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FCPA Compliance Report

FCPA Compliance Report: Mary Inman on The DOJ Whistleblower Incentive Initiative

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this special edition of the FCPA Compliance Report, we welcome back fan favorite Mary Inman, now at her new firm, Whistleblower Partners LLP, a firm dedicated to assisting whistleblowers navigate various reward programs.

Mary joins Tom Fox to discuss what we know so far about the DOJ Whistleblower Incentive Initiative.

Mary has a positive perspective on the Department of Justice’s (DOJ) White Collar Whistleblower Program. She acknowledges the gaps in existing whistleblower reward programs across multiple agencies and sees the DOJ program as a crucial opportunity to fill these lacunae. Inman’s expertise, particularly in the SEC program, allows her to identify specific gaps, such as the lack of financial protections for whistleblowers reporting Foreign Corrupt Practices Act violations involving companies not publicly listed on US exchanges.

From her perspective, the DOJ program will address serious financial crimes, including domestic corruption. Inman also anticipates that the DOJ will establish its own office of the whistleblower, mirroring similar initiatives in other agencies, hence providing both confidential and anonymous reporting avenues.

Topics Covered in This Episode:

  • Specialized Law Firm for Whistleblower Reward Programs
  • Financial Crime Reporting Enhancement Initiative
  • Establishing a Central Office for Whistleblowers
  • Championing Transparency: Grassley’s Whistleblower Advocacy
  • Wellness Fund Support for Whistleblowers

Resources:

Mary Inman on LinkedIn

Whistleblower Partners LLP

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
FCPA Compliance Report

FCPA Compliance Report: Mary Inman on DOJ Whistleblower Bounty Program

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom welcomes back Mary Inman, partner at the newly formed Whistleblower Partners LLP. They talk about the new Department of Justice (DOJ) initiative to pay a bounty to whistleblowers.

Mary Inman is a well-recognized authority in the realm of whistleblowing programs. In this episode, she focuses on DOJ whistleblower program. Her perspective on the program is cautiously optimistic, acknowledging the potential gains in encouraging whistleblowers to disclose information about financial crimes and corruption. However, she has expressed concerns about certain aspects of the program’s design, such as excluding culpable whistleblowers and limiting the type of information that can be provided.

These viewpoints stem from her extensive experience and deep understanding of the complexities involved in implementing effective whistleblower programs. Drawing from her expertise, Inman also emphasizes the need for confidentiality and anonymity for whistleblowers, similar to the SEC program, suggesting that while the DOJ program is a positive step, careful consideration and potential revisions are required to ensure its effectiveness and fairness.

Key Highlights:

  • Financial Crime Whistleblower Reward Initiative
  • Promoting Transparency Through Compliance Officer Resignations
  • Whistleblower Protection for Mental Well-being

Resources:

Mary Inman on LinkedIn

Whistleblower Partner LLP

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Everything Compliance

Everything Compliance – Episode 131, The Whistleblower Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. In this episode, we have a quintet of commentators; Jonathan Marks, Matt Kelly, Jonathan Armstrong, Jay Rosen, and Special Guest Mary Inman; all hosted by Tom Fox.

1. Matt Kelly bemoans the lack of monitoring in recent FCPA enforcement actions. He shouts out to Ken Buck for his resignation from Congress.

2. Host Tom Fox shouts out to the Ides of March and the Mooring Theater Company’s Production of Shakespeare’s play Julius Caesar,  starring Corin and Vanessa Redgrave.

3. Jonathan Armstrong reviews NIS2 and the changing climate around cybersecurity regulation. He rants about the disaster management failures of the British Crown around Kate Middleton.

4. Jay Rosen looks at the enforcement action involving Gunvor S.A. and the potential Vice-Presidential candidacy of Aaron Rogers and says, “You ain’t no Bill Bradley.”.

5. Special Guest Mary Inman takes a deep dive into the DOJ whistleblower bounty program.  She shouts out to whistleblower John Barnett and rants about the need for mental health resources to be made available to whistleblowers.

6. Jonathan Marks looks at the DOJ’s renewed call for self-disclosure. shouts out a fast-thinking and fast-acting McDonald’s employee who used CPR to save a customer who had a heart attack.

The members of the Everything Compliance are:

Jay Rosen– Jay can be reached at Jay.r.rosen@gmail.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 in London.

