Podcasts by FCPA Compliance Report

FCPA Compliance Report

The FCPA Compliance Report is the longest running podcast in the in compliance and business ethics. Join its award-winning host, Tom Fox, the Voice of Compliance as he visits with top compliance practitioners, key figures from business, the government and law firms in the top podcast dedicated to all things compliance.

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FCPA Compliance Report
Maria D’Avanzo on the Intersection of AI, ChatGPT and Compliance from 2023-07-19T04:00

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In the latest episode of FCPA Compliance Report, Maria D’Avanzo from Traliant returns to discuss the ...

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FCPA Compliance Report
FCPA Compliance Report: Miranda Zolot - Remote Work Revolution, the Distributed Workforce from 2023-07-17T04:00

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Tom welcomes Miranda Zolot, General Counsel at Oyster HR in this episode. They discussed the distribu...

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FCPA Compliance Report
HHR Webinar on Strategic Competition Between US and China from 2023-03-10T05:00

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. Today, we have a special edition of the FCPA Compliance Report. On Wednesday, February 22, 2023, Hugh...

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FCPA Compliance Report
Matt Silverman on Potential Sanctions Against Russia from 2022-02-21T05:00

In this episode of the FCPA Compliance Report, I am joined by Matt Silverman, Director of Trade Compliance at VIAVI. In this Part 1 of a special two-part podcast series, we look at issues related t...

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FCPA Compliance Report
James Koukios on the MoFo November Int’l Anti-Corruption Newsletter from 2022-02-14T11:08

In this episode of the FCPA Compliance Report, I am joined by fan favorite James Koukios, partner at Morrison and Foerster. In this episode we consider some of the key ABC issues in the always grea...

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FCPA Compliance Report
James Koukios on the Monaco Speech from 2022-02-07T05:00

In this episode of the FCPA Compliance Report, I am joined by fan favorite James Koukios, partner at Morrison and Foerster. In this episode we take a deep dive into the Lisa Monaco speech from Octo...

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FCPA Compliance Report
Mike DeBernardis on Compliance Developments from Q4 2021 from 2022-01-31T05:00

In this episode of the FCPA Compliance Report, I am joined by fan favorite Mike DeBernardis, partner at Hughes Hubbard. In this episode we look at compliance and temporal timeline developments from...

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FCPA Compliance Report
Andrew Neblett and Brian Beeghly Join Ethisphere from 2022-01-24T05:00

In this episode of the FCPA Compliance Report, I am joined by Andrew Neblett and Brian Beeghly, co-founders of Informed360 who recently joined forces with Ethisphere. Highlights of this podcast inc...

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FCPA Compliance Report
Gordon Firemark on Legal Developments in Podcasting from 2022-01-17T05:00

In this episode of the FCPA Compliance Report, I am joined by Gordon Firemark, from the Firemark Law Firm. Gordon was one of the first lawyers working on the legal side of podcasting. He returns to...

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FCPA Compliance Report
Mike Volkov on FCPA Enforcement and Compliance from 2021 and into 2022 from 2022-01-10T05:00

In this episode of the FCPA Compliance Report, I am joined by Mike Volkov to take a look back at FCPA enforcement and compliance from 2021 and prognosticate to where it may be going in 2022. Highli...

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FCPA Compliance Report
Karen Woody on JPMorgan and Nikola SEC Enforcement Actions from 2022-01-03T05:00

In this episode of the FCPA Compliance Report, I am joined by Professor Karen Woody. We discuss the recent SEC enforcement actions involving JPMorgan and Nikola which were announced in December 202...

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FCPA Compliance Report
John Katsos - Due Diligence in Conflict Zones from 2021-12-27T05:00

In this episode of the FCPA Compliance Report, I visit with John Katsos, Assistant Professor and Scholar at American University of Sharjah. John has researched and performed due diligence in confli...

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FCPA Compliance Report
Brandon Daniels-Ongoing v. Point in Time Due Diligence from 2021-12-20T05:00

In this episode of the FCPA Compliance Report, I visit with Brandon Daniels, President of Exiger. Brandon is a long-time favorite on the FCPA Compliance Report and he always brings a unique perspec...

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FCPA Compliance Report
Kyle Brasseur, Editor in Chief at Compliance Week from 2021-12-13T05:00

In this episode of the FCPA Compliance Report, I visit with Kyle Brasseur, new appointed Editor in Chief at Compliance Week. We talk about Kyle’s professional career at ESPN, his move to Compliance...

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FCPA Compliance Report
Kevin O’Brien on the Elizabeth Holmes Trial from 2021-12-06T05:00

In this episode of the FCPA Compliance Report, I visit with Kevin O’Brien, partner at Ford O’Brien in NYC. Kevin is a long-time white-collar defense lawyer and former AUSA in the Eastern District o...

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FCPA Compliance Report
Irene Kaushanky on Why Supply Chain is the Connective Tissue in the Fight Against Modern Slavery from 2021-11-29T05:00

In this Episode of the FCPA Compliance Report, I visit with Irene Kaushansky, Associate Director of Compliance and Operational Integrity at Global Fund to End Modern Slavery. Irene is passionate ab...

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FCPA Compliance Report
John Davis and James Tillen on WPP from 2021-11-22T05:00

In this Episode of the FCPA Compliance Report, I visit with Miller&Chevalier members John Davis and James Tillen. We take a deep dive into the WPP Foreign Corrupt Practices Act enforcement action. ...

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FCPA Compliance Report
Mary Inman on an International Whistleblower Practice from 2021-11-15T05:00

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 podcas...

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FCPA Compliance Report
Mike DeBernardis on Q3 Compliance and Enforcement Highlights from 2021-11-09T11:59:19

In this Episode of the FCPA Compliance Report, I have thrilled to have back fan favorite Mike DeBernardis, partner at Hughes Hubbard. Mike is back for our quarterly FCPA and compliance review and i...

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FCPA Compliance Report
Matt Silverman - Trade Compliance, Part 2 from 2021-11-01T04:00

In this Episode of the FCPA Compliance Report, I conclude a special two-part series with Matt Silverman on trade compliance. Matt leads the VIAVI Global Trade team and provides strategic guidance t...

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FCPA Compliance Report
Matt Silverman - Trade Compliance, Part 1 from 2021-10-25T04:00

In this Episode of the FCPA Compliance Report, I begin a special two-part series with Matt Silverman on trade compliance. Matt leads the VIAVI Global Trade team and provides strategic guidance to m...

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FCPA Compliance Report
Trish Refo-Lawyers in the Public Square from 2021-10-18T04:00

In this episode of the FCPA Compliance Report, I am joined by Trish Refo, Immediate Past President of the ABA. Trish recently penned an article for the ABA magazine entitled “Lawyers in the Public ...

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FCPA Compliance Report
Dean Cherie Taylor on a Compliance Certification at STCL from 2021-10-11T04:00

In this Episode of the FCPA Compliance Report, I am joined by Cherie Taylor, Vice President, Associate Dean for Academics, Professor of Law, and Director of Institute for International Legal Practi...

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FCPA Compliance Report
Bill Athanas- Factors In Defending White Collar Criminal Cases from 2021-09-27T04:00

In this Episode of the FCPA Compliance Report, I am joined by Bill Athanas, partner at the Waller Law Firm in Birmingham. Bill is a former DOJer in the Fraud Section who worked on FCPA enforcement ...

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FCPA Compliance Report
Randy Sorrels-A New Law Firm from 2021-09-20T04:00

In this Episode of the FCPA Compliance Report, I am joined by Randy Sorrels, an old colleague in the legal practice from Houston. Randy is also a former President of the State Bar of Texas. He also...

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FCPA Compliance Report
Lisa Beth Lentini Walker and Stef Tschida - Raise Your Game, Not Your Voice from 2021-09-13T04:00

In this Episode of the FCPA Compliance Report, I am joined by Lisa Beth Lentini Walker and Stef Tschida, co-authors of the book Raise Your Game, Not Your Voice. They explain what happens when a com...

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FCPA Compliance Report
Karen Woody on Comings and Goings at the SEC from 2021-08-30T04:00

In this Episode of the FCPA Compliance Report, I am joined by Professor Karen Woody to look at the current state of the SEC in the Biden Administration. Highlights of this podcast include: A.    SE...

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FCPA Compliance Report
James Koukios on MoFo April International Anti-Corruption Newsletter from 2021-08-23T04:00

In this Episode of the FCPA Compliance Report, I am joined by fan fav James Koukios to review the Morrison&Foerster April International Anti-Corruption Newsletter.  Highlights of this podcast inclu...

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FCPA Compliance Report
James Koukios on MoFo March International Anti-Corruption Newsletter from 2021-08-09T04:00

In this Episode of the FCPA Compliance Report, I am joined by fan fav James Koukios to review the Morrison&Foerster March International Anti-Corruption Newsletter.    Highlights of this podcast inc...

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FCPA Compliance Report
Episode 560-Mike DeBernardis on Enforcement and Oversight in Q2-2021 from 2021-08-02T04:00

In this Episode of the FCPA Compliance Report, I am joined by fan fav and now Hughes Hubbard&Reed partner Mike DeBernardis. We take a look back at some of the key enforcement actions and issues fro...

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FCPA Compliance Report
Executives at Risk, Summer 2021 Newsletter from 2021-07-26T04:02

In this Episode of the FCPA Compliance Report, I visit with three lawyers from Miller&Chevalier to discuss the Summer 2021 Edition. I am joined by Lauren Briggerman, Katherine Pappas and Ian Herber...

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FCPA Compliance Report
Jason Mefford from 2021-07-19T04:00

In this Episode of the FCPA Compliance Report, I am joined by Jason Mefford, a top thought leader in internal controls. We discuss his podcast Jamming with Jason, his online academy cRisk Academy a...

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FCPA Compliance Report
Cristina Revelo-a PhD in Compliance from 2021-07-12T17:57:35

In this Episode of the FCPA Compliance Report, I am joined by Cristina Revelo. Cristina got a PhD in Compliance working at KPMG on the Wal-Mart account and later went in-house at Wal-Mart. She has ...

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FCPA Compliance Report
Welcome to ¡(H)Ola Compliance! from 2021-06-28T04:00

In this Episode of the FCPA Compliance Report, I am joined by Miller&Chevalier Members Alejandra Almonte and Matt Ellis to discuss ¡(H)Ola Compliance!. ¡(H)Ola Compliance! is the only Spanish and P...

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FCPA Compliance Report
Mary Ann Faremouth on Revolutionary Reinvention from 2021-06-21T04:01

In this Episode of the FCPA Compliance Report, I am joined by Mary Ann Faremouth, founder of Faremouth and Company and inventor of the Faremouth Method. She joins me to discuss her latest book Revo...

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FCPA Compliance Report
Charles Thomas on the Current State of 3rd Party Risk Solutions from 2021-06-14T04:04

In this Episode of the FCPA Compliance Report, I am joined by Charles Thomas Market Planning Director for LexisNexis Risk Solutions. In this episode we take a look at the current state of risk area...

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FCPA Compliance Report
Greg Keating on the Current State of Whistleblower Regs and Law from 2021-06-07T04:02

In this Episode of the FCPA Compliance Report, I am joined by Greg Keating, well-known employment lawyer who focuses on whistleblower regulation and litigation.  In this episode we take a look at t...

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FCPA Compliance Report
András Bácsfalvi on AML Compliance in Hungary from 2021-05-24T04:03

In this Episode of the FCPA Compliance Report, I am joined by András Bácsfalvi, an AML compliance specialist in Hungary and more importantly host of the podcast Védelmi Vonalak .  In this episode w...

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FCPA Compliance Report
James Koukios on MoFo January and February Int'l ABC Newsletter from 2021-05-17T04:00

In this Episode of the FCPA Compliance Report, I am joined by fan fav James Koukios, partner at Morrison&Foerster and editor of the firm’s great monthly International Anti-Corruption Developments N...

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FCPA Compliance Report
Joey Seeber, Part 2 from 2021-05-12T04:06

In this Episode of the FCPA Compliance Report, I am joined by Joey Seeber, CEO of Level Legal, an alternative legal services provider with a wide range of talented skills. We explore how an alterna...

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FCPA Compliance Report
Joey Seeber, Part 1 from 2021-05-10T04:01

In this Episode of the FCPA Compliance Report, I am joined by Joey Seeber, CEO of Level Legal, an alternative legal services provider with a wide range of talented skills. We explore how an alterna...

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FCPA Compliance Report
Mike DeBernardis on Enforcement and Oversight in 2021 from 2021-05-03T04:04

In this Episode of the FCPA Compliance Report, I am joined by fan fav and now Hughes Hubbard&Reed partner Mike DeBernardis. We take a look back at some of the early pronouncements from the Biden Ad...

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FCPA Compliance Report
Max Keating, Controls and ESG in eSports from 2021-04-26T11:11:59

In this Episode of the FCPA Compliance Report, I am joined by Max Keating, CEO and co-founder of Kleos, a scheduling and payment platform for the eSports industry. We take a deep dive into eSports,...

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FCPA Compliance Report
Laura Tulchin on the Year Everything Changed from 2021-04-19T04:02

In this Episode of the FCPA Compliance Report, I am joined by Laura Tulchin, Director at Exiger. We take a deep dive into ESG and compliance, both now and in the future in a fascinating episode abo...

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FCPA Compliance Report
Quyen Truong on the Direction of the CFPB under the Biden Administration from 2021-04-12T04:03

In this Episode of the FCPA Compliance Report, I am joined by Quyen Truong, partner at Stroock&Stroock&Lavan. During her career in government, she worked at the Consumer Financial Protection Bureau...

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FCPA Compliance Report
Erica Salmon Byrne on Ethisphere’s 2021 WME from 2021-04-05T04:02

In this Episode of the FCPA Compliance Report, I am joined by Erica Salmon Byrne, EVP at Ethisphere. We take a deep dive into Ethisphere’s 2021 WME report and white papers on the award-winning best...

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FCPA Compliance Report
Raman Kalyan&Tahlal Mir on Insider Risks from 2021-03-29T04:01

In the Episode, the hosts of the Microsoft podcast, Uncovering Hidden Risks join me. Raman Kalyan is a Director of Product Marketing on the Microsoft 365 Security and Compliance team focused primar...

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FCPA Compliance Report
Bryan Sillaman on the Intersection of Compliance, ESG and Clean Energy from 2021-03-22T04:01

In the Episode, HughesHubbard partner Bryan Sillaman returns to discuss how a compliance professional can think through setting up an ESG program and clean energy issues. Highlights include  What ...

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FCPA Compliance Report
ECI 2021 Global Business Ethics Survey: Episode 4 - Covid-19 and Culture from 2021-03-15T04:11

In this special five-part podcast series, I visit with Dr. Pat Harned, President of the Ethics&Compliance Initiative (ECI), about the organization’s 2021 Global Business Ethics Survey (GBES). Since...

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FCPA Compliance Report
ECI 2021 Global Business Ethics Survey: Episode 5 - Conclusions and Recommendations from 2021-03-15T04:11

Over this special five-part podcast series, I have visited with Dr. Pat Harned, President of the Ethics&Compliance Initiative (ECI), about the organization’s 2021 Global Business Ethics Survey (GBE...

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FCPA Compliance Report
ECI 2021 Global Business Ethics Survey: Episode 3 - Retaliation from 2021-03-15T04:10

In this special five-part podcast series, I visit with Dr. Pat Harned, President of the Ethics&Compliance Initiative (ECI), about the organization’s 2021 Global Business Ethics Survey (GBES). Since...

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FCPA Compliance Report
ECI 2021 Global Business Ethics Survey: Episode 2 - Key Findings from 2021-03-15T04:09

In this special five-part podcast series, I visit with Dr. Pat Harned, President of the Ethics&Compliance Initiative (ECI), about the organization’s 2021 Global Business Ethics Survey (GBES). Since...

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FCPA Compliance Report
ECI 2021 Global Business Ethics Survey: Episode 1 - Introduction from 2021-03-15T04:08

In this special five-part podcast series, I visit with Dr. Pat Harned, President of the Ethics&Compliance Initiative (ECI), about the organization’s 2021 Global Business Ethics Survey (GBES). Since...

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FCPA Compliance Report
James Koukios on MoFo Top 10 Int’l ABC Developments for December 2020 from 2021-03-15T04:03

In the Episode, fan fav and MoFo partner James Koukios returns to discuss the firm’s always informative Top 10 International Anti-Corruption Developments for December 2020. We focus this episode on...

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FCPA Compliance Report
Loren Steffy on the Texas Power Disaster from 2021-03-08T05:02

In the Episode, Loren Steffy returns to take a deep dive into the Texas power failure during our recent snow-pocolypse. Steffey, a long-time business journalist who has been covering the Texas busi...

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FCPA Compliance Report
Michael Rasmussen on Policy Management Pro from 2021-03-04T05:02

In the Special Episode, I visit with Michael Rasmussen, who together with OCEG have rolled out a fabulous new resource for the compliance community, the Policy Management Pro and publication of the...

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FCPA Compliance Report
James Koukios on MoFo Top 10 Int’l ABC Developments for November 2020 from 2021-03-01T05:03

In the Episode, fan fav and MoFo partner James Koukios returns to discuss the firm’s always informative Top 10 International Anti-Corruption Developments for November 2020. We focus this episode on...

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FCPA Compliance Report
Kris Krimitsos on Podfest Global Summit from 2021-02-22T05:02

In the Episode, I visit with Podfest Expo founder Chris Krimitsos about the upcoming Podcast Global Summit, March 1-5. Podfest Global Summit is a gathering for those who are passionate about sharin...

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FCPA Compliance Report
Philip Urofsky on Shearman&Sterling’s 2020 FCPA Digest from 2021-02-15T05:02

In the Episode, I have back Philip Urofsky, a partner at Shearman&Sterling and editor of the firm’s FCPA Digest. Urofsky joins me to discuss the 2020 FCPA Digest and where anti-corruption enforceme...

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FCPA Compliance Report
Mike Volkov Turns the Tables from 2021-02-08T05:02

In the Episode, Mike Volkov turns the tables on me as he interviews me for a wide-ranging discussion about the new Justice Department leadership and the likely impact on enforcement and overall com...

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FCPA Compliance Report
Pamela Fierst-Walsh on Responsible Sourcing from 2021-02-01T05:02

In the Episode, I have back Pamela Fierst-Walsh, Senior Advisor for Conflict&Critical Minerals, Bureau of Economic and Business Affairs, U.S. Department of State. Pamela joins me to discuss the res...

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FCPA Compliance Report
Asher Miller on Doing Compliance in Israel from 2021-01-25T05:01

In the Episode, I visit with Asher Miller, a Compliance Consultant and Business Law Expert. Miller advises some of Israel's major corporations in the areas of anti-corruption, anti-money laundering...

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FCPA Compliance Report
Doreen Edelman on CFIUS under the Biden Administration from 2021-01-11T05:03

In the Episode, I visit with Doreen Edelman, chair of the Lowenstein Sandler Global Trade&Policy practice. She leads a unique team that combines global trade and policy expertise with cross-border ...

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FCPA Compliance Report
James Koukios on the MoFo Top 10 International Anti-Corruption Developments for October 2020 from 2021-01-04T05:03

In the Episode, I visit with James Koukios, partner at Morrison&Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 Internati...

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FCPA Compliance Report
Bonus Edition-Everything Ethics from 2020-12-31T14:01

Today I have a special year end episode where I am interviewed by Kevin Foster for his show Everything Ethics, which he has graciously allowed me to cross-post. It is a free flowing conversation ab...

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FCPA Compliance Report
Eric Young on Key Compliance&Enforcement Changes 2010 to 2020 from 2020-12-28T05:00

In this episode, I am joined by Eric Young, recently retired long-time compliance professional. In a continuing series on the FCPA Compliance Report, Eric joins me to explore some of the key change...

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FCPA Compliance Report
James Koukios on the MoFo Top 10 International Anti-Corruption Developments for September 2020 from 2020-12-21T05:03

In the Episode, I visit with James Koukios, partner at Morrison&Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 Internati...

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FCPA Compliance Report
Fry Wernick and Mike Ward Dissect the Year’s 3 Biggest Anti-Corruption Cases from 2020-12-14T05:01

In this episode, I was pleased to visit with Fry Wernick and Mike Ward, both partners at Vinson&Elkins. We dissect the three biggest anticorruption enforcement actions: Airbus, J&F Investments and ...

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FCPA Compliance Report
Don Stern on the US Attorney Offices from 2020-12-07T05:03

In this episode, I am joined by Don Stern, Managing Director at Affiliated Monitors and former US Attorney for Massachusetts. We discuss the 93 US Attorneys offices across the US; how they work, ho...

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FCPA Compliance Report
Eric Young on the Fed and DFS Components of the Goldman Sachs Corruption Enforcement from 2020-11-30T05:03

In this episode, I am joined by Eric Young, recently retired long-time compliance professional. We explore an under-looked aspect of the Goldman Sachs FCPA enforcement action; the independent enfor...

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FCPA Compliance Report
How the Lion’s Mouth Informs Your Internal Reporting System from 2020-11-25T05:01

The week of Thanksgiving is the time of our annual trip to the most beautiful and unique city on earth-Venice, Italy. With travel to Italy shut down this year due to Covid-19, I am visiting Venice ...

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FCPA Compliance Report
Arsenale and Incentivizing Compliance from 2020-11-24T05:02

The week of Thanksgiving is the time of our annual trip to the most beautiful and unique city on earth-Venice, Italy. With travel to Italy shut down this year due to Covid-19, I am visiting Venice ...

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FCPA Compliance Report
Mike Lindsey on Legal Issues Related to Cyber, E-Commerce and Internal Communications from 2020-11-23T05:02

In this episode, I am joined by Mike Lindsey, a partner in the Los Angeles law firm of Steinbrecher and Span. Lindsay specializes in cyber risk issues. He joins me to discuss those legal issues aro...

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FCPA Compliance Report
How the Venetian Gondolier Informs Your Compliance Program from 2020-11-23T05:01

If there is one thing that is ubiquitous throughout this city it is the Gondolier, the Venetian Gondola boatman. You are never far from hearing their cry of “Gondola, Gondola” to attract tourists f...

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FCPA Compliance Report
Dave Lefort, Reflections on Tommy Heinsohn from 2020-11-16T05:01

In the episode, I take things in a different direction as I visit with Compliance Week Editor-in-Chief Dave Lefort. We reflect on the life and meaning of the recently deceased Tommy Heinsohn. We ta...

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FCPA Compliance Report
Mike DeBernardis on Q3 FCPA Enforcement and Related Issues from 2020-11-09T05:05

In the Episode, I visit with Mike DeBernardis, Counsel and Hughes Hubbard. We take a look back at the FCPA world in Q3. It started off with a bang and never slowed down.  Some of the highlights inc...

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FCPA Compliance Report
James Koukios on the MoFo Top 10 International Anti-Corruption Developments for April 2020 from 2020-11-02T05:01

In the Episode, I visit with James Koukios, partner at Morrison&Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 Internati...

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FCPA Compliance Report
Wirecard Part 10, On the Beach from 2020-10-28T13:44

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecu...

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FCPA Compliance Report
Susan Divers on Evolution in Compliance over the Past Decade from 2020-10-26T04:00

In this episode, I visit with Susan Divers, Senior Advisor at LRN. It is part of my continuing series this year looking back over the past decade of Foreign Corrupt Practices Act enforcement and th...

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FCPA Compliance Report
Gar Hurst on Biggest Import Issue You Have Never Heard About from 2020-10-19T04:02

In this episode, I visit with Gar Hurst a partner at Givens and Johnston. Gar and the firm specialize on import control issues. Today we take a major issue that is bedeviling companies in the Port ...

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FCPA Compliance Report
Carrie Penman on Beyond the Moment from 2020-10-16T04:03

In this podcast, I am joined I am joined by Carrie Penman, Chief Risk and Compliance Officer at NAVEX Global, Inc. We visit about their upcoming 2020 virtual conference, NAVEX Next, which is entitl...

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FCPA Compliance Report
Wirecard Part 9, Running to Fraud with Hermes from 2020-10-14T19:53:37

In our continuing series, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors.  Mikhail’s areas of expertise include technology, privacy...

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FCPA Compliance Report
The FinCen Papers from 2020-10-12T04:00

In this podcast, I am joined by Piero Molinario, Senior Managing Director, Head of Financial Crimes Risk and Compliance for EMEA for K2 Intelligence FIN and Joanne Taylor, Managing Director, K2 Int...

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FCPA Compliance Report
Jonathan Armstrong on Herbalife from a UK Perspective from 2020-10-09T04:00

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Arms...

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FCPA Compliance Report
Jonathan Marks on the Role of Gatekeepers from 2020-10-08T04:00

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Arms...

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FCPA Compliance Report
Compliance Book Club Interview of Robert Chesnut on Intentional Integrity from 2020-10-07T15:46:36

In this special edition, I am pleased to cross-post a recent live event hosted by Sean Freidlin, Director Product Marketing at SAI Global. He hosted the third edition of SAI Global’s Compliance Boo...

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FCPA Compliance Report
Wirecard Part 9, Bring Lawyers Guns and Money from 2020-10-07T04:00

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecu...

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FCPA Compliance Report
Matt Kelly on the Role of Internal Audit from 2020-10-07T04:00

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Arms...

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FCPA Compliance Report
Jay Rosen on the Lack of Monitorship from 2020-10-06T04:00

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Arms...

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FCPA Compliance Report
Mike Volkov on the Herbalife FCPA Resolution from 2020-10-05T04:01

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Arms...

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FCPA Compliance Report
The Miller&Chevalier 2020 Latin American Corruption Survey-Part 5, 12-Year Retrospective from 2020-10-02T04:03

Welcome to a special five-part podcast series where I take a deep dive into the Miller&Chevalier Chartered Latin American Corruption Survey. Over this five-part series I will visit with firm lawyer...

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FCPA Compliance Report
The Miller&Chevalier 2020 Latin American Corruption Survey-Part 4, Compliance Program Design and Implementation from 2020-10-01T04:05

Welcome to a special five-part podcast series where I take a deep dive into the Miller&Chevalier Chartered Latin American Corruption Survey. Over this five-part series I will visit with firm lawyer...

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FCPA Compliance Report
Lies, Spies and Wirecard from 2020-09-30T17:13:35

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecu...

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FCPA Compliance Report
The Miller&Chevalier 2020 Latin American Corruption Survey-Part 3, Compliance Trends from 2020-09-30T04:05

Welcome to a special five-part podcast series where I take a deep dive into the Miller&Chevalier Chartered Latin American Corruption Survey. Over this five-part series I will visit with firm lawyer...

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FCPA Compliance Report
The Miller&Chevalier 2020 Latin American Corruption Survey-Part 2, Country Specific Corruption Issues from 2020-09-29T04:05

Welcome to a special five-part podcast series where I take a deep dive into the Miller&Chevalier Chartered Latin American Corruption Survey. Over this five-part series I will visit with firm lawyer...

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FCPA Compliance Report
The Miller&Chevalier 2020 Latin American Corruption Survey-Part 1, Introduction from 2020-09-28T04:05

Welcome to a special five-part podcast series where I take a deep dive into the Miller&Chevalier Chartered 2020 Latin American Corruption Survey. Over this five-part series I will visit with firm l...

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FCPA Compliance Report
Wirecard-Part 6, End of Summer Wrap UP from 2020-09-23T13:22:38

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors.  Mikhail’s areas of expertise include technology, privacy, cybersec...

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FCPA Compliance Report
John Fons and Current Issues Facing CCOs from 2020-09-21T04:01

In this episode, I visit with John Fons. Over his career, Fons has been the Director, Global Compliance&Ethics, Modine Manufacturing, Senior Counsel, Modine Manufacturing, General Counsel, Joy Glob...

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FCPA Compliance Report
Jordan Arnold and Surjeet Mahant on the DFS Cyber Enforcement Action on First American Title from 2020-09-14T04:01

In this episode, I take a deep dive into the first cyber-security enforcement action brought by the state of New York, Department of Financial Services. It was against First American Title. In this...

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FCPA Compliance Report
Special 500th Anniversary Episode from 2020-08-31T12:49:55

The FCPA Compliance Report is the longest running podcast in compliance. Today, I am extraordinarily honored to post my 500th Anniversary podcast. Today, I switch seats to be the guest as I am inte...

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FCPA Compliance Report
Jonathan Marks on the Evolution of Compliance Through the Eyes of Internal Audit from 2020-08-28T04:00

The FCPA Compliance Report is the longest running podcast in compliance, premiering on July 31, 2015. This week begins a series of podcasts leading up to the 500th anniversary episode of the FCPA C...

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FCPA Compliance Report
Jay Rosen on Changes from the Compliance Vendor Perspective from 2020-08-27T04:00

The FCPA Compliance Report is the longest running podcast in compliance, premiering on July 31, 2015. This week begins a series of podcasts leading up to the 500th anniversary episode of the FCPA C...

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FCPA Compliance Report
Jonathan Armstrong on the UKBA, GDPR and Modern Slavery Compliance from 2020-08-26T04:00

The FCPA Compliance Report is the longest running podcast in compliance, premiering on July 31, 2015. This week begins a series of podcasts leading up to the 500th anniversary episode of the FCPA C...

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FCPA Compliance Report
Matt Kelly on Changes Seen by the 4th Estate from 2020-08-25T04:00

The FCPA Compliance Report is the longest running podcast in compliance, premiering on July 31, 2015. This week begins a series of podcasts leading up to the 500th anniversary episode of the FCPA C...

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FCPA Compliance Report
Mike Volkov on Changes in FCPA Enforcement from 2020-08-24T04:00

The FCPA Compliance Report is the longest running podcast in compliance, airing on July 31, 2015. This week begins a series of podcasts leading up to the 500th anniversary episode of the FCPA Compl...

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FCPA Compliance Report
Wirecard and Fraud from 2020-08-19T19:35:03

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecu...

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FCPA Compliance Report
Eric Lorber on How the Trade Sanction Sausage is Made from 2020-08-17T16:15:46

Ever wonder how the sausage is made around economic and trade sanctions? What is the process for persons and companies to be put on the sanctioned lists? Then this is the podcast for you as I am jo...

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FCPA Compliance Report
Mikhail Reider-Gordon on AML and Wirecard, Part 1 from 2020-08-12T20:41:05

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors.  Mikhail’s areas of expertise include technology, privacy, cybersec...

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FCPA Compliance Report
James Koukios on the MoFo Top 10 International Anti-Corruption Developments for March 2020 from 2020-08-10T04:04

In the Episode, I visit with James Koukios, partner at Morrison&Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 Internati...

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FCPA Compliance Report
WireCard and Germany Inc. from 2020-08-05T21:23

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors.  Mikhail’s areas of expertise include technology, privacy, cybersec...

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FCPA Compliance Report
Mike DeBernardis on 2020 Update to the Evaluation of Corporate Compliance Programs and FCPA Resource Guide, 2nd edition from 2020-08-03T04:03

In the Episode, I am joined by Mike DeBernardis, Counsel at Hughes Hubbard, in the firm’s Washington office and a member of the firm’s Anti-Corruption and Internal Investigations and White Collar&R...

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FCPA Compliance Report
Wirecard and Short Sellers from 2020-07-30T14:43

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecu...

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FCPA Compliance Report
Gordon Platt-from Investigative Journalism to White Collar Defense from 2020-07-27T04:04

In the Episode, I am joined by Gordon Platt.  Platt is an attorney, award-winning investigative journalist and filmmaker, and long-time entrepreneur and strategic consultant. His legal practice foc...

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FCPA Compliance Report
Wirecard-a podcast series on the scandal, with Mikhail Reider-Gordon, Part 1-Introduction from 2020-07-20T04:01

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics&Integrity at Affiliated Monitors.  Mikhail’s areas of expertise include technology, privacy, cybersec...

