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FCPA Survival Guide

FCPA Survival Guide – Step 10 – Lesson on Speak Up Culture, Triage, and Internal Investigations

How can you survive an FCPA enforcement action? In this special podcast series, Tom Fox and Nick Gallo lay out the Top 10 things you can do to reduce your overall fine and penalty, perhaps down to a full declination. All of the actions you can take come from recent DOJ prosecutions under the FCPA and speeches from DOJ representatives. This podcast, sponsored by Ethico, is the companion series to the book The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action. Today, we discuss lesson number 10, your investigation process.

Tom and Nick discuss the importance of establishing a culture where employees feel empowered to speak up, the process of triaging and conducting internal investigations, and the significance of these practices in modern compliance programs. They reflect on the shift in workforce mentality towards valuing integrity and the practical implications for ethics and compliance teams in today’s knowledge economy. They emphasize the necessity of effective internal reporting mechanisms and middle management’s strategic role in capturing risk intelligence. The conversation explores the challenges and opportunities in optimizing compliance processes to mitigate risks and demonstrate organizational effectiveness to regulators like the DOJ and SEC.

Key Highlights and Issues

  • The Importance of Speak Up Culture
  • Workforce Dynamics and Compliance
  • Challenges in Compliance Reporting
  • Whistleblower Programs and Internal Reporting
  • Optimizing Compliance Processes

Resources:

Nick Gallo on LinkedIn

Ethico

The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action

Tom

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FCPA Survival Guide

FCPA Survival Guide – Step 8 – Investing in Compliance

How can you survive an FCPA enforcement action? In this special podcast series, Tom Fox and Nick Gallo outline the Top 10 things you can do to reduce your overall fine and penalty, perhaps down to a complete declination. All of the actions you can take come from recent DOJ prosecutions under the FCPA and speeches from DOJ representatives. This podcast, sponsored by Ethico, is the companion series to the book The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action. Today, we discuss lesson number eight: investing in your compliance program.

Tom and Nick highlight case studies from Albemarle, SAP, and ABB, emphasizing the importance of investing in resources, experienced personnel, and the need for continuous testing. The conversation underscores how these efforts build a credible compliance story for the DOJ and provide insights into successfully navigating FCPA remediation.

Key Highlights and Issues

  • Enhancing Your Compliance Program
  • ABB’s Compliance Transformation
  • Building a Compliance Story
  • The Importance of Authenticity in Compliance
  • Crafting a Persuasive Compliance Narrative

Resources:

Nick Gallo on LinkedIn

Ethico

The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action 

Tom

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FCPA Survival Guide

FCPA Survival Guide – Step 7 – Changing Your Business Model

How can you survive an FCPA enforcement action? In this special podcast series, Tom Fox and Nick Gallo outline the Top 10 things you can do to reduce your overall fine and penalty, perhaps down to a complete declination. All of the actions you can take come from recent DOJ prosecutions under the FCPA and speeches from DOJ representatives. This podcast, sponsored by Ethico, is the companion series to the book The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action. Today, we discuss lesson number seven: changing your business model.

In this episode, Tom and Nick discuss the significant transformations by companies like Albemarle and SAP, which shifted from using third-party sales agents to internal teams to enhance compliance and reduce risk. The conversation delves into the Department of Justice’s role in recognizing and endorsing such changes, eventually becoming industry standards. The session also covers the challenges and considerations in explaining such fundamental shifts to stakeholders and effectively managing the associated risks.

Key Highlights and Issues:

  • The Role of DOJ in Compliance Solutions
  • Case Studies: Albemarle and SAP
  • Philosophical Changes in Sales Models
  • Risks in Internal vs. Third-Party Sales Model
  • Business Reasons for Internal Sales
  • Explaining Changes to Stakeholders

Resources:

Nick Gallo on LinkedIn

Ethico

The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action

Tom

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FCPA Survival Guide

FCPA Survival Guide – Step 6 – Clawbacks and Holdbacks

How can you survive an FCPA enforcement action? In this special podcast series, Tom Fox and Nick Gallo lay out the Top 10 things you can do to reduce your overall fine and penalty, perhaps down to a full declination. All of the actions you can take come from recent DOJ prosecutions under the FCPA and speeches from DOJ representatives. This podcast, sponsored by Ethico, is the companion series to the book The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action. Today, we discuss the importance of using clawbacks and holdbacks.

In episode six of the FCPA Survival Guide, Tom Fox and Nick Gallo delve into the relatively new DOJ enforcement strategies: clawbacks and holdbacks. They discuss how these financial disincentives, formalized in the 2023 Monaco memo, aim to promote corporate compliance. The conversation highlights practical examples from companies like SAP and Albemarle, which implemented these strategies and received substantial credits from the DOJ. Nick emphasizes the importance and effectiveness of financial disincentives in driving behavior change and maintaining corporate integrity. The episode explores how these methods can operationalize compliance at all organizational levels.