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

The host, 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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Compliance Week Conference Podcast

Compliance Week 2023 Speaker Preview Series – A Fireside Chat with Compliance Director Turned Whistleblower

In this episode of the Compliance Week 2023 Speaker Preview Podcasts series, Mary Inman discusses her fireside chat at Compliance Week 2023, “Compliance Director Turned Whistleblower – Lessons, Learnings and Pitfalls.” Her talk is with Ted Siedle, and they will examine the whistleblower’s mindset, his personal experiences in discovering wrongdoing as a compliance professional, and learnings that can be useful in your organization.

I hope you can join me at Compliance Week 2023. This year’s event will be May 15-17 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 18th 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, gain insights into the agency’s enforcement areas, and walk away with guidance on remaining compliant within emerging areas such as ESG disclosure, third-party risk management, cybersecurity, cryptocurrency, and more.
  • Bring actionable takeaways from your program from various session types, including ESG, Human Trafficking, Board obligations, and many others, for you to listen, learn and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

For information on the event, click here. Listeners of this podcast will receive a discount of $200 by using code TF200 on the link here.

Categories
FCPA Compliance Report

Mary Inman on Top FCA Recoveries and Issues from 2022

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, I am joined by with Mary Inman, a partner at Constantine Cannon. We discuss the recently released US Fraud statistics and preventative measures with Inman. Inman explains that the US Department of Justice put out statistics on the False Claims Act for 2022, with healthcare dominating the recovered funds. Inman discusses how whistleblowers can still launch cases, even if the government does not join in, and encourage listeners to report fraud to their respective insurance departments if it later results in higher premiums for their organizations.

Key Topics:

·      The Increase of Managed Care Plans in Medicare [00:04:16]

·       The Power of Whistleblowing and the Impact of Joining Government Cases [00:08:19]

·      Medicare and Medicaid Fraud in California and Florida [00:12:21]

·       Impact of Insurance Fraud on Premiums [00:16:44]

·      The False Claims Act and the Escobar Decision [00:26:09]

Notable Quotes

1.      “And they were basically paying kickbacks to their they know who the physicians are, who are the largest prescribers of their drugs. And they were paying kickbacks to encourage them to basically discourage them from prescribing their competitors’ products and to direct it to them.”

2.     “What happened here is that Mallinckrodt improperly calculated their rebate by claiming that the drug they developed in 1990 was a new drug in 2013. And so that allowed them to greatly decrease the amount of the rebate they would have owed to the Medicaid program.”

3.    “It’s another kind of false billing scenario. It was notable to me that we had 2 big settlements.”

4.     “The whistleblower had accused the Association of shifting costs that it shouldn’t have reimbursed onto the Florida Medicaid program.

 Resources:

Mary Inman on Linkedin

Constantine Cannon

Tom Fox on LinkedIn

Categories
FCPA Compliance Report

Mary Inman on the Current State of Whistleblowing


In this episode of the FCPA Compliance Report, I am joined by Mary Inman, partner at Constatine Cannon. We look at recent developments in whistleblowing and how the Ukraine War has increased the visibility of whistleblowers. Highlights of this podcast include:

  1. Whistleblower Reward Program at the US Treasury Department/FinCEN – what is its relevance to corruption, anti-money laundering and the Ukraine conflict.
  2. The House Committee on Financial Services voted to strengthen the U.S. Treasury’s Anti-Money Laundering (AML) whistleblower program.  What does this mean for this  nascent program?
  3. How does a minimum whistleblower reward threshold, whistleblower incentives and injects more certainty into the Anti-Money Laundering whistleblower program.
  4. How does expanding AML whistleblower rewards to cover laws applicable to Russian sanctions, Congress is enlisting the help of the private citizenry.
  5. Lisa Monaco recently spoke about the government relying on corporations to ID instancesof money-laundering and other activities to help enforcement Russia economic sanctions and broader trade sanctions. Do you see private citizen or other whistleblowers as a key component of this fight?
  6. How has the Ukraine War raised the profile of whistleblowers and whistleblowing?
  7. Starting with SOX, then Dodd-Frank and the AML Law of 2020 has the US government began to understand whistleblowers as a key component in the fight against fraud, waste and abuse.
  8. Has the government embraced these same strategies and tactics in the wider fight against corruption?
  9. Tribute to Chuck Grassley for his advocacy of whistleblowers.

 Resources
Mary Inman on Constantine Cannon website

Categories
Compliance Week Conference Podcast

Mary Inman on How Global Companies Are Responding to the EU Whistleblower Protection Directive

In this episode of the Compliance Week 2022 Preview Podcasts series, Mary will discuss some of her presentation at Compliance Week 2022 “How Global Companies Are Responding to the EU Whistleblower Protection Directive”. Some of the issues she will discuss in this podcast and her presentation are:

  • Understand how to comply with both the EU Whistleblower Directive and GDPR requirements around call recordings, interview notes, records, and whistleblower rights to privacy
  • Learn how to run a Data Privacy Impact Assessment (DPIA)
  • Discover where requirements between the EU Whistleblower Directive and data privacy regulations conflict with each other

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.

Categories
FCPA Compliance Report

Mary Inman on an International Whistleblower Practice


In this Episode of the FCPA Compliance Report, I visit with Mary Inman, partner at Constantine Cannon. She runs the firms International Whistleblower practice from London. Highlights of this podcast include:

  1. The power of internal whistleblowing.
  2. EU whistleblower Directive.
  3. FCA whistleblowers.
  4. SEC bounty program as a model for other federal agencies.
  5. CFTC whistleblower awards.
  6. Where is whistleblower regulation headed.

Resources
Mary Inman on Constantine Cannon website.

Categories
The Ethics Movement

Converge21-Mary Inman on Whistleblower Programs That Foster Speak Up Culture


CONVERGE is in its 6th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with like-minded professionals. This year the conference has gone virtual. You will leave the conference with new resources and best practices allowing you to continue the hard work of driving ethics to the center of your business. In today’s episode I visit with Mary Inman. We visit about her presentation at Converge21 on Whistleblower Programs That Foster Speak Up Culture.
A successful whistleblowing program doesn’t start with installing a helpline–it starts with fostering an environment that protects whistleblowers, makes them feel supported, and makes clear the value they bring to the business. So how do you build that “speak-up culture?” Join this session to hear from a panel of practitioners who manage whistleblowing programs and whistleblower advocates who’ll share their insights, experiences, and challenges they’ve faced.
For more information, go to Converge21.

Categories
Great Women in Compliance

Blowing the Whistle, the Advocate-Mary Inman


Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
When we think about lawyers in the Compliance context, a number come to mind.  Those who represent us in the event of government action taking place, those who help us with investigations, those who help us objectively evaluate our Compliance program, those who give us advice on a point of law when we need it, those who are appointed to us as monitors and so on.  One area that doesn’t get a lot of attention is the role of the lawyer as whistleblower representative.  This Great Women in Compliance Podcast sheds some light on this advocate role by way of our interview with Mary Inman who heads up the International Whistleblower Practice at Constantine Cannon.
In her legal practice, Inman represented the high profile Theranos whistleblower Tyler Schulz, among others.  We draw on this fascinating experience to bring you Part 1 of a two-part series on whistleblowing starting with Inman’s perspective as an advocate for whistleblowers and ending with the view from the other side of the fence as the whistleblower with Erika Cheung, another of the Theranos whistleblowers.
Inman, who is the epitome of effervescence, does some level setting for us by explaining the role of a whistleblower lawyer and why a whistleblower might want one.  She gives her view on whether there are any differences between male and female whistleblowers based on her extensive experience and as someone who has spent her entire career in private practice, shares a tip on avoiding burnout.
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 which is hosted on the Compliance Podcast Network.
Lisa and Mary have extended the Great Women in Compliance brand to the booking “Sending the Elevator Back Down: What We’ve Learned from Great Women in Compliance”  (CCI Press, 2020) which can be found on Amazonand features valuable wisdom and advice from Great Women in Compliance across the world.
If you’ve already read the booked and liked it, will you help out other women to make the decision to leverage off the tips and advice given by rating the book and giving it a glowing review on Amazon?
As always we’re so grateful for all of your support and if you have any feedback or suggestions for our 2021 line up, or would just like to reach out and say hello, we always welcome hearing from our listeners.
Join the Great Women in Compliance community on LinkedIn here.