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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 

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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

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Greetings and Felicitations

Ulysses at 100-Lessons for the 21st Century Compliance Professional-Leopold Bloom


Matt Kelly once challenged me write a blog post for Bloomsday. Well aware of my great love for Joyce’s magnum opus, I accepted the challenge. This year is the 100th anniversary of the publication of the book. To celebrate this event, James Joyce novel at 100 and the compliance profession, I have decided to do a 5-part podcast series on Ulysses. Over this podcast series, I will highlight some of the book and commentary and tie what Joyce, Dublin, Leopold Bloom and his wife Molly, together with his mentor Stephen Daedalus can teach the modern compliance professional. I hope you will join me in the short celebration and trip through Dublin 1904 for the 100th anniversary of Bloomsday. In Part 2, Leopold Bloom and the passion for compliance.
Compliance Quote-Kristy Grant-Hart-“As an aggregate, the compliance profession is changing how business is done, and therefore changing the world. We are part of a movement that is palpably shifting the landscape for so many, especially in the developing world. It’s such an exciting experience and I am proud to be a part of it.”
Resources
The Teaching Compliance-James Joyce Ulysses, by James Heffernan
“Ulysses” and the Moral Right to Pleasure by Dan Chiasson in the New Yorker

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Compliance Week Conference Podcast

Kristy Grant-Hart on Navigating the Global Regulatory Environment

In this episode of the Compliance Week 2022 Preview Podcasts series, Kristy will discuss some of her presentation at Compliance Week 2022 “Deep Dive: Navigating the Global Regulatory Environment”. Some of the issues she will discuss in this podcast and her presentation are:

  • Driving compliance culture change across diverse geographies, functions, and teams
  • How global organizations can remain compliant within global areas with conflicting laws
  • Sharing data across borders
  • Setting up SOPs to remain compliant
  • Keeping up with changing requirement across the globe, including high-conflict areas (China, Russia, etc.), FCPA enforcement, EU development, etc.

In this first full compliance conference in over 2 years, I hope you can join me at Compliance Week 2022. This year’s event will be May 16-18 at the JW Marriott in Washington DC. The line-up of this year’s event is simply first rate with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 17th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. and many others to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders and ethics and compliance visionaries.
  • Hear from 75+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from the two SEC Commissioners and gain insights into the agency’s areas of enforcement and walk away with guidance on how to remain compliant within emerging areas such as ESG disclosure, third-party risk management, cybersecurity, cryptocurrency and more.
  • Bring actionable takeaways back to your program from various session types including ESG, Human Trafficking, Board obligations and many others for you to listen, learn and share.
  • The goal of Compliance Week is to arm you with information, strategy and tactics to transform your organization and your career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. As an extra benefit to listeners of this podcast, Compliance Week is offering a $200 discount off the registration price. Enter discount code discount code TFLAW $200 OFF.

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Great Women in Compliance

Kristy Grant-Hart – Adult Learning Theory and Compliance Training

Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.

Kristy Grant-Hart was one of the Great Women in Compliance podcast’s inaugural guests, whose episode launched on 6 December 2018. She agreed to be on the show before we had a track record and reputation – we’re grateful to her for supporting us right from the start.

We invited Kristy, one of the Compliance community’s most respected voices, to return to the show to share with us how adult learning theory can best be applied to your Compliance training to make it more effective. Listen in to get a baseline understanding of adult learning theory and Kristy’s tips for enhancing your training program. We also hear about how Compliance Competitor is going and what the ever moving and shaking Kristy is up to next.

Are you attending Compliance Week’s annual conference? The GWIC team of Lisa, Tom and Mary will all be speaking and look forward to saying hello to listeners of Compliance Podcast Network listeners in DC.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings to listen in to. If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it. You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast. Corporate Compliance Insights is a much appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020).

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.