Key Highlights and Issues

  • Understanding Holdbacks and Clawbacks
  • DOJ’s Pilot Program and Case Studies
  • The Impact of Financial Incentives
  • Corporate Responsibility and Individual Accountability
  • Employee Awareness and Compliance Culture
  • Balancing Positive and Negative Incentives

Resources:

Nick Gallo on LinkedIn

Ethico

The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action

Tom

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FCPA Survival Guide

FCPA Survival Guide – Introduction

How can you survive an FCPA enforcement action? In this special podcast series, Tom Fox and Nick Gallo outline the Top 10 things you can do to reduce your overall fine and penalty, perhaps down to a full declination. All of the actions you can take come from recent DOJ prosecutions under the FCPA and speeches from DOJ representatives. This podcast, sponsored by Ethico, is the companion series to the book The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action.

The Department of Justice (DOJ) has been unequivocal in its expectations for any company facing an FCPA enforcement action. This guide is tailored for compliance professionals and business executives who are part of such an investigation. It outlines the necessary steps to secure the most favorable resolutions, offering a glimmer of hope even in the most daunting circumstances. Since the introduction of the FCPA Corporate Enforcement Policy, the default position for any company that self-discloses a potential FCPA violation to the DOJ is that of a declination. This policy provides a significant advantage, even if a company does not self-disclose or there are aggravating factors, as it allows for substantial discounts from the DOJ. In the words of the DOJ, this guide details the actions a company can take to reduce any fine or penalty for an FCPA violation, providing a clear path to a more favorable outcome.

In this 10-part podcast series, we will examine the following tactics for reducing potential exposure if your company finds itself in the FCPA crosshairs:

1.     Self-Disclosure.

2.     The Need for Speed

3.     Extensive Remediation

4.     Root Cause, Risk Assessment and Gap Analysis.

5.     Data Analytics.

6.     Clawback and Holdbacks.

7.     Change in sales models.

8.     Enhancement of Compliance.

9.     Internal Controls.

10.  Investigative Protocol

Resources:

Nick Gallo on LinkedIn

Ethico

The FCPA Survival Guide: Surviving and Thriving a Foreign Corrupt Practices Act Enforcement Action

Tom

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Great Women in Compliance

Great Women in Compliance: Nick Gallo on Being an Ally

Welcome to the Great Women in Compliance Podcast. In this episode, Lisa Fine visits with a great gentleman in compliance, Nick Gallo, co-CEO at Ethico.

Nick started his career in private equity, and when he and his brother Gio wanted to grow a business together, they both saw the opportunity to build something that would benefit the compliance space.

Nick’s view about being an ally was shaped when he was young and saw his mother’s challenges as a woman in male-dominated industries, which continues today, where he is an advocate for supporting women and diversity, particularly in Ethics and Compliance.

Nick and Lisa discuss the importance of being proactive as allies and constantly trying to improve our workplaces, whether that means speaking up against injustice or supporting those who may not be heard.

They also speak about how unique and special this profession, and this community are, and the importance of building the next generation of compliance leaders and women in the profession.

Key Highlights:

  • Advocacy for Equality and Workplace Support
  • Active Allyship for Positive Social Change
  • A Mentorship’s Role in Professional Development Journeys
  • Fostering Inclusivity for Diverse Women in Compliance
  • Fostering Transparency and Fairness in Hiring

Resources:

Join the Great Women in Compliance community on LinkedIn here.

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FCPA Compliance Report

FCPA Compliance Report – Nick Gallo on The Ethics and Compliance Optimization System

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes back Nick Gallo, co-CEO at Ethico, to discuss its Ethics and Compliance Optimization System.

Nick Gallo, co-CEO of Ethico, is a seasoned professional with a robust background in ethics and compliance, and a key player in the development and promotion of Ethico’s ethics and compliance optimization system. Gallo’s perspective on the topic of ethics and compliance optimization systems is shaped by his belief in a comprehensive, integrated approach to managing compliance efforts. He sees this system as a next-generation tool that interacts with other data pools, generating more analytics and insights. His experience has led him to advocate for a centralized repository for various types of business information, which can be accessed by compliance teams for better visibility across all data silos within an organization. Gallo also stresses the importance of automation and integration to eliminate manual and repetitive tasks, allowing compliance professionals to focus on more strategic and value-added activities.

 

Key Highlight:

  • Creating a centralized system for streamlining ethics and compliance
  • Why compliance needs a centralized data system for compliance professionals
  • The prevalence of retaliation in organizations
  • Leveraging data for proactive risk mitigation

Resources:

Nick Gallo on LinkedIn

Ethico

Ethics and Compliance Optimization System

Tom Fox

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For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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Report from IMPACT 2023

Report from IMPACT 2023: Nick Gallo on Generational Change in the Workplace and Importance of Culture

ECI’s IMPACT 2023 was one of the leading compliance events in 2023. At this conference, Tom Fox, the Voice of Compliance, was able to visit with several of the speakers, exhibitors, participants and one group of ethically minded Girl Scout Troop. In this limited podcast series, Report from IMPACT 2023, Tom explores many of the most cutting-edge topics in ethics and compliance through short podcast episodes. Check out the full series of interviews. You will be enlightened, informed and come away with a fuller and more thorough understanding of the most cutting-edge topics in ethics and compliance. In this episode, Tom visits with Nick Gallo, co-CEO at Ethico and Keynote speaker at Impact 2023. He and Tom talk about the themes from Nick’s Keynote.