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FCPA Compliance Report
Eric Young on the Plumbing and Wiring of Compliance from 2020-07-13T04:00

In the Episode, I am joined by Eric Young. Eric has been in the compliance field longer than anyone I know and long before it was called Compliance. Eric graduated from Columbia University at the a...

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FCPA Compliance Report
Compliance Line 2020 Hotline Benchmark Report from 2020-07-06T04:02

In the Episode, I am joined Compliance Line co-CEOs Nick and Gio Gallo to discuss the firm’s 2020 Ethics and Compliance Hotline Benchmark Report. We consider various issues related to the Report in...

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FCPA Compliance Report
Louis Perold on the State of Compliance In South Africa from 2020-06-29T04:04

In the Episode, I am joined by Louis Perold, founder of Citadel Compliance. Perold has with more than 20 years’ experience in legal and compliance across various industries including financial, oil...

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FCPA Compliance Report
Stanley Foodman on the Travel Act and FCPA from 2020-06-22T04:07

In the Episode, I am joined by Stanley Foodman, President and CEO of Foodman CPAs&Advisors. He is a bilingual professional that specializes in Forensic Accounting, Complex Tax and Financial Institu...

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FCPA Compliance Report
Ian McDougall on the Rule of Law from 2020-06-15T04:03

In this episode, I am joined by Ian McDougall, the General Counsel for LexisNexis. He is also the President of the LexisNexis Rule of Law Foundation. McDougall is also the Chair of the Global Marke...

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FCPA Compliance Report
Loren Steffy with Reflections on the 25th Anniversary of Oklahoma City Bombing from 2020-06-08T04:03

In the Episode, I am joined by Loren Steffy. I met Loren when he was the business columnist for the Houston Chronicle. Steffy now has his own consulting practice. He has been a long-time business j...

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FCPA Compliance Report
Kevin Abikoff and Aline Osorio on Distribution of Proceeds from ABC Enforcement Actions from 2020-06-01T04:02

In the Episode, I am joined by Kevin Abikoff, partner at Hughes Hubbard and Aline Osorio, International Specialist at the firm. The co-authored a very interesting article entitled “Corruption Settl...

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FCPA Compliance Report
John Warren on 2020 ACFE Report to the Nations from 2020-05-18T04:02

In the Episode, I am joined by John Warren Vice President and General Counsel at the Association of Certified Fraud Examiners (ACFE). We discuss the 2020 ACFE Report to the Nations, which is the mo...

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FCPA Compliance Report
Joel Androphy on the Role of the FCA in Fighting Government Procurement Fraud from 2020-05-10T15:43

In the Episode, I am joined by Joel Androphy, co-founder at Berg&Androphy. Joel is well-known literally across the country as a white-collar defense lawyer and plaintiff’s counsel in high-profile F...

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FCPA Compliance Report
Mike DeBernardis on Q1 FCPA Enforcement Highlights from 2020-05-03T16:24:17

In the Episode, I am joined by Mike DeBernardis, Counsel and Hughes Hubbard. We review the Foreign Corrupt Practices Act enforcement from Q1 and take a look into that veiled land of the future.  So...

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FCPA Compliance Report
From the Unthinkable to a Culture of Compliance-Lucas Bianchini on Environmental Compliance in Brazil from 2020-04-27T04:14

In this special podcast series, I visit with lawyers from Azevedo Sette in Sao Paulo. The lawyers and topics include: Isabel Franco on a CarWash changed a culture, Lucas Bianchini on environmental ...

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FCPA Compliance Report
From the Unthinkable to a Culture of Compliance- Ingrid Santos and Guiliana Boniha on #MeToo and Sexual/Moral Harassment from 2020-04-27T04:13

In this special podcast series, I visit with lawyers from Azevedo Sette in Sao Paulo. The lawyers and topics include: Isabel Franco on a CarWash changed a culture, Lucas Bianchinni on environmental...

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FCPA Compliance Report
From the Unthinkable to a Culture of Compliance- Glaucia Ferreira on Background Investigations from 2020-04-27T04:12

In this special podcast series, I visit with lawyers from Azevedo Sette in Sao Paulo. The lawyers and topics include: Isabel Franco on a CarWash changed a culture, Lucas Bianchinni on environmental...

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FCPA Compliance Report
From the Unthinkable to a Culture of Compliance-Luiz Salles on Investigations and Anti-Trust Compliance from 2020-04-27T04:11

In this special podcast series, I visit with lawyers from Azevedo Sette in Sao Paulo. The lawyers and topics include: Isabel Franco on a CarWash changed a culture, Lucas Bianchinni on environmental...

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FCPA Compliance Report
From the Unthinkable to a Culture of Compliance-How a Car Wash Changed a Culture, Isabel Franco from 2020-04-27T04:10

In this special podcast series, I visit with lawyers from Azevedo Sette in Sao Paulo. The lawyers and topics include: Isabel Franco on a CarWash changed a culture, Lucas Bianchinni on environmental...

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FCPA Compliance Report
Susan Divers on LRN’s 2020 Compliance Program Effectiveness Report from 2020-04-27T04:03

In the Episode, I visit with Susan Divers, Senior Executive at LRN. Susan is one of the leaders of the LNR team which annually produces the Program Effectiveness Report. The 2020 version has been r...

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FCPA Compliance Report
Pat Harned on ECI’s IMPACT 2020 from 2020-04-20T04:00

In the Episode, I visit with Pat Harned, President of the Ethics&Compliance Initiative (ECI). We discuss ECI’s upcoming virtual conference IMPACT 2020. As the first major compliance annual conferen...

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FCPA Compliance Report
James Koukios on the MoFo Top 10 International Anti-Corruption Developments for February 2020 from 2020-04-13T04:03

In the Episode, I visit with James Koukios, partner at Morrison&Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 Internati...

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FCPA Compliance Report
Karen Woody on Profit Disgorgement at the Supreme Court from 2020-04-06T04:03

In the Episode, I visit with Karen Woody, Assistant Professor of Law. Her areas of expertise include, Securities Law, Financial Regulation and White-Collar Crime. We visit about the recent Supreme ...

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FCPA Compliance Report
James Koukios on the MoFo Top 10 International Anti-Corruption Developments for January 2020 from 2020-03-30T04:03

In the Episode, I visit with James Koukios, partner at Morrison&Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 Internati...

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FCPA Compliance Report
Quyen Truong on California’s Proposed Mini-CFPB: National Impact and Enforcement Threat from 2020-03-23T04:03

In this Episode, I visit with Quyen Truong, a partner at Stroock&Stroock&Lavan in Washington DC. In this podcast we discuss the firm’s recent article on the national impact of this proposed mini-CF...

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FCPA Compliance Report
Bryan Sillaman on the French Airbus Enforcement Action from 2020-03-16T04:05

In the Episode, I visit with Bryan Sillaman, Managing Partner of the Paris office of Hughes Hubbard&Reed. In this podcast we discuss the French portion of the Airbus anti-corruption enforcement act...

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FCPA Compliance Report
Tony Charles on Managing a 3rd Party Process from 2020-03-09T04:02

In this Episode, I visit with Tony Charles, Chief Client Officer at Steele Compliance Solutions, Inc. In this podcast we discuss the firm’s recent article 3rd Party Due Diligence: Creating a Credib...

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FCPA Compliance Report
Erica Salmon Byrne on Ethisphere’s 2020 WME Honorees from 2020-03-02T05:02

In the Episode, I visit with Erica Salmon Byrne, EVP at Ethisphere, Governance and Compliance and Chair of the Business Ethics Leadership Alliance. In this podcast we discuss Ethisphere’s 2020 Worl...

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FCPA Compliance Report
Airbus-Part 5, Tom Fox with some final thoughts on Airbus from 2020-02-28T05:02

In this special 5-part podcast series on the FCPA Compliance Report, I am considering the Airbus international anti-corruption enforcement action from a variety of perspectives from some of the top...

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FCPA Compliance Report
Airbus-Part 4, Cecilia Fellouse-Guenkel on the French Perspective from 2020-02-27T05:01

In this special 5-part podcast series on the FCPA Compliance Report, I am considering the Airbus international anti-corruption enforcement action from a variety of perspectives from some of the top...

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FCPA Compliance Report
Airbus-Part 3, Jonathan Armstrong on the UK-SFO Enforcement from 2020-02-26T05:01

In this special 5-part podcast series on the FCPA Compliance Report, I am considering the Airbus international anti-corruption enforcement action from a variety of perspectives from some of the top...

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FCPA Compliance Report
Airbus-Part 2 Mike Volkov on ITAR and Trade Sanction Enforcement from 2020-02-25T05:01

In this special 5-part podcast series on the FCPA Compliance Report, I am considering the Airbus international anti-corruption enforcement action from a variety of perspectives from some of the top...

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FCPA Compliance Report
Airbus, Part 1-Jay Rosen on the FCPA Enforcement from 2020-02-24T05:01

In this special 5-part podcast series on the FCPA Compliance Report, I am considering the Airbus international anti-corruption enforcement action from a variety of perspectives from some of the top...

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FCPA Compliance Report
Joanne Taylor on the UK Airbus Enforcement Action from 2020-02-17T05:02

In the Episode, I visit with Joanne Taylor, Managing Director at K2, an industry leading investigative, compliance and cyber defense services firm. Joanne joined K2 Intelligence with 20 years of ex...

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FCPA Compliance Report
James Koukios on the MoFo Top 10 International Anti-Corruption Developments for December 2019 from 2020-02-10T05:01

In the Episode, I visit with James Koukios, partner at Morrison&Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 Internati...

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FCPA Compliance Report
James Koukios on the MoFo Top 10 International Anti-Corruption Developments for November 2019 from 2020-02-03T05:06

In the Episode, I visit with James Koukios, partner at Morrison&Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 Internati...

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FCPA Compliance Report
Day 31 | Levels of due diligence from 2020-01-31T17:00

Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to dete...

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FCPA Compliance Report
Day 30 | Using a root cause analysis for remediation from 2020-01-30T17:00

We previously considered the Prong in the Evaluation that was not present in the Ten Hallmarks of an Effective Compliance Program; that being root cause analysis. The requirement was first raised i...

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FCPA Compliance Report
Day 29 | What is a root cause analysis? from 2020-01-29T17:00

Well known fraud investigator Jonathan Marks, defined a root cause analysis as “a research based approach to identifying the bottom line reason of a problem or an issue; with the root cause, not th...

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FCPA Compliance Report
Day 28 | Post-acquisition integration plan from 2020-01-28T17:00

Your company has just made its largest acquisition ever and your CEO says they want you to have a compliance post-acquisition integration plan on their desk in one week. Where do you begin? A good ...

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FCPA Compliance Report
Day 27 | Pre-acquisition due diligence in mergers and acquisitions from 2020-01-27T17:00

A company that does not perform adequate due diligence prior to a merger or acquisition may face both legal and business risks. Perhaps most commonly, inadequate due diligence can allow a course of...

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FCPA Compliance Report
Philip Urofsky on the Shearman&Sterling 2020 FCPA Digest from 2020-01-27T05:04

In the Episode, I visit with Philip Urofsky, partner at Shearman&Sterling, Editor-in-Chief of the firm’s most excellent FCPA Digest. We visit about the firm’s 2020 FCPA Digest, Recent Trends and Pa...

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FCPA Compliance Report
Day 26 | Operationalizing compliance through payroll from 2020-01-26T17:00

One of the areas articulated in the 2019 Guidance was around payments and payroll. For the both the compliance professional and the corporate payroll function, there is a significant role to play i...

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FCPA Compliance Report
Day 25 | Compliance function in an organization from 2020-01-25T17:00

The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. When it came to the corporate compliance function, 20...

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FCPA Compliance Report
Day 24 | CCO authority and independence from 2020-01-24T17:00

The role of the CCO has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance, under Hallmark Three of the Ten Hallmarks of an Effective Compliance Program, it focused on...

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FCPA Compliance Report
Day 23 | Updates and feedback from 2020-01-23T17:00

One of the critical elements found in the 2019 Guidance is the need to use the information you obtain, whether through risk assessment, root cause analysis, investigation, hotline report or any oth...

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FCPA Compliance Report
Day 22 | Assessing compliance internal controls from 2020-01-22T17:00

Control Testing – Has the company reviewed and audited its compliance program in the area relating to the misconduct? More generally, what testing of controls, collection and analysis of compliance...

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FCPA Compliance Report
Day 21 | Continuous improvement in a compliance program from 2020-01-21T17:00

The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) was very clear about the need for continuous improvement in any compliance program. It stated quite succinctly, “...

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FCPA Compliance Report
Day 20 | Responding to investigative findings from 2020-01-20T17:00

There is nothing like an internal whistleblower report about a compliance violation, the finding of such an issue, or (even worse) a subpoena from the DOJ or notice letter from the SEC to trigger t...

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FCPA Compliance Report
Dave Lefort on 10 Stories CW Will Follow in 2020 from 2020-01-20T07:01

In the Episode, I visit with Dave Lefort, Editor in Chief for Compliance Week. Dave recently wrote “It’s hard to tell whether the age we’re living in is the calm before the storm or if it is the st...

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FCPA Compliance Report
Day 19 | The investigation protocol from 2020-01-19T17:00

After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it, promptly, thoroughly and with competent personnel. Your company should have a ...

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FCPA Compliance Report
Day 18 | Internal reporting and the triaging of claims from 2020-01-18T17:00

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it w...

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FCPA Compliance Report
Day 17 | Managing your third parties from 2020-01-17T17:00

The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners...

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FCPA Compliance Report
Day 16 | The third-party risk management process from 2020-01-16T17:00

As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) devo...

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FCPA Compliance Report
Day 15 | How do you evaluate a risk assessment? from 2020-01-15T17:00

After you complete your risk assessment, you must then translate it into a risk profile. If your estimate of where your bribery risk is greatest is wrong, it will be an effort to address it. As Ben...

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FCPA Compliance Report
Day 14 | Risk Assessments from 2020-01-14T17:00

One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based upon a risk assessment, to underst...

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FCPA Compliance Report
Day 13 |Institutional Justice and The Fair Process Doctrine from 2020-01-13T17:00

Companies have finally come to realize that institutional justice and fairness are perhaps the most basic tenet of any successful workplace. If employees believe they will be treated fairly, it wil...

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FCPA Compliance Report
André H. Paris on the Brazilian Compliance Scene from 2020-01-13T05:00

In the Episode, I visit with André H. Paris, a Brazilian Compliance Consultant and Lawyer. He is a specialist in building a Corporate Culture based on Ethics, Transparency and Respect. Paris has ex...

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FCPA Compliance Report
Day 12 | Financial Incentives for Compliance from 2020-01-12T17:00

One of the areas that many companies have not paid as much attention to in their compliance programs is compensation. However, the DOJ and SEC have long made clear that they view monetary structure...

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FCPA Compliance Report
Day 11 | What is Effective Compliance Training? from 2020-01-11T17:00

One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance program; and to create and foster a culture of comp...

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FCPA Compliance Report
Day 10 | The use of social media in compliance from 2020-01-10T17:00

What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presen...

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FCPA Compliance Report
Day 9 | 360 degrees of compliance communications from 2020-01-09T17:00

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is a...

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FCPA Compliance Report
Day 8 | Internal controls and compliance from 2020-01-08T17:00

What specifically are internal controls in a compliance program? The starting point is the FCPA itself, which requires issuers to devise and maintain a system of internal controls that can reasonab...

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FCPA Compliance Report
Day 7 | Policies and Procedures from 2020-01-07T17:00

There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the government comes knocking. The Evaluation of Co...

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FCPA Compliance Report
Day 6 | The Code of Conduct from 2020-01-06T17:00

What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to wave in regulator’s face during an enforcement action as proof o...

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FCPA Compliance Report
Fry Wernick on the Hoskins Jury Instructions from 2020-01-06T05:00

In the Episode, I visit with Ephraim (Fry) Wernick. He is a partner in the Government Investigations and White-Collar Practice Group at Vinson&Elkins LLP in Washington, DC. Mr. Wernick joined V&E i...

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FCPA Compliance Report
Day 5 | The Board and operationalizing compliance from 2020-01-05T17:00

In addition to a company’s senior management, there is a Board of Directors at the top. Yet the role of the Board is different than that of senior management. For the Board of Director, the Evaluat...

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FCPA Compliance Report
Day 4 | Moving compliance tone down through an organization from 2020-01-04T17:00

Mike Volkov, in a blog post entitled “Mood in the Middle Versus Tone at the Top”, said, “Even when a company does all the right things at the senior management level, the real issue is whether or n...

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FCPA Compliance Report
Day 3 | Leadership’s conduct at the top from 2020-01-03T17:00

Obviously, in every compliance program, the ethical tone of a company and accountability all starts at the top and most specifically senior management. The Evaluation of Corporate Compliance Progra...

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FCPA Compliance Report
Day 2 | Measuring your risk from 2020-01-02T17:00

Operationalizing your compliance program can take many shapes and forms. Using the entire risk management process to embed your compliance program within the contours of your organization is an imp...

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FCPA Compliance Report
Day 1 | What 2019 Brought to Compliance Programs from 2020-01-01T17:00

2019 was a very significant year for every compliance practitioner and compliance program. Not only was it the year with the single highest amount of FCPA enforcement actions, fines and penalties a...

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FCPA Compliance Report
Karen Woody on the SEC year in FCPA Enforcement from 2019-12-30T05:00

In the Episode, I visit with Karen Woody, Assistant Professor of Law at Washington and Lee. Karen was in private practice for many years before going into Academia. She specializes in the SEC and i...

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FCPA Compliance Report
James Koukios on the MoFo October International Anti-Corruption Newsletter from 2019-12-23T05:00

In the Episode, I visit with James Koukios, a partner at Morrison and Foerster in Washington DC. Koukios is a former prosecutor from the Department of Justice who worked in the FCPA Unit. He is bac...

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FCPA Compliance Report
James Koukios on the MoFo September International Anti-Corruption Newsletter from 2019-12-16T05:00

In the Episode, I visit with James Koukios, a partner at Morrison and Foerster in Washington DC. Koukios is a former prosecutor from the Department of Justice who worked in the FCPA Unit. He is bac...

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FCPA Compliance Report
Stacie Hartman on Whistleblowers, the CFTC and the FCPA from 2019-12-09T05:00

In this episode I visit with Stacie Hartman, co-chair of the Financial Services Group at Steptoe&Johnson LLP. She offers insight in how this new appeal to whistleblowers could impact the type or vo...

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FCPA Compliance Report
Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 5: Developments from Brazil with Salim Saud from 2019-12-04T16:13:46

Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard&Reed 2019 FCPA and Anti-Bribery Alert. I visit with five f...

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FCPA Compliance Report
Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 2: Year in FCPA with Laura Perkins from 2019-12-04T16:13:32

Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard&Reed 2019 FCPA and Anti-Bribery Alert. I visit with five f...

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FCPA Compliance Report
Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 3: Anti-Bribery Enforcement in France with Bryan Sillaman from 2019-12-04T16:13:16

Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard&Reed 2019 FCPA and Anti-Bribery Alert. I visit with five f...

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FCPA Compliance Report
Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 4: Developments from Multilateral Development Banks with Michael DeBernardis from 2019-12-04T14:06

Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard&Reed 2019 FCPA and Anti-Bribery Alert. I visit with five f...

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FCPA Compliance Report
Hughes Hubbard 2019 FCPA and Anti-Bribery Alert, Part 1: Overview with Kevin Abikoff from 2019-12-04T14:00

Welcome to a special five-part podcast series from the Compliance Podcast Network. In this series I am taking a look at the Hughes Hubbard&Reed 2019 FCPA and Anti-Bribery Alert. I visit with five f...

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FCPA Compliance Report
Executives at Risk Report Summer/Fall 2019 from 2019-12-02T05:12

In this episode I visit with Lauren Briggerman, Member at Miller&Chevalier and Katherine Pappas, Counsel at Miller&Chevalier about the firm’s most recent edition of the publication Executives at Ri...

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FCPA Compliance Report
Mikhail Gordon on Aspects of Monitorships: Part 5, Evolution of Situations Requiring Monitors from 2019-12-02T05:10

In this special five-part podcast series, I have been joined by Mikhail Reider-Gordon, Managing Director of Global Affairs at Affiliated Monitors, Inc. (AMI) the sponsor of this podcast series. We ...

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FCPA Compliance Report
Mikhail Gordon on Aspects of Monitorships: Part 4, Cultural Differences in Int'l and Domestic US Monitorships from 2019-12-02T05:08

In this special five-part podcast series, I am joined by Mikhail Reider-Gordon, Managing Director of Global Affairs at Affiliated Monitors, Inc. (AMI) the sponsor of this podcast series. In this se...

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FCPA Compliance Report
Mikhail Gordon on Aspects of Monitorships: Part 3, International Teaching from 2019-12-02T05:06

In this special five-part podcast series, I am joined by Mikhail Reider-Gordon, Managing Director of Global Affairs at Affiliated Monitors, Inc. (AMI) the sponsor of this podcast series. In this se...

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FCPA Compliance Report
Mikhail Gordon on Aspects of Monitorships: Part 2, ABA Guidelines on Monitors from 2019-12-02T05:04

In this special five-part podcast series, I am joined by Mikhail Reider-Gordon, Managing Director of Global Affairs at Affiliated Monitors, Inc. (AMI) the sponsor of this podcast series. In this se...

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FCPA Compliance Report
Mikhail Gordon on Aspects of Monitorships: Part 1, Why Independence in a Monitor Matters from 2019-12-02T05:01

In this special five-part podcast series, I am joined by Mikhail Reider-Gordon, Managing Director of Global Affairs at Affiliated Monitors, Inc. (AMI) the sponsor of this podcast series. In this se...

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FCPA Compliance Report
Update on Varsity Blues from 2019-11-18T17:53:37

In this episode I visit with Benjamin Britz, a partner at Hughes Hubbard&Reed. We review the current state of the Varsity Blues prosecutions, including the guilty pleas and those still maintaining ...

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FCPA Compliance Report
Episode 452, Mike Volkov on the Hoskins Jury Verdict from 2019-11-11T05:00

In this episode I visit with Mike Volkov about the Hoskins verdict, which was announced on Friday, November 8. In it Lawrence Hoskins was found guilty on six counts of violating the FCPA, three cou...

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FCPA Compliance Report
Pamela Fierst-Walsh on the Kimberley Process from 2019-11-03T16:38:21

In this episode I visit with Pamela Fierst-Walsh, who works at the US State Department as the Senior Advisor on Conflict&Critical Minerals and U.S. Representative to the Kimberley Process. Every co...

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FCPA Compliance Report
Episode 450-Steven Lofchie and the Cadwalader Cabinet from 2019-10-28T04:01

In this episode I visit with Steven Lofchie, a partner in the NYT office of Cadwalader, Wickersham and Taft. Lofchie and his team have developed an incredible new resource called The Cadwalader Cab...

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FCPA Compliance Report
Francine McKenna with an update on the KPMG-PCAOB Scandal from 2019-10-21T04:00

In this episode I visit with one of my favorite people, Francine McKenna, a reporter at MarketWatch. We check in on the current developments in the KPMG-PCAOB scandal including recent guilty pleas,...

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FCPA Compliance Report
Parth Chanda on integrating data analytics into a compliance platform from 2019-10-14T04:10

In this episode I visit with Parth Chanda, CEO of Lextegrity, a leading technology platform that combines the up-front due diligence approval of planned third-party spend with the analysis of actua...

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FCPA Compliance Report
Why Culture Matters-Episode 5, How is ethical culture a part of an overall ethics and compliance assessment? from 2019-10-14T04:08

Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists ...

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FCPA Compliance Report
Why Culture Matters-Episode 4, How Does a Company Assess its Culture? from 2019-10-14T04:06

Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists ...

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FCPA Compliance Report
Why Culture Matters-Episode 3, the Role of the CCO in Culture from 2019-10-14T04:04

Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists ...

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FCPA Compliance Report
Why Culture Matters-Episode 2, What Factors Influence a Company’s Culture from 2019-10-14T04:02

Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists ...

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FCPA Compliance Report
Why Culture Matters-Episode 1, What is Ethical Culture and Why Does it Matter from 2019-10-14T04:00

Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists ...

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FCPA Compliance Report
Joe Gerard on Conducting Fraud Investigations with Case Management Software from 2019-10-07T04:00

In this episode I visit with Joe Gerard, CEO of i-Sight Software. We consider i-Sight’s recent eBook, Conducting Fraud Investigations with Case Management Software and how case management software ...

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FCPA Compliance Report
The Future of Financial Compliance: Maintaining Oversight from 2019-10-04T14:00

In this special five-part podcast series, I have visited with Phil Fry, VP, Go To Market at Verint, which is the sponsor of this podcast series. In this podcast series, we consider how Verint is ch...

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FCPA Compliance Report
The Future of Financial Compliance: Sustainability from 2019-10-03T14:00

In this special five-part podcast series, I visit with Phil Fry, VP, Go To Market at Verint, which is the sponsor of this podcast series. In this podcast series, we consider how Verint is changing ...

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FCPA Compliance Report
The Future of Financial Compliance-Challenging Accepted Wisdom from 2019-10-03T11:03:52

In this special five-part podcast series, I visit with Phil Fry, VP Go To Market at Verint, which is the sponsor of this podcast series. In this podcast series, we consider how Verint is changing t...

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FCPA Compliance Report
The Future of Financial Compliance: Control from 2019-10-02T14:00

In this special five-part podcast series, I visit with Phil Fry, VP Go To Market at Verint, which is the sponsor of this podcast series. In this podcast series, we consider how Verint is changing t...

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FCPA Compliance Report
The Future of Financial Compliance: Capture from 2019-10-01T14:00

In this special five-part podcast series, I visit with Phil Fry, VP Go To Market at Verint, which is the sponsor of this podcast series. In this podcast series, we consider how Verint is changing t...

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FCPA Compliance Report
Episode 446-Matthew Jacobs on the Juniper Networks FCPA Resolution from 2019-09-30T04:00

In this episode I visit with Matthew Jacobs, a partner at Vinson&Elkins in San Francisco who represented the Audit Committee of the Board of Directors of Juniper Networks in the company’s recently ...

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FCPA Compliance Report
Episode 445- Shon Ramey on the Navex Global Acquisition of Lockpath from 2019-09-23T04:00

In this episode I visit with Shon Ramey, General Counsel at Navex Global. We discuss Navex’s recent acquisition of Lockpath. In addition to his discussion on how Lockpath fits into the strategic pl...

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FCPA Compliance Report
Jim Murphy on the Dangers in Using Slack from 2019-09-16T04:00

In this episode I visit with podcast favorite Jim Murphy, who is the VP of Products at Hanzo. We discuss a recent article by Murphy which appeared on Corporate Compliance Insights and was entitled,...

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FCPA Compliance Report
James Koukios on the Morrison and Foerster Top 10 International Anti-Corruption Developments for April 2019 from 2019-09-09T04:00

In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for April 2019. We look at some of the key ...

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FCPA Compliance Report
Episode 442-Serco Geografix DPA from 2019-08-26T04:02

In this episode I visit with Sacha Harber-Kelly, a partner at Gibson Dunn in the UK and Steve Melrose, a senior Associate at the firm. They authored what I think is one of the best summaries of the...

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FCPA Compliance Report
Episode 441- Compliance Training to Influence Behavior from 2019-08-19T04:00

In this episode I visit with Matt Galvin, Vice President, Ethics&Compliance at Anheuser-Busch InBev and Peter Grossman, Co-Founder, Chief Strategist at Labyrinth Training about their work on compli...

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FCPA Compliance Report
Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part V-Cost Issues When Hiring a Monitor from 2019-08-12T04:10

This week, over a five-part podcast series, we have considered some of the basic questions around monitors and monitorships. I have been joined in this exploration by Jay Rosen, the Vice President ...

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FCPA Compliance Report
Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part IV-Considerations When Hiring a Monitor from 2019-08-12T04:08

In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Developme...

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FCPA Compliance Report
Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part III-the Power of a Pre-Settlement Monitorship from 2019-08-12T04:06

In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Developme...

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FCPA Compliance Report
Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part II-Post-Resolution Monitorships from 2019-08-12T04:02

In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Developme...

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FCPA Compliance Report
Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part I-Introduction from 2019-08-12T04:00

In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Developme...

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FCPA Compliance Report
Jesse Caplan on the DOJ Evaluation of Corporate Compliance Programs for Antitrust from 2019-08-05T04:00

In this episode I visit with Affiliated Monitor’s Managing Director Jesse Caplan on the recently released DOJ Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations.  High...

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FCPA Compliance Report
FCPA Compliance Report-Episode 439, James Koukios on the Morrison and Foerster Top 10 International Anti-Corruption Developments for March 2019 from 2019-07-29T04:00

In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for March 2019. We look at some of the key ...

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FCPA Compliance Report
Bonus Episode-Mike Volkov's Interviews the Compliance Evangelist for 100th Episode of Corruption Crime and Compliance from 2019-07-27T04:00

This special bonus episode is a cross-post of Mike Volkov's 100th episode podcast, where he interviewed me. It was a ton of fun and Mike was gracious enough to allow me to post on the FCPA Complian...

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FCPA Compliance Report
Bonus Episode-Sean Freidlin Interviews Elizabeth O'Keefe from 2019-07-26T04:00

In this special bonus episode, In the newest episode of Hanzo's Profiles in Excellence series, Sean Freidlin interviews Elizabeth O'Keefe, Compliance Manager at KAYAK and OpenTable. Their conversat...

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FCPA Compliance Report
The Use of Monitors by State Attorneys General: Part V-The Road Ahead from 2019-07-22T04:10

In this five-part podcast series, I consider the use of monitors by state Attorneys General. I am joined in this podcast series by Jerry Coyne, the Managing Director of State Monitoring Services at...

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FCPA Compliance Report
The Use of Monitors by State Attorneys General: Part IV-The Challenges of Multi-state in Today’s Litigation Environment from 2019-07-22T04:08

In this five-part podcast series, I consider the use of monitors by state Attorneys General. I am joined in this podcast series by Jerry Coyne, the Managing Director of State Monitoring Services at...

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FCPA Compliance Report
The Use of Monitors by State Attorneys General: Part III-Multistate Litigation in the Post-Tobacco Era from 2019-07-22T04:06

In this five-part podcast series, I consider the use of monitors by state Attorneys General. I am joined in this podcast series by Jerry Coyne, the Managing Director of State Monitoring Services at...

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FCPA Compliance Report
The Use of Monitors by State Attorneys General: Part II-Reaction to the Big Tobacco Settlement and Criticisms of State Attorneys General from 2019-07-22T04:04

In this five-part podcast series, I consider the use of monitors by state Attorneys General. I am joined in this podcast series by Jerry Coyne, the Managing Director of State Monitoring Services at...

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FCPA Compliance Report
The Use of Monitors by State Attorneys General-Part I: The Role of State Attorneys General as Enforcers from 2019-07-22T04:02

In this five-part podcast series, I consider the use of monitors by state Attorneys General. I am joined in this podcast series by Jerry Coyne, the Managing Director of State Monitoring Services at...

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FCPA Compliance Report
FCPA Compliance Report-Episode 438, Michael DeBernardis on The China Initiative and FCPA Enforcement from 2019-07-22T04:01

In this episode of the FCPA Compliance Report, I visit Michael DeBernardis, Counsel at Hughes Hubbard. We discuss the Trump Administration’s China Initiative and how it may impact FCPA enforcement ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 437, Kelly Leonard on The Second City Works and Compliance from 2019-07-15T04:00

In this episode of the FCPA Compliance Report, I visit Kelly Leonard, Executive Director, Insights and Applied Improvisation at The Second City Works. We discuss the compliance training which The S...

