This Week in FCPA

    This Week in FCPA-Episode 46, the On the Rode to Prague Edition

  • Why powerful people fail to stop bad behavior by their underlings. Click here for the article.
  • Some policy management lesson, courtesy United Airlines. Click here for Matt Kelly’s article on Radical Compliance.
  • Why you shouldn’t linger too long in the wrong compliance position. See Julie DiMauro’s blog post on the FCPA Blog.
  • Bribe recipient in the Gerald and Patricia Green FCPA case gets 50 years in prison. See article in the FCPA Blog.
  • Using data to operationalize your compliance program. Read Tom’s blog post, by clicking here.
  • What the New York state Department of Financial Services new regulation on cybersecurity for financial services companies means for compliance officers. See Tom’s blog post by clicking here.
  • Jay previews his weekend report.

    • Jay Rosen new contact information:
    Jay Rosen, CCEP
    Vice President, Business Development
    Monitoring Specialist
    Affiliated Monitors, Inc.
    Mobile (310) 729-6746
    Toll Free (866)-201-0903
    JRosen@affiliatedmonitors.com
    [tweet_box design=”default” url=”http://wp.me/p6DnMo-3aD” float=”none”]How can the use of data help to operationalize your compliance program?[/tweet_box]]]>

    Categories
    Everything Compliance

    This Week in FCPA-Episode 38, the M&M Edition

    Show Notes for Episode 38, for the week ending February 3, the M&M edition:

    1. January a month for the FCPA record books. See article in the FCPA Blog.
    2. Are hunting trips a FCPA violation? How about in Sweden? See article in by Tom Fox in Compliance Week.
    3. VW update-what the former CEO knew and when did he know it and CCO ‘departs’. What does it all mean? See Tom Fox articles in Compliance Week on the former CEO and the departure of the CCO.
    4. New Tom Fox series on One Month to a Better Board, FCPA Compliance Report.
    5. Everything Compliance-Episode 6 is out. It is dedicated exclusively to Rolls-Royce.
    6. Jay Rosen Weekend Report preview.
    7. Super Bowl predictions.

    [tweet_box design=”default” url=”http://wp.me/p6DnMo-31q” float=”none”]What were the week’s top FCPA, compliance and ethics stories? Check out This Week in FCPA to find out. [/tweet_box]]]>

    Categories
    Compliance Into the Weeds

    Compliance into the Weeds-Episode 14, Wells Fargo and the Fraud Triangle

    Fitting the Fraud Triangle to Wells Fargo
    For more on the Wells Fargo, compliance and ethics disaster, see the following:

    1. What is Risk?
    2. Tones at the Top; and
    3. Wells Knew all Along.

    [tweet_box design=”default” url=”http://wp.me/p6DnMo-2LH” float=”none”]Learn how the fraud triangle works for a the Wells Fargo and a variety of other corporate scandals.[/tweet_box]]]>