Nick Gallo brings a wealth of experience from his background in private equity to the discussion of the changing landscape of work, ethics and culture. Gallo’s unique insights are shaped by his belief that traditional hierarchical structures in workplaces have been replaced with more flat and remote structures, presenting a significant opportunity for industry transformation. Drawing from his firsthand experience during his PE acquisitions and mergers career, he emphasizes the critical role of authentic culture in enhancing employee engagement and performance. Gallo also highlights the need for aligning personal values with the purpose of an organization, a concept he believes is lacking in today’s transactional economy. Join Tom Fox and Nick Gallo as they delve deeper into these insights on this episode of the Report from Impact podcast.

 Highlights Include 

·      The impact of culture in M&A

·      The role of ethics in the workplace

·      A new generation in the workforce

 Resources 

Nick Gallo on LinkedIn

Ethico

ECI

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GalloCast

Gallocast – Episode 8

Welcome to the GalloCast. You have heard of the Manningcast in football. Now we have the GalloCast in compliance. The two top brothers in compliance, Nick and Gio Gallo, come together for a free-form exploration of compliance topics. It is a great insight on compliance brought to you by the co-CEOs of Ethico. Fun, witty, and insightful with a dash of the two brothers throughout. It’s like listening to the Brothers Gallo talk compliance at the Sunday dinner table. Hosted by Tom Fox, the Voice of Compliance.

In the Gallo Cast, host Tom Fox visits with brothers Nick and Gio Gallo to discuss topics from Silicon Valley Bank’s $200 billion accounting fraud to the importance of daddy-daughter dates. They debate the role of leadership and the importance of non-financial incentives for corporate compliance. Nick and Gio touch on discussions about risk and return in banking, the impact of social media, and the use of metrics for executive performance assessment. They urge people to reach out for help when struggling and encourage leaders to create a workplace that fosters connection, compassion and understanding. Listen to the GalloCast and find out how to be a better leader and a better person.

Key Highlights

·       The Impact of Low Interest Rates and Yield Chasing: Discussing the Silicon Valley Bank Collapse

·       The Impact of Silicon Valley Bank’s Composition of Depositors and Yield Chasing on the Stock Market Crash.

·       The Risks of Taking Big Swings: A Look at Silicon Valley Bank Leadership

·       The Role of a Bank’s Chief Risk Officer in Times of Crisis and the Implications of a Zero Interest Policy.

·       The return of capital and the risks to improve income for short-term gain.

·       The Role of Executive Leadership in setting Company Goals and Values.

·       Rewarding Compliance to Promote a Positive Culture

·       Corporate Transparency and Measures to Assess Compliance Team Performance

·       Measuring the Effectiveness of Compliance Teams

·       Creating Space to Talk About Mental Wellbeing in the Workplace

·       Creating an Empathetic Workplace for Stress Relief and Support

·       Creating a Comfortable and Supportive Workplace Environment

·       The Benefits of Creating Lasting Memories with Loved Ones

·       The Impact of Daddy-Daughter Activities on Emotional Bonding

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Tom Fox 

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GalloCast

Gallocast – Episode 7

Welcome to the GalloCast. You have heard of the Manningcast in football. Now we have the GalloCast in compliance. The two top brothers in compliance, Nick and Gio Gallo, come together for a free-form exploration of compliance topics. It is a great insight on compliance brought to you by the co-CEOs of ComplianceLine. Fun, witty, and insightful with a dash of the two brothers throughout. It’s like listening to the Brothers Gallo talk compliance at the dinner table. Hosted by Tom Fox, the Voice of Compliance.

Tom Fox peppers questions to Nick Gallo and Gio Gallo from Ethico with topics like what companies should consider doing business in Ukraine and how to identify great business risks. They also provide an understanding of compliance, changing human behavior, and techniques to get around ethical controls. Topics are spiced up with references to the recent Pope’s speech and technological advancements. Be sure to tune in, and don’t miss out on the brothers’ educational insights and witty dialogue.

Key Highlights

·       Logistical Challenges of Working in Ukraine –[00:04:00]

·       Compliance as an Opportunity to Manage Business Risk – [00:07:20]

·       The Role of Persuasion in Ethics and Compliance -[00:10:40]

·        US Semiconductor Industry Moves Away from Supply Chains – [00:13:43]

·        Risk Assessment and Crowdsourcing -[00:17:00]

·       The Ineffectiveness of Risk Assessment Strategies – [00:20:30]

·       Behavioral Psychology in Compliance Programs and Compliance Discipline -[00:23:50]

·       CEO Understanding of Compliance and Its Impact on Budgeting -[00:27:00]

·       The Benefits of Exploring Different Perspectives Through Reading -[00:29:52]

·       The Ethical Implications of AI-Generated Content – [00:36:25]

·       The Impact of Technology on the Economy – [00:39:37]

·       The Power of Simplifying Your Policy with Technology –[00:42:40]

·       Pope’s Condemnation of Corruption – [00:46:02]

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico