Tag: Monaco Memo

Categories
Innovation in Compliance

Corporate Case Management in the Era of the DoJ’s Monaco Memo: Episode 3 -Ethical Investigations

Welcome to a special podcast series, Corporate Case Management in the Era of the DoJ’s Monaco Memo, sponsored by i-Sight Software Solutions. Over this five-part podcast series, I speak with Jakub Ficner, Director of Partnership Development at i-Sight Software. This series considers how the Monaco Doctrine and Monaco Memo have impacted compliance in several key areas. In this Part 3, we look at ethical investigations and how to allow your organization to meet the strictures of the Monaco Memo. Highlights include:

  • How did the Monaco Memo impact investigations?
  • The importance of keeping the reporter informed.
  • Why consistency and transparency are key aspects of the investigative process.
  • Creating an audit trail is in your investigation protocol.

For more information, check out i-Sight here.

Categories
Innovation in Compliance

Corporate Case Management in the Era of the DoJ’s Monaco Memo: Episode 2-Strategic Triage

Welcome to a special podcast series, Corporate Case Management in the Era of the DoJ’s Monaco Memo, sponsored by i-Sight Software Solutions. In this series, I am joined by Jakub Ficner, Director of Partnership Development at i-Sight. Over this series, we detail the changes wrought by the Monaco Memo and how compliance professionals can respond to these new challenges. In this Part 2, we look at the need for active triage in your investigative protocol to allow your organization to meet the strictures of the Monaco Memo. Some of the highlights include:

  • What is triage in a best practices compliance program?
  • Why triage is as important as the original report coming in.
  • How to document triage for regulators.
  • What to do when new issues are discovered
  • Why is the ability to ultimately learn from your collected data a key outcome?

For more information, check out i-Sight here.

Categories
Innovation in Compliance

Corporate Case Management in the Era of the DoJ’s Monaco Memo: Episode 1-A Speak-Up Culture

Welcome to a special podcast series, Corporate Case Management in the Era of the DoJ’s Monaco Memo, sponsored by i-Sight Software Solutions. Over this series, we detail the changes wrought by the Monaco Memo and how compliance professionals can respond to these new challenges. In this Part 1, we look at the role of a speak-up culture in responding to the DOJ changes set out in the Monaco Memo. Highlights include:

  • What did the Monaco Memo say about corporate culture?
  • What is a ‘speak-up culture?
  • How do we encourage and foster a speak-up culture?  
  • Why is setting expectations critical to creating and maintaining a speak-up culture?
  • How a speak-up culture can provide valuable compliance and business operations information.

For more information, check out i-Sight here.

Categories
Great Women in Compliance

All Star Women Monitors, Part 2

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

Today is the second part of a 2-part series that we have been planning for a while, and the timing turned out to be perfect.  Lisa is speaking with an all-star panel of Audrey Harris, Bethany Hengsbach and Dionne Lomax,  Managing Directors from Affiliated Monitors.  Audrey’s area is  Global Anticorruption, Compliance, Ethics & Non–Financial Risk, Bethany focuses on Global Corporate Compliance, with a focus on healthcare, and Dionne works in Antitrust and Trade Regulation, as well as being a professor at Boston University. The timing for this series turned out perfectly, as the group was able to get into an in-depth discussion about Lisa Monaco’s statements in September about the Monaco Doctrine and some of their key takeaways.

In Part 2, the group discusses the statements about compensation and clawbacks, and the importance of appropriate resources, among other topics. They also provide their individual perspectives on two other topics that many of us discuss.  One is the reporting line for CECOs, and the importance of a direct line to the Board or Audit Committees.  The other is the certification of Corporate Compliance programs by CEOs and CECOs. The entire discussion was extremely insightful, filled with practical ideas and good tips for everyone who is trying to build and/or maintain a program.

Listen to Part 1 here.

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.  If you have a moment to leave a review at the same time, Mary and Lisa would be so grateful.  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).

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

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.

Categories
Compliance Into the Weeds

Thinking about Clawbacks

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject. In this episode, we consider the recent SEC requirement for companies to publicly report clawback provisions and their effects in conjunction with the DOJ requirements for clawbacks. Highlights include:

·       What are clawbacks?

·       What does the SEC rule require?

·       Are clawbacks the mirror of executive incentives?

·       How does the DOJ position, as laid out in the Monaco Memo, differ (if any) from the SEC requirements?

·       How far down the corporate chain must a clawback provision impact?