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FCPA Compliance Report
FCPA Compliance Report-Episode 436, Justin Muscolino on Creating eLearning Training from 2019-07-08T04:00

In this episode of the FCPA Compliance Report, I visit Justin Muscolino, Head of North American Compliance Training Operations for GRC Solution.  Some of the highlights include:  Why do organizatio...

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FCPA Compliance Report
FCPA Compliance Report-Episode 435, Dave Lefort on Compliance Week’s Re-platforming from 2019-07-02T04:00

In this episode of the FCPA Compliance Report, I visit Dave Lefort, Editor of Compliance Week. We discuss the re-platforming of the Compliance Week website. Some of the highlights include:  The nea...

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FCPA Compliance Report
FCPA Compliance Report-Episode 434, Brandon Daniels on Using Investigations to Drive Continuous Improvement from 2019-07-01T04:00

In this episode of the FCPA Compliance Report, I visit with Brandon Daniels, who is the President of Global Technology Markets for Exiger. Daniels is regulatory expert and technology practitioner, ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 433, Sean Freidlin on the Current State of Internal Investigations from 2019-06-27T04:04

In this episode I visit with Sean Freidlin, the Senior Product Marketing Manager, Compliance at Hanzo. We take a deep dive into the state of compliance investigation in 2019, focusing on the impact...

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FCPA Compliance Report
The Current State of Compliance - Issues and Challenges: Part 5 - New Compliance Concerns in Healthcare from 2019-06-24T04:10

Over this five-part podcast series, I have visited with Terry L Orr, a Managing Director at Kroll, a division of Duff&Phelps, and the sponsor of this podcast series. We have taken a comprehensive l...

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FCPA Compliance Report
The Current State of Compliance - Issues and Challenges: Part 4 - Private Equity and Compliance from 2019-06-24T04:08

In this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff&Phelps, the sponsor of this podcast series. We visit on the current state of compliance ...

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FCPA Compliance Report
The Current State of Compliance - Issues and Challenges: Part 3 - Evaluation of Corporate Compliance Programs from 2019-06-24T04:06

During this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff&Phelps, the sponsor of this podcast series. We visit on the current state of complia...

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FCPA Compliance Report
Walmart FCPA Settlement from 2019-06-24T04:05

In this special bonus podcast, I am joined by Jay Rosen to discuss the stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, t...

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FCPA Compliance Report
The Current State of Compliance - Issues and Challenges: Part 2 - Lessons Learned from Recent Enforcement Actions from 2019-06-24T04:02

In this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff&Phelps, the sponsor of this podcast series. We visit on the current state of compliance ...

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FCPA Compliance Report
The Current State of Compliance - Issues and Challenges: Part 1 - Orr and his Journey to Compliance from 2019-06-24T04:00

In this five-part podcast series, I visit with Terry L Orr, a Managing Director at Kroll, a division of Duff&Phelps, the sponsor of this series. We visit on the current state of compliance through ...

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FCPA Compliance Report
Impacts of Emerging Regulations: Part 5- Scaling to Meet Change from 2019-06-17T04:10

In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I have explored the market impacts of emerging regulations on supply chain compliance and the supply chain profession...

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FCPA Compliance Report
Impacts of Emerging Regulations: Part 4- the Current State of Responsible Minerals from 2019-06-17T04:08

In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During...

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FCPA Compliance Report
Impacts of Emerging Regulations: Part 3- What is Your CSR Value Proposition? from 2019-06-17T04:06

In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During...

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FCPA Compliance Report
Impacts of Emerging Regulations: Part 2- Instituting a Broader Risk Management Program from 2019-06-17T04:02

In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During...

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FCPA Compliance Report
Impacts of Emerging Regulations: Part 1 – The HTS Landscape from 2019-06-17T04:00

In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During...

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FCPA Compliance Report
FCPA Compliance Report-Episode 432, Mark Lanpher on DOJ Change in M&A Enforcement under the FCPA from 2019-06-10T04:00

In this episode I visit with Mark Lanpher, a partner at Shearman&Sterling LLP, practicing in the firm’s White Collar and Regulatory Enforcement group. Lanpher is a former Assistant Chief Litigation...

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FCPA Compliance Report
Life With GDPR: Episode 29- GDPR Year 1 Review-Part II, the Issues from 2019-06-06T04:03

In this podcast, data privacy/data security expert Jonathan Armstrong and Compliance Evangelist Tom Fox use the framework of GDPR to discuss a wide range of issues relating to these topics. They co...

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FCPA Compliance Report
Daily Compliance News: June 4, 2019, the leadership edition from 2019-06-04T04:00

In today’s edition of Daily Compliance News:Why are bashful bosses better leaders? (FT)Leaders must know their weaknesses better than their strengths? (FT)A key leadership problem-setting boundarie...

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FCPA Compliance Report
FCPA Compliance Report-Episode 431, Pat Harned On ECI's Impact 2019 Wrap Up from 2019-06-03T04:11

In this episode I visit with Pat Harned, CEO at the Ethics and Compliance Initiative. We discuss the ECI’s recently concluded annual conference, Impact and some of the highlights for both Pat and m...

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FCPA Compliance Report
DOJ 2019 Guidance: Part V – Final Thoughts from 2019-06-03T04:10

Over the course of this podcast series, sponsored by Affiliated Monitors, Inc. (AMI), I have visited with Eric Feldman, Senior Vice President of AMI. We have considered the Department of Justice (D...

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FCPA Compliance Report
DOJ 2019 Guidance: Part IV – Does your compliance program work in practice? from 2019-06-03T04:08

Over the course of this podcast series, sponsored by Affiliated Monitors, Inc. (AMI), I am visiting with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) Evalu...

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FCPA Compliance Report
DOJ 2019 Guidance: Part III – Is It Being Effectively Implemented? from 2019-06-03T04:06

This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I am visiting with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) Evaluation of ...

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FCPA Compliance Report
DOJ 2019 Guidance: Part II – Is Your Program Well Designed? from 2019-06-03T04:02

This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I am visiting with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) Evaluation of ...

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FCPA Compliance Report
DOJ 2019 Guidance: Part I - Introduction from 2019-06-03T04:00

This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) Evaluation of Corpor...

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FCPA Compliance Report
Daily Compliance News: June 1, 2019-the Management Incentives edition from 2019-06-01T04:00

In today’s edition of Daily Compliance News:What are management incentives?(Huffington Post)Vale employees warned of dam collapse and were ignored. (WSJ)Think meetings are bad? Just wait until you ...

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FCPA Compliance Report
Daily Compliance News: May 31, 2019-the May is done edition from 2019-05-31T04:04

In today’s edition of Daily Compliance News:CITGO now part of PdVSA/Venezuelan corruption scandal. (Houston Chronicle)Who else did Chuck Blazer bribe? (NYT)Who is in your supply chain? (FT)Former h...

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FCPA Compliance Report
Life With GDPR: Episode 28- GDPR Year 1 Review-Part I, the Numbers from 2019-05-30T04:10

In this podcast, data privacy/data security expert Jonathan Armstrong and Compliance Evangelist Tom Fox use the framework of GDPR to discuss a wide range of issues relating to these topics. They co...

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FCPA Compliance Report
Daily Compliance News: May 30, 2019-is a spanking is coming edition from 2019-05-30T04:05

In today’s edition of Daily Compliance News: Is the SEC useless? Mark Cuban thinks so. (Yahoo Finance)Monitor orderd for Wynn Casinos in Massachusettes. (WSJ)Frederick Pierucci continues his crusad...

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FCPA Compliance Report
Bonus Episode-Compliance Week 2019 Wrap Up from 2019-05-29T10:00

In this special bonus podcast, I am joined by the co-hosts of Great Women in Compliance, Lisa Fine and Mary Shirley as well as Amii Bernard-Bahn. We all participated in the recently concluded Compl...

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FCPA Compliance Report
Daily Compliance News: May 29, 2019-the Workers Unite edition from 2019-05-29T04:02

 In today’s edition of Daily Compliance News:Braskem Board OK’s $101MM for corruption settlement. (Reuters)Mexican steel company shut down by Mexican government for AML violations. (FT)Workers of A...

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FCPA Compliance Report
Daily Compliance News: May 27, 2019-the Memorial Day edition from 2019-05-27T13:08

In today’s edition of Daily Compliance News: ·       Is corruption across the EU ‘stunning’? (BBC)·       What is management duty to set right tone at the top? (Harvard Law School Forum on Corporat...

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FCPA Compliance Report
Leveraging AI in Compliance Investigation: Part 5 – Where are investigations headed? from 2019-05-27T04:09

Today we conclude a five-part podcast series sponsored by Hanzo, where we have considered how to leverage Artificial Intelligence (AI) in compliance investigations. I have been joined by several me...

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FCPA Compliance Report
Leveraging AI in Compliance Investigation: Part 4-Improving Investigative Efficiencies from 2019-05-27T04:08

I am on a five-part podcast series sponsored by Hanzo. In this series we consider how to leverage artificial intelligence (AI) in compliance investigations. In this series I am joined by several me...

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FCPA Compliance Report
Leveraging AI in Compliance Investigation: Part 3-Overcoming Investigative Challenges from 2019-05-27T04:04

This week I embark on a five-part podcast series sponsored by Hanzo. In this series we consider how to leverage artificial intelligence (AI) in compliance investigations. In this series I am joined...

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FCPA Compliance Report
Leveraging AI in Compliance Investigation: Part 2-Using AI and Web-Based Evidence from 2019-05-27T04:02

This week I embark on a five-part podcast series sponsored by Hanzo. In this series we consider how to leverage artificial intelligence (AI) in compliance investigations. In this series I am joined...

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FCPA Compliance Report
Leveraging AI in Compliance Investigation: Part 1-Current State of Investigations from 2019-05-27T04:00

This week I embark on a five-part podcast series sponsored by Hanzo. In this series we consider how to leverage artificial intelligence (AI) in compliance investigations. In this series I am joined...

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FCPA Compliance Report
Daily Compliance News: May 26, 2019-the Sunday Book Review edition from 2019-05-26T04:00

n today’s edition of Daily Compliance News:Oliver Wendall Holmes by Stephen BudianskyBrothers Down by Walter BornemanSacred Duty by Tom CottonRise and Fall: The Story of 9/11 by Mitchell Zuckoff Le...

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FCPA Compliance Report
Daily Compliance News: May 25, 2019-the execs behaving badly edition from 2019-05-25T04:00

In today’s edition of Daily Compliance News:Chief Executives behaving badly. (Financial Times)Deloitte offices raided in connection with 1MDB scandal. (Channel News Asia)What is leadership? (WSJ)Wh...

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FCPA Compliance Report
Daily Compliance News: May 24, 2019-the Memorial Day Weekend edition from 2019-05-24T04:00

In today’s edition of Daily Compliance News:BeIN Media Group CEO charged in corruption scandal. (FoxNews)Deutche Bank finds flaw in reporting system. (Wall Street Journal)Whose in your supply chain...

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FCPA Compliance Report
Daily Compliance News: May 23, 2019-the life or death from 2019-05-23T10:46

In today’s edition of Daily Compliance News: Guyana Investigating Leases Controlled by Exxon&Tullow (Bloomberg)In EU 75% of those who observe illegal corp activity afraid to report it. (FT)KPMG to ...

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FCPA Compliance Report
Daily Compliance News: May 22, 2019, the what is ethics edition from 2019-05-22T04:00

In today’s edition of Daily Compliance News:What is ethics? Pimco and Rick Singer (WSJ)Big changes coming to Corporate Leniency Program? (DOJ Press Release)France seeks trial of former IAAF head. (...

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FCPA Compliance Report
Daily Compliance News: May 20, 2019, Compliance Week 2019 is here edition from 2019-05-20T10:16:20

In today’s edition of Daily Compliance News: ·       So many myths, so little time. The FT lunches with Laura Codruta Kövesi. (FT)·       Red flags on Trump and Kushner? I’m shocked. (New York Time...

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FCPA Compliance Report
Maintaining Market Access: Part 5 – Chemical and Product Compliance from 2019-05-20T04:10

During this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I have explored market access for supply chain data. I have visited with several Assent team members to introduce...

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FCPA Compliance Report
Maintaining Market Access: Part 4 - FARs flow downs from 2019-05-20T04:08

Over this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I have been exploring market access for supply chain data. I have visited with several Assent team members to intro...

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FCPA Compliance Report
Maintaining Market Access: Part 3 - Continuous Monitoring in Trade Compliance from 2019-05-20T04:06

In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market access for supply chain data. Over this series, I have visited with several Assent team members to i...

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FCPA Compliance Report
Maintaining Market Access: Part 2 - Trade Compliance from 2019-05-20T04:03

In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market access for supply chain data. In this series, I visit with several Assent team members to introduce ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 430, Scott Moritz on a Forensic Response to Varsity Blues from 2019-05-20T04:01

In this episode I visit with Scott Moritz, the Global Lead, Protiviti Forensics. We discuss the Varsity Blues scandal from the forensic perspective. Some of the highlights from the podcast include:...

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FCPA Compliance Report
Maintaining Market Access: Part 1 - Introduction to Market Access from 2019-05-20T04:00

In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market access for supply chain data. During the course of this series, I visit with several members of the ...

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FCPA Compliance Report
Daily Compliance News: May 19, 2019-the Sunday Book Review-con men edition from 2019-05-19T04:00

In today’s edition of Daily Compliance News:King Con by Paul WillettsChasing Phil by David HowardUltimate Folly by Henry MacroryDuped by Abbe EllinThe Confidence Game by Maris KonnikovaAdditional r...

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FCPA Compliance Report
Daily Compliance News: May 18, 2019-the more bad news from Brazil edition from 2019-05-18T04:00

In today’s edition of Daily Compliance News: Four more banks named in London bribery suit. (Bloomberg)Can blockchain help in the fight against corruption? (World Economic Forum)South African Presid...

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FCPA Compliance Report
This Week in FCPA-Episode 154 - the Take It Back edition from 2019-05-17T16:26

This week's highlights include: 1.    Uber stumbles at going IPO. What role did its culture, lack of compliance and ethics play? 2.    Belying those who advocate a paper program compliance defense,...

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FCPA Compliance Report
Daily Compliance News: May 16, 2019-the CEOs and ethical lapses edition from 2019-05-16T04:00

In today’s edition of Daily Compliance News:More business leaders forced out for ethical lapses than for poor financial performance in 2019. (Washington Post)Do large companies fear legal violation...

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FCPA Compliance Report
Everything Compliance-Episode 46, the Justice Department's 2019 Guidance for FCPA Compliance Programs from 2019-05-15T11:52

Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Armstrong and our newest colleague, Sarah Hadden. We take on on...

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FCPA Compliance Report
Compliance into the Weeds: Episode 123-Whistleblower Protection from 2019-05-15T04:05

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: May 15, 2019-the whistleblower protection edition from 2019-05-15T04:00

In today’s edition of Daily Compliance News: ·       FCA Whistleblowers given additional protection by US Supreme Court . (Mondovisione)·       More regulatory on capture of the FAA by Boeing? (Wal...

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FCPA Compliance Report
Daily Compliance News: May 14, 2019-the from bad to worser edition edition from 2019-05-14T04:00

In today’s edition of Daily Compliance News:Judge scolds SEC over VW lawsuit. (WSJ)With friends like this? (Corporate Counsel)Bombadier faces World Bank debarment. (org.cn)Things go from bad to ter...

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FCPA Compliance Report
Daily Compliance News: May 13, 2019-the regime change edition from 2019-05-13T04:00

In today’s edition of Daily Compliance News:DOJ asks Judge to remove lead defense counsel for Huawei. (NYT)Did cost cutting cause Boeing 737 Max crashes? (Bloomberg)House Financial Services approve...

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FCPA Compliance Report
FCPA Compliance Report-Bonus Episode-ECI High Quality Program Framework Assessent from 2019-05-13T04:00

In special bonus episode, I present a full hour's presentation of a panel discussion I recently chaired at the ECI Impact 2019 conference. The panel consisted of Steve Scarpino, Director, Ethics an...

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FCPA Compliance Report
Daily Compliance News: May 11, 2019-the what is data security edition from 2019-05-11T11:25

In today’s edition of Daily Compliance News: ·      What is data security? Ask Jonathan Armstrong. (Financial Times)·      Uber tanks at IPO opening. What did compliance have to do with it? (WSJ)· ...

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FCPA Compliance Report
This Week in FCPA-Episode 153 – the You’ll Never Walk Alone edition from 2019-05-10T04:06

A big tip of the hat to the Liverpool Football Club for its stunning 4-0 trouncing of Barcelona at Anfield to roar back into the Champions League finals for the second consecutive year. With Tom st...

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FCPA Compliance Report
Daily Compliance News: May 10, 2019-the what is hubris edition from 2019-05-10T04:02

In today’s edition of Daily Compliance News:Theranos founder Elizabeth Holmes defense? The government defrauded Theranos (not the other way around). (New York Times)Wells Fargo creates new complian...

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FCPA Compliance Report
Daily Compliance News: May 9, 2019-the regime change edition from 2019-05-09T04:00

In today’s edition of Daily Compliance News: ·       Regime change and more corruption claims. (Bloomberg)·       Another guilty plea in NCAA hoops bribery scandal. (NY Daily News)·       US return...

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FCPA Compliance Report
Daily Compliance News: May 8, 2019-the Is He or Isn’t He edition from 2019-05-08T05:00

In today’s edition of Daily Compliance News: Judge says Roger Ng in negotiations with the DOJ, although his lawyer denies it. (New York Times)Colleges in ‘Willful Ignorance’ of corruption, say it a...

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FCPA Compliance Report
Daily Compliance News: May 7, 2019-the Welcome to the US edition from 2019-05-07T05:01

In today’s edition of Daily Compliance News: ·       Roger Ng extradited to US. (New York Times)·       Closing arguments made in NCAA bribery scandal case. (ESPN)·       Hell hath no fury like a c...

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FCPA Compliance Report
Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 5, In Non-Profits and Varsity Blues from 2019-05-06T05:09

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I have been joined by AMI Managing Director Stern. We have considered how defense counsel can work proactively with i...

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FCPA Compliance Report
Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 4, In the Health Care Industry from 2019-05-06T05:07

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent mon...

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FCPA Compliance Report
Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 3, Case Studies of Working with 3rd Party Independents from 2019-05-06T05:05

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent mon...

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FCPA Compliance Report
Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 2, The Nuts and Bolts from 2019-05-06T05:03

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent mon...

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FCPA Compliance Report
Daily Compliance News: May 6, 2019-the Diamonds are Forever edition from 2019-05-06T05:02

In today’s edition of Daily Compliance News: ·       Regulatory capture, regulatory ineptitude or just don’t care? (Washington Post)·       1MDB diamonds headed to US. (Reuters)·       Boeing knew ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 429, James Koukios on MoFo’s February Anti-Corruption Newsletter from 2019-05-06T05:00

In this episode I have back with me, fan favorite James Koukios, partner at Morrison and Foerster.  This is Part 2 of a two-part series where we discuss the firm’s always great Top 10 International...

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FCPA Compliance Report
Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 1, Introduction from 2019-05-06T05:00

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Stern. We consider how defense counsel can work proactively with independent mon...

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FCPA Compliance Report
Daily Compliance News: May 5, 2019-the Sunday Book Review edition from 2019-05-05T05:00

In today’s edition of Daily Compliance News: ·       New David McCullough book. (Wall Street Journal)·       How streaming changed music and us. (Financial Times)·       The Lord Lucan Murder case ...

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FCPA Compliance Report
Daily Compliance News: May 4, 2019-the Enter Slow, Exit fast edition from 2019-05-04T11:44

In today’s edition of Daily Compliance News:What to do when the founder is toxic? (New York Times)Michael Senna informs 3rdparty risk management. (Wall Street Journal)Exxon sues Cuban companies for...

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FCPA Compliance Report
Daily Compliance News: May 3, 2019-the Insys execs guilty edition from 2019-05-03T05:00

In today’s edition of Daily Compliance News: ·  Insys execs found guilty of racketeering. (New York Times)    Is a socialist revolt coming? (New York Times)·       What’s the going rate for paying...

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FCPA Compliance Report
Daily Compliance News: May 2, 2019-the Evaluation edition from 2019-05-02T10:55

In today’s edition of Daily Compliance News: ·      Wall Street Journal·      Radical Compliance·      FCPA Compliance and Ethics Blog (Part 1)·       Board and FraudLearn more about your ad choic...

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FCPA Compliance Report
Life With GDPR: Episode 26- The Importance of Passwords from 2019-05-02T05:03

In this episode, I visit with Jonathan Armstrong a topic which does not seem to garner the attention that it deserves in data protection; that being passwords. Some of the issues and highlights are...

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FCPA Compliance Report
Compliance into the Weeds: Episode 121-The Role of the CRO in ERM from 2019-05-01T05:03

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: May 1, 2019-the May Day edition from 2019-05-01T05:00

In today’s edition of Daily Compliance News: ·      What happens when your customer is hit by scandal? (Wall Street Journal)·      Tear gas and the Whitney, what does it all mean? (New York Times)·...

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FCPA Compliance Report
Daily Compliance News: April 30, 2019-the End of April edition from 2019-04-30T05:00

In today’s edition of Daily Compliance News:Prosecutors ask for hold on Sunny Balwani SEC civil action. (MarketWatch)What’s $5bn among friends? (New York Times)Did Varsity Blues parents engage in a...

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FCPA Compliance Report
Across the Board – Episode 5: The Road Ahead from 2019-04-29T05:11

Over this special 5-part podcast series, I have visited with David Greenberg, Special Advisor at LRN. We took a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board ...

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FCPA Compliance Report
Across the Board – Episode 4: Metrics and Senior Management from 2019-04-29T05:10

In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We are taking a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Boa...

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FCPA Compliance Report
Across the Board – Episode 3: Not Enough Time/Not Enough Depth from 2019-04-29T05:08

In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and...

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FCPA Compliance Report
Daily Compliance News: April 29, 2019-the Welcome to my Tweet-Up edition from 2019-04-29T05:06

In today’s edition of Daily Compliance News:SW Airlines not told of deactivated safety feature on Boeing 737 Max. (Wall Street Journal)Sexual harassment claims hit the energy industry. (I’m shocked...

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FCPA Compliance Report
Across the Board – Episode 2: BOD Understanding and the Game Plan from 2019-04-29T05:04

In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and...

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FCPA Compliance Report
FCPA Compliance Report-Episode 428, James Koukios on MoFo’s January Anti-Corruption Newsletter from 2019-04-29T05:00

In this episode I have back with me, fan favorite James Koukios, partner at Morrison and Foerster.  This is Part 1 of a two-part series where we discuss the firm’s always great Top 10 International...

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FCPA Compliance Report
Across the Board – Episode 1: What’s the Tone at the Very Top from 2019-04-29T05:00

In this special 5-part podcast series, I visit with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compl...

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FCPA Compliance Report
Daily Compliance News: April 28, 2019-the Sunday Book Review edition from 2019-04-28T16:11

In today’s edition of Daily Compliance News: ·      What was behind “Our Man in Havana? (Financial Times)·      Why Ovid is still an inspiration. (New York Times)·       Life of John Hersy. (Wall S...

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FCPA Compliance Report
Episode 106-Metropolis by Philip Kerr from 2019-04-27T05:00

Richard Lummis and I are back and today we head in a different direction. We consider the final Bernie Gunther novel by Philip Kerr Metropolis. It is the final Gunther novel as Kerr died earlier th...

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FCPA Compliance Report
Daily Compliance News: April 27, 2019-the Havlicek stole the ball edition from 2019-04-27T05:00

In today’s edition of Daily Compliance News: ·      What hath Zion wrought? (NY Post)·      Petrobras revisiting its ill treatment of whistleblowers. (Reuters.com)·       Glencore under CFTC invest...

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FCPA Compliance Report
Daily Compliance News: April 26, 2019-the Endgame edition from 2019-04-26T05:06

In today’s edition of Daily Compliance News:DOJ wants Goldman Sachs to plead guilty over 1MDB. (Financial Times)How did Wirecard generate its profits? (Financial Times)UK agrees to use Huawei to bu...

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FCPA Compliance Report
This Week in FCPA-Episode 151 – the World Domination edition from 2019-04-26T05:00

Is the US utilizing FCPA enforcement for world domination? Recovering screenwriter Jay Rosen and frustrated novelist Tom Fox consider this while they also take a look at some of this week’s top com...

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FCPA Compliance Report
Everything Compliance-Episode 45, the Drink the Kool-aid edition from 2019-04-25T05:00

Welcome to the only roundtable podcast in compliance. Today, in Episode 45 we celebrate our newest addition to the Everything Compliance gang; Sarah Hadden. Sarah is the Publisher at Corporate Comp...

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FCPA Compliance Report
Compliance into the Weeds: Episode 120-On the Ethical Tarmac from 2019-04-24T05:03

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: April 24, 2019-the bit player edition from 2019-04-24T05:00

In today’s edition of Daily Compliance News: ·      Opioid distributor faces criminal charges. (New York Times)·      NCAA scandal; little fish=big charges. (New York Times)·       Walmart investig...

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FCPA Compliance Report
Daily Compliance News: April 23, 2019-the pay for information edition from 2019-04-23T05:04

In today’s edition of Daily Compliance News: ·      Should shareholder authorize payments to corrupt execs to tell what they know about corruption. (Bloomberg)·      Google employees claim retaliat...

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FCPA Compliance Report
Supply Chain Data Management: Part -5, Market Drivers for Continued Legislation from 2019-04-22T16:40

In this five-part podcast series, sponsored by Assent Compliance, I have explored supply chain data management. I have visited with several members of the Assent Compliance team to introduce the to...

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FCPA Compliance Report
Supply Chain Data Management: Part -4, Failures in Supply Chain Compliance from 2019-04-22T16:24

In this five-part podcast series, sponsored by Assent Compliance, I explore supply chain data management. In this series, I visit with several members of the Assent Compliance team to introduce the...

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FCPA Compliance Report
Supply Chain Data Management: Part -3, Development of Supply Chain Risk Management from 2019-04-22T16:04

In this five-part podcast series, sponsored by Assent Compliance, I explore supply chain data management. In this series, I visit with several members of the Assent Compliance team to introduce the...

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FCPA Compliance Report
Supply Chain Data Management: Part -2, Introduction to Supply Chain Data Management from 2019-04-22T14:16

In this five-part podcast series, sponsored by Assent Compliance, I explore supply chain data management. In this series, I visit with several members of the Assent Compliance team to introduce the...

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FCPA Compliance Report
Supply Chain Data Management: Part -1, Who is Assent? from 2019-04-22T14:08

In this five-part podcast series, sponsored by Assent Compliance, I explore supply chain data management. In this series, I visit with several members of the Assent Compliance team to introduce the...

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FCPA Compliance Report
Daily Compliance News: April 22, 2019-the asking for a Ferrari edition from 2019-04-22T10:33

In today’s edition of Daily Compliance News: ·      McKesson employee compares asking for compliance resources to ‘asking for a Ferrari’. (New York Times)·      Odebrecht scandal shows no sign of w...

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FCPA Compliance Report
FCPA Compliance Report-Episode 427, Hanzo Q1 2019 Compliance, Risk, and Regulations Research Roundup from 2019-04-22T05:00

In this episode I take things in a bit of a different direction as I am interviewed by Sean Freidlin, Senior Product Marketing Manager, Compliance at Hanzo, on a project commissioned by Hanzo which...

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FCPA Compliance Report
Daily Compliance News: April 19, 2019-the Good Friday edition from 2019-04-19T10:07

In today’s edition of Daily Compliance News:When safety has a training issue, what is the answer? (Wall Street Journal)Where will Fyre bankruptcy lead? (Wall Street Journal)More focus on Peru after...

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FCPA Compliance Report
This Week in FCPA-Episode 150– the Easter/Passover edition from 2019-04-19T05:05

On this weekend, we have the dual celebrations of Easter and Passover. As Tom enjoys the Astros 11-0 run and sweeps of the Yankees and Mariners; Jay mourns his Red Sox going into the doghouse, they...

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FCPA Compliance Report
Life With GDPR: Episode 25- Data Breach=Deadly Consequences from 2019-04-18T05:05

In this episode, I visit with Jonathan Armstrong to consider the recent regulatory fine leveled against London Borough of Newham £145,000 for a data breach involving the data of more than 200 peopl...

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FCPA Compliance Report
Daily Compliance News: April 18, 2019-the what am I going to be edition from 2019-04-18T05:00

In today’s edition of Daily Compliance News: ·      Pension fund demands GE can KPMG. (Accounting Today)·      What will be the role for compliance when it ‘grows up’? (Wall Street Journal)·       ...

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FCPA Compliance Report
Daily Compliance News: April 17, 2019-the whistleblower protection edition from 2019-04-17T05:00

In today’s edition of Daily Compliance News: ·      Ongoing graft in India? I’m shocked! (The Economic Times)·      When is a facilitation payment a bribe? (FCPA Blog)·       Whistleblowers garner ...

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FCPA Compliance Report
Compliance into the Weeds: Episode 119-Rule Making Power Grab from 2019-04-17T05:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: April 16, 2019-the Integrity edition from 2019-04-16T05:05

In today’s edition of Daily Compliance News: ·      What is the most important leadership trait? (Inc.com)·      When is a facilitation payment a bribe? (FCPABlog)·       What happened to one-stop ...

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FCPA Compliance Report
Federal Contractor Responsibility: Part 5-Keeping it Fresh from 2019-04-15T05:30

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Rod Grandon. We have considered the responsibility of federal contractors to mai...

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FCPA Compliance Report
Federal Contractor Responsibility: Part 4-Why Are We Still Talking About This? from 2019-04-15T05:25

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Rod Grandon. We consider the responsibility of federal contractors to maintain t...

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FCPA Compliance Report
Federal Contractor Responsibility: Part 3-Small Business Compliance Programs from 2019-04-15T05:15

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Rod Grandon. We consider the responsibility of federal contractors to maintain t...

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FCPA Compliance Report
Federal Contractor Responsibility: Part 2-What Does the Government Expect from 2019-04-15T05:10

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Rod Grandon. We consider the responsibility of federal contractors to maintain t...

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FCPA Compliance Report
Federal Contractor Responsibility: Part 1-Introduction of Responsible Contractors from 2019-04-15T05:05

In this five-part podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Rod Grandon. We consider the responsibility of federal contractors to maintain t...

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FCPA Compliance Report
Daily Compliance News: April 15, 2019-the Tiger Wins edition from 2019-04-15T05:03

Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
FCPA Compliance Report-Episode 426, Jon Rusch on Dipping Through Geometries from 2019-04-15T05:00

In this episode I finally have Jon Rusch on the podcast. Jon is the author of one of the most recent podcasts in law around law and compliance. His topics include the FCPA, AML, export control, ant...

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FCPA Compliance Report
Daily Compliance News: April 123, 2019-the Saturday the 13th edition from 2019-04-13T12:35

In today’s edition of Daily Compliance News: ·      Les Moonves forfeited $34.5MM in comp. (Wall Street Journal)·      Grant Thornton in how water in UK. (Wall Street Journal)·       Conflict of in...

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FCPA Compliance Report
Daily Compliance News: April 12, 2019-the Uber FCPA investigation edition from 2019-04-12T05:05

In today’s edition of Daily Compliance News: ·      Uber is under FCPA investigation. (FCPA Blog)·      Did you break the rules? Just rewrite them in your favor. (Wall Street Journal)·       Apple ...

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FCPA Compliance Report
This Week in FCPA-Episode 149 – the White Privilege edition from 2019-04-12T05:00

After a one-week hiatus, the lads are back. While debating white privilege and the Varsity Blues scandal, they also take a look at some of this week’s top compliance and ethics stories which caught...

