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Everything Compliance

Everything Compliance: Episode 136 – The Great Women in Compliance Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. In this episode, we have a very special group of guest panelists and one special guest host—some of the great women in compliance.

In this special episode, Everything Compliance is by Kristy Grant-Hart, and the guest panelists include Karen Woody, Karen Moore, Lisa Fine, and Hemma Lomax.

1. Karen Woody takes a deep dive into the current evolution of Caremark in Delaware. She raves about her alma mater, UVA, making the college baseball World Series and about this special GWIC-inspired edition of Everything Compliance.

2. Host Kristy Grant-Hart shouts out to Rachel Rodgers, author of We Should All Be Millionaires, and her call to action for women to lead more in politics, business, and entrepreneurship.

3. Karen Moore explores whether Boeing will be prosecuted under its current DPA. She sends sympathies to the family of John Barnett, the Boeing whistleblower who died.

4. Lisa Fine takes a deep dive into the recent acquittal of Mike Lynch in his criminal case for the sale of Autonomy to HP. In her Raves and Rants segment, she has two raves. First to all the Dads out there, Happy Father’s Day!  Her second is Compliance Week, retiring EIC Kyle Brasseur for his tenure at Compliance Week.

5. Hemma Lomax goes into a deep rant about compliance training. She raves about Everything Compliance for its first Great Women podcast and Jiminy Cricket, whose signature phrase is “Let your conscience be your guide.”

 

The members of this special episode of Everything Compliance are:

Karen Woody is one of the top academic experts on the SEC. She is also the co-host of the award-winning podcast, The Woody Report.

Karen Moore is an Adjunct Law professor at the Fordham School of Law.

Lisa Fine is a co-host of the award-winning Great Women in Compliance.

Hemma Lomax is a co-host of the award-winning Great Women in Compliance.

The host of this special episode of Everything Compliance is Kristy Grant-Hart, founder of Spark Compliance and co-host of the award-winning podcast 2 Gurus Talk Compliance.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance: Episode 30 — Make a Plan

What happens when two top compliance commentators get together? They talk about compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!

In this episode, Kristy and Tom discuss various pressing issues and developments in compliance. Topics include the introduction of a new regulator in Europe, concerns of AI employees about retaliation for raising alarms on potential threats, California’s new workplace violence compliance requirements, and unusual attempts to use live animals as payment in Florida.

The episode also highlights the significance of the Women in Compliance conference, the importance of crisis communication strategies, and the recent extension of the sanctions statute of limitations by the U.S. government. The conversation also covers networking for job seekers and the implications of the newly formed European Financial Crime Agency. The episode concludes with a bizarre payment method by our good friend, Florida Man.

Highlights Include:

 Resources:

Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

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2 Gurus Talk Compliance

2 Gurus Talk Compliance: Episode 28 — CZ v. SBF Edition

What happens when two top compliance commentators get together? They talk about compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!

In this episode, Tom and Kristy take on a wide variety of compliance related topics.

One of the key issues they look at are reports suggesting China is strategically relocating forced labor from the Uyghur region to different parts of the country in an attempt to bypass US laws prohibiting goods sourced from areas associated with forced labor.

This could trigger wider limitations on goods originating from China, stressing the necessity for intensive audits and transparency in business operations. This issue has sparked bipartisan concern, hinting at potential upcoming legal actions.

Tom stresses the need for companies to react effectively to reduce risks, possibly through on-the-ground audits and increased accountability in business operations in China. Kristy underscores the need for thorough audits and proactive measures in response to the risks associated with forced labor in China. She raises the possibility of legal consequences for companies found to be misleading about their involvement with forced labor. Both perspectives serve to underline the gravity and complexity of this issue.

Highlights Include:

  • An ex-McKinsey partner says he was scapegoated. (Reuters)
  • CFTC names its first AI Chief. (WSJ)
  • CZ gets 4 months. (WSJ)
  • FCPA violator Ericsson bemoans ‘over-regulation’.  (FT)
  • Corporate investigations are under scrutiny.   (FT)
  • China Moving Forced Laborers Amid U.S. Crackdown, Biden Official Says (WSJ)
  • Robinhood Crypto gets Wells notice from US SEC (Reuters)
  • Report Spotlights Privacy Access Requests (Radical Compliance)
  • Why Employee Bonuses Do Not Work (and What to Do Instead) (Inc.)
  • A Florida man runs to the police for help after committing a crime and ends up behind bars. (Aol.)

Resources:

Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Sunday Book Review

Sunday Book Review: April 14, 2024 Compliance Books Edition

In the Sunday Book Review, I consider books that would interest the compliance professional, the business executive, or anyone who might be curious.