Categories
GalloCast

Gallocast – Episode 4 – October 2022

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. Topics in this episode include:

  • ComplianceLine rebranded to Ethico. How does this reflect the overall products and services of the organization in 2022 and beyond.
  • The Oracle FCPA Enforcement Action. What are some key lessons for compliance?
  • The Monaco Memo. Focus on employee incentives and clawbacks.
  • Employees having two jobs post pandemic. When is it a conflict of interest?
  • Quiet quitting and the opportunity for employee engagement.

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Categories
From the Editor's Desk

September and October in Compliance Week

Welcome to From the Editor’s Desk, a podcast where co-hosts Tom Fox and Kyle Brasseur, EIC at Compliance Week, unpack some of the top stories which have appeared in Compliance Week over the past month, look at top compliance stories upcoming for the next month, talk some sports and generally try to solve the world’s problems.

In this month’s episode, we look back at top stories in CW from September around the FCPA enforcement actions involving GOL and Oracle, the Monaco Doctrine as reflected in the Monaco Memo, and the SEC spanking of banks for nearly $2MM over employees using messaging apps. We discussed the ESG virtual event and previewed the CW 2022 in Europe, which will be held in Scotland, and the virtual 3rd Party Risk conference, scheduled for December.

We conclude with a look at some of the top sports stories, including a look at the Tua Tagavoiloa and the NFL concussion protocols, and ask Kyle how he would have covered; the Boston Celtic’s imbroglio regarding its suspended head coach Ime Udoka and  Aaron Judge and his season for the ages.

Categories
FCPA Compliance Report

The EC Gang on the Monaco Doctrine

In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, we have the Award-Winning Everything Compliance quartet of Jonathan Marks, Jonathan Armstrong, Karen Woody, and Tom Fox on the Monaco Memo.

1. Tom Fox looks at the Monaco Memo through the monitorship language and answers a listener’s questions about compliance programs under the Monaco Memo.

2. Karen Woody reviews the Monaco Memo, the self-disclosure angle, and investigatory considerations and ponders the role of defense counsel going forward.

3. Jonathan Marks also looks at investigatory issues under the Monaco Memo, the role of the Board of Directors, and the role of the forensic auditor under the Monaco Memo.

4. Jonathan Armstrong’s self-disclosure from a UK angle joins Karen Woody in questioning how defense counsel should move forward.

Resources

Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog

1.     A Jolt for Compliance

2.     Timely Self-Disclosure

3.     Corporate Compliance Programs

4.     Monitors

5.     The Heat is On

Monaco Memo

Categories
FCPA Compliance Report

Laura Perkins on the Monaco Memo

In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, I am joined by Hughes Hubbard partner Laura Perkins to take a deep dive into the Monaco Memo. Some of the highlights include:

  1. Determination of Monitor Need.
  2. Roadmap to proa-active compliance.
  3. Timely self-disclosure as criteria for monitorship?
  4. Monitor selection criteria.
  5. Monitor review and oversight.

 Resources

Laura Perkins on HughesHubbard.com

Tom 5-Part blog post series in the FCPA Compliance and Ethics Blog

  1. A Jolt for Compliance
  2. Timely Self-Disclosure
  3. Corporate Compliance Programs
  4. Monitors
  5. Polite Speech

Monaco Memo

Categories
Everything Compliance

Episode 105 – the Monaco Memo and Antitrust in the EU

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. In 2021, Everything Compliance was honored by W3 as a top talk show in podcasting. In this episode, we have the quartet of Jonathan Marks, Jonathan Armstrong, Karen Woody, and Tom Fox on the Monaco Memo and antitrust enforcement going forward in Europe. We conclude with our fan Shout Outs and Rants section.

  1. Tom Fox looks at the Monaco Memo through the monitorship language and answers a listener’s questions about compliance programs under the Monaco Memo. He shouts out to Aaron Judge, who has a year for the ages.
  2. Karen Woody reviews the Monaco Memo, the self-disclosure angle, and investigatory considerations and ponders the role of defense counsel going forward. She shouts out to the HBO film Elvis and the movie portrayal of Presley.
  3. Jonathan Marks also looks at the Monaco Memo’s investigatory issues, the Board of Directors’ role, and the forensic auditor’s role under the Monaco Memo. He rants about compliance professionals and fraud examiners who have no idea what internal control is.
  4. Jonathan Armstrong looks at the EU communications around Facebook and antitrust enforcement and how things may change dramatically. He shouts out to King Charles III, who had a 70-year apprenticeship as the Heir Apparent to the British throne.

The members of Everything Compliance are:

  • Jay Rosen– Jay is Vice President, 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, an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com.
  • Jonathan Marks is Partner, Firm Practice Leader – Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at marks@bakertilly.com.

The host and producer, ranter (and sometime 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.