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FCPA Compliance Report
Compliance into the Weeds: Episode 118-Hotline Metrics from 2019-04-11T05:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: April 10, 2019-the $1.1bn edition from 2019-04-10T05:00

In today’s edition of Daily Compliance News: Standard Chartered joins the $1 bn fine club. (New York Times)Are you missing any hotline metrics? (Radical Compliance)AML charges in Varsity Blues, can...

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FCPA Compliance Report
Daily Compliance News: April 9, 2019-the Varsity Blues-guilty pleas edition from 2019-04-09T05:00

APRIL 9, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      First round of guilty pleas in Varsity Blues. (Huffington Post)·      How can you tell if a company is overpaying its CE...

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FCPA Compliance Report
Shakespeare on Compliance – the Fool (In theater and in business) from 2019-04-08T06:00

In this podcast series, I have used the current Broadway performance by Glenda Jackson as King Lear to introduce several compliance topics. Today, I want to discuss the role of The Fool. Initially ...

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FCPA Compliance Report
Shakespeare on Compliance – A Different Interpretation from 2019-04-08T05:50

In this episode, I want to discuss how Jackson, starring in the role of King Lear, added a new level of complexity, nuance and interpretation to the entire play.  Jackson is an octogenarian, the ol...

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FCPA Compliance Report
Shakespeare on Compliance - Engaging Your Audience from 2019-04-08T05:40

In this episode, I want to discuss the opening scene where Lear bids his daughters express the breadth and scope of their love for him.  Lear has called a conference to divide his kingdom between h...

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FCPA Compliance Report
Shakespeare on Compliance - Changing Your Focus from 2019-04-08T05:30

In this episode, I want to discuss how this production changed the focus of the play, away from the madness of the king to the actions of the three daughters.  Perhaps it was my perception of the p...

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FCPA Compliance Report
Shakespeare On Compliance - Innovation from 2019-04-08T05:20

I recently saw the performance ofKing Learwith Glenda Jackson as the mad king. It was a magnificent production and if you have the chance to see, I would certainly urge you to do so. The production...

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FCPA Compliance Report
FCPA Compliance Report-Episode 425, the Fresenius FCPA Enforcement Action from 2019-04-08T05:00

In this episode I have back fan fav Mike Volkov. We break down the recently released Fresenius FCPA enforcement action. Some of the highlights from the podcast include: Ø  A detailed discuss of the...

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FCPA Compliance Report
Daily Compliance News: April 8, 2019-the changing spots edition from 2019-04-08T05:00

In today’s edition of Daily Compliance News: ·      Can a leopard (in this case Equifax) change its spots. (New York Times)·      Investigations for Boeing mount. (Washington Post)·       More corr...

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FCPA Compliance Report
Daily Compliance News: April 6, 2019-the return on bribe (ROB) edition from 2019-04-06T11:39

APRIL 6, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Pharma exec who developed return on bribe metric goes to jury. (NPR)·      Wilkie-Farr co-chair pleads guilty in admissi...

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FCPA Compliance Report
Daily Compliance News: April 5, 2019-the I feel very much loved edition from 2019-04-05T05:00

APRIL 5, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Judge gives SEC and Musk 14 days to settle their differences. (New York Times)·      3 drug companies settle FCA claims ...

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FCPA Compliance Report
Daily Compliance News: April 4, 2019-the Bigot Law edition from 2019-04-04T05:00

APRIL 4, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Wynn Casinos said to have hidden claims against Steve Wynn. (New York Times)·      Is your airline watching you? (New Yo...

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FCPA Compliance Report
Everything Compliance-Episode 44, the April is Here edition from 2019-04-04T05:00

Welcome to the only roundtable podcast in compliance. Today, in Episode 44 Tom Fox sits in for Mike Volkov, who is on assignment.   Jonathan Armstrong discusses a recent presentation he saw by the ...

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FCPA Compliance Report
Compliance into the Weeds: Episode 117-Wells Fargo Update from 2019-04-03T11:03

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: April 3, 2019-the trial of the century begins edition from 2019-04-03T05:05

In today’s edition of Daily Compliance News: ·      Trial of ex-Malaysian PM Najib Razak to begin. (The Guardian)·      Shocked, just shocked to find out drug company pushed opioids. (NPR)·       F...

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FCPA Compliance Report
IMPACT2019, Amy Edmondson on Creating a Safe Workspace from 2019-04-02T05:00

 In this episode I visit with Amy Edmondson about her upcoming keynote speech at IMPACT2019, entitled “The Fearless Organization: Creating Psychological Safety for Learning, Innovation, and Growth”...

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FCPA Compliance Report
Daily Compliance News: April 2, 2019-the FB mea culpa edition from 2019-04-02T05:00

In today’s edition of Daily Compliance News: ·      Is it illegal to do business with corrupt governments? (New York Times)·      Does PG&E really want a judge running its business? (Hint-no). (Wal...

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FCPA Compliance Report
Are You Creating Barriers to Your Art? from 2019-04-01T06:00

On this episode of the Modern Medium Podcast, we are exploring barriers: might artists inadvertently create these barriers to their art? And how does this affect its experience? BarriersBarriers ca...

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FCPA Compliance Report
Daily Compliance News: April 1, 2019-the Not April Fool’s edition from 2019-04-01T05:00

In today’s edition of Daily Compliance News: ·      GOP congressmen threaten to kill NAFTA 2. (Washington Post)·      CBS Credit Union shut down as one employee embezzled $40MM.  (Deadline)·       ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 424, David Childers on the New ECI Self-Assessment Tool from 2019-04-01T05:00

In this episode I visit with David Childers, the Senior Vice President at Ethics&Compliance Initiative (ECI). We discuss ECI’s High-Quality Ethics&Compliance Program (HQP) Self-Assessment Tool. Som...

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FCPA Compliance Report
Daily Compliance News: March 30, 2019-the Sackler family sued edition from 2019-03-30T12:59

In today’s edition of Daily Compliance News: Wirecare in deep trouble. (Financial Times)Nissan was in big trouble and still may be. (New York Times)New York state sues Sackler family directly. (Wal...

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FCPA Compliance Report
This Week in FCPA-Episode 148 – the Hope Springs Eternal edition from 2019-03-29T17:16

As Opening Day near and the Astros are predicted to unseat Jay’s Red Sox to win the 2019 World Series, both lads are eternally hopeful for their hometown heroes. While debating this issue, they als...

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FCPA Compliance Report
Daily Compliance News: March 29, 2019-the out like a lamb edition from 2019-03-29T05:00

MARCH 29, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      JPMorgan under fire for bribery in Nigeria.  (New York Times)https://www.nytimes.com/2019/03/28/business/jpmorgan-niger...

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FCPA Compliance Report
Daily Compliance News: March 28, 2019-the SFO sued edition from 2019-03-28T05:08

MARCH 28, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      What is your cybersecurity rating?  (Wall Street Journal)·      Trump tweets on North Korea sanctions as coverup for in...

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FCPA Compliance Report
Life With GDPR: Episode 24- Phishing from 2019-03-28T05:00

In this episode, I visit with Jonathan Armstrong consider the increasing business risk around phishing. There have recently been some multi-million-dollar losses around phishing so you need to be p...

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FCPA Compliance Report
Daily Compliance News: March 27, 2019-the Autonomy trial begins edition from 2019-03-27T05:00

MARCH 27, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Former Autonomy CEO goes to trial in UK.  (The Register)·      Want credit in FCPA sentencing? Engage in random acts of...

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FCPA Compliance Report
Compliance into the Weeds: Episode 116-Brexit Risks from 2019-03-27T05:00

Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Daily Compliance News: March 26, 2019-the UK AG edition from 2019-03-26T05:15

MARCH 26, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Why is UK Attorney General sitting on Airbus corruption case? (The Guardian) ·      Ex-HK official sentenced to jail fo...

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FCPA Compliance Report
Making Art a Sensory Experience from 2019-03-25T06:00

On this episode of the Modern Medium Podcast, we’re exploring our senses: while it’s common for art to have visual and aural components, we don’t normally think about art in terms of smell, taste, ...

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FCPA Compliance Report
Setting the Right Tone from the Top from 2019-03-25T06:00

The board of directors, in concert with the CEO and others, set the tone and conduct for corporate behavior throughout the organization, and is the most important element for promoting honesty in a...

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FCPA Compliance Report
Daily Compliance News: March 25, 2019-the would you do business with this man edition from 2019-03-25T05:15

MARCH 25, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Jeff Skilling wants you to invest your money with him. What could go wrong? (Wall Street Journal) ·      Most bitcoin t...

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FCPA Compliance Report
FCPA Compliance Report-Episode 423, Sarah Hadden on the New CCI from 2019-03-25T05:00

In this episode I visit with Sarah Hadden, the new Editor-in-Chief at Corporate Compliance Insights (CCI). We discuss her professional background in journalism and her journey to becoming EIC at Co...

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FCPA Compliance Report
Emerging Issues in Healthcare Compliance-Episode 5, Proactive Monitoring from 2019-03-25T05:00

In this special five-part podcast series, sponsored by Affiliated Monitors, Inc., I visit with AMI Managing Director Jesse Caplan on emerging issues in healthcare compliance and monitoring. In the ...

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FCPA Compliance Report
Emerging Issues in Healthcare Compliance and Monitoring-Episode 1 –Focus on Opioid Prescribing – Regulatory and Liability Risks from 2019-03-25T05:00

In this special five part podcast series, sponsor by Affiliated Monitors, I visit with Jesse Caplan, Managing Director at AMI on emerging issues in healthcare compliance and monitoring. Healthcare ...

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FCPA Compliance Report
Emerging Issues in Healthcare Compliance and Monitoring-Episode 3-Expanded Use of Independent Monitoring by Health Regulators from 2019-03-25T05:00

In this special five-part podcast series, sponsored by Affiliated Monitors, Inc., I visit with AMI Managing Director Jesse Caplan on emerging issues in healthcare compliance and monitoring. In this...

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FCPA Compliance Report
Emerging Issues in Healthcare Compliance and Monitoring-Episode 2- Focus on Opioid Prescribing – Identifying and Mitigating the Risks from 2019-03-25T05:00

In this special five-part podcast series, sponsored by Affiliated Monitors, Inc., I visit with AMI Managing Director Jesse Caplan on emerging issues in healthcare compliance and monitoring. In Epis...

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FCPA Compliance Report
Emerging Issues in Healthcare Compliance and Monitoring-Episode 4 - Independent Integrity Monitoring of Healthcare Organizations from 2019-03-25T05:00

In this special five-part podcast series, sponsored by Affiliated Monitors, Inc., I visit with AMI Managing Director Jesse Caplan on emerging issues in healthcare compliance and monitoring. In the ...

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FCPA Compliance Report
Daily Compliance News: March 23, 2019-the who’s on your Board edition from 2019-03-23T05:00

MARCH 23, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Should safety be a ‘nice to have’? (New York Times)·      Boeing loses first contract for 737 MAX jets. (Wall Street Jo...

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FCPA Compliance Report
IMPACT 2019- Sam Silverstein on Accountability from 2019-03-22T17:00

In this episode I visit with Sam Silverstein about his upcoming keynote speech at IMPACT 2019, entitled “Inspiring Accountability at Every Level”. Some of the highlights from the podcast include: 1...

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FCPA Compliance Report
Daily Compliance News: March 22, 2019-the my bracket is already blown edition from 2019-03-22T05:00

MARCH 22, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Google&Facebook defrauded to the tune of $100. (Wall Street Journal)·      Too scared to drink Miller Lite? (New York T...

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FCPA Compliance Report
IMPACT 2019, Tony Brigmon on Joy and Laughter from 2019-03-21T17:00

In this episode I visit with Tony Brigmon about his upcoming keynote speech at IMPACT 2019, entitled “The Funomenal Workplace: Energizing People&Culture with the Positive Power of Fun”. Some of the...

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FCPA Compliance Report
Daily Compliance News: March 21, 2019-the Google spanked edition from 2019-03-21T05:00

MARCH 21, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Chuck Pearson pleads guilty. (France24.com) ·      USC goes after the students fraudulently admitted. (NPR)·      EU sp...

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FCPA Compliance Report
Life With GDPR: Episode 23- Looking into the 2019 Crystal Ball from 2019-03-21T05:00

In this episode, I visit with Jonathan Armstrong consider some of his predictions for the rest of 2019. Even if these predictions do not become fully formed, you should consider them in light of yo...

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FCPA Compliance Report
Compliance into the Weeds: Episode 115-Regulatory Capture and Regulatory Approval at the FAA from 2019-03-20T10:38

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: March 20, 2019-the Risky Business edition from 2019-03-20T05:00

MARCH 20, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Cambridge Analytica cover up? (The Daily Beast) ·      SEC ‘stunned’ Musk violated court order. (Bloomberg)·      Japan...

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FCPA Compliance Report
Daily Compliance News: March 19, 2019-the filling out my bracket edition from 2019-03-19T05:00

MARCH 19, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Of money laundering and cars in Ireland. (Irish Mirror)·      Warner Brothers head to step down due to an inappropriate...

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FCPA Compliance Report
Freud and Fraud from 2019-03-18T14:12

On this episode, we’re putting Freud to fraud and getting inside the minds of crooks. Today’s white collar criminals have decades of technological evolution at their fingertips, creating new opport...

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FCPA Compliance Report
Incorporating Time into Art from 2019-03-18T14:06

On this episode of the Modern Medium Podcast, we’re talking about a medium not often thought about in the art field: time. How can we incorporate this into art, and what might that look like? Time...

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FCPA Compliance Report
Daily Compliance News: March 18, 2019-the selection Monday edition from 2019-03-18T05:00

MARCH 18, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      Bribery and tax breaks, only in America? (Washington Post) ·      When you snow plough what does it teach? (New York T...

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FCPA Compliance Report
FCPA Compliance Report-Episode 422, Vera Cherepanova from 2019-03-18T05:00

In this episode I visit with Vera Cherepanova author of the book, “Compliance Program of an Organisation”. We visit about her recent article on the FCPA Blog and its implication. Some of the highli...

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FCPA Compliance Report
MTS Foreign Corrupt Practices Act Enforcement Action: Part V – Lessons Learned from 2019-03-18T05:00

We are on Episode V of a five-part exploration of the recent the Department of Justice and Securities Exchange Commission resolution of a Foreign Corrupt Practices Act enforcement action against th...

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FCPA Compliance Report
MTS Foreign Corrupt Practices Act Enforcement Action: Part IV – the Individual Indictments from 2019-03-18T05:00

We are on Episode IV of a five-part exploration of the recent the Department of Justice and Securities Exchange Commission resolution of a Foreign Corrupt Practices Act enforcement action against t...

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FCPA Compliance Report
MTS Foreign Corrupt Practices Act Enforcement Action: Part II-the Bribery Schemes from 2019-03-18T05:00

In a stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the Department of Justice and Securities Exchange Commission both a...

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FCPA Compliance Report
MTS Foreign Corrupt Practices Act Enforcement Action: Part III – Missed Red Flags and Overridden Controls from 2019-03-18T05:00

In a stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the Department of Justice and Securities Exchange Commission both a...

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FCPA Compliance Report
MTS Foreign Corrupt Practices Act Enforcement Action: Part I-Introduction from 2019-03-18T05:00

In a stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the Department of Justice and Securities Exchange Commission both a...

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FCPA Compliance Report
Popcorn and Compliance: Captain Marvel from 2019-03-16T17:22

In this podcast series, recovering screenwriter (and Mr. Monitor) Jay Rosen and myself will indulge in passion for the movies by looking at them through the lens of compliance. Jay is a contemporar...

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FCPA Compliance Report
Daily Compliance News: March 16, 2019-the VW sued (yet again) edition from 2019-03-16T13:47

MARCH 16, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Will horseracing end in California? (New York Times) ·      Will NAFTA 2 get thru? Texas Senator John Cornyn says it wi...

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FCPA Compliance Report
This Week in FCPA-Episode 146 – Ides of March (formerly St. Patty’s Day) edition from 2019-03-15T17:21

On this Ides of March with the St. Patrick’s Day weekend is upon, and we are all Irish at least for a day, Tom and Jay are joined by our favorite Irishman (and the Coolest Guy in Compliance), Matt ...

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FCPA Compliance Report
Daily Compliance News: March 15, 2019-the all-NYT edition from 2019-03-15T05:00

MARCH 15, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      No. 3 at Facebook leaves of Facebook’s new direction. (New York Times)·      Admissions scandal hits USC hard. (New Yor...

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FCPA Compliance Report
Daily Compliance News: March 14, 2019-the ethics premium edition from 2019-03-14T05:00

MARCH 14, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      What is the ‘ethics premium? (Radical Compliance)·      The strippings start. (Risk&Compliance Journal) ·      60 Minut...

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FCPA Compliance Report
Everything Compliance-Episode 43, the Cohen Testifies edition-Part 2 from 2019-03-14T05:00

Welcome to the only roundtable podcast in compliance. This episode is the conclusion of a special two-part episode. Today, in Episode 43 Jonathan Armstrong and Matt Kelly weigh in on issues that ar...

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FCPA Compliance Report
Compliance into the Weeds: Episode 114-Lessons on Internal Control Overrides from 2019-03-13T05:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: March 13, 2019-the Back to School edition from 2019-03-13T05:00

MARCH 13, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Ex-Olympus boss wins pension suit. (Financial Times)·      Feds bring massive college admission scam action. (Washingto...

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FCPA Compliance Report
Daily Compliance News: March 12, 2019-the loonshot edition from 2019-03-12T11:41

MARCH 12, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Did Oracle violate the FCPA? (Tech Central)·      General David Petraeus calls for the end of shell companies. (Washing...

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FCPA Compliance Report
Adventures in Compliance –Episode IV: The Six Napoleons from 2019-03-11T15:32

In this episode, I consider the theme of mentoring in compliance.   In the story The Adventure of the Six Napoleons, Inspector Lestrade says to Holmes, “Well,” said Lestrade, “I’ve seen you handle ...

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FCPA Compliance Report
Daily Compliance News: March 11, 2019-the Wells Fargo edition from 2019-03-11T05:00

MARCH 11, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Wells Fargo and terrible corporate culture. (New York Times) ·      Martin Shekreli continues to run company (from pris...

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FCPA Compliance Report
Adventures in Compliance: Episode II-The Abbey Grange from 2019-03-11T05:00

Today, I consider The Adventure of the Abbey Grange.  In the story The Adventure of the Abbey Grange, Holmes feels something is just not right about the story told by Lady Mary Brackenstall regardi...

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FCPA Compliance Report
Adventures in Compliance: Episode III: The Priory School from 2019-03-11T05:00

Today, I consider the Adventure of the Priory School.  In the story The Adventure of the Priory School, Watson meets a character, Reuben Hayes, who  believes to be the most “self-evident villain” h...

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FCPA Compliance Report
Adventures in Compliance: Episode I: The Red Circle and Communication from 2019-03-11T05:00

This week I return to one my favorite themes for every Chief Compliance Officer (CCO), compliance professional and compliance program: Sherlock Holmes. Over the next five days, I will be considerin...

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FCPA Compliance Report
FCPA Compliance Report-Episode 421, Andrew Beato from 2019-03-11T05:00

In this episode I visit with Andrew Beato from the law firm of Stein Mitchell Beato&Missner LLP. We discuss the firm’s recent Federal Claims Act settlement with Walgreen on behalf of firm client  M...

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FCPA Compliance Report
FCPA Compliance Report-Bonus Episode-the MTS FCPA Settlement from 2019-03-10T17:32:12

In this special bonus podcast, I am joined by Mike Volkov to discuss the stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage,...

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FCPA Compliance Report
FCPA Compliance Report-Episode 420, Erica Salmon Byrne on the 2019 WME-the Ethics Premium from 2019-03-09T13:22

In this episode I visit with podcast favorite Erica Salmon Byrne, the EVP and Executive Director of Business Ethics Leadership Alliance at Ethisphere on its 2019 World’s Most Ethical company awards...

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FCPA Compliance Report
Daily Compliance News: March 9, 2019-the Podfest Expo edition from 2019-03-09T12:24

MARCH 9, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      A COI at the top is bad. (Financial Times)·      There are more $100 bills than $1 bills. What does that mean for compli...

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FCPA Compliance Report
This Week in FCPA-Episode 145– Conferencing in America edition from 2019-03-08T16:38

Tom and Jay were both conferencing this week, albeit in different disciplines. Tom at Podfest Expo and Jay at the ABA White Collar Crime conference. In between they discussed some of this week’s to...

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FCPA Compliance Report
Opinion Release Papers-11-01: Using the Opinion Release Procedure from 2019-03-08T06:00

The only Opinion Release of 2011 (11-01) may have left compliance practitioners initially scratching their heads. However, this collective head scratching is not because the Opinion Release is so d...

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FCPA Compliance Report
Daily Compliance News: March 8, 2019-the Gulnara Karimova edition from 2019-03-08T06:00

MARCH 8, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Gulnara Karimova charged with conspiracy to commit money laundering in the whooping amount of $866MM. (FCPA Blog)·      ...

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FCPA Compliance Report
Daily Compliance News: March 7, 2019-the Russian Telecom edition from 2019-03-07T06:00

MARCH 7, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Russia based MTS settles FCPA violations for $850MM (FCPA Blog)·      CTFT to follow DOJ lead on enforcement and SEC lea...

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FCPA Compliance Report
Everything Compliance-Episode 42, the Cohen Testifies edition-Part 1 from 2019-03-07T06:00

Welcome to the only roundtable podcast in compliance. This episode is Part 1 of a special two-part episode. Today, in Episode 42 Mike Volkov and Jay Rosen sound off. Next week, in Episode 43 Jonath...

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FCPA Compliance Report
Compliance into the Weeds: Episode 113-Corporate Governance Nightmare from 2019-03-06T06:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: March 6, 2019-the Remember the Alamo edition from 2019-03-06T06:00

MARCH 6, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Huawei sues US claiming Bill of Attainder. (Zero Hedge)·      The clown show ends. (New York Times)·      Rule 29 ruling...

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FCPA Compliance Report
Collusion and Conflict of Interest in Compliance from 2019-03-05T20:28

Corruption can take many forms, but its root causes often include a conflict of interest and possibly some type of collusion. In this episode, we’re illustrating these concepts and how they intertw...

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FCPA Compliance Report
Welcome to the Modern Medium Podcast! from 2019-03-05T20:20

Welcome to the Modern Medium Podcast! We talk about the tools, strategies, tactics, and possibilities in modern medium design. In our first episode, we’re exploring ideas: how they form, how they c...

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FCPA Compliance Report
Daily Compliance News: March 5, 2019-the Shell in in trouble edition from 2019-03-05T06:00

MARCH 5, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Uber’s GC is trying to clean up its mess. What about its culture? (New York Times)·      Dutch authorities about to char...

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FCPA Compliance Report
Opinion Release Papers-07-02-Business Entertainment for Foreign Officials from 2019-03-04T15:04:31

In the second Opinion Release of 2007, 07-02, the Department of Justice (DOJ) considered another scenario where a US company desired to pay for travel to the US of foreign officials and for some bu...

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FCPA Compliance Report
Opinion Release Papers- 07-01-Travel for Foreign Officials from 2019-03-04T14:48:52

In 2007, the DOJ issued two Foreign Corrupt Practices Act (FCPA) Opinion Releases which offered guidance to companies considering whether to, and if so how to, incur travel and lodging expenses for...

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FCPA Compliance Report
Opinion Release Papers-10-02- Charitable Donations under the FCPA from 2019-03-04T14:35:47

What is a company to do if, in order to obtain a contract with a foreign government, they must agree to invest a percentage of the proceeds of the transaction into the community in which it operate...

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FCPA Compliance Report
Opinion Release Papers- 10-03-Foreign Officials as Agents from 2019-03-04T14:33:01

Can you hire a foreign official as your agent? Is a foreign official always a foreign official for the purposes of the Foreign Corrupt Practices Act (FCPA)? Can a person be a foreign official yet n...

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FCPA Compliance Report
FCPA Compliance Report-Episode 420, Andrew Beato from 2019-03-04T06:00

In this episode I visit with Andrew Beato from the law firm of Stein Mitchell Beato&Missner LLP. We discuss the firm’s recent False Claims Act settlement with Walgreen on behalf of firm client  Mar...

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FCPA Compliance Report
Daily Compliance News: March 4, 2019-the WSJ edition from 2019-03-04T06:00

MARCH 4, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Why is prosecuting bankers so hard? (Wall Street Journal)·      Huawei fights back against jailed exec. (Wall Street Jou...

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FCPA Compliance Report
This Week in FCPA-Episode 144 – Farewell to Sam edition from 2019-03-01T19:36

Tom returns from London to find Sam Rubenfeld announcing his departure from the WSJ Risk and Compliance Journal via Twitter. Tom and Jay are back together to take a look  at some of this week’s top...

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FCPA Compliance Report
Daily Compliance News: March 1, 2019-Lion or Lamb? edition from 2019-03-01T06:00

MARCH 1, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      What should the SEC do about Elon Musk? (Financial Times)·      Israeli PM to be arrest on corruption charges. (New York...

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FCPA Compliance Report
Episode 105-Leadership Lessons from the Oscars-The Last Emperor from 2019-02-28T06:00

We are back with our fan favorite Oscar movie month. During the month of February each year, we look at Oscar-winning Best Pictures and consider the leadership lessons we glean from our viewing. Th...

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FCPA Compliance Report
Daily Compliance News: February 28, 2019-the farewell to February edition from 2019-02-28T06:00

FEBRUARY 28, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Bio-Rad GC retains most of his whistleblower award. (San Francisco Chronicle) ·      Judge orders Musk to explain tw...

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FCPA Compliance Report
Daily Compliance News: February 27, 2019-the CITGO in more trouble edition from 2019-02-27T06:00

FEBRUARY 27, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      CITGO sued for retaliation in Houston. (Houston Chronicle)·      SEC says Elon Musk in contempt. (Wall Street Journa...

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FCPA Compliance Report
Compliance into the Weeds: Episode 112-Robert Kraft and Compliance from 2019-02-27T06:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Live from London, Part IV- Regime Change and Compliance from 2019-02-25T15:20:11

In this 4th and final episode of my special four-part podcast series Live from London, Jonathan Armstrong interviews me on how regime change has modified the risk calculus for the compliance practi...

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FCPA Compliance Report
Live from London, Part III-Cognizant Technology from 2019-02-25T15:18:43

In this Episode 3 of my special Live from London series, Jonathan Armstrong interviews me on the recent on the Cognizant Technology Solutions Corp FCPA enforcement action, declination and C-Suite c...

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FCPA Compliance Report
Live from London, Part II-State of Compliance in 2019 from 2019-02-25T15:16:58

In this Episode 2 of my special Live from London series, Jonathan Armstrong interviews me on the state of compliance in 2019. I highlight some of the emerging developments and what they may mean fo...

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FCPA Compliance Report
Live from London, Part I-Customers as Emerging Corruption Risks from 2019-02-25T15:14:28

In this Episode 1 of my special Live from London series, Jonathan Armstrong interviews me on the recent several FCPA enforcement actions where customer were a part of the bribery scheme. I highligh...

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FCPA Compliance Report
FCPA Compliance Report-Episode 419, James Tillen and Marc Bohn on Miller’s FCPA Winter Review 2019 from 2019-02-25T06:00

In this episode I visit with Miller&Chevalier lawyers James Tillen and Marc Bohn on the firm’s FCPA Winter Review 2019. Miller releases a FCPA review quarterly each year and it is one of the top re...

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FCPA Compliance Report
Daily Compliance News: February 25, 2019-the risk management edition from 2019-02-25T06:00

FEBRUARY 25, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Does power corrupt or just expose your character? (Washington Post)·      Risk management has been around since Baby...

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FCPA Compliance Report
This Week in FCPA-Episode 143 –the London Homesick Blues edition from 2019-02-23T06:00

Tom in is London this week, thinking about Gary P. Nunn, the Lost Gonzo Band and London Homesick Blues(special bonus points if you have heard Nunn or his group live). He takes a look  at some of th...

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FCPA Compliance Report
Daily Compliance News: February 22, 2019-the farewell to UK edition from 2019-02-22T09:57

FEBRUARY 22, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      The table comes to Zuckerberg. (BBC)·      When is your value chain in jeopardy? (The Telegraph)·      When is your ...

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FCPA Compliance Report
Everything Compliance-Episode 41, the Kudos to Dick Cassin edition from 2019-02-22T06:00

Welcome to the only roundtable podcast in compliance. In this week’s episode, the gang looks at some the issues that are on their collective minds. Shout outs and one rant follow after the commenta...

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FCPA Compliance Report
Episode 104-Leadership Lessons from the Oscars-The Sting from 2019-02-21T06:00

We are back with our fan favorite Oscar movie month. During the month of February each year, we look at Oscar-winning Best Pictures and consider the leadership lessons we glean from our viewing. Th...

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FCPA Compliance Report
Daily Compliance News: February 21, 2019-the Lex edition from 2019-02-21T06:00

FEBRUARY 21, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      HSBC is still compliance challenged? (Financial Times)·      Manolete takes a bow. (Financial Times)·      What does...

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FCPA Compliance Report
Across the Board: Episode 26-Rakhi Kumar on SSGA’s Culture Framework from 2019-02-20T06:00

I recently had the chance to visit with Rakhi Kumar, Senior Managing Director, Head of ESG Investments and Asset Stewardship, at State Street Global Advisors. We discussed the firm’s recent initiat...

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FCPA Compliance Report
Daily Compliance News: February 20, 2019-the still in London edition from 2019-02-20T06:00

FEBRUARY 20, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      What does the fraying of Atlanticism mean for compliance? (Financial Times)·      Telia execs walks free on Uzbekist...

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FCPA Compliance Report
Daily Compliance News: February 19, 2019-the Financial Times edition from 2019-02-19T06:00

FEBRUARY 19, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      How green are you and your supply chain? (Financial Times)·      How will a no deal Brexit negatively impact crime f...

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FCPA Compliance Report
Daily Compliance News: February 18, 2019-the London Times edition from 2019-02-18T09:13

FEBRUARY 18, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      How much reputational damage with PwC take? (The London Times)·      PwC audit leads to potential criminal charges. ...

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FCPA Compliance Report
ECI’s 2018 Global Business and Ethics Survey: Part I - The State of Ethics and Compliance in the Workplace from 2019-02-18T06:00

In this podcast series I visit with Patricia Harned, Ph.D., the Chief Executive Officer (CEO) of Ethics and Compliance Initiative (ECI), about the firm’s 2018 Global Business and Ethics Survey (GBE...

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FCPA Compliance Report
ECI’s 2018 Global Business and Ethics Survey: Part IV - Interpersonal Misconduct in the Workplace: What It Is, Where It Occurs and What You Should Do About It from 2019-02-18T06:00

In this podcast series I visit with Pat Harned, the Chief Executive Officer (CEO) of Ethics and Compliance Initiative (ECI) about the firm’s 2018 Global Business and Ethics Survey (GBES). In this s...

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FCPA Compliance Report
FCPA Compliance Report-Episode 418, Joel Androphy on Prosecuting FCA cases from 2019-02-18T06:00

In this episode I visit Joel Androphy, a co-founder of the law firm of Berg and Androphy in Houston. Androphy is a well-known white-collar defense lawyer and plaintiff’s counsel in Federal Claims A...

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FCPA Compliance Report
ECI’s 2018 Global Business and Ethics Survey: Part II - Measuring the Impact of Ethics&Compliance Programs from 2019-02-18T06:00

I continue the discussion with Pat Harned, Chief Executive Officer (CEO) of Ethics and Compliance Initiative (ECI), about the firm’s 2018 Global Business and Ethics Survey (GBES). In this series we...