It could be books about business, compliance, history, leadership, current events, or anything else that might interest me.

In today’s edition of the Sunday Book Review, we look at some of the top books on compliance you should read in 2024.

  • The Business Guide to Effective Compliance and Ethics, by Tony Osborn and Andrew Hayward
  • How to be a Wildly Effective Compliance Officer by Kristy Grant-Hart
  • Fully Compliant by Travis Waugh
  • Governance, Risk Management and Compliance by Richard Steinburg

Resources:

The best compliance books for 2024

For more information on Ethico and a free White Paper on ROI for your compliance program, click here.

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Everything Compliance

Everything Compliance – The Albemarle Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. In this episode, we have the quartet of Jay Rosen, Jonathan Armstrong, Matt Kelly, and special guests Karen Moore and Kristy Grant-Hart, with Tom Fox hosting. Our topic today (with the exception of Mr. Armstrong) is the recently announced Albemarle FCPA enforcement action with both the DOJ and SEC. We conclude with our always popular and fan-favor Shout Outs and Rants.

1. Matt Kelly provides an overview of the enforcement action. He rants about former House Speaker Kevin McCarthy and the GOP’s desire for chaos rather than governing.

2. Guest Karen Moore takes a deep dive into the SEC FCPA enforcement action involving Albemarle. She rants about lawyer fees over $2000+ per hour.

3. Tom Fox shouts out to the MLB playoffs and pays tribute to Dick Butkus.

4. Guest Kristy Grant-Hart takes a deep dive into the holdback provision noted in the DOJ enforcement action.

5. Jonathan Armstrong reviews CEOs misbehaving and the corporate response. He shouts out Kortney Nordrum for her presentation on what it is like to go through a data breach.

The members of the Everything Compliance are:

•       Jay Rosen– Jay is Vice President of Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com

•       Karen Woody – One of the top academic experts on the SEC. Woody can be reached at kwoody@wlu.edu

•       Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com

•       Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at jonathan.armstrong@corderycompliance.com

•       Jonathan Marks can be reached at jtmarks@gmail.com.

•       Special Guest Kristy Grant-Hart is the founder of Spark Consulting.

•       Special Guest Karen Moore is an Adjunct Professor at Fordham University School of Law

The host and producer, ranter (and sometimes panelist) of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Mary Releases A Book Edition

What happens when two top compliance commentators get together? They talk compliance of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!

In this episode, Tom and Kristy cover a range of topics including new anti-money laundering rules, India’s requirement for auditors to report suspected fraud, FCPA enforcement, messaging app compliance, compliance budget challenges, the settlement of an FCPA case, changing work dynamics, the purpose of a corporation, and the impact of ESG factors on corporate governance. They discuss the American Bar Association’s delayed support for anti-money laundering efforts, India’s significant change in auditor reporting rules, SEC enforcement of messaging app compliance, and the potential settlement of an FCPA case. They also emphasize the need for businesses to adapt to changing work styles and values and the benefits of incorporating ESG factors into corporate decision-making.

Highlights Include

  1. ABA agrees to new client due diligence rules.
  2. Mary Shirley releases a new book.
  3. More messaging app non-compliance fines.
  4. Albemarle makes FCPA settlement reserve.
  5. Capitalism at an Inflection Point?
  6. New India rules require auditors to report suspected bribery and kickbacks to the government.
  7. Grupo Aval FCPA Settlement.
  8. Stretching Your Compliance Budget.
  9. Leaving the Office at 5 Is Not a Moral Failing.
  10. Florida woman doused herself in Diet Mountain Dew to erase DNA after killing roommate, 79.

 Resources 

  1. WSJ
  2. Amazon
  3. WSJ
  4. FCPA Blog
  5. CCI
  6. WSJ
  7. Radical Compliance
  8. NYT
  9. NY Post
  10. Corruption, Crime and Compliance

Connect with Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Florida Man Moves Outside of Florida

What happens when two top compliance commentators get together? They talk compliance of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode! This week on the podcast, we discussed a variety of financial fraud and corruption cases that have recently come to light. From Bank of America’s creation of millions of fake accounts to KPMG getting caught cheating in the Netherlands, these cases serve as a reminder to the importance of strong compliance programs and the need for companies to be proactive in preventing fraud. Additionally, the DOJ is utilizing data analytics to enhance their ability to prosecute FCPA cases, while Women in Compliance work to empower and support female professionals in the industry. Finally, the Florida Man Scam highlights the need to be aware of the potential for scams and to exercise caution when giving out personal information.