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This Week in FCPA

Episode 293 – the Ukraine Hangs On edition


As Ukraine hangs on from the Russian invasion, Jay is on assignment so fan fav Kristy Grant-Hart joins this week as a co-host with Tom to look at some of the week’s top compliance and ethics stories from the impact of the Ukrainian crisis in the Ukraine Hangs On edition. 
Stories

  1. What Russia invasion means for companies and compliance. Tom with a series in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance.
  2. Dick Cassin says sanctions may lead to more corruption in the FCPA Blog.
  3. Jaclyn Jaeger looks at supply chain disruption and issues in Compliance Week (sub req’d)
  4. Matthew Murray asks if Putin invaded Ukraine to advance corruption, in GAB.
  5. Chasing oligarchs’ money, from the Washington Post.
  6. The Swiss approach to Ukraine crisis. Mark Pieth in Risk and Compliance Europe.
  7. Mike Volkov focuses on new and evolving sanctions, in Corruption Crime and Compliance.
  8. Economic nationalism and corporate governance. Martin Geller, in Harvard Law School Forum on Corporate Governance.
  9. Illicit finance and High-value art. Sullivan & Cromwell lawyers in Compliance and Enforcement.
  10. The invasion and cybersecurity. Jonathan Armstrong in Cordery Compliance.

Podcasts and More

  1. In March on The Compliance Life, I visit with Audrey Harris, Managing Director at AMI, formerly CCO at BHP. In Part 1, she discusses her academic background and early professional career.
  2. On the FCPA Compliance Report, Tom has a 2-part series with Trade Compliance guru Matt Silverman on the full extent of possible Russia sanctions (Part 1) and the corporate response you need to make (Part 2).
  3. Tom and Loren Steffy look energy issues and fallout from the Russian invasion in Greetings and Felicitations.
  4. Tom and Matt Kelly take a deep dive into the compliance weeds about the Russian invasion on Compliance into the Weeds.
  5. Silvia Surman devotes the entire week to Russian trade sanctions and economic issues in The Compliance Kitchen.
  6. Tom celebrates Texas Independence Day and the anniversary of the Alamo in a podcast with Don Frazier, Executive Director of the Texas Institute at Schreiner University on The Hill Country Podcast.

Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Kristy Grant-Hart is Compliance Kristy and can be reached at kgranthart@sparkcompliance.com.

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The Compliance Handbook

Third Parties with Kristy Grant Hart


Third parties are still perceived as the most prominent high risk for companies. Other than bribery and corruption — modern slavery/human trafficking, data privacy, information and cybersecurity, anti-money laundering, and other areas are requiring third-party integrated risk assessment and planning. Compliance and data privacy law thought leader Kristy Grant-Hart, CEO of Spark Compliance Consulting, offers an innovative approach and inspiring perspective in this conversation.
Major takeaways discussed in the episode:

  • Bribery and Corruption: This remains the most significant problem since the general business population’s perception that what a third party does on your behalf isn’t your problem. Because some countries have laws like that, this built the sensibility that “if I didn’t do it, then it doesn’t matter.”
  • Due Diligence Integration: Every company is different; however, it is crucial to apply a comprehensive and consistent approach to conducting due diligence in all categories in appointing and maintaining relationships with third parties.
  • Scoping: By defining the degree of risk to be reviewed and identifying the highest probable risk scenario, this will be based on the quantitative things that we know, like the CPI score, like the Trafficking in-person report. That’s where you try to start so that you’re looking at the right risk with the right tools.
  • Digital Assets: Many parts of the business are not working together to have that third-party onboarding. The problem is that they don’t want to work together necessarily. Using various technology-enabled solutions for your clients will enable you to clearly and effectively see across the entire risk spectrum.

The “Nuts and Bolts” for Creating a Comprehensive Compliance Plan 
The first chapter of this unique work lays out a succinct yet thorough 31-day approach to operationalizing a company’s compliance regimen. Beginning with a section on what 2020 brought to the compliance landscape, the 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
Order your copy OR copies of The Compliance Handbook: A Guide to Operationalizing Your Compliance Program. Save 25% off.
http://www.lexisnexis.com/fox25