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FCPA Compliance Report
ECI’s 2018 Global Business and Ethics Survey: Part V - Implications for Compliance Going Forward from 2019-02-18T06:00

In this podcast series I have visited with Pat Harned, Chief Executive Officer (CEO) of Ethics and Compliance Initiative (ECI), about the firm’s 2018 Global Business and Ethics Survey (GBES). In th...

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FCPA Compliance Report
ECI’s 2018 Global Business and Ethics Survey: Part III - Building Companies Where Values and Ethical Conduct Matter from 2019-02-18T06:00

Pat Harned, Chief Executive Officer (CEO) of Ethics and Compliance Initiative (ECI) and myself are discussing the firm’s 2018 Global Business and Ethics Survey (GBES). In this series we consider ea...

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FCPA Compliance Report
FCPA Compliance Report-Bonus Episode, the Cognizant Technology Solutions Corp’s FCPA Enforcement Action from 2019-02-17T18:27:41

In this special bonus episode I visit with Mike Volkov on the Cognizant Technology Solutions Corp FCPA enforcement action, declination and C-Suite criminal indictments which were all announced on F...

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FCPA Compliance Report
This Week in FCPA-Episode 142 - the What’s in Your Supply Chain? edition from 2019-02-15T06:00

A special guest joins the lads this week. Tom and Jay were panelists this week’s at Assent’s Supply Chain Conference as was our guest Pamela Fierst-Walsh who joins in for this special live edition ...

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FCPA Compliance Report
Daily Compliance News: February 15, 2019-the coming home edition from 2019-02-15T06:00

FEBRUARY 15, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Disgraced former Goldman Sachs MD Roger Ng to waive extradition and come to US to stand trial? (New York Times)·    ...

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FCPA Compliance Report
Episode 103-Leadership Lessons from the Oscars-No Country for Old Men from 2019-02-14T06:00

We are back with our fan favorite Oscar movie month. During the month of February each year, we look at Oscar-winning Best Pictures and consider the leadership lessons we glean from our viewing. Th...

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FCPA Compliance Report
Daily Compliance News: February 14, 2019-the Valentine’s Day edition from 2019-02-14T06:00

FEBRUARY 14, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Did KPMG game the audit oversight system? (Bloomberg)·      Is your dog microchipped? How about you? (Compliance and...

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FCPA Compliance Report
Compliance into the Weeds: Episode 111- What is supply chain risk? from 2019-02-13T06:00

Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Daily Compliance News: February 13, 2019-the Batman edition from 2019-02-13T06:00

FEBRUARY 13, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Ole Miss Vacates 33 Wins After NCAA Violations. (Sports Illustrated)·      Hawaii businessman pleads guilty to FCPA ...

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FCPA Compliance Report
Daily Compliance News: February 12, 2019-the Big Headache for AB edition from 2019-02-12T06:00

FEBRUARY 12, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Ex-Malaysia PM trial delayed. (The Straits Times)·      Big Four accountants push back against breakup proposals. (C...

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FCPA Compliance Report
Affiliated Monitors: 15 Years of Independent Monitoring Excellence -Episode 5, Final Reflections on 15 Years from 2019-02-11T06:00

Over this five-part podcast series, I have visited with Vin DiCianni, CEO and founder of Affiliated Monitors, Inc. (AMI) as a retrospective of the company’s first 15 years of existence. AMI sponsor...

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FCPA Compliance Report
Affiliated Monitors: 15 Years of Independent Monitoring Excellence -Episode 4, the Marriage of Independent Monitors and C&E Programs from 2019-02-11T06:00

Over five podcasts, I visit with Vin DiCianni, CEO and founder of Affiliated Monitors, Inc. (AMI) as a retrospective of the company’s first 15 years. AMI sponsored this podcast series. This podcast...

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FCPA Compliance Report
FCPA Compliance Report-Episode 417, Miller&Chevalier Releases Inaugural Europe-Caucasus-Asia Corruption Survey from 2019-02-11T06:00

In this episode I visit with three lawyers from Miller&Chevalier: Maryna Kavaleuskaya, Michael Skopets, and Ann Sultan on the firm’s Inaugural Europe-Caucasus-Asia Corruption Survey. The report pro...

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FCPA Compliance Report
Affiliated Monitors: 15 Years of Independent Monitoring Excellence -Episode 2, The Early Days from 2019-02-11T06:00

Over five podcasts, I will visit with Vin DiCianni, CEO and founder of Affiliated Monitors, Inc. (AMI) as a retrospective of the company’s first 15 years. AMI sponsored this podcast series. This po...

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FCPA Compliance Report
Affiliated Monitors: 15 Years of Independent Monitoring Excellence -Episode 1, DiCianni's Idea from 2019-02-11T06:00

Over the next five podcasts, I will visit with Vin DiCianni, CEO and founder of Affiliated Monitors, Inc. (AMI) as a retrospective of the company’s first 15 years. AMI sponsored this podcast series...

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FCPA Compliance Report
Affiliated Monitors: 15 Years of Independent Monitoring Excellence -Episode 3, the Expansion of Independent Monitors from 2019-02-11T06:00

Over five podcasts, I visit with Vin DiCianni, CEO and founder of Affiliated Monitors, Inc. (AMI) as a retrospective of the company’s first 15 years. AMI sponsored this podcast series. This podcast...

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FCPA Compliance Report
Daily Compliance News: February 11, 2019-the Venezuela in turmoil edition from 2019-02-11T06:00

FEBRUARY 11, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Why it’s important that PdVSA money go into a trust? (Wall Street Journal)·      The Scorpions reappear in South Afr...

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FCPA Compliance Report
This Week in FCPA-Episode 141 - the We’re on Spotify edition from 2019-02-08T18:30

The Patriots won the Super Bowl (yet again). Even more significantly This Week in FCPA is now on Spotify. To celebrate, Tom and Jay are back to at some of this week’s top compliance and ethics stor...

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FCPA Compliance Report
Daily Compliance News: February 8, 2019-the what’s your password edition from 2019-02-08T15:05

FEBRUARY 8, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Former Petrofac Unit Executive Pleads Guilty to Bribery. (Wall Street Journal)·      More trouble for Danske bank. (W...

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FCPA Compliance Report
Daily Compliance News: February 7, 2019-the stupid is as stupid does edition from 2019-02-07T06:00

FEBRUARY 7, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Stupid CEO remarks=new activist investor on Board. The Papa John saga continues. (Wall Street Journal)·      Reportin...

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FCPA Compliance Report
Life With GDPR: Episode 22- Morrisons’ and vicarious liability from 2019-02-07T06:00

In this episode, I visit with Jonathan Armstrong on the recent UK court of appeals decision in the Morrisons’ case. This decision stretched the limits of vicarious liability for a corporation to th...

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FCPA Compliance Report
Daily Compliance News: February 6, 2019-the send in the clowns edition from 2019-02-06T06:00

FEBRUARY 6, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Send in the clowns. The NCAA investigates Sean Miller and Arizona (Sports Illustrated)·      Will Australian report o...

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FCPA Compliance Report
Compliance into the Weeds: Episode 110- the Ralph Northam edition from 2019-02-06T06:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: February 5, 2019-the Monty Python edition from 2019-02-05T06:00

FEBRUARY 5, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Now monitorships based upon political loyalty. (National Review)·      Bangladesh sues of bank heist. (Wall Street Jo...

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FCPA Compliance Report
Daily Compliance News: February 4, 2019-the Champion’s edition from 2019-02-04T11:31

FEBRUARY 4, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Goldman Sachs institutes a clawback provision for exec involved with 1 MDB (New York Times)·      What is bad press? ...

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FCPA Compliance Report
The Evolution of Compliance: From Disconnected to Connected- Part I - Introduction from 2019-02-04T06:00

In this special five-part podcast series, hosted by Gan Integrity, we consider the evolution of compliance, from disconnected to connected. Over the next five episodes we will explore why complianc...

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FCPA Compliance Report
The Evolution of Compliance: From Disconnected to Connected-Part III-Constructing a Connected Program from 2019-02-04T06:00

In this special five-part podcast series, hosted by Gan Integrity, we consider the evolution of compliance, from disconnected to connected. Over the next five episodes we will explore why complianc...

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FCPA Compliance Report
The Evolution of Compliance: From Disconnected to Connected- Part II – Connected, as Under One Roof from 2019-02-04T06:00

In this special five-part podcast series, hosted by Gan Integrity, we consider the evolution of compliance, from disconnected to connected. Over five episodes we will explore why compliance is disc...

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FCPA Compliance Report
The Evolution of Compliance: From Disconnected to Connected, Part V-The Human Side of Connected Compliance from 2019-02-04T06:00

In this special five-part podcast series, sponsored by Gan Integrity, we have considered the evolution of compliance, from disconnected to connected. We have explored why compliance is disconnected...

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FCPA Compliance Report
The Evolution of Compliance: From Disconnected to Connected: Part IV-How Connected Technology Works from 2019-02-04T06:00

In this special five-part podcast series, hosted by Gan Integrity, we consider the evolution of compliance, from disconnected to connected. Over the next five episodes we will explore why complianc...

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FCPA Compliance Report
FCPA Compliance Report-Episode 416, James Koukios on the Morrison and Foerster Top 10 International Anti-Corruption Developments for December 2018 from 2019-02-04T06:00

In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for December 2018. We look at some of the k...

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FCPA Compliance Report
Daily Compliance News: February 2, 2019-the Groundhog’s Day edition from 2019-02-02T13:57

FEBRUARY 2, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Venezuela is moving towards a divided government. What does it mean for businesses? (Financial Times)·      What is m...

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FCPA Compliance Report
This Week in FCPA-Episode 140 - the Godfather retires edition from 2019-02-01T17:29

The Super Bowl is Sunday. Will the ads be better than the game? Tom and Jay are back and as the pay tribute to the Godfather of compliance bloggers and commentators, Dick Cassin, who turned over Ed...

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FCPA Compliance Report
Daily Compliance News: February 1, 2019-the I can’t believe its February already edition from 2019-02-01T06:00

FEBRUARY 1, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Things get worse for PG&E as federal judge slams company. (Wall Street Journal)·      What is due diligence? Foxxconn...

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FCPA Compliance Report
Daily Compliance News: January 31, 2019-the scam season edition from 2019-01-31T06:00

JANUARY 31, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Defamation suit under based upon allegations of FCPA violations is dismissed. (Global Investigation Review)·      Why...

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FCPA Compliance Report
Life With GDPR: Episode 21- Cambridge Analytica Subject Access Case from 2019-01-31T06:00

In this episode I visit with Jonathan Armstrong on the recent fine levied by British regulators against the insolvent institution Cambridge Analytica for violations of the British privacy law which...

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FCPA Compliance Report
Compliance into the Weeds: Episode 109- Does the NFL Even Care? from 2019-01-30T06:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: January 30, 2019-the new charges and new sanctions edition from 2019-01-30T06:00

JANUARY 30, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      US levels new charges at Huawei. (Wall Street Journal)·      US slaps sanctions on PdVSA. (Wall Street Journal)·     ...

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FCPA Compliance Report
Daily Compliance News: January 29, 2019-the 1MDB and Nissan investigations expand edition from 2019-01-29T06:00

JANUARY 29, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Did bribery pave the way for the opioid crisis? (ABC News)·      SEC open investigation into Nissan over Carlos Ghosn...

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FCPA Compliance Report
Shakespeare’s Problem Plays: Part 3 - Measure for Measure and Creating a Game Plan from 2019-01-28T06:00

Next, we consider Measure for Measure. In the age of #MeToothis play has taken on a renewed and frankly disturbing existence. Seeing the play in the past year was a much difference experience for m...

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FCPA Compliance Report
Shakespeare's Problems Plays: Part 1 - All’s Well That Ends Well and Compliance Resilience from 2019-01-28T06:00

This podcast opens a five-part podcast series on Shakespeare’s Problem Plays. These are plays where the structure of comedy ends the plays; i.e. everyone gets married at the end of the day. Yet the...

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FCPA Compliance Report
Shakespeare’s Problems Plays: Part 5- Timon of Athens and Risk Ranking Logistics Companies from 2019-01-28T06:00

Today, I round out the series by discussing the final play considered in this oeuvre, “Timon of Athens”. While the first four Problem Plays are most generally described as a play where the mask of ...

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FCPA Compliance Report
Daily Compliance News: January 28, 2019, the rooftop edition from 2019-01-28T06:00

JANUARY 28, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Why the Beatle rooftop (and final) concert still resonate? (Financial Times)·      Has #MeToomade men afraid to mento...

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FCPA Compliance Report
FCPA Compliance Report-Episode 415, Michael DeBernardis on Hughes Hubbard 2018 FCPA&Anti-Bribery Alert from 2019-01-28T06:00

In this episode I visit with Hughes Hubbard partner Michael DeBernardis on the Hughes Hubbard 2018FCPA&Anti-Bribery Alert. We look at some of the key DOJ pronouncements, key enforcement actions, ke...

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FCPA Compliance Report
Shakespeare’s Problem Plays: Part 4-The Winter’s Tale and Terminating a Third Party from 2019-01-28T06:00

Today, we consider The Winter’s Tale. In this play, King Leontes of Sicily and King Polixenes of Bohemia are old friends and Polixenes is about to return home after a six month visit to Sicily. Leo...

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FCPA Compliance Report
Shakespeare’s Problem Plays: Part 2 - Troilus and Cressida and Farce in Compliance as Tragedy from 2019-01-28T06:00

We continue our consideration of Shakespeare’s Problem Plays with today’s offering on Troilus and Cressidaas an introduction to problems in compliance. Today, we consider Troilus and Cressidaand ho...

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FCPA Compliance Report
Daily Compliance News: January 26, 2019-the Shutdown ends edition from 2019-01-26T15:08

JANUARY 26, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      What happens when fired CEO is asked to repay expenses? (Wall Street Journal)·      Is Davos elite out to kill compli...

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FCPA Compliance Report
Popcorn and Compliance: Aquaman from 2019-01-26T06:00

In this podcast series, recovering screenwriter (and Mr. Monitor) Jay Rosen and myself will indulge in passion for the movies by looking at them through the lens of compliance. Jay is a contemporar...

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FCPA Compliance Report
This Week in FCPA-Episode 139 - the Worst Officiating (Non) call ever edition from 2019-01-25T11:50

As the Pats and Rams advance, Tom and Jay ask if the NFL even cares about get it right? They also look at some of this week’s top compliance and ethics stories which caught their collective eyes.  ...

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FCPA Compliance Report
Life With GDPR: Episode 20-Google Fined €50 for GDPR Violations from 2019-01-25T06:00

In this episode I visit with Jonathan Armstrong and André Bywater on the recent fine levied by the French Data Privacy regulator CNIL against Google for violations under GDPR. Some of the highlight...

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FCPA Compliance Report
Daily Compliance News: January 25, 2019-the Damasian moment edition from 2019-01-25T06:00

JANUARY 25, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Renault (finally) replaces Ghosn. (New York Times)·      South African President vows to clean up graft. (New York Ti...

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FCPA Compliance Report
Daily Compliance News: January 24, 2019-the Golden Visa edition from 2019-01-24T06:00

JANUARY 24, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      Oversight in EU ‘golden visa’ programs missing. (Wall Street Journal)·      Waters says she’ll investigate Mick Mulv...

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FCPA Compliance Report
Everything Compliance-Episode 40, the Carnac the Magnificent edition from 2019-01-24T06:00

Welcome to the only roundtable podcast in compliance. In this week’s episode, the gang looks at what 2019 might bring in the ethics and compliance field. Rants follow this week’s episode.   1. Mike...

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FCPA Compliance Report
Compliance into the Weeds: Episode 108- Distributors and Compliance from 2019-01-23T06:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: January 23, 2019-the horsemeat trial edition from 2019-01-23T06:00

JANUARY 23, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Horsemeat scandal opens in France. (BBC)·      Theranos whistleblowers speak for transparency. (The Stanford Daily)· ...

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FCPA Compliance Report
Daily Compliance News: January 22, 2019-the integrity of the game edition from 2019-01-22T06:00

JANUARY 22, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Google is fine $57 MM for GDPR violations by French regulators. (Washington Post) ·      OECD to evaluate Ireland’s a...

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FCPA Compliance Report
Compliance Strategies Under the Benczkowski Memo: Part V-Proactive Monitoring from 2019-01-21T06:00

This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI) I have visited with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We ha...

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FCPA Compliance Report
Compliance Strategies Under the Benczkowski Memo: Part I-Introduction from 2019-01-21T06:00

This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We look at ...

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FCPA Compliance Report
Daily Compliance News: January 21, 2019-the MLK edition from 2019-01-21T06:00

JANUARY 21, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Meg Whitman sits down for Lunch with the FT. (Financial Times)·      Trump continued to negotiate for hotel in Moscow...

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FCPA Compliance Report
FCPA Compliance Report-Episode 414, Jim Garcia on auditing the San Diego Zoo from 2019-01-21T06:00

What is one of the most fulfilling audit assignments of a 30+ year audit professional? His audit at the San Diego Zoo. In this episode of the FCPA Compliance Report, I visit with internal auditor J...

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FCPA Compliance Report
Compliance Strategies Under the Benczkowski Memo: Part IV-New Guidance as Both a Sword and Shield from 2019-01-21T06:00

This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We look at ...

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FCPA Compliance Report
Compliance Strategies Under the Benczkowski Memo: Part II-Internal Use from 2019-01-21T06:00

This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We look at ...

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FCPA Compliance Report
Compliance Strategies Under the Benczkowski Memo: Part III-Using External Resources from 2019-01-21T06:00

This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We look at ...

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FCPA Compliance Report
This Week in FCPA-Episode 138 - the The (Burger) King at the White House edition from 2019-01-19T17:14

As Trump serves Burger King to the national champion Clemson Tigers, the Pats, Chiefs, Saints and Rams roll into the NFL’s version of the final four. Will the new guard arise (Mahomes and Goff) or ...

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FCPA Compliance Report
Daily Compliance News: January 17, 2019-the drugs can kill edition from 2019-01-17T06:00

JANUARY 17, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      MSU Interim President in (more) deep water. (ESPN)·      SEC gets hacked.  (CNBC)·      I am not a crook, er spy. Hua...

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FCPA Compliance Report
Compliance into the Weeds: Episode 107- Management Review Controls from 2019-01-16T11:55

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: January 16, 2019-the $100 MM bribe edition from 2019-01-16T06:00

JANUARY 16, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Deutsche Bank launches yet another internal AML probe. (Financial Times)·      How to keep your head up in an office ...

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FCPA Compliance Report
Daily Compliance News: January 15, 2019-a very bad day for PG&E edition from 2019-01-15T06:00

JANUARY 15, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      PG&E faces collapse. (Wall Street Journal)·      PG&E CEO resigns.  (Wall Street Journal)·      PG&E announces it wil...

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FCPA Compliance Report
Five Famous Fraudsters-Episode 1, Nathan Mueller and the Fraud Triangle from 2019-01-14T06:00

In this special five-part podcast series, I interview John Gill, the Vice President for Education at the Association of Certified Fraud Examiners (ACFE). In this series, John discusses five well-kn...

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FCPA Compliance Report
FCPA Compliance Report-Episode 413, Scott Shaffer and Tom Engelhart on the Human Element of Due Diligence from 2019-01-14T06:00

Last year brought several FCPA enforcement actions where the underlying due diligence performed on third parties was insufficient. While many companies have gone to automated due diligence as a par...

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FCPA Compliance Report
Five Famous Fraudsters-Episode 3, Andrea Baxendale and What is risk? from 2019-01-14T06:00

In this special five-part podcast series, I interview John Gill, the Vice President for Education at the Association of Certified Fraud Examiners (ACFE). In this series, John discusses five well-kn...

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FCPA Compliance Report
Five Famous Fraudsters-Episode 2, Mark Whitacre and Tone at the Top from 2019-01-14T06:00

In this special five-part podcast series, I interview John Gill, the Vice President for Education at the Association of Certified Fraud Examiners (ACFE). In this series, John discusses five well-kn...

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FCPA Compliance Report
Five Famous Fraudsters-Episode 5, Joseph Grmovsek and the human cost of fraud from 2019-01-14T06:00

In this special five-part podcast series, I interview John Gill, the Vice President for Education at the Association of Certified Fraud Examiners (ACFE). In this series, John discusses five well-kn...

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FCPA Compliance Report
Daily Compliance News: January 14, 2019-the 2020 Olympic corruption edition from 2019-01-14T06:00

In today’s edition of Daily Compliance News: ·      Boeing probed by SEC. (Seattle Times)·      Ghosn faces more woes.  (New York Times)·      Sloan Kettering cuts back on industry ties. (New York ...

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FCPA Compliance Report
Popcorn and Compliance: Mary Poppins Returns from 2019-01-12T19:30

In this new podcast series, recovering screenwriter (and Mr. Monitor) Jay Rosen and myself will indulge in passion for the movies by looking at them through the lens of compliance. Jay is a contemp...

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FCPA Compliance Report
This Week in FCPA-Episode 137- the Double Doink edition from 2019-01-11T17:51

The Texans stink up their playoff game, the Bears double-doink their way out, the Seahawks lose but have a great backdoor cover, while in the college ranks Clemson absolutely destroys the previousl...

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FCPA Compliance Report
Daily Compliance News: January 11, 2019-the Bad Money edition from 2019-01-11T06:00

JANUARY 11, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      When is the color of your money B-A-D? (Wall Street Journal)·      Think CEOs aren’t involving in kickbacks? Think ag...

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FCPA Compliance Report
Episode 102-Review of 2018 and Preview of 2019 from 2019-01-10T06:00

In this episode of 12 O’Clock High, a podcast on business leadership, Richard Lummis and I take a look back at some of our favorite (and listener favorites as well) episodes from 2018 and where we ...

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FCPA Compliance Report
Daily Compliance News: January 10, 2019-the Board OK’d it edition from 2019-01-10T06:00

JANUARY 10, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      No mooncakes for you this year. (BNA)·      Carlos Ghosn says Nissan Board approved his conflicts of interest, unethi...

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FCPA Compliance Report
Daily Compliance News: January 9, 2019-the SODDIT edition from 2019-01-09T06:00

JANUARY 9, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Peru AG who tried to scuttle Odebrecht corruption investigation forced to resign. (Reuters)·      Carlos Ghosn say SOD...

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FCPA Compliance Report
Compliance into the Weeds: Episode 106- the Nine for 2019 Edition from 2019-01-09T06:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: January 8, 2019-the getting a raise edition from 2019-01-08T06:00

JANUARY 8, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      You thought “The Wolf of Wall Street” was bad? Leonard DiCaprio testifies to Grand Jury on 1MDB corruption scandal. (T...

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FCPA Compliance Report
FCPA Compliance Report-Episode 412, Philip Urofsky on Shearman&Sterling’s 2019 FCPA Digest from 2019-01-07T06:00

At the start of each year are a number of reviews of the prior year in FCPA and more general anti-corruption compliance enforcement. One of the top reviews is the Shearman&Sterling annual digest. T...

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FCPA Compliance Report
Top Five Corporate Scandals of 2018: Episode V-Nissan and Carlos Ghosn from 2019-01-07T06:00

In this five-part podcast series, I visit with Amii Barnard-Bahn to consider five of the top corporate scandals from 2018. The five we discuss are CBS, 1MDB/Goldman Sachs, Facebook, Tesla and Nissa...

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FCPA Compliance Report
Top Five Corporate Scandals of 2018: Episode IV-Tesla and its Elon Problem from 2019-01-07T06:00

In this five-part podcast series, I visit with Amii Barnard-Bahn to consider five of the top corporate scandals from 2018. The five we discuss are CBS, 1MDB/Goldman Sachs, Facebook, Tesla and Nissa...

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FCPA Compliance Report
Top Five Corporate Scandals of 2018: Episode I-CBS and Les Moonves from 2019-01-07T06:00

In this five-part podcast series, I visit with Amii Barnard-Bahn to consider five of the top corporate scandals from 2018. The five we discuss are CBS, 1MDB/Goldman Sachs, Facebook, Tesla and Nissa...

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FCPA Compliance Report
Top Five Corporate Scandals of 2018: Episode III-Facebook’s Drip, Drip, Drip from 2019-01-07T06:00

In this five-part podcast series, I visit with Amii Barnard-Bahn to consider five of the top corporate scandals from 2018. The five we discuss are CBS, 1MDB/Goldman Sachs, Facebook, Tesla and Nissa...

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FCPA Compliance Report
Daily Compliance News: January 7, 2019-the COI edition from 2019-01-07T06:00

JANUARY 7, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Carlos Ghosn scheduled to a court appearance in Tokyo on Tuesday. What could go wrong? (New York Times)·      PG&E to ...

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FCPA Compliance Report
Top Five Corporate Scandals of 2018: Episode II-1MDB and Goldman Sachs from 2019-01-07T06:00

In this five-part podcast series, I visit with Amii Barnard-Bahn to consider five of the top corporate scandals from 2018. The five we discuss are CBS, 1MDB/Goldman Sachs, Facebook, Tesla and Nissa...

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FCPA Compliance Report
This Week in FCPA-Episode 136 from 2019-01-04T16:58

The Texas Longhorns won the Sugar Bowl and Tom is still celebrating. Will he come down to earth with both the Cowboys and Texans playing on Saturday in the first round of the NFL playoffs? Tom and ...

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FCPA Compliance Report
Daily Compliance News: January 4, 2019-the ‘Just Kidding’ edition from 2019-01-04T06:00

JANUARY 4, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Peru AG reverses course on derailing Odebrecht investigation. (Reuters)·      Do you have a succession plan? (Wall Str...

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FCPA Compliance Report
Everything Compliance-Episode 39, the Post-Election edition, Part II from 2019-01-03T06:00

Welcome to the only roundtable podcast in compliance. This week’s episode is the second of a two-part podcast series where we consider the results of the 2018 mid-term elections and what it may mea...

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FCPA Compliance Report
Daily Compliance News: January 3, 2019-the All Things Must Pass edition from 2019-01-03T06:00

JANUARY 3, 2019 BY TOM FOX In today’s edition of Daily Compliance News:Peru AG kills Odebrecht investigation. (New York Times)How the Dallas Mavericks responded to their #MeToo moment. (Bloomberg)...

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FCPA Compliance Report
Compliance into the Weeds: Episode 105- the Polycom FCPA Enforcement Action from 2019-01-02T13:34

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: January 2, 2019-Sugar Bowl champs edition from 2019-01-02T11:35

JANUARY 2, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Is Facebook facing a reckoning? (Financial Times)·      Can nudges make your workplace better. (New York Times) ·     ...

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FCPA Compliance Report
Daily Compliance News: January 1, 2019-Welcome to the New Year edition from 2019-01-01T06:00

JANUARY 1, 2019 BY TOM FOX In today’s edition of Daily Compliance News:·      Data abuses abound but will the FTC take action? (New York Times)·      Never good to be on the front page of the NYT ...

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FCPA Compliance Report
McChrystal on Leadership: Part 1- the Founders-Walt Disney and Coco Chanel from 2018-12-31T06:00

In this special five-part podcast series, we consider the business leadership issues raised by General Stanley McChrystal (ret.) recent book Leaders-Myth and Reality, which he co-authored with Jeff...

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FCPA Compliance Report
McChrystal on Leadership: Part 4- the Power Brokers-Boss Tweed and Thatcher from 2018-12-31T06:00

In this special five-part podcast series, we consider the business leadership issues raised by General Stanley McChrystal (ret.) recent book Leaders-Myth and Reality, which he co-authored with Jeff...

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FCPA Compliance Report
McChrystal on Leadership: Part 5- the Reformers-Martin Luther and Martin Luther King, Jr. from 2018-12-31T06:00

In this special five-part podcast series, we consider the business leadership issues raised by General Stanley McChrystal (ret.) recent book Leaders-Myth and Reality, which he co-authored with Jeff...

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FCPA Compliance Report
McChrystal on Leadership: Part 3- the Heroes, Harriett Tubman and Zheng He from 2018-12-31T06:00

In this special five-part podcast series, we consider the business leadership issues raised by General Stanley McChrystal (ret.) recent book Leaders-Myth and Reality, which he co-authored with Jeff...

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FCPA Compliance Report
Daily Compliance News: December 31, 2018-the farewell to 2018 edition from 2018-12-31T06:00

DECEMBER 31, 2018 BY TOM FOX In today’s edition of Daily Compliance News:Larry Ellison joins the Tesla board. What could go wrong? (Wall Street Journal)The rise and fall of Carlos Ghosn. (New York...

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FCPA Compliance Report
McChrystal on Leadership: Part 2- the Geniuses, Albert Einstein and Leonard Bernstein from 2018-12-31T06:00

In this special five-part podcast series, we consider the business leadership issues raised by General Stanley McChrystal (ret.) recent book Leaders-Myth and Reality, which he co-authored with Jeff...

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FCPA Compliance Report
This Week in FCPA-Episode 135 - the Shutdown edition from 2018-12-28T14:42

While Trump has shut down the government over the holidays, compliance and ethics has not been shutdown. With Jay taking some time off to spend time with the family over this holiday week, Tom take...

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FCPA Compliance Report
Daily Compliance News: December 28, 2018-the Trek across the Pole edition from 2018-12-28T10:53

DECEMBER 28, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      Polycom receives declination with disgorgement in FCPA enforcement action. (FCPA Blog)·      ISIS has $400MM to spen...

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FCPA Compliance Report
Everything Compliance-Episode 38, the Post-Election edition, Part I from 2018-12-27T14:35

Welcome to the only roundtable podcast in compliance. This week’s episode will be the first of a two-part podcast series where we consider the results of the 2018 mid-term elections and what it may...

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FCPA Compliance Report
Daily Compliance News: December 27, 2018-Betting in Tennis edition from 2018-12-27T06:00

DECEMBER 27, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      India getting more foreign investment monies. Is your compliance program ready? (Wall Street Journal)·      How clos...

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FCPA Compliance Report
Daily Compliance News: December 26, 2018-The Boxing Day edition from 2018-12-26T06:00

DECEMBER 26, 2018 BY TOM FOX In today’s edition of Daily Compliance News:How did the Gupta family capture the South African government? (New York Times)How did GE burn out? ( Wall Street Journal)G...

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FCPA Compliance Report
Daily Compliance News: December 24, 2018-The Christmas Eve edition from 2018-12-24T12:02

DECEMBER 24, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      Want teamwork, think of Shackleton? (Financial Times)·      The Big Story profiles Tim Leissner. (Financial Times)· ...

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FCPA Compliance Report
Daily Compliance News: December 21, 2018-What is sophisticated corruption ? from 2018-12-21T19:34

DECEMBER 21, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      What is ‘sophisticated corruption’? (FCPA Blog)·      Rivals beating up SNC-Lavalin for the corruption. (Bloomberg)·...

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FCPA Compliance Report
This Week in FCPA-Episode 134 from 2018-12-21T11:11

As the lads put on their final holiday push to make sure they are on the nice list, they consider some of the companies that may be on the naughty list, including Les Mooves and CBS, Goldman Sachs ...

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FCPA Compliance Report
Popcorn and Compliance: Elf from 2018-12-21T06:00

In this new podcast series, recovering screenwriter (and Mr. Monitor) Jay Rosen and myself will indulge in passion for the movies by looking at them through the lens of compliance. Jay is a contemp...

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FCPA Compliance Report
Daily Compliance News: December 20, 2018-What is a wolf culture? from 2018-12-20T11:31

DECEMBER 20, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      Barclays fined $15MM by NY-DFS for attempted whistleblower unmasking. (Wall Street Journal)·      CBS on hook for Mo...

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FCPA Compliance Report
Daily Compliance News: December 19, 2018-Will the Moonves family get presents this year? from 2018-12-19T06:00

DECEMBER 19, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      CBS will not pay Les Moonves $120MM in severance. (BBC)·      UBS draws $15MM fine for AML violations. (Wall Street ...