Highlights Include

·      Bank of America Scandal

·      Navex Survey

·      Corruption in Singapore

·      KPMG Cheating Scandal

·      Kenneth Polite Reflects

·      Lisa Osofsky Reflects

·      Women in Compliance

·      Florida Man Should Stay in FL

·      Contracts and Emojis

 

Resources 

  1. WSJ Risk and Compliance Journal
  2. FCPA Blog
  3. Radical Compliance
  4. Dutch News
  5. WSJ Risk and Compliance Journal
  6. DOJ Press Release
  7. 2023 Navex Survey
  8. Reuters
  9. Compliance Week
  10. BBC

Connect with Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 2

What happens when two top compliance commentators get together? They talk compliance of course. Join Kristy Grant-Hart and Tom Fox for their new podcast, 2 Gurus Talk Compliance! But it is not simply Kristy and Tom talking compliance. In this podcast series Kristy and Tom review  other top commentators in compliance as well. In this podcast, we will consider all things compliance, corporate ethics, ESG, governance, and whatever else is on our minds and the minds of other experts in the field. Kristy and Tom explore all of these topics with expertise and wit.

2 Gurus Talk Compliance will include a deep dive into the latest headlines, as well as ask hard hitting questions and provide valuable insights on the current happenings of the world. Don’t miss out this week, as Tom and Kristy look at how the new DOJ pilot program and update to the evaluation of corporate compliance program guidance will affect dailiness operations.

 Highlights Include

·      Moral hazard for DOJ/Compliance

·      Global Corporate Governance Trends for 2023

·      Assessment of Monaco/Polite Speeches and new ECCP

·      Compliance in the Metaverse

·      Five hard leadership bills to swallow.

·      Former Blue Bell CEO Pleads Guilty

·      $9 Million Cow Manure Ponzi Scheme

·      Lessons Learned from Ericsson’s DPA Breach

·      Serious Fraud Office Abandons Prosecution

·      2023 Evaluation of Corporate Compliance Programs

 Notable Quotes

1.      “The effect on the economy is much more severe than I would have ever thought. The market tanked, basically, for 3 days. And of course, the market runs on perceptions. Pretty much like bank runs run on per perceptions.”

2.     “We had some assets disappear over the weekend. We’ve had the federal government come in at backstop that amount, full amount, not just limited to the 250000 per person or entity that the FDIC ensures I think banking regulations will probably change forever because of this event.”

3.      “A couple of weeks ago, we had 2 major speeches by deputy attorney general Lisa Monaco and Kenneth Polite, at the ABA white collar conference that were followed by the release of an updated 2023 version of the Evaluation of Corporate Compliance Programs, a new policy regarding monitors as well, and the announcement of a pilot program.”

Resources 

  1. Moral hazard for DOJ/Compliance 
  2. Global Corporate Governance Trends for 2023 
  3. Assessment of Monaco/Polite Speeches and new ECCP
  4. Compliance in the Metaverse
  5. Five hard leadership bills to swallow
  6. Former Blue Bell CEO Pleads Guilty to Misdemeanor Over Listeria Outbreak
  7. Central Valley Man Pleads Guilty to Nearly $9 Million Cow Manure Ponzi Scheme
  8. Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare
  9. U.K. Serious Fraud Office Abandons Prosecution of Former G4S Executives
  10. DOJ Announces Major Changes To Corporate Compliance Program Evaluation

Connect with Kristy Grant-Hart on LinkedIn

Spark Consulting

Connect with Tom Fox on Linkedin

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 1

What happens when two top compliance commentators get together? They talk compliance, of course. Join Kristy Grant-Hart and Tom Fox for their new podcast, 2 Gurus Talk Compliance! But it is not simply Kristy and Tom talking about compliance. In this podcast series, Kristy and Tom also review other top commentators in compliance. In this podcast, we will consider all things compliance, corporate ethics, ESG, governance, and whatever else is on our minds and the minds of other experts in the field. Kristy and Tom explore all of these topics with expertise and wit.

In this inaugural episode, they discuss the latest compliance trends and news, including two Supreme Court cases that have implications for the compliance profession. They also cover the Department of Justice and whistleblower trends, taking a look at Miranda and Upjohn’s warnings and increasing numbers of whistleblower reports to the SEC. They also dive into an article from the Harvard Law School Forum on corporate governance and discuss the Illinois Biometric law. Join the conversation and discover the latest on compliance and regulations with 2 Gurus Talk Compliance.

Highlights Include

The Role of In-House Attorneys in Communication Between Outside Counsel and Businesses [00:05:17]

Supreme Court Decision on the Future of the CFPB [00:09:11]

Impact of the Colorado Draft Regulation on Artificial Intelligence Compliance Programs [00:13:23]

The Benefits of Automated Data Deletion [00:17:23]

A Miranda component to corporate Upjohn Warnings [00:21:25]

The Obligation of Society to Address Climate Change [00:25:33]

The Benefits of Self-Disclosure in the DOJ Justice System [00:29:18]

The Role of the Board in Overseeing Third Parties in High-Risk Countries [00:33:14]

The Impact of Whistleblowers on the SEC [00:40:54]

White Castle’s Violation of Illinois Biometric Law [00:45:05]

Notable Quotes

  1. The DOJ is urging a federal judge to sanction Google’s parent, Alphabet, for its practice of setting employee chats to auto delete despite promising to preserve records.”
  2. “It goes beyond the specifics of this law, something you and I have talked about for several years now, that the compliance function and the CCO is well perhaps the most well-suited corporate discipline to deal with these new initiatives because it’s the basic framework of compliance that you and I have worked with for 15 years.”
  3. “Most compliance programs just don’t have good frameworks for things like AI or for big data even though we’ve been using that word for a long time.”

Resources

  1. Boards and 3rd Party Risk Oversight
  2. CO Draft AI Rules for Insurance
  3. Miranda Warnings in Corp Investigation
  4. Current whistleblowing landscape
  5. Has the stature of the CCO changed? 
  6. Analysis of the DOJ’s update to the self-disclosure program
  7. Supreme Court considering defunding the CFTC
  8. Trends in state privacy law   
  9. Litigation holds and records retention/Google/DOJ  
  10. Individuals charged – first enforcement action 2023 

Connect with Kristy Grant-Hart on LinkedIn

Spark Consulting

Connect with Tom Fox on Linkedin

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The ESG Report

Why Compliance Should Lead the Corporate ESG Effort with Kristy Grant-Hart

What does remodeling a home have to do with ESG? In this episode of the ESG Report, Tom Fox and Kristy Grant-Hart discuss the role of compliance in leading the ESG initiative within a corporation. Kristy, the founder of Spark Consulting, explains how compliance professionals can expand their role to lead the E, S and G components of ESG. She also shares her personal experience of remodeling her new home with her husband and how it relates to ESG.

Kristy Grant Hart is a well-known figure in the compliance field. She is the founder and CEO of Spark Consulting, a global compliance and ethics consultancy that recently celebrated its 6th anniversary. Spark Consulting now has locations in Chicago, New York, Los Angeles, and London. The company also recently released a business simulation game called Compliance Competitor, which has been picked up by many companies. Kristy has over 15 years of experience in compliance and governance, working with clients across multiple industries. She is also the author of four books, including How To Be A Wildly Effective Compliance Officer and The Compliance Entrepreneurs Handbook, which was written with Kirsten Liston and Joseph Murphy.

 

You’ll hear Tom and Kristy talk about:

  • ESG is a bridge between compliance, governance, and board relationships.
  • ESG can be a huge driver for change and reputation enhancement.
  • CCOs are skilled at bringing together people and putting programs into a framework, and this lends itself well to running a successful ESG program. 
  • The renewed focus on G (Governance) is a positive development, as better governance leads to more ethical behavior and compliance. Compliance has a relationship with the board, the Audit and Risk Committee, and it makes sense for compliance to expand its remit of reporting and talk about different stakeholders in different ways for better board management.
  • The push for gender diversity on boards is a step towards greater perspective and understanding of different stakeholders.
  • Supply chain management is an important aspect of the compliance function.
  • The June 2020 Update to the Evaluation of Corporate Compliance Programs from the Department of Justice emphasizes the importance of institutional justice and fairness within corporations, which ties into ESG principles.
  • The compliance function and CCO must have access to all corporate data, not just compliance data, in order to effectively lead ESG efforts.
  • The S in ESG, which stands for social, encompasses issues such as diversity, equity and inclusion, and responsible sourcing in the supply chain.
  • The evolution of supply chain compliance and its integration into ESG efforts has been growing in recent years.
  • Compliance professionals already have a wide range of skills and experience that can be applied to leading E efforts within ESG. They have an important role to play, even if they are not experts in the field.
  • Remodeling a home can also be a valuable learning experience: her personal experience of learning new construction skills aligns with the idea that compliance professionals can learn and lead the E component of ESG.

 

KEY QUOTE

“I think that the more that we see diversity on boards, the better companies will do, but also the opportunities become more expansive and that’s something that I’m passionate about and feel that’s incredibly important. I also think compliance should have much more of a seat on boards.” – Kristy Grant Hart

 

Resources:

Kristy Grant-Hart on Website | LinkedIn | YouTube  

Kristy Grant-Hart books

Spark Compliance