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FCPA Compliance Report
Compliance into the Weeds: Episode 104- Culture and Compliance Structure Failures at CBS from 2018-12-19T06:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: December 18, 2018-Goldman Criminally Indicted over 1MDB from 2018-12-18T06:00

DECEMBER 18, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      Goldman Sachs criminally indicted in Malaysia. (Wall Street Journal)·      Facebook has another breach, this time on...

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FCPA Compliance Report
Advantages of a Whistleblower Reporting System: Part IV - Key Findings of the Report from 2018-12-17T06:00

During this podcast series, I have been interviewing Dr. Kyle Welch, Assistant Professor at George Washington University (GWU), on his recently released paper, co-authored with Stephen Stubben, Ass...

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FCPA Compliance Report
Advantages of a Whistleblower Reporting System: Part V - For Compliance Practitioners from 2018-12-17T06:00

Over this special five-part podcast series, I have visited with Dr. Kyle Welch, Assistant Professor at George Washington University (GWU), on his recently released paper, co-authored with Stephen S...

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FCPA Compliance Report
FCPA Compliance Report-Episode 411, Doreen Edelman CFIUS for Compliance Professionals, Part II from 2018-12-17T06:00

The FCPA Compliance Report is the longest running podcast in compliance. In this episode, I visit with Doreen Edelman, partner at Lowenstein Sandler. She is a noted trade law and trade policy exper...

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FCPA Compliance Report
Daily Compliance News: December 17, 2018-Lying will put you on the Naughty List from 2018-12-17T06:00

DECEMBER 17, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      Why was the CFO of Huawei charged with criminal conduct? She lied to HSBC. (New York Times)·      Why with Michael F...

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FCPA Compliance Report
Advantages of a Whistleblower Reporting System: Part I – Introduction to Research on Whistleblowing Systems from 2018-12-17T06:00

In this special five-part podcast series, I interviewed Dr. Kyle Welch, Assistant Professor at George Washington University (GWU), on his recently released paper, co-authored with Stephen Stubben, ...

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FCPA Compliance Report
Advantages of a Whistleblower Reporting System: Part III - Impact on Power Users from 2018-12-17T06:00

In this podcast series, I interviewed Dr. Kyle Welch, Assistant Professor at George Washington University (GWU), on his recently released paper, co-authored with Stephen Stubben, Associate Professo...

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FCPA Compliance Report
Advantages of a Whistleblower Reporting System: Part II - Internal v. External Reporting from 2018-12-17T06:00

In this podcast series, I interviewed Dr. Kyle Welch, Assistant Professor at George Washington University (GWU), on his recently released paper, co-authored with Stephen Stubben, Associate Professo...

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FCPA Compliance Report
Daily Compliance News: December 14, 2018-What is a COI? from 2018-12-14T06:00

Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
This Week in FCPA-Episode 133 - the NYC at Christmastime edition from 2018-12-14T06:00

As Tom prepares to head to NYC for a magical December weekend in the big city, he celebrates the Cowboys taking control of the NL East and Jay mourns yet another Patriot loss to the Dolphins in Mia...

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FCPA Compliance Report
Daily Compliance News: December 13, 2018-Bribes of $1 Illegal in Singapore from 2018-12-13T06:00

DECEMBER 13, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      What is your investigation protocol? What will the NFL do? (Sports Illustrated)·      OECD finds fewer penalties lev...

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FCPA Compliance Report
Daily Compliance News: December 12, 2018-CBS Worried (and its not a good worry) from 2018-12-12T06:00

DECEMBER 12, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      CBS Corp more concerned that internal investigation leaked than substance of the report. (Wall Street Journal)·     ...

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FCPA Compliance Report
Compliance into the Weeds: Episode 103- Conspiracy or Coincidence? from 2018-12-12T06:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Daily Compliance News: December 11, 2018-Shopping for Christmas? from 2018-12-11T06:00

DECEMBER 11, 2018 BY TOM FOX In today’s edition of Daily Compliance News:Two British banks ensnared in Huawei scandal. (Wall Street Journal)How exposed is Goldman Sachs in the 1MDB scandal? (New Y...

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FCPA Compliance Report
International due diligence investigations-Episode 2, Insights from Recent Enforcement Actions from 2018-12-10T06:00

During this series, I will be visiting with Candice Tal, founder and Chief Executive Officer (CEO) of Infortal Worldwide, the sponsor of this podcast series. We will be considering various aspects ...

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FCPA Compliance Report
International due diligence investigations-Episode 3, What is and is not working from 2018-12-10T06:00

Over this series, I am visiting with Candice Tal, founder and Chief Executive Officer (CEO) of Infortal Worldwide, the sponsor of this podcast series. We consider various aspects of international d...

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FCPA Compliance Report
International Due Diligence Investigations: Episode 4 - M&A from 2018-12-10T06:00

Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
International Due Diligence Investigations: Episode 5 - Global Investigations and Innovation from 2018-12-10T06:00

Over this series, I have been visiting with Candice Tal, founder and Chief Executive Officer (CEO) of Infortal Worldwide, who sponsored this podcast. We have considered aspects of international due...

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FCPA Compliance Report
Daily Compliance News: December 10, 2018-Send in the Clowns from 2018-12-10T06:00

DECEMBER 10, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      China threatens Canada over Huawei arrest. (Wall Street Journal)·      Huawei accused of fraud in indictment. (New Y...

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FCPA Compliance Report
FCPA Compliance Report-Episode 410, Doreen Edelman CFIUS for Compliance Professionals, Part I from 2018-12-10T06:00

The FCPA Compliance Report is the longest running podcast in compliance. In this episode, I visit with Doreen Edelman, partner at Lowenstein Sandler. She is a noted trade law and trade policy exper...

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FCPA Compliance Report
International due diligence investigations: Episode 1-When basic due diligence is no longer enough from 2018-12-10T06:00

Over the next five episodes, I will be visiting with Candice Tal, founder and Chief Executive Officer (CEO) of Infortal Worldwide, who is the sponsor of this podcast series. We will be considering ...

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FCPA Compliance Report
Popcorn and Compliance: Bohemian Rhapsody from 2018-12-08T06:00

In this new podcast series, recovering screenwriter (and Mr. Monitor) Jay Rosen and I will indulge in passion for the movies by looking at them through the lens of compliance. Jay is a contemporary...

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FCPA Compliance Report
Daily Compliance News: December 7, 2018-Better Late Than Never from 2018-12-07T06:00

DECEMBER 7, 2018 BY TOM FOX In today’s edition of Daily Compliance News:·      US has Canada arrest Huawei CFO. Markets roiled. (New York Times)·      Some 5 years after scandal broke, Wells Fargo...

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FCPA Compliance Report
Daily Compliance News: December 6, 2018, How Bad is Bad-Very Bad from 2018-12-06T06:00

What are some of the top compliance and corruption stories of December 6, 2018? Sit back with a cup of coffee and join Tom Fox, the Compliance Evangelist and listen in on the Daily Compliance News....

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FCPA Compliance Report
Daily Compliance News: December 5, 2018-Does the NFL Even Care? from 2018-12-05T06:00

DECEMBER 5, 2018 BY TOM FOX  In today’s edition of Daily Compliance News:Is ‘forced hugging’ sexual harassment? (Washington Post)Is the NFL simply incompetent or does it intentionally ignore eviden...

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FCPA Compliance Report
Daily Compliance News: More Bad on 1MDB from 2018-12-04T06:00

DECEMBER 4, 2018 BY TOM FOX In today’s edition of Daily Compliance News:Goldman Sachs says it will use monitoring for high-risk transactions. (Financial Times)·      Did Marriott meet the SEC sta...

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FCPA Compliance Report
Return of the Jedi – Effective Compliance Training from 2018-12-03T16:00

Today we continue our celebration and exploration of the original trilogy of Star Wars movies with a look at Episode VI. Return of the Jedi. In this final movie from the original three, the good gu...

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FCPA Compliance Report
The Force Awakens and Disruptive Innovation in Compliance from 2018-12-03T16:00

Today Jay and I consider the first ‘new’Star Wars movie entry, Episode VII –The Force Awakens. I say it is a new Star Wars movie as it was the first one not created by LucasFilms, as George Lucas h...

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FCPA Compliance Report
The Empire Strikes Back - Due Diligence from 2018-12-03T16:00

Second in our 5-part series on compliance through the lens of Star Wars is Episode V - The Empire Strikes Back, which is my personal favorite of the original three movies. The film begins with a co...

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FCPA Compliance Report
A New Hope-What is Risk? from 2018-12-03T16:00

Today I begin a new podcast series with recovering screenwriter, Jay Rosen. The Podcast series is entitled Popcorn and Compliance-at the Movies with Tom and Jay. In this new offering from the Compl...

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FCPA Compliance Report
Rogue One and the Myth of the Rogue Employee from 2018-12-03T16:00

We conclude our 5-part series on the intersection of Star Wars and compliance by looking at the only stand-alone entry in the Star War series, Rogue One. This movie tells the tale of the spies who ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 409, Ann Sultan on the Miller&Chevalier’s Autumn FCPA Report 2018 from 2018-12-03T12:00

 The FCPA Compliance Report is the longest running podcast in compliance. In this episode, I visit with Ann Sultan, Counsel and Miller&Chevalier. We discuss the firm’s Autumn FCPA Report 2018. It i...

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FCPA Compliance Report
Daily Compliance News: December 3, 2018-Autonomy CEO Indicted from 2018-12-03T06:00

In today’s edition of Daily Compliance News:Former Autonomy CEO indicted in US over HP deal. (The Guardian)Marriott hit with huge data breach.(Wall Street Journal)Former Nissan CEO jail time extend...

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FCPA Compliance Report
This Week in FCPA-Episode 131 from 2018-11-30T18:21:47

As Tom and Jay prepare for the December holiday season, they consider the DOJ/SEC’s strong affirmation that aggressive FCPA enforcement is here to stay, changes to the Yates Memo/plea for increased...

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FCPA Compliance Report
Daily Compliance News: November 28, 2018-Banks Behaving Badly from 2018-11-30T05:00

Why are banks continuing to behave badly? Will they ever learn their lesson? Find out the latest news on the Daily Compliance News with Tom Fox, on the Compliance Podcast Network. Learn more about ...

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FCPA Compliance Report
Life With GDPR: Episode 19-Class Actions around Data Privacy from 2018-11-29T17:00

What are your risks of a data privacy breach? Do they include disgruntled employees turning over personal payroll data to the Fourth Estate? Have you performed a Data Privacy Impact Assessment? If ...

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FCPA Compliance Report
Daily Compliance News: November 29, 2018-Need a Yacht? from 2018-11-29T05:00

What are some of the top compliance and corruption stories for November 29? Sit back with a cup of coffee and Tom Fox, the Compliance Evangelist and listen to the Daily Compliance News. Learn more...

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FCPA Compliance Report
Compliance into the Weeds: the Vantage Drilling FCPA Enforcement Action from 2018-11-28T17:00

In this episode, Matt Kelly and I take a deep dive into the recent Vantage Drilling FCPA enforcement action. It is a highly unusual enforcement action with some very different facts from the standa...

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FCPA Compliance Report
Daily Compliance News: Parliament Steps In from 2018-11-28T06:00

What are some of the top compliance stories for November 28, 2018? Sit back with a cup of coffee and listen in with Tom Fox on the Daily Compliance News. Learn more about your ad choices. Visit me...

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FCPA Compliance Report
Compliance Lessons from Venice: Doing Compliance the Old-Fashioned Way from 2018-11-26T17:00

Today I begin a five-part podcast series on compliance lessons I observed from a recent holiday in Venice. I start the series with a look at the manner in which building repairs are done in the cit...

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FCPA Compliance Report
Compliance Lessons from Venice: Arsenale and Incentivizing Compliance from 2018-11-26T17:00

I continue with my Venice themed podcast series by focusing on the Arsenale. This is not a precursor to that famous north London football club, the Arsenal Gunners, but the district in Venice where...

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FCPA Compliance Report
Compliance Lessons from Venice: Selfie-Sticks and Risk Assessments from 2018-11-26T17:00

Today our compliance insight comes not from the old Venice but from the new and ever-changing Venice, its street vendors. It is about using their ‘invisible hand’ to inform your risk assessments. L...

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FCPA Compliance Report
Compliance Lessons from Venice: How the Lion’s Mouth Informs Your Hotline from 2018-11-26T17:00

As podcast series on compliance lessons from Venice draws to an end, I am reminded how much the western world has to thank the Republic of Venice. From the forms of republican democracy, to helpin...

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FCPA Compliance Report
Compliance Lessons from Venice: How the Venetian Gondolier Informs Your Compliance Program from 2018-11-26T17:00

If there is one thing that is ubiquitous throughout this city it is the Gondolier. In addition to having a stout pairs of lungs, the Gondolier are in very good physical condition. As a CCO, the mor...

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FCPA Compliance Report
FCPA Compliance Report-Episode 408 from 2018-11-26T16:00

In this episode I have back noted data protection expert Brad Davis. Our topic is data protection and Davis’ advocacy of social engineering as the first line of defense for every corporation from h...

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FCPA Compliance Report
Life With GDPR: Emergency Episode-Facebook Files from 2018-11-26T15:50:09

In this episode, Jonathan Armstrong and I record our first emergency podcast on Life with GDPR. It relates to documents obtained by the UK Parliamentary Digital, Culture, Media and Sports Committee...

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FCPA Compliance Report
Daily Compliance News: Lunch with the FT from 2018-11-26T07:00

What are some of the top compliance and corruption stories for November 26? Sit back with a cup of coffee and Tom Fox, the Compliance Evangelist to find out. Learn more about your ad choices. Visi...

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FCPA Compliance Report
This Week in FCPA-Episode 130 from 2018-11-23T21:22:24

As Tom and Jay move from eating way to much to watching some great college football on this Thanksgiving holiday weekend, they look at some of the week’s top compliance and ethics stories on This W...

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FCPA Compliance Report
Daily Compliance News: Post Thanksgiving Edition from 2018-11-23T10:49:01

What are some of the top compliance and corruption stories for November 23? Find out on the Daily Compliance News, with Tom Fox. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Daily Compliance News: Danske Bank scandal spreads from 2018-11-21T05:00

What are some of the day's top compliance and corruption stories? Sit back with a cup of coffee and find out with Tom Fox on the Daily Compliance News. Learn more about your ad choices. Visit mega...

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FCPA Compliance Report
Daily Compliance News: Year of the Whistleblower? from 2018-11-20T05:30

What were some of the top compliance and corruption stories for November 20, 2018? Sit back with a good cup of joe and listen to Tom Fox on the Daily Compliance News. Learn more about your ad choi...

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FCPA Compliance Report
Daily Compliance News: Stranger than Fiction from 2018-11-19T07:00

What are some of the top corruption and compliance stories to read to start your day? Find out with Tom Fox on the Daily Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/ad...

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FCPA Compliance Report
This Week in FCPA-Episode 129 the Farewell to Stan Lee edition from 2018-11-16T17:00

As Tom and Jay mourn the death of cultural icon Stan Lee, they consider that story and look at some of the week’s top compliance and ethics stories.  Learn more about your ad choices. Visit megapho...

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FCPA Compliance Report
Daily Compliance News: Facebook Attacks from 2018-11-16T07:00

What are some of the day's top compliance and corruption stories? Find out on the Daily Compliance News. Today we consider Facebook and its response to various scandals. Learn more about your ad ch...

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FCPA Compliance Report
Everything Compliance-Episode 37 from 2018-11-15T17:00

Welcome to the only roundtable podcast in compliance. This week’s episode was is dedicated to considering one article which recently appeared in the New York Times, entitled, “Trump Administration ...

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FCPA Compliance Report
Daily Compliance News: A Public Spanking from 2018-11-15T07:00

What were some of the top compliance and corruption stories for November 15? Check in with the Tom Fox, the Compliance Evangelist, a cup of coffee and the Daily Compliance News. Learn more about y...

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FCPA Compliance Report
Daily Compliance News-Bad Blood from 2018-11-14T07:00

What are some of the top compliance stories for November 14, 2018? Check with a cup of coffee, the Compliance Evangelist on the Daily Podcast News.  Learn more about your ad choices. Visit megaphon...

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FCPA Compliance Report
Daily Compliance News: Farewell to Stan Lee from 2018-11-13T07:00

What were today's top compliance, leadership and corruption stories? Find out on November 13, 2018 edition of the Daily Compliance News, with a tribute to Stan Lee. Learn more about your ad choice...

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FCPA Compliance Report
Ethics and Compliance Monitoring Across the EU and Beyond: Part 3 from 2018-11-12T17:00

In this podcast series, I visit with Vin DiCianni, founder and President of Affiliated Monitors, Inc. (AMI) and Eric Feldman, Senior Vice President of AMI. We consider the global view of ethics, co...

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FCPA Compliance Report
FCPA Compliance Report-Episode 407 from 2018-11-12T17:00

In the Episode, I visit with podcast favorite Mike Volkov and we consider FCPA enforcement and compliance programs over the past five years and where it may be going in the future. Learn more about...

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FCPA Compliance Report
Ethics and Compliance Monitoring Across the EU and Beyond: Part 4 from 2018-11-12T17:00

In this podcast series, I visit with Vin DiCianni, founder and President of Affiliated Monitors, Inc. (AMI) and Eric Feldman, Senior Vice President of AMI. We consider the global view of ethics, co...

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FCPA Compliance Report
Ethics and Compliance Monitoring Across the EU and Beyond: Part 5 from 2018-11-12T17:00

In this concluding Part 5, I discuss some of the challenges for monitors in the international arena with Feldman. AMI has a long history of working with internationally based companies. It is there...

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FCPA Compliance Report
Ethics and Compliance Monitoring Across the EU and Beyond: Part 1 from 2018-11-12T17:00

In this podcast series, I visit with Vin DiCianni, founder and President of Affiliated Monitors, Inc. (AMI) and Eric Feldman, Senior Vice President of AMI. We consider the global view of ethics, co...

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FCPA Compliance Report
Ethics and Compliance Monitoring Across the EU and Beyond: Part 2 from 2018-11-12T17:00

In this podcast series, I visit with Vin DiCianni, founder and President of Affiliated Monitors, Inc. (AMI) and Eric Feldman, Senior Vice President of AMI. We consider the global view of ethics, co...

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FCPA Compliance Report
Daily Compliance News: Honoring Veterans from 2018-11-12T07:00

What are some of the top stories in compliance and ethics for November 12, 2018? Grab a cup of coffee and join Tom Fox, the Compliance Evangelist to find out. Learn more about your ad choices. Vis...

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FCPA Compliance Report
This Week in FCPA-Episode 128 from 2018-11-09T18:08:57

Goldman Sachs has a very bad week, most particularly around its role in the 1MDB scandal. Tom and Jay consider that story and look at some of the week’s top compliance and ethics stories.  Learn mo...

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FCPA Compliance Report
Daily Compliance News-November 9 from 2018-11-09T07:00

What are some of the top compliance and corruption stories for November 9, 2018? Sit down with a cup of coffee and Tom Fox, the Compliance Evangelist to find out on the Daily Compliance News. Learn...

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FCPA Compliance Report
Across the Board-Episode 25 from 2018-11-08T17:00

In this episode of Across the Board, I visit with Doreen Lilienfield. She is a partner at Shearman&Sterling in New York. Today we visit on the firm’s Shearman&Sterling Annual Corporate Governance&E...

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FCPA Compliance Report
Compliance into the Weeds: Episode 100 from 2018-11-07T17:00

In this episode, Matt Kelly and I take a deep dive into the recently announced reorganization of the Michigan State University compliance function, rolling it into the newly created Office of Audit...

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FCPA Compliance Report
Daily Compliance News: November 7 from 2018-11-07T05:00

What were some of the day's top compliance and corruption stories? Find out on the Daily Compliance News. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Daily Compliance News-November 6, 2018 from 2018-11-06T20:56:02

What are some of the top stories around bribery, corruption, compliance and ethics for November 6, 2018? Find out on the Daily Compliance News. Learn more about your ad choices. Visit megaphone.fm...

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FCPA Compliance Report
Life With GDPR: Episode 18 from 2018-11-06T17:00

In this episode I visit with Jonathan Armstrong and we update the current status of Privacy Shield in EU, US and UK. On both sides of the Atlantic, Privacy Shield is still a topic of hot conversati...

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FCPA Compliance Report
FCPA Compliance Report-Episode 406 from 2018-11-05T17:00

In the episode, I visit with James Koukios, a partner at Morrison and Foerster in Washington DC. Koukios is a former prosecutor from the Department of Justice who worked in the FCPA Unit. He is bac...

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FCPA Compliance Report
Daily Compliance News, November 5, 2018 from 2018-11-05T05:00

The top compliance and ethics stories for November 5, 2018. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Daily Compliance News: November 2, 2018 from 2018-11-02T04:00

In today’s edition of Daily Compliance News: Maryland football coach DJ Durkin fired one day after Systems Board of Regents reinstated him. (New York Times)Big news in the 1MDB scandal. Tim Leiss...

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FCPA Compliance Report
This Week in FCPA-Episode 127 from 2018-11-01T22:59:02

The Boston Red Sox thrashed the LA Dodgers in World Series, bringing the trophy back to Boston for the 4th time in 15 years. What’s it like to support such a loveable winner? Jay shares some of the...

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FCPA Compliance Report
Across the Board-Episode 24, Amii Barnard-Bahn from 2018-11-01T16:00

In this episode of Across the Board, I visit with Amii Barnard-Bahn. Today’s topic is the Board’s failures at Theranos and how they helped lead to the demise of the company.  Learn more about your...

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FCPA Compliance Report
Daily Compliance News-November 1, 2018 from 2018-11-01T04:00

Check out the compliance news for November 1, 2018. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Life With GDPR: Episode 17 from 2018-10-31T16:00

In this episode I visit with Jonathan Armstrong on some of the themes that have emerged in the nearly six months since GDPR has gone live. Armstrong has traveled literally across the globe to work ...

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FCPA Compliance Report
Adventures in Compliance- Episode 10 from 2018-10-29T16:00

In this podcast, I consider Sherlock Holmes as a teacher and the role he sets out for every Chief Compliance Officer. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Adventures in Compliance - Episode 6 from 2018-10-29T16:00

In this episode, I consider Conan Doyle’s third Sherlock Homes novel, The Hound of the Baskervilles. The novel, originally serialized in The Strandfrom 1901 to 1902, is generally recognized by Sher...

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FCPA Compliance Report
Adventures in Compliance - Episode 7 from 2018-10-29T16:00

How does a Chief Compliance Officer or compliance professional think through the innovation process? In this podcast I lay out four steps for doing so. Learn more about your ad choices. Visit megap...

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FCPA Compliance Report
Adventures in Compliance - Episode 9 from 2018-10-29T16:00

How are you using power? While many compliance departments may have begun more as a command and control function, set up by lawyers to comply with anti-bribery laws such as the FCPA; this type of l...

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FCPA Compliance Report
Adventures in Compliance - Episode 8 from 2018-10-29T16:00

In this podcast, we celebrate Doyle’s final novel, The Valley of Fear. It was notable for two reasons. The first that it was at least inspired by events in America involving the Molly Maguires, the...

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FCPA Compliance Report
FCPA Compliance Report-Episode 405 from 2018-10-28T16:00

In the Episode, I visit with Yvette Lingom, Associate Director, Programming at C5 Communications Ltd. We discuss the opening of the nomination process for C5’s Women in Compliance Awards which are ...

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FCPA Compliance Report
This Week in FCPA-Episode 126 from 2018-10-26T16:00

What were the top stories in compliance and ethics over the past week? Find out in This Week in FCPA with Tom Fox and Jay Rosen.  Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Everything Compliance-Episode 36 from 2018-10-25T16:00

Welcome to the only roundtable podcast in compliance. The genesis of Everything Compliance was our first podcast three years ago at SCCE in Chicago. We reconvene for this  week’s episode at the SCC...

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FCPA Compliance Report
Compliance into the Weeds: Episode 99 from 2018-10-24T16:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
FCPA Compliance Report-Episode 404 from 2018-10-22T16:00

In the Episode, I visit with Dave Lefort, the Editor in Chief of Compliance Week. We visit on Dave’s route as a journalist and online sports leader to compliance. We discuss some of his new initiat...

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FCPA Compliance Report
This Week in FCPA-Episode 125 from 2018-10-19T12:16:22

The Boston Red Sox storm into the World Series after defeating the Houston Astros in the ALCS. Will the team with the best record in baseball take home the trophy this year? Jay and Tom (well reall...

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FCPA Compliance Report
Across the Board-Episode 23 from 2018-10-18T16:00

In this episode of Across the Board, I visit with Amii Barnard-Bahn. Today’s topic is the ongoing turmoil at Tesla around its founder and CEO Elon Musk and his ‘funding secured’ tweet from the corp...

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FCPA Compliance Report
Compliance into the Weeds: Episode 98 from 2018-10-17T14:48:19

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Adventures in Compliance - Episode II from 2018-10-15T16:00

This week returns to one my favorite themes for every Chief Compliance Officer, compliance professional and compliance program: Sherlock Holmes. In this podcast series I will be focusing on themes...

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FCPA Compliance Report
Adventures in Compliance – Episode I from 2018-10-15T16:00

This week I return to one my favorite themes for every Chief Compliance Officer, compliance professional and compliance program: Sherlock Holmes. Over this new podcast series, I will be considering...

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FCPA Compliance Report
Adventures in Compliance – Episode IV from 2018-10-15T16:00

This week is a return to one my favorite themes for every Chief Compliance Officer (CCO), compliance professional and compliance program: Sherlock Holmes. Over this week, I am considering themes fr...

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FCPA Compliance Report
Adventures in Compliance - Episode V from 2018-10-15T16:00

This podcast series returns to one my favorite themes for every Chief Compliance Officer (CCO), compliance professional and compliance program: Sherlock Holmes. In Adventures in Compliance, I consi...

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FCPA Compliance Report
Adventures in Compliance - Episode III from 2018-10-15T16:00

This week I have returned to one my favorite themes for every Chief Compliance Officer, compliance professional and compliance program: Sherlock Holmes. I am using themes from the Holmes short stor...

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FCPA Compliance Report
This Week in FCPA-Episode 124 from 2018-10-12T15:51:33

The reigning World Series Champions, the Houston Astros storm into the ALCS with a sweep of Cleveland.  The team with the best record in baseball, the Boston Red Sox destroy the Yankees. The ALCS o...

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FCPA Compliance Report
Across the Board-Episode 22 from 2018-10-11T16:00

In this very special episode of Across the Board, I continue my celebration of 1000 podcasts on the Compliance Podcast Network. In this episode of Across the Board. I visit with Sheila Hooda about ...

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FCPA Compliance Report
Compliance into the Weeds: Episode 97 from 2018-10-10T16:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
The Opinion Release Papers: Opinion Release 12-01 from 2018-10-08T22:42:50

Opinion Release 12-01is significant as it demonstrated not only the evolving nature of best practices under the FCPA but also the DOJ’s thinking on the subject. Learn more about your ad choices. Vi...

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FCPA Compliance Report
The Opinion Release Papers: Opinion Release 12-02 from 2018-10-08T16:00

In Opinion Release 12-02, certain Requestors, which were 19 non-profit adoption agencies located in the US, asked the DOJ about bringing certain foreign governmental officials involved in the forei...

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FCPA Compliance Report
The Opinion Release Papers: Opinion Release14-02 from 2018-10-08T16:00

In this episode of the Opinion Release Papers, we consider Opinion Release 14-02. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
The Opinion Release Papers: Opinion Release 14-01 from 2018-10-08T16:00

In this episode, we consider Opinion Release 14-01, where the Department of Justice opined that paying a foreign government official for monies he was owed in the sale of a business interest that h...

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FCPA Compliance Report
The Opinion Release Papers: Opinion Release 13-01 from 2018-10-08T16:00

Late in 2013 the DOJ issued its only Opinion Release, that being Opinion Release 13-01. One of the things that this Opinion Release stands for is that each fact scenario presented under the FCPA mu...

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FCPA Compliance Report
FCPA Compliance Report-Episode 402 from 2018-10-08T14:00

In the Episode, I visit with one of the top outside counsel in field of FCPA and compliance. It is Stephen Martin, a partner at Arnold&Porter. In this episode we deconstruct the Petrobras FCPA enfo...

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FCPA Compliance Report
This Week in FCPA-Episode 123 from 2018-10-05T16:00

The baseball playoffs are here.  For the Sox, the hated Yankees. For the Astros, they begin their World Series defense against the Cleveland Indians. Tom and Jay discuss and take a look at some of ...

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FCPA Compliance Report
Everything Compliance-Episode 35 from 2018-10-04T16:00

Welcome to the only roundtable podcast in compliance. This week’s episode is entirely dedicated to the spectacle of the Ford-Kavanaugh hearings from the past week. Jonathan Armstrong is on assignme...

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FCPA Compliance Report
Compliance into the Weeds: Episode 96 from 2018-10-03T16:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
How Tech Informs Compliance to Create Business Efficiency: Part I from 2018-10-01T16:00

In this special five-part podcast series, I visit with Thomas Sehested, founder and CEO of Gan Integrity. In this series, we will consider how the effective use of technology can drive not only a m...

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FCPA Compliance Report
How Tech Informs Compliance to Create Business Efficiency: Part IV from 2018-10-01T16:00

In this special five-part podcast series, I visit with Thomas Sehested, founder and CEO of, Valerie Charles, Chief Strategy Officer and Peter Chang, Head of Customer Success of Gan Integrity. In th...

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FCPA Compliance Report
How Tech Informs Compliance to Create Business Efficiency: Part V from 2018-10-01T16:00

In this special five-part podcast series, I have visited with Thomas Sehested, founder and CEO of, Valerie Charles, Chief Strategy Officer and Peter Chang, Head of Customer Success of GAN Integrity...

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FCPA Compliance Report
How Tech Informs Compliance to Create Business Efficiency: Part II from 2018-10-01T16:00

In this special five-part podcast series, I visit with Thomas Sehested, founder and CEO of, Valerie Charles, Chief Strategy Officer and Peter Chang, Head of Customer Success of Gan Integrity. In th...

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FCPA Compliance Report
How Tech Informs Compliance to Create Business Efficiency: Part III from 2018-10-01T16:00

In this special five-part podcast series, I have visit with Thomas Sehested, Valerie Charles, and Peter Chang all from Gan Integrity. In this Part III, I visit with Thomas Sehested how tech soluti...

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FCPA Compliance Report
FCPA Compliance Report-Episode 401 from 2018-09-30T19:32:15

In the episode, I visit with Doug Allen, Managing Director at Ethisphere. We discuss the application process for Ethisphere’s 2019 World’s Most Ethical company designation. We consider the process ...

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FCPA Compliance Report
Compliance Report-International Edition-Timur Khasanov-Batirov from 2018-09-28T01:24:56

This month I am celebrating 1000 podcasts by discussing with my colleagues and friends from professional community on past, present and future of compliance. Today we have Timur Khasanov-Batirov, m...

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FCPA Compliance Report
This Week in FCPA-Episode 122 from 2018-09-27T22:26:06

Both the Astros and Red Sox have over 100 wins. Who will come out on top this year? Tom and Jay are back to tackle the week's top ethics and compliance stories on This Week in FCPA. Learn more abou...

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FCPA Compliance Report
FCPA Compliance Report-Episode 400 from 2018-09-24T16:00

In this very special 400th anniversary episode, I visit with Ben Reiter, the author of Astroball—The New Way to Win It All. The Astros experience, Reiter’s book and our discussion directly apply ...

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FCPA Compliance Report
CONVERGE18-Preview Podcasts-Philip Winterburn from 2018-09-22T16:00

In this episode of the CONGERGE18 Preview Podcasts series, I visit with Philip Winterburn, Chief Product Officer at Convercent. We discuss the issue of KPIs around benchmarking your ethics and comp...

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FCPA Compliance Report
This Week in FCPA-Episode 121 from 2018-09-21T21:01:51

As Tom and Mrs. Compliance Evangelist trek to Ann Arbor MI to attend his law school reunion, Go Blue and watch the Wolverines trounce Nebraska and enjoy some cool autumn weather, he and Jay are bac...

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FCPA Compliance Report
Compliance into the Weeds: Episode 95 from 2018-09-19T16:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
CONVERGE18-Preview Podcasts- David Deitchman from 2018-09-17T17:00

In this episode of the CONGERGE18 Preview Podcasts series, I visit with Jacki David Deitchman, Deputy General Counsel, Employment, Ethics&Compliance at HP. We discuss some of his tactics and techni...

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FCPA Compliance Report
CONVERGE18-Preview Podcasts- Susan du Becker from 2018-09-17T17:00

In this episode of the CONGERGE18 Preview Podcasts series, I visit with Susan du Becker, Global Compliance Enablement at Cisco Systems. We discuss some of her strategies for breaking down silos to ...

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FCPA Compliance Report
CONVERGE18-Preview Podcasts- Jacki Cheslow from 2018-09-17T17:00

In this episode of the CONGERGE18 Preview Podcasts series, I visit with Jacki Cheslow, the Director Business Ethics&Compliance, Avis Budget. We discuss breaking down silos to facilitate compliance ...

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FCPA Compliance Report
CONVERGE18-Preview Podcasts- Amy Much from 2018-09-17T17:00

In this episode of the CONGERGE18 Preview Podcasts series, I visit with Amy Much, Ethics and Compliance Officer at Under Armor. We discuss some her presentation at Converge18 “Learn From My Mistake...

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FCPA Compliance Report
The Evolving Role of Risk, Compliance, and Ethics-Part III from 2018-09-17T15:00

In this Part III of my five-part series on the evolving nature of risk, compliance and ethics, I visit Rebecca Turco on the new SAI Global training solution at EthicsAnywhere. Learn more about your...

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FCPA Compliance Report
The Evolving Role of Risk, Compliance, and Ethics-Part II from 2018-09-17T15:00

In this Part II of my five-part podcast series on the evolving nature of risk, compliance and ethics, I visit Rebecca Turco on the shifting compliance mindset. Learn more about your ad choices. Vis...

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FCPA Compliance Report
The Evolving Role of Risk, Compliance, and Ethics-Part I from 2018-09-17T15:00

In this Part I, I visit Paul Johns on the evolving nature of the ethics and compliance marketplace and what that means for compliance programs. Learn more about your ad choices. Visit megaphone.fm/...

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FCPA Compliance Report
The Evolving Role of Risk, Compliance, and Ethics-Part V from 2018-09-17T15:00

In this final episode of my 5 part exploration of the evolving nature of risk, ethics, and compliance, I visit Paul Johns on the need for an integrated approach to risk management. Learn more about...

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FCPA Compliance Report
The Evolving Role of Risk, Compliance, and Ethics-Part IV from 2018-09-17T15:00

In this Part IV of this five-part series on the evolving nature of risk, ethics and compliance, I visit Rebecca Turco on the current trends she is seeing in culture, ethics and compliance and where...

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FCPA Compliance Report
FCPA Compliance Report-Episode 399 from 2018-09-16T19:17:06

In this episode, I visit with podcast favorite Matt Ellis, a member at Miller&Chevalier on the firm’s always excellent FCPA Summer Review 2018. The first half of 2018 has brought some very interest...

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FCPA Compliance Report
This Week in FCPA-Episode 120 from 2018-09-14T16:00

As Hurricane Florence is headed to the Carolinas and beyond, Hurricane Issac is hurtling towards the Gulf of Mexico and Storm X is taking aim at Texas, Tom and Jay are back with a look at some of t...

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FCPA Compliance Report
Everything Compliance-Episode 34 from 2018-09-13T16:00

Welcome to the only roundtable podcast in compliance. Inspired by our UK colleague, Jonathan Armstrong who inquired if we could explore the guilty plea of Michael Cohen and the guilty verdict again...

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FCPA Compliance Report
CONVERGE18-Preview Podcasts- Keturah Pestel from 2018-09-13T16:00

In this episode of the CONGERGE18 Preview Podcasts series, I visit with Keturah Pestel, Program Manager, Business Ethic and Legal Support Office at Thrivent. We discuss her company’s innovative use...

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FCPA Compliance Report
Compliance into the Weeds: Episode 94 from 2018-09-12T10:54:34

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
CONVERGE18-Preview Podcasts-Sheryl Zaworski from 2018-09-11T16:00

In this episode of the CONGERGE18 Preview Podcasts series, I visit with Sheryl Zaworski, VP, Director of Global Ethics Escalation, Investigation and Analytics at U.S. Bank. We discuss the the data ...

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FCPA Compliance Report
Assessing Ethics and Compliance in M&A-Episode 3 from 2018-09-10T16:00

Over this special five-part podcast series, I will visit with Eric Feldman, Senior Vice President, Don Stern,  Corporate and Rod Grandon, Managing Director Government Services; all from Affiliated ...

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FCPA Compliance Report
Assessing Ethics and Compliance in M&A-Episode 2 from 2018-09-10T16:00

Over the next five episodes, I will visit with Eric Feldman, Senior Vice President, Don Stern,  Corporate and Rod Grandon, Managing Director Government Services; all from Affiliated Monitors, Inc.,...

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FCPA Compliance Report
Assessing Ethics and Compliance in M&A-Episode 4 from 2018-09-10T16:00

Over the next five episodes, I will visit with Eric Feldman, Senior Vice President, Don Stern,  Corporate and Rod Grandon, Managing Director Government Services; all from Affiliated Monitors, Inc.,...

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FCPA Compliance Report
Assessing Ethics and Compliance in M&A-Episode 1 from 2018-09-10T16:00

Over the next five podcast episodes, I will visit with Eric Feldman, Senior Vice President, Don Stern,  Corporate and Rod Grandon, Managing Director Government Services; all from Affiliated Monitor...

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FCPA Compliance Report
Assessing Ethics and Compliance in M&A-Episode 5 from 2018-09-10T16:00

Over these past five episodes, I have visited with Eric Feldman, Senior Vice President, Don Stern,  Corporate and Rod Grandon, Managing Director Government Services; from Affiliated Monitors, Inc.,...

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FCPA Compliance Report
FCPA Compliance Report-Episode 398 from 2018-09-10T14:00

In this episode, I visit with podcast fan favorite Laura Perkins, a partner at Hughes, Hubbard and Reed. We discuss the recent 2ndCircuit Court of Appeals decision in the Hoskins matter. With Laura...

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FCPA Compliance Report
This Week in FCPA-Episode 119 from 2018-09-07T16:35:14

As the Houston Texans head to Boston for the NFL Season Opener and the Houston Astros head to Boston for a preview of the ALCS , Tom and Jay are back with a look at some of the week’s top complianc...

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FCPA Compliance Report
Everything Compliance-Episode 33 from 2018-09-06T16:00

Welcome to the only roundtable podcast in compliance. Inspired by our UK colleague, Jonathan Armstrong who inquired if we could explore the guilty plea of Michael Cohen and the guilty verdict again...

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FCPA Compliance Report
12 O'Clock High-Episode 100 from 2018-09-05T16:00

In this episode of 12 O’Clock High, a podcast on business leadership, Richard Lummis and I continue to explore leadership lessons from GE. Today, we continue our exploration of the travails at GE, ...

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FCPA Compliance Report
Converge18 Preview-David Bunker from 2018-09-04T16:00

In this episode of the CONVERGE18 Preview Podcasts series, I visit with David Bunker, Compliance Officer at Vulcan Inc. We discuss managing the risk of conflicts of interest when employing workers ...

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FCPA Compliance Report
Converge18-Preview of Philip Winterburn from 2018-09-04T16:00

In this episode of the CONVERGE18 Preview Podcasts series, I visit with Philip Winterburn, Chief Product Officer at Convercent. We discuss the issue of perverse incentive and compliance. Learn mor...

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FCPA Compliance Report
Converge18 Preview-Ellen Hunt from 2018-09-04T16:00

In this episode of the CONVERGE18 Preview Podcasts, I visit with Ellen Hunt, Senior Vice President, Audit, Ethics&Compliance Officer at AARP. We discuss the role of the Board of Directors and compl...

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FCPA Compliance Report
Converge18-Preview of Eric Feldman from 2018-09-04T16:00

In this episode of the CONVERGE18 Preview Podcasts series, I visit with Eric Feldman, Senior Vice President at Affiliated Monitors. We discuss the issue of perverse incentive and compliance.Learn m...

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FCPA Compliance Report
This Week in FCPA-Episode 118 from 2018-08-31T19:00:19

You can put away your all white linen suits and your seer sucker suits as well. With that hint of fall in the air, we are upon the (unofficial) end of summer with the Labor Day Weekend, Tom and Jay...

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FCPA Compliance Report
Life With GDPR: Episode 15 from 2018-08-30T16:00

The Administration’s attacks on allies, perhaps former allies and other in the area of trade and sanctions has not occurred in vacuum. Many other countries and groups such as the EU have retaliated...

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FCPA Compliance Report
12 O’Clock High-Episode 99 from 2018-08-29T16:00

What is due diligence? What is zero tolerance? How do these impact employee morale? How do these concepts link together? Richard Lummis and I explore these questions and more in considering the Jul...

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FCPA Compliance Report
King Arthur Week: Part V from 2018-08-27T22:32:32

We conclude our Arthurian themed week with the Holy Grail, which has fired the imagination of artists for millennia. What was the Holy Grail? It means many things to many people. The quixotic ques...

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FCPA Compliance Report
King Arthur Week: Part IV from 2018-08-27T22:32:05

As I end this month of the Land of 1000 podcasts, I conclude with a week of King Arthur and his Roundtable themed-podcasts. It turns out there are many compliance lessons from the entire oeuvre of ...

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FCPA Compliance Report
King Arthur and Compliance: Part III from 2018-08-27T22:31:41

As I end this month of the Land of 1000 podcasts, I conclude with a week of King Arthur and his Roundtable themed-podcasts. It turns out there are many compliance lessons from the entire oeuvre of ...

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FCPA Compliance Report
King Arthur Week: Part II from 2018-08-27T22:31:11

As I end this month of the Land of 1000 podcasts, I conclude with a week of King Arthur and his Roundtable themed-podcasts. It turns out there are many compliance lessons from the entire oeuvre of ...

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FCPA Compliance Report
King Arthur, the Roundtable and Compliance from 2018-08-27T22:30:40

As I end this month of the Land of 1000 podcasts, I conclude with a week of King Arthur and his Roundtable themed-podcasts. It turns out there are many compliance lessons from the entire oeuvre of ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 397 from 2018-08-27T16:00

In this episode, I chat with Erica Salmon Byrne, the EVP and Executive Director of Business Ethics Leadership Alliance for Ethisphere. We visit on Ethisphere’s 2018 World’s Most Ethical Company awa...

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FCPA Compliance Report
This Week in FCPA-Episode 117 from 2018-08-24T17:31:50

Jay has returned from an Alaskan Disney cruise with the family. As OSU suspends its head coach and added a new phrase to our compliance and ethics lexicon significant memory issues; Tom and Jay are...

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FCPA Compliance Report
Life with GDPR-Episode 14 from 2018-08-23T16:00

The recent case involving the Jehovah's Witnesses and data privacy in the UK raised some very interesting legal issues. It also demonstrated just how broad the reach of GDPR could be. In this podca...

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FCPA Compliance Report
12 O'Clock High-Episode 98 from 2018-08-22T16:00

In this episode, Richard Lummis and I consider how the Houston Astros went from literally the worst team ever in baseball to World Series Champions, as been chronicled by Sports Illustrated writer ...

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FCPA Compliance Report
Ethical Culture-Episode 2 from 2018-08-20T16:00

Over the next five episodes, I visit with Vin DiCianni, founder and CEO and Eric Feldman, Senior Vice President both of Affiliated Monitors, Inc., who is the sponsor of this series. In it, we explo...

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FCPA Compliance Report
Ethical Culture-Episode 5 from 2018-08-20T16:00

Over the past five podcasts, I have visited with Vin DiCianni, founder and CEO and Eric Feldman, Senior Vice President both of Affiliated Monitors, Inc., who is the sponsor of this series. In it, w...

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FCPA Compliance Report
Ethical Culture-Episode 3 from 2018-08-20T16:00

Over this five-part podcast series, I am visiting visit with Vin DiCianni, founder and CEO and Eric Feldman, Senior Vice President both of Affiliated Monitors, Inc., who is the sponsor of this seri...

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FCPA Compliance Report
FCPA Compliance Report-Episode 396 from 2018-08-20T16:00

In this episode, I visit with Jonathan Marks, a partner at Baker&Tilly.  This podcast part of my Land of 1000 podcasts celebration. In this special series of podcasts I am reviewing the growth, mat...

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FCPA Compliance Report
Ethical Culture-Episode 4 from 2018-08-20T16:00

Over these five podcast episodes, I have been visiting with Vin DiCianni, founder and CEO and Eric Feldman, Senior Vice President both of Affiliated Monitors, Inc., who is the sponsor of this serie...

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FCPA Compliance Report
Ethical Culture-Episode 1 from 2018-08-20T16:00

Over the next five episodes, I visit with Vin DiCianni, founder and CEO and Eric Feldman, Senior Vice President both of Affiliated Monitors, Inc., who is the sponsor of this series. In it, we explo...

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FCPA Compliance Report
Compliance into the Weeds: Quarterly Reporting Discussion from 2018-08-18T14:25:18

In this episode, Matt Kelly and I take a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very dee...

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FCPA Compliance Report
This Week in FCPA-Episode 116 from 2018-08-17T16:00

Jay is on an Alaskan Disney cruise with the family. Through the prism of Trump’s attacks on the US free press and their robust response, Tom takes a solo look at some of the top compliance stories ...

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FCPA Compliance Report
Everything Compliance-Episode 32 from 2018-08-16T16:00

To celebrate the Month of 1000 podcasts I am running for each of my podcasts this month, in this episode, the Everything Compliance gang focuses on the past five years; giving a retrospective of wh...

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FCPA Compliance Report
The Future of Audit, Compliance, and Analytics: Part V from 2018-08-13T16:00

In this special five-podcasts series, Matt Kelly and I have been exploring the future of internal audit (IA), compliance and analytics. In the final episode, Part V, we discuss how IA can get start...

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FCPA Compliance Report
The Future of Audit, Compliance, and Analytics: Part I from 2018-08-13T16:00

Over the next five podcasts, Matt Kelly and I will be exploring the future of internal audit, compliance and analytics. In today’s Part I, we introduce the topic, explaining why internal audit is i...

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FCPA Compliance Report
The Future of Audit, Compliance, and Analytics: Part III from 2018-08-13T16:00

In this special five-podcasts series, Matt Kelly and I are exploring the future of internal audit (IA), compliance and analytics. For Part III, we consider three examples of how a framework of a ri...

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FCPA Compliance Report
The Future of Audit, Compliance, and Analytics: Part II from 2018-08-13T16:00

In this special five-podcasts series, Matt Kelly and I are exploring the future of internal audit, compliance and analytics. In today’s Part II, we go through the three steps of evolution that an i...

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FCPA Compliance Report
The Future of Audit, Compliance, and Analytics: Part IV from 2018-08-13T16:00

In Part IV of this five part exploration of the future of internal audit, we consider the new working relationships internal audit will need to develop with for this risk management framework. Lea...

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FCPA Compliance Report
Life With GDPR: Episode 13 from 2018-08-09T16:00

The General Data Protection Regulation (GDPR) which went live on May 25, 2018. What has happened since then in the data privacy and data protection world? In this episode, Jonathan Armstrong, partn...

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FCPA Compliance Report
FCPA Compliance Report-Episode 394 from 2018-08-06T16:00

What is the purpose of rehabilitation in a best practices compliance program? In this episode, I use the recent trade by the Houston Astros for closer Roberto Osuna last week as an introduction int...

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FCPA Compliance Report
Everything Compliance-Episode 31 from 2018-08-02T16:00

As we begin the dog days of summer and the long spell between July 4thand Labor Day, the Everything Compliance gang returns to its four focused topics. After the commentary we follow with rants. Le...

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FCPA Compliance Report
Across the Board-Episode 21 from 2018-07-26T16:00

In this episode of Across the Board, I visit with Amii Barnard-Bahn.  She is a strategic advisor to Boards of Director and executive coach many C-Suite members. She specializes in accelerating the ...

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FCPA Compliance Report
Compliance into the Weeds: Episode 90 from 2018-07-25T16:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
The Bard&Compliance-Henry V from 2018-07-23T16:00

Most people remember the St. Crispin’s Day speech in Henry V as one of the greatest speeches in all of Shakespeare. However many people do not focus on what led to that speech which was that Henry ...

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FCPA Compliance Report
The Bard&Compliance - Henry IV, Part II from 2018-07-23T16:00

What is the most famous line in Shakespeare about lawyers? That is an easy one because lawyer-haters across the world (and lawyer-lovers as well) know it - First thing we do is kill all the lawyers...

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FCPA Compliance Report
The Bard&Compliance -Day III: Much Ado About Nothing from 2018-07-23T16:00

One of the first companies to embrace social media as a key tool in their compliance strategy was Dun&Bradstreet (D&B) who actively uses social media to make more effective the company’s compliance...

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FCPA Compliance Report
The Bard&Compliance -Othello from 2018-07-23T16:00

One of the more difficult things to predict in a merger and acquisition context is how the cultures of the two entities will merge. While many mergers claim to be a  ‘merger of equals’ the reality...

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FCPA Compliance Report
The Bard&Compliance -King Lear from 2018-07-23T16:00

If your corporate culture is such that you not only communicate internally about illegal conduct but also record those communications in the form of PowerPoint presentations, it speaks to a culture...

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FCPA Compliance Report
FCPA Compliance Report-Episode 392 from 2018-07-23T11:20:28

In this podcast, I chat with one of the authors, Jonathan Marks, a partner at Marcum LLP, on the limitations of the Fraud Triangle and why a new model can be helpful in the modern fraud detection a...

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FCPA Compliance Report
Everything Compliance-Episode 30 from 2018-07-19T16:00

This week the gang returns to its four focused topics. After the commentary we follow with rants. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
A Strategic Culture Framework to Manage Risk: Part I from 2018-07-16T16:00

Over a five-part series I will visit with Caterina Bulgarella on the recently released white paper by SAI Global, entitled “Predicting Risk: A Strategic Culture Framework for the C-Suite. Today we ...

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FCPA Compliance Report
A Strategic Culture Framework to Manage Risk: Part II from 2018-07-16T16:00

Over this five-part series I, visit with Caterina Bulgarella on the recently released white paper by SAI Global, entitled “Predicting Risk: A Strategic Culture Framework for the C-Suite”. In this P...

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FCPA Compliance Report
A Strategic Culture Framework to Manage Risk: Part V- the Ins and Outs of Ethical Reasoning from 2018-07-16T16:00

Over this five part podcast series I have been visiting with Caterina Bullgarella on the recently released white paper by SAI Global entitled, Predicting Risk: A Strategic Culture Framework for the...

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FCPA Compliance Report
A Strategic Culture Framework to Manage Risk: Part IV from 2018-07-16T16:00

Over this week’s five part podcast series I have been visting with Caterina Bullgarella on the recently released white paper by SAI Global entitled, Predicting Risk: A Strategic Culture Framework f...

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FCPA Compliance Report
A Strategic Culture Framework to Manage Risk: Part III from 2018-07-16T16:00

I am visiting with Caterina Bullgarella on the recently released white paper by SAI Global entitled, Predicting Risk: A Strategic Culture Framework for the C-Suite. In this Part III, we discuss wh...

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FCPA Compliance Report
Monitoring in Healthcare: Episode 5 from 2018-07-09T16:00

Over this five-part podcast series, I have been taking a deep dive into health care monitoring and how the pro-active use of a health care monitor can positively impact all stakeholders in the heal...

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FCPA Compliance Report
Monitoring in Healthcare: Episode 3 from 2018-07-09T16:00

In this five-part podcast series, I am taking a deep dive into health care monitoring and how the pro-active use of a health care monitor can positively impact all stakeholders in the healthcare in...

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FCPA Compliance Report
Monitoring in the Healthcare Sector: Episode 1 from 2018-07-09T16:00

In this five part podcast series, I will be taking a deep dive into health care monitoring and how the pro-active use of a health care monitor can positively impact all stakeholders in the healthca...

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FCPA Compliance Report
Monitoring in Healthcare: Episode 2 from 2018-07-09T16:00

In this five-part podcast series, I am taking a deep dive into health care monitoring and how the pro-active use of a health care monitor can positively impact all stakeholders in the healthcare in...

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FCPA Compliance Report
Monitoring in Healthcare: Episode 4 from 2018-07-09T16:00

In this five-part podcast series, I am taking a deep dive into health care monitoring and how the pro-active use of a health care monitor can positively impact all stakeholders in the healthcare in...

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FCPA Compliance Report
FCPA Compliance Report-Episode 390 from 2018-07-09T14:00

In this episode I podcast favorite James Koukios returns to discuss some of the highlights from the Morriston and Foerster April newsletter on Top Ten International Anti-Corruption Developments for...

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FCPA Compliance Report
This Week in FCPA-Episode 110 from 2018-07-06T18:28:40

As we begin the post-holiday portion of our 4thof July week, Jay Rosen and myself are back in the saddle again to take a look at some of the top compliance stories from the past week. Learn more ab...

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FCPA Compliance Report
Compliance into the Weeds: Episode 88 from 2018-07-05T16:00

In this episode Matt Kelly and I unpack the proposed changes to the SEC Whistleblower program. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
FCPA Compliance Report-Episode 389 from 2018-07-02T16:00

In this episode I visit with Shawn Rogers, Lead Counsel, Compliance Training and Communications at General Motors. Rogers was brought in to beef up the company’s compliance training after the ignit...

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FCPA Compliance Report
This Week in FCPA-Episode 109 from 2018-06-29T13:37:56

As get ready for a holiday week, Jay Rosen and myself are back in the saddle again to take a look at some of the top compliance stories from the past week. Learn more about your ad choices. Visit...

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FCPA Compliance Report
Compliance into the Weeds: Episode 87 from 2018-06-28T16:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
Life After GDPR: Episode 11 from 2018-06-27T23:00

How does a company transfer data from the European Union (EU) to the US under the General Data Protection Regulation (GDPR) which went live on May 25, 2018? I recently had the opportunity to visit ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 388 from 2018-06-25T16:00

The ACFE report to the Nations is an excellent reference tool for all compliance practitioner to show where fraudsters explode weak points.  It also has important data around corruption and from th...

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FCPA Compliance Report
This Week in FCPA-Episode 108 from 2018-06-23T15:03:13

Before we head to Boston for bagels, coffee and compliance at the offices of AMI, Jay Rosen and I review the week's top ethics and compliance stories on This Week in FCPA. Learn more about your ad ...

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FCPA Compliance Report
Life With GDRP-Epiosde 10 from 2018-06-21T16:00

While most practitioners focused on the heavy fines and penalties available under GDPR of up to 4% of total global revenues or other very large fines, there are other remedies that each EU and UK d...

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FCPA Compliance Report
Compliance into the Weeds: Episode 86 from 2018-06-20T16:00

In this episode, Matt Kelly and I take a deep dive back into the issue of the ZTE monitorship announced recently as a part of the settlement with the Department of Commerce on the death penalty san...

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FCPA Compliance Report
FCPA Compliance Report-Episode 387 from 2018-06-18T16:00

In this episode, I visit with Kristy Grant-Hart, founder of Spark Compliance Consulting and author of now three books in the compliance arena. We discuss her most recent book “How to Have a Wildly ...

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FCPA Compliance Report
Everything Compliance-Episode 29 from 2018-06-14T16:00

Everything Compliance is the only roundtable podcast in compliance, with four of the top compliance practitioners around. This week the gang returns to its four focused topics on its Four of a Kind...

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FCPA Compliance Report
Compliance into the Weeds-Episode 85 from 2018-06-13T16:00

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt K...

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FCPA Compliance Report
FCPA Compliance Report-Episode 386 from 2018-06-11T16:00

In this episode, I visit with Rick Pearl, the Global Corporate Responsibility Officer and Vice President of Corporate Citizenship at State Street Corp. We discuss the 2017 State Street Corporation,...

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FCPA Compliance Report
This Week in FCPA-Episode 106, the Back in the (FCPA) Saddle Again edition from 2018-06-07T22:57:35

With a wild ride of FCPA cases over the past week, Jay Rosen and myself are back in the FCPA saddle  again to take a look at some of the top compliance stories from the past week. Learn more about ...

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FCPA Compliance Report
Compliance into the Weeds-Episode 84 from 2018-06-06T16:00

In this episode, Matt Kelly and I take a deep dive into the issue of two factor authentication of cloud-based solutions and the intersection with compliance. Learn more about your ad choices. Visit...

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FCPA Compliance Report
Suspension and Debarment: Part 3 from 2018-06-04T16:00

Today, we discuss some of the convergence between the FCPA and suspension and debarment. The bottom line is that conduct which violates the FCPA can become the basis for a suspension or debarment, ...

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FCPA Compliance Report
Suspension and Debarment: Part 1 from 2018-06-04T16:00

Today, I begin a five-part series on Suspension and Debarment, with Rod Grandon, Managing Director at Affiliated Monitors, Inc., the sponsor of this series. We start this Part I with introduction t...

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FCPA Compliance Report
Suspension and Debarment: Part 2 from 2018-06-04T16:00

I continue my five-part series on Suspension and Debarment, with Rod Grandon, Managing Director at Affiliated Monitors, Inc., the sponsor of this series. In this episode, we consider the difference...

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FCPA Compliance Report
Suspension and Debarment: Part 4 from 2018-06-04T16:00

I continue my five-part series on Suspension and Debarment, with Rod Grandon, Managing Director at Affiliated Monitors. In this episode, we discuss present responsibility and its determination. Lea...

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FCPA Compliance Report
Suspension and Debarment: Part 5 from 2018-06-04T16:00

Today, we conclude the series with a discussion of remedies and compliance in suspension and debarment. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
FCPA Compliance Report-Episode 385 from 2018-06-04T16:00

In this episode I visit with John Torres, the COO of Guidepost Solutions. We discuss the recent SEC enforcement action involving Yahoo and its failure to disclose data breaches in 2014, 2015 and 20...

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FCPA Compliance Report
This Week in FCPA-Episode 105 from 2018-06-01T16:00

With The Complete Compliance Handbook still sitting at the top of the rankings in its first week of sales, Jay Rosen and myself take a look at some of the top compliance stories over the past week,...

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FCPA Compliance Report
Compliance into the Weeds-Episode 83 from 2018-05-31T16:00

In this episode, Matt Kelly and I take a deep dive into the travails of Roseanne, her television network ABC and compliance over her vile and racist tweet comparing Obama advisor Valerie Jarrad to ...

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FCPA Compliance Report
12 O'Clock High-Episode 86 from 2018-05-30T16:00

One of the challenges many compliance practitioners face when they move up in their careers is to move from tactical to strategic thinking. It is a requirement for any Chief Compliance Officer (CCO...

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FCPA Compliance Report
Excerpts from The Complete Compliance Handbook-Root Cause Analysis from 2018-05-29T16:00

One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was t...

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FCPA Compliance Report
Excerpts From the Complete Compliance Handbook-Hallmark VII from 2018-05-29T16:00

As every compliance practitioner is well aware, third-parties still present the highest risk under the FCPA. The Department of Justice Evaluation of Corporate Compliance Programs devotes an entire ...

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FCPA Compliance Report
Excerpts from The Complete Compliance Handbook-Hallmark VIII from 2018-05-29T16:00

The call, e-mail or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it ...

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FCPA Compliance Report
Excerpts from The Complete Compliance Handbook-Hallmark IX from 2018-05-29T16:00

Hallmark Nine of Ten Hallmarks of an Effective Compliance Program, as articulated in the 2012 FCPA Guidance, states: "a good compliance program should constantly evolve." Learn more about your ad c...

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FCPA Compliance Report
Excerpts from The Complete Compliance Handbook from 2018-05-29T16:00

The 2012 FCPA Guidance stated “mergers and acquisitions present both risks and opportunities. A company that does not perform adequate FCPA due diligence prior to a merger or acquisition may face b...

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FCPA Compliance Report
Excerpts from the Complete Compliance Handbook-Hallmark VI from 2018-05-29T16:00

Both incentives and discipline are critical in any best practices compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
This Week in FCPA-Episode 104 from 2018-05-25T14:05:49

With The Complete Compliance Handbooksitting at the top of the rankings in its first week of sales, Jay Rosen and myself take a look at some of the top compliance stories over the past week.  Learn...

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FCPA Compliance Report
Everything Compliance-Episode 28 from 2018-05-24T16:00

This week the gang sticks a roundtable Q&A, with a focus on the Michael Cohen imbroglio. Jay Rosen considers the lessons to be learned in hiring third-parties. Matt Kelly considers issue from the C...

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FCPA Compliance Report
Countdown to GDPR: Episode 8 from 2018-05-23T16:00

Today we consider Subject Access Requests (SARs) under General Data Protection Regulation (GDPR). As always, I am joined in this exploration by Jonathan Armstrong, a partner in Cordery Compliance i...

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FCPA Compliance Report
Working with Monitors-Part II from 2018-05-07T16:00

I continue my five-podcast exploration of working with monitors. I am joined by Don Stern, Managing Director, Corporate Monitors and Consulting Services at Affiliated Monitors, Inc. (the sponsor of...

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FCPA Compliance Report
Working with Monitors-Part I from 2018-05-07T16:00

Over the next five podcasts, I will visit with Don Stern, Managing Director, Corporate Monitors and Consulting Services at Affiliated Monitors, Inc. on working with monitors. At the end of this ser...

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FCPA Compliance Report
Working with Monitors-Part V from 2018-05-07T16:00

I conclude this five-podcast exploration of working with monitors, where I have been joined by Don Stern, Managing Director, Corporate Monitors and Consulting Services at Affiliated Monitors, Inc. ...

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FCPA Compliance Report
Working with Monitors-Part IV from 2018-05-07T16:00

I continue my five-podcast exploration of working with monitors. I am joined by Don Stern, Managing Director, Corporate Monitors and Consulting Services at Affiliated Monitors, Inc. on working with...

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FCPA Compliance Report
Working with Monitors-Part III from 2018-05-07T16:00

I continue my five-podcast exploration of working with monitors. I am joined by Don Stern, Managing Director, Corporate Monitors and Consulting Services at Affiliated Monitors, Inc. on working with...

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FCPA Compliance Report
This Week in FCPA-Episode 101 from 2018-05-04T16:00

As we celebrate all things Star Wars on the May the Fourth Be With You edition, Jay Rosen and myself take a look at some of the top compliance stories over the past week. Learn more about your ad c...

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FCPA Compliance Report
Across the Board-Episode 18 from 2018-05-03T16:00

In this episode of Across the Board, I visit with Preston Pugh and AIysha Hussain from the firm of Miller&Chevalier on their recent paper entitled, “A More Effective Way For Corporate Boards To Res...

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FCPA Compliance Report
Compliance into the Weeds-Episode 80 from 2018-05-02T16:00

In this episode, Matt Kelly and I take a continued deep dive the underlying assumptions around the reasons for lack of IPOs by small and mid-cap sized firms. We focus on a speech by SEC Commissione...

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FCPA Compliance Report
FCPA Compliance Report-Eposide 381 from 2018-04-30T16:00

In this episode I visit with Morrison and Foerster partner James Koukios on the firm's January and February Top Ten international anti-corruption cases, issues and developments. Learn more about yo...

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FCPA Compliance Report
This Week in FCPA-Episode 100 from 2018-04-27T12:44:35

After being joined by Jay’s girls to celebrate our 100th  anniversary episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week. Learn more about your ad ch...

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FCPA Compliance Report
This Week in FCPA-Episode 99 from 2018-04-20T16:00

With Wells Fargo about to be fined $1 billion for behaving badly, Jay Rosen and myself take a look at some of the top compliance stories over the past week. Learn more about your ad choices. Visit ...

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FCPA Compliance Report
Everything Compliance-Episode 27 from 2018-04-19T16:00

This week the gang goes for more of a roundtable Q&A with a couple of topics. We first consider the testimony of Facebook CEO Mark Zuckerberg before Congress and his company’s imbroglio with Cambri...

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FCPA Compliance Report
Compliance into the Weeds-Episode 78 from 2018-04-18T16:00

In this episode, Matt Kelly and I go meta as we go into the weeds about Weed, in the context of the recent announcement by the administration that it would not prosecute persons or producers in sta...

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FCPA Compliance Report
FCPA Compliance Report-Episode 379 from 2018-04-16T16:00

In March the SEC made its biggest-ever whistleblower award giving one person $33 million and in the same case split nearly $50 million between two others. All three whistleblowers were represented ...

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FCPA Compliance Report
This Week in FCPA-Episode 98 from 2018-04-13T16:00

With the Red Sox leading the AL with a 10-2 start and back to brawling with the NY Yankees, Jay Rosen and myself take a look at some of the top compliance stories over the past week Learn more abou...

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FCPA Compliance Report
Countdown to GDPR-Episode 5 from 2018-04-12T16:00

In this episode of Countdown to GDPR, Jonathan Armstrong, a partner at Cordery Compliance in London and I consider the roles of vendors in GDPR. These roles are both in complying with GDPR and subs...

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FCPA Compliance Report
Compliance into the Weeds-Episode 77 from 2018-04-11T16:00

Privilege and Arrogance at the EPA Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
FCPA Compliance Report-Episode 378 from 2018-04-09T16:00

In this episode of the FCPA Compliance Report, I visit Hogan Lovells partner Stephanie Yonekura on the always difficult decision on whether a company should self-disclose a potential FCPA violation...

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FCPA Compliance Report
This Week in FCPA-Episode 97 from 2018-04-07T16:48:08

With the Astros off to a 6-1 start and the Facebook FUBAR continuing, Jay Rosen and myself take a look at some of the top compliance stories over the past week.  Learn more about your ad choices. V...

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FCPA Compliance Report
Everything Compliance-Episode 26 from 2018-04-05T16:00

The top compliance roundtable podcast is back with a wrap up of the some of the top compliance stories over the first quarter of 2018. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
12 O'Clock High-a podcast on leadership-Episode 83 from 2018-04-04T16:00

The golden age of polar exploration lasted from about 1895 to 1912 during which time explorers reached both the North Pole and the South Pole. Yet even today their explorations and expeditions rais...

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FCPA Compliance Report
Corporate Monitorships-Episode 5 from 2018-04-02T18:51:56

This week, in a five-part podcast series, I have been exploring the role of corporate monitorships in compliance and some of the key issues which companies and compliance professionals may face in ...

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FCPA Compliance Report
Corporate Monitorships-Episode 1 from 2018-04-02T16:00

In this five-part podcast series, I am exploring the role of corporate monitorships in compliance and some of the key issues which companies and compliance professionals may face in dealing with mo...

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FCPA Compliance Report
Corporate Monitorships-Episode 3 from 2018-04-02T16:00

This week, in a five-part podcast series, I am exploring the role of corporate monitorships in compliance and some of the key issues which companies and compliance professionals may face in dealing...

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FCPA Compliance Report
Corporate Monitorships-Episode 4 from 2018-04-02T16:00

This week, in a five-part podcast series, I am exploring the role of corporate monitorships in compliance and some of the key issues which companies and compliance professionals may face in dealing...

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FCPA Compliance Report
FCPA Compliance Report-Episode 377 from 2018-04-02T16:00

In this episode, Tom Sporkin explains how whistleblowers has different, yet complimentary rights and obligations under SOX and Dodd-Frank.  Learn more about your ad choices. Visit megaphone.fm/adch...

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FCPA Compliance Report
Corporate Monitorships-Episode 2 from 2018-04-02T16:00

This week, in a five-part podcast series, I am exploring the role of corporate monitorships in compliance and some of the key issues which companies and compliance professionals may face in dealing...

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FCPA Compliance Report
This Week in FCPA-Episode 96 from 2018-03-30T16:00

With Opening Day and the Astros raising the WS banner only a couple of days away, Jay and Tom take a look at some of the top compliance stories over the past week. Learn more about your ad choices....

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FCPA Compliance Report
Countdown to GDPR-Episode 4 from 2018-03-29T16:00

In this episode, we take up a key element in the upcoming General Data Protection Regulation (GDPR), which comes into effect on May 25, 2018, that being the issue of the Data Protection Impact Asse...

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FCPA Compliance Report
Compliance into the Weeds-Episode 76 from 2018-03-28T11:02:49

Today we consider the plight of soon-to-be former Facebook Chief Information Security Officer Alex Stamos who was seemingly retaliated against for his actions to try and bring the data hacking of F...

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FCPA Compliance Report
FCPA Compliance Report-Episode 376 from 2018-03-26T16:00

In this episode, I visit with Donna Bucella, the President-Compliance at Guidepost Solutions. Guidepost Solutions is well-known in the monitorship realm, but the company has a much wider focus, whi...

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FCPA Compliance Report
This Week in FCPA-Episode 95 from 2018-03-23T16:00

In the midst of this true madness in the NCAA tournament this year, Jay Rosen and myself take a look at some of the top compliance stories over the past week. Learn more about your ad choices. Visi...

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FCPA Compliance Report
Across the Board-Episode 17 from 2018-03-22T16:00

Managing Director of Strategy at LRN. We discuss how leading with principles has become even more important after the current wave of corporate scandals all in the context of Board of Directors acc...

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FCPA Compliance Report
Compliance into the Weeds-Episode 75 from 2018-03-21T17:54:31

In this episode, Matt Kelly and I take a deep dive into the recent SEC enforcement action against Elizabeth Holmes, the disgraced founder of Theranos, for her massive fraud around the former unicor...

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FCPA Compliance Report
FCPA Compliance Report-Episode 375 from 2018-03-19T16:00

In this episode, I welcome back Steve Durham, a partner with Labaton and Sucharow to discuss the continued reverberations from the recent Supreme Court decision narrow the definition of whistleblow...

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FCPA Compliance Report
This Week in FCPA-Episode 94 the March Madness edition from 2018-03-17T19:05:31

March Madness is upon us, with the first ever #16 knocking off a Number 1 see. In the midst of this true madness, Jay Rosen and myself take a look at some of the top compliance stories over the pas...

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FCPA Compliance Report
12 O'Clock High-Episode 82 from 2018-03-14T16:00

Henry Worsley and Ernest Shackleton are related by more than blood. They are related by their souls. In this episode, we explore leadership lessons from both in the Antarctic expeditions. Learn m...

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FCPA Compliance Report
Compliance into the Weeds-Episode 74 from 2018-03-13T16:00

In this episode, Matt Kelly and I continue our exploration of the fallout from the recent Supreme Court decision in Digital Realty Trust v. Somers in light of the filing by BioRad in its appeal of ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 374, John Davis from 2018-03-12T16:00

In this episode, I visit with Miller&Chevalier Member John Davis on the firm’s FCPA Winter Review 2017. We discuss the key FCPA enforcement actions from 2017 and developments in compliance. Learn ...

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FCPA Compliance Report
This Week in FCPA-Episode 93 from 2018-03-09T17:00

Check out the week's top FCPA, compliance and ethics stories in This Week in FCPA, with Tom Fox and Jay Rosen. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Across the Board-Episode 16 from 2018-03-08T17:00

In this episode I consider the role of the Board of Directors in having a Compliance Committee and having a compliance expert on the Board itself. This lack of a key resource to the Board is someth...

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FCPA Compliance Report
Countdown to GDPR-Episode 3 from 2018-03-07T17:00

In this episode we explore the basic policies and procedures that you need to have in place to comply with the General Data Protection Regulation or GDPR. Learn more about your ad choices. Visit me...

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FCPA Compliance Report
Compliance into the Weeds-Episode 73 from 2018-03-06T17:00

In this episode, Matt Kelly and I explore the recent revelations of systemic sexual harassment and abuse present in the front office of the Dallas Mavericks. The allegations were not lodged against...

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FCPA Compliance Report
FCPA Compliance Report-Episode 373 from 2018-03-05T17:00

In this podcast I welcome back John Hanson, founder and President of the International Association of Independent Compliance Monitors (IAICM) the only professional group for independent corporate m...

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FCPA Compliance Report
This Week in FCPA-Episode 92 from 2018-03-02T20:18:06

In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week as we celebrate Texas Independence Day. Learn more about your ad choices. Visit megaphone....

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FCPA Compliance Report
Acorss the Board-Episode 14 from 2018-03-01T17:00

In this episode, I visit with Joel Solomon on his new book "The Clean Money Revolution". Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Countdown to GDPR-Episode 2 from 2018-02-28T17:00

In today’s episode of Countdown to General Data Protection Regulation (GDRP), Jonathan Armstrong, a partner at Cordery Compliance Ltd in London, and myself consider the role of the Data Protection ...

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FCPA Compliance Report
Compliance into the Weeds-Episode 72 from 2018-02-27T14:42:42

In this episode, Matt Kelly and I take a deep dive into the implications flowing from the Supreme Court’s decision last week in the Digital Realty Trust v. Somers decision. Matt initiated a ‘tweets...

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FCPA Compliance Report
FCPA Compliance Report-Episode 372 from 2018-02-26T17:00

In this episode, I split it into two parts. The first is a legal analysis of the recent Supreme Court decision narrowing the definition of whistleblowers, Digital Realty Trust v. Somers. In part 2,...

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FCPA Compliance Report
This Week in FCPA-Episode 91 from 2018-02-23T21:17:26

In this episode Jay Rosen and myself discuss the week's top compliance and ethics stories. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Everything Compliance-Episode 25 from 2018-02-22T17:00

The top compliance roundtable podcast is back with a wrap up with a review of  the first year of the Trump Administration and its impact on the compliance profession. Stayed tuned to the end for ri...

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FCPA Compliance Report
Compliance into the Weeds-71 from 2018-02-21T17:00

In this episode Matt Kelly and I go meta as we podcast about another podcast that Matt posted this week on his site, Radical Compliance, where he interviewed Paul Sobel, the incoming Chairman of CO...

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FCPA Compliance Report
Countdown to GDPR-Episode 1 from 2018-02-20T17:00

Whether you are ready or not, the EU General Data Protection Regulation (GDPR) goes live on May 25, 2018. It will impact companies doing business in London as much as any other EU legislation. To h...

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FCPA Compliance Report
FCPA Compliance Report-Episode 371 from 2018-02-19T17:00

In this episode, podcast favorite James Koukios returns to discuss highlights from international anti-corruption efforts, enforcement actions and developments highlighted in Morrison and Foerster’s...

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FCPA Compliance Report
This Week in FCPA-Episode 90 from 2018-02-16T18:39:02

In this episode, Jay Rosen and I discuss some of the week's top compliance and ethics stories on the only weekly compliance podcast wrap-up. Learn more about your ad choices. Visit megaphone.fm/ad...

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FCPA Compliance Report
Across the Board-Episode 15 from 2018-02-15T14:49

One of the ongoing questions from members of Board of Directors is how to resolve the tension between oversight and managing. I recently had the opportunity to visit with Joe Howell, the Executive ...

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FCPA Compliance Report
Compliance into the Weeds-Episode 70 from 2018-02-14T17:05:44

In this episode, Matt Kelly and I go into the weeds on the fascinating subject relating to the intersection of compliance and technology: AI and hotlines. We explore how this phone app can assist ...

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FCPA Compliance Report
12 O'Clock High-Episode 77 from 2018-02-13T17:00

On of the traditions of this podcast is each February, Richard Lummis and I rewatch Oscar winning movies with an eye towards the leadership lessons that might be drawn from them. It is a great way ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 370 from 2018-02-12T17:00

In this episode I visit with Carlos Ayres, partner at Medea, Ayres and Sarubbi in Sao Paulo. We visit on the past year in anti-corruption enforcement in Brazil and where it may lead in 2018 Learn m...

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FCPA Compliance Report
This Week in FCPA-Episode 89 - the Eagles Soar edition from 2018-02-10T13:43:58

Is Jay still in mourning over the Patriots Super Bowl loss? Find out in Episode 89 of This Week in FCPA where Jay and myself take a look at some of the top compliance stories over the past week.  ...

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FCPA Compliance Report
Compliance into the Weeds-Episode 69 from 2018-02-08T17:00

In this episode, Matt Kelly and I take a deep dive into the events which led to the resignation of Steve Wynn as the CEO and Chairman of Wynn Casinos for sexual harassment and misconduct. Learn mo...

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FCPA Compliance Report
FCPA Compliance Report-Episode 369 from 2018-02-06T17:00

In this episode I visit with Dr. Marsha Ershaghi Hames, Managing Director, Strategy Development at LRN. We discuss the ongoing national conversation about sexual harassment which has been ongoing f...

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FCPA Compliance Report
This Week in FCPA-Episode 88 from 2018-02-02T20:35:41

In this edition, Jay Rosen and I celebrate the birthdays of daughters, mothers, grandmothers and a great-grandmother in discussing the weeks top compliance and ethics stories. Learn more about you...

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FCPA Compliance Report
Day 31 of 31 Days to a More Effective Compliance Program from 2018-01-31T17:00

I next want to take a deep dive and exploration of the levels of due diligence. Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for...

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FCPA Compliance Report
Compliance into the Weeds-Episode 68 from 2018-01-31T17:00

In this episode Matt Kelly and myself take a deep dive into the weeds of the recent remarks by Neomi Rao, head of the Office for Information and Regulatory Affairs (OIRA), the Administration’s top ...

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FCPA Compliance Report
Day 30 of 31 Days to a More Effective Compliance Program from 2018-01-30T17:00

We previously considered the Prong in the Evaluation of Corporate Compliance Programs which was not present in the Ten Hallmarks of an Effective Compliance Program; that being root cause analysis. ...

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FCPA Compliance Report
Compliance Report International Edition from 2018-01-30T17:00

Welcome to Episode 9 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on things, which actually could kill compliance in the org...

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FCPA Compliance Report
Day 29 of 31 Days to a More Effective Compliance Program from 2018-01-29T17:00

One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was t...

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FCPA Compliance Report
Day 28 of 31 Days to a More Effective Compliance Program from 2018-01-28T17:00

Your company has just made its largest acquisition ever and your Chief Executive Officer (CEO) says that he wants you to have a compliance post-acquisition integration plan on his desk in one week....

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FCPA Compliance Report
This Week in FCPA-Episode 87 from 2018-01-27T19:24:02

In this special Supplemental edition Jay Rosen reports on Friday’s SCCE Southern California Regional Compliance and Ethics Conference. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 27 of 31 Days to a More Effective Compliance Program from 2018-01-27T17:00

A company that does not perform adequate FCPA due diligence prior to a merger or acquisition may face both legal and business risks. While most compliance practitioners have been long aware of the...

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FCPA Compliance Report
Day 26 of 31 Days to a More Effective Compliance Program from 2018-01-26T17:00

One of the new areas articulated in the Evaluation of Corporate Compliance Programs was around payments and payroll. For the both the compliance professional and the corporate payroll function, the...

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FCPA Compliance Report
This Week in FCPA-Episode 86, the Headin' to Minneapolis edition from 2018-01-26T17:00

As the Patriots and Eagles head to Minneapolis for Super Bowl LIII, join Tom and Jay for the week's top compliance related stories. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 25 of 31 Days to a More Effective Compliance Program from 2018-01-25T17:00

The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance (Guidance), under Hallmark ...

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FCPA Compliance Report
Across the Board-Episode 13 from 2018-01-25T17:00

In this episode I visit again with Rakhi Kumar, the Managing Director, Head of ESG and Asset Stewardship at State Street Global Advisors. We discuss the firm’s role in advocating for greater Board ...

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FCPA Compliance Report
Day 24 of 31 Days to a More Effective Compliance Program from 2018-01-24T17:00

The role of the Chief Compliance Officer (CCO) has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance, under Hallmark Three of the 10 Hallmarks of an Effective Complia...

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FCPA Compliance Report
12 O'Clock High-Episode 75 from 2018-01-24T17:00

In this episode, I visit with Andi Simon, the Principal of Simon Consulting and author of On the Brink: A Fresh Lens to Take Your Business to New Heights. Simon is a corporate anthropologist and wo...

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FCPA Compliance Report
Compliance into the Weeds-Episode 67 from 2018-01-24T17:00

In this episode Matt Kelly and I take a deep dive into the absolutely stunning indictment of five former partners or employees of KPMG and one former employee at the Public Company Oversight Accoun...

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FCPA Compliance Report
FCPA Compliance Report-Episode 368 from 2018-01-23T17:00

In this episode I visit with Damon Brenner, partner at Control Risks on the 2018 Control Risk Map. He details some of the company’s findings in the document entitled RiskMap 2018. Jonathan Wood, Di...

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FCPA Compliance Report
Day 23 of 31 Days to a More Effective Compliance Program from 2018-01-23T17:00

Compliance Programs (Evaluation) is the need to use the information you obtain, whether through risk assessment, root cause analysis, investigation, hotline report or any other manner to remediate ...

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FCPA Compliance Report
Day 22 of 31 Days to a More Effective Compliance Program from 2018-01-22T17:00

How do you assess internal compliance controls under a best practices compliance program? In this episode I consider how to do so in the most effective manner. Learn more about your ad choices. Vi...

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FCPA Compliance Report
FCPA Compliance Report-Episode 367 from 2018-01-22T15:50:12

Today I visit with James Shields, the Creative Director for Twist and Shout Communications, a UK company which creates training video using comedy as the touchstone. You can check out a selection o...

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FCPA Compliance Report
Day 21 of 31 Days to a More Effective Compliance Program from 2018-01-21T17:00

Under Hallmark Nine of Ten Hallmarks of an Effective Compliance Program as articulated in the 2012 FCPA Guidance, it stated, “Finally, a good compliance program should constantly evolve.” This insi...

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FCPA Compliance Report
Day 20 of 31 Days to a More Effective Compliance Program from 2018-01-20T17:00

There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to trigger the Board of Directors and senior mana...

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FCPA Compliance Report
This Week in FCPA-Episode 85 from 2018-01-19T18:49:37

In this episode, Jay Rosen and I return for a review of some of the week's top compliance and ethics stories. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 19 of 31 Days to a more Effective Compliance Program from 2018-01-19T17:00

Focusing on investigations under Prong 7 in the Evaluation it stated, Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly s...

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FCPA Compliance Report
Everything Compliance-Episode 24 from 2018-01-18T17:00

In this episode, the top compliance roundtable podcast is back with a look at some of the top FCPA, compliance and data privacy/data security issues from 2017 and how they inform what will be the t...

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FCPA Compliance Report
Day 18 of 31 Days to a More Effective Compliance Program from 2018-01-18T17:00

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it w...

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FCPA Compliance Report
Compliance into the Weeds-Episode 66 from 2018-01-17T20:53:59

In this episode Matt Kelly and I take a deep dive into a fascinating paper from Harvard Business School. Boris Groysberg and George Serafeim, worked with a global recruitment firm to study more tha...

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FCPA Compliance Report
Day 17of 31 Days to a More Effective Compliance Program from 2018-01-17T17:00

The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the lifecycle management of third parties, most compliance practitioners ...

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FCPA Compliance Report
Day 16 of 31 Days to a More Effective Compliance Program from 2018-01-16T17:00

As every compliance practitioner is well aware, third parties still present the highest risk under the Foreign Corrupt Practices Act (FCPA). The Department of Justice Evaluation of Corporate Compli...

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FCPA Compliance Report
Day 15 of 31 Days to a More Effective Compliance Program from 2018-01-15T17:00

After you complete your risk assessment, you must then translate it into a risk profile, as Rick Messick has noted, to estimate where bribery is likely occur, so prevention efforts will be properly...

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FCPA Compliance Report
FCPA Compliance Report-Episode 366 Jonathan Marks from 2018-01-15T12:03:21

In this podcast, I visit Jonathan Marks, a partner at Marcum LLP on how to perform a root cause analysis and it uses in the remediation phase of a best practices compliance program. Learn more abou...

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FCPA Compliance Report
Day 14 of 31 Days to a More Effective Compliance Program from 2018-01-14T17:00

One cannot really say enough about risk assessments in the context of an anti-corruption programs. Since at least 1999, in the Metcalf&Eddy enforcement action, the DOJ has said that risk assessment...

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FCPA Compliance Report
Day 13 of 31 Days to More Effective Compliance Program from 2018-01-13T17:00

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary ...

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FCPA Compliance Report
Day 12 of 31 Days to a More Effective Compliance Program from 2018-01-12T17:00

One of the areas that many companies have not paid as much attention to in their compliance programs is compensation. However, the DOJ and SEC have long made clear that they view monetary structure...

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FCPA Compliance Report
This Week in FCPA- Episode 84 from 2018-01-12T17:00

Jay and Tom weigh in on the week's top compliance related stories in This Week in FCPA. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 11 of 31 Days to a More Effective Compliance Program from 2018-01-11T17:00

One of the key goals of any FCPA compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance program; and to create and foster a culture of...

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FCPA Compliance Report
Across the Board-Episode 12 from 2018-01-11T17:00

In this episode I discuss a Board of Director's obligations for a compliance program and how a Board might prudently discharge that obligation. Learn more about your ad choices. Visit megaphone.fm/...

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FCPA Compliance Report
Day 10 of 31 Days to a More Effective Compliance Program from 2018-01-10T17:00

What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presen...

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FCPA Compliance Report
Compliance into the Weeds-Episode 65 from 2018-01-10T17:00

In this episode Matt Kelly and I take deep dive into the issue of non-GAAP metrics and its implications. We were inspired an article in this quarter's MIT Sloan Management Review entitled, "The Pit...

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FCPA Compliance Report
Day 9 of 31 Days to a More Effective Compliance Program from 2018-01-09T17:00

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is a...

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FCPA Compliance Report
FCPA Compliance Report-Episode 365 from 2018-01-08T17:00

In this episode, I visit with QuantaVerse CEO/Founder David McLaughlin on the company’s new tool, the Chief Audit Checkup service, which leverages the QuantaVerse AI Financial Crime Platform to ana...

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FCPA Compliance Report
Day 8 of 31 Days to a More Effective Compliance Program from 2018-01-08T17:00

What specifically are internal controls in a compliance program? Internal controls are not only the foundation of a company but are also the foundation of any effective anti-corruption compliance p...

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FCPA Compliance Report
Day 7 of 31 Days to a More Effective Compliance Program from 2018-01-07T14:01:33

There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the government comes knocking. The 2012 FCPA Guidan...

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FCPA Compliance Report
Day 6 of 31 Days to a More Effective Compliance Program from 2018-01-06T16:32:15

What is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven ...

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FCPA Compliance Report
This Week in FCPA-Episode 83 from 2018-01-05T17:57:42

In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week. Jonathan Marks joins us to discuss his new Board and Fraud blog.  Learn more about your a...

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FCPA Compliance Report
Day 5 of 31 Days to a More Effective Compliance Program from 2018-01-05T17:00

What is the role of a company’s Board of Director as laid out in the Evaluation of Corporate Compliance Programs for more fully operationalizing a best practices compliance program.Learn more about...

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FCPA Compliance Report
Day 4 of 31 Days to a More Effective Compliance Program from 2018-01-04T17:00

The Evaluation of Corporate Compliance Programs makes clear, a company must have more than simply at good ‘Tone-at-the-Top’; it must move down through the organization from senior management down t...

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FCPA Compliance Report
Across the Board-Episode 11 from 2018-01-04T15:04:23

In this episode, Richard Lummis and I consider the recent revelations which came to light that during the tenure of the former Chief Executive Officer, Jeff Immelt, he had an empty plane fly behind...

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FCPA Compliance Report
Day 3 of 31 Days to a More Effective Compliance Program from 2018-01-03T17:00

This requirement is more than simply the ubiquitous ‘tone-at-the-top’ as it focuses on the conduct of senior management. The Justice Department wants to see a company’s senior leadership actually d...

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FCPA Compliance Report
Compliance into the Weeds-Episode 64 from 2018-01-03T17:00

In this episode, Matt Kelly and I take a look at some of the more intriguing issues in compliance and ethics, FCPA and greater GRC issues in the new year of 2018. Learn more about your ad choices. ...

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FCPA Compliance Report
Day 2 of 31 Days to a More Effective Compliance Program from 2018-01-02T17:00

Operationalizing your compliance program can take many shapes and forms. Using the entire risk management process to embed your compliance program within the contours of your organization is an imp...

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FCPA Compliance Report
FCPA Compliance Report-Episode 364 from 2018-01-02T17:00

In this episode, I visit with SCCE incoming President Gerry Zack about his new role with the organization. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
This Week in FCPA-Episode 82 from 2017-12-31T19:20:50

Jay and I take things in a different direction this week. We take the top five podcasts from 2017 and each of us, gives a highlight from that episode to highlight some of the key compliance issues ...

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FCPA Compliance Report
Day 1 of 31 Days to a More Effective Compliance Program from 2017-12-31T19:08:45

Over the next 31 days, I will be exploring the best way to more fully operationalize a compliance program using the DOJ resources. Join me as we engage in 31 days to a more effective compliance pro...

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FCPA Compliance Report
Day 21 of One Month to Better Written Standards from 2017-12-31T17:00

This entry provides a wrap up on written standards, with a discussion on policies on cybersecurity. Regarding policies on cybersecurity, it has become so critical for corporation that the CCO and m...

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FCPA Compliance Report
Day 20 of One Month to Better Written Standards from 2017-12-30T17:00

The next area for policies is extortion payments, which are completely exempted out of the FCPA. Extortion payments are made for any action which threatens or demands payment for life, liberty, or ...

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FCPA Compliance Report
Day 19 of One Month to Better Written Standards from 2017-12-29T17:00

As every compliance practitioner is well aware, third parties still present the highest risk under the Foreign Corrupt Practices Act. The Department of Justice Evaluation of Corporate Compliance Pr...

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FCPA Compliance Report
Day 18 of One Month to Better Written Standards from 2017-12-28T17:00

From the information provided by the Justice Department in Opinion Releases and in enforcement actions, there are several different insights which may be drawn on what should go into your policy on...

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FCPA Compliance Report
Everything Compliance-Episode 23 from 2017-12-28T17:00

In Part II of a two-part series, the top compliance roundtable podcast is back with a review of the new Justice Department’s FCPA Corporate Enforcement Policy. This episode features Jay Rosen and J...

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FCPA Compliance Report
12 O’Clock High-Episode 71 from 2017-12-27T17:00

In this special 2017 year-end wrap up, host Richard Lummis and myself reflect back on the leadership lessons we explored over the past year. In this momentous year for leadership, both in business ...

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FCPA Compliance Report
Day 17 of One Month to Better Written Standards from 2017-12-27T17:00

What are some of the key court cases and enforcement actions around facilitation payments? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
FCPA Compliance Report-Episode 363 from 2017-12-27T17:00

In this episode, I visit with Keith Read, Advisor to Convercent and Angus Robertson, Senior Vice President for Convercent on some of the key trends they observed in the marketplace in 2017, from th...

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FCPA Compliance Report
This Week in FCPA-Episode 81 from 2017-12-22T17:53:03

Jay Rosen and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, in this special holiday edition. Learn more about your ad choices. Visit...

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FCPA Compliance Report
May the Podcast Be With You-Part V from 2017-12-22T17:00

Welcome to the Part V and our final entry of this five-part podcast series Jay Rosen and I produced in honor of the latest Star Wars movie The Last Jedi. Each day over this week, Jay and I reviewed...

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FCPA Compliance Report
Day 16 of One Month to Better Written Standards from 2017-12-22T17:00

The FCPA contains an explicit exception to the bribery prohibition for any “facilitation or expediting payment to a foreign official, political party, or party official for the purpose of which is ...

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FCPA Compliance Report
Everything Compliance-Episode 22 from 2017-12-21T17:00

In Part I of a two-part series, the top compliance roundtable podcast is back with a review of the new Justice Department’s FCPA Corporate Enforcement Policy.  Learn more about your ad choices. Vis...

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FCPA Compliance Report
New Revenue Recognition Standard-Part I from 2017-12-11T17:00

In May 2014, FASB issued Accounting Standards Update, Revenue from Contracts with Customers for public business entities, certain not-for-profit entities, and certain employee benefit plans. In ad...

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FCPA Compliance Report
Day 7 of One Month to Better Written Standards from 2017-12-11T17:00

How can you work to operationalize the Code of Conduct as articulated in the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs? The Evaluation focuses not on whether a company...

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FCPA Compliance Report
FCPA Compliance Report-Episode 361 from 2017-12-11T12:00

In this episode, I visit with Don Fischer, a San Francisco and Washington, based lawyers who is one of the country’s leading practices dedicated to assisting corporations, universities and research...

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FCPA Compliance Report
Day 6 of One Month to Better Written Standards from 2017-12-08T17:00

What about the training on your finalized Code of Conduct? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
This Week in FCPA-Episode 79 from 2017-12-08T15:00:22

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week ending December 8, 2017. Learn more about your ad choices. Visit megaphone.fm/adc...

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FCPA Compliance Report
Day 5 of One Month to Better Written Standards from 2017-12-07T19:42:51

Next is the design of your Code of Conduct. Through attention to detail in the design process, you should be able to come out at the end with a Code of Conduct which will help you to more fully ope...

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FCPA Compliance Report
Day 4 of One Month to Better Written Standards from 2017-12-06T13:00

Next, the evolution of the structure and format of a best practices Code of Conduct. Initially, my experience with Codes of Conduct was that they were written by lawyers, largely for lawyers. This ...

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FCPA Compliance Report
12 O'Clock High-Episode 68 from 2017-12-05T17:00

In this episode Richard Lummis and I explore the leadership lessons from the Battle of Hue in Vietnam in 1968. We consider the failures of the American high command, the role of leaders on the grou...

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FCPA Compliance Report
Day 3 of One Month to Better Written Standards from 2017-12-05T13:00

The Code of Conduct forms the basis of your ethical commitments. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 2 of One Month to More Effective Written Standards from 2017-12-04T13:00

The cornerstone of a best practices compliance program is its written standards. These include a Code of Conduct, policies and procedures. These requirements have long been memorialized in the US F...

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FCPA Compliance Report
12 O'Clock High-Episode 66 from 2017-11-16T17:00

In the episode, I consider two different issues around communication skills. The first is communicating across cultural boundaries.  The second is the technique of asking questions to boost leaders...

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FCPA Compliance Report
Day 11 of One Month to 360 Degrees of Communication in Compliance from 2017-11-15T17:00

What if you could multiple the impact and effectiveness of your compliance program throughout your company? That would be a great boon to any compliance practitioner and compliance program. It is a...

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FCPA Compliance Report
Day 10 of One Month to 360 Degrees of Communication in Compliance from 2017-11-14T17:00

Many compliance professionals in the corporate world work long and hard to rise to the senior management level in their organizations. It takes subject matter expertise, hard work and sometime prop...

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FCPA Compliance Report
Compliance into the Weeds-Episode 60 from 2017-11-14T17:00

In this podcast, we consider the joint role of a GC-CCO and the potential corporate governance issues involved when the roles are held by one person. Does this create an irreconcilable conflict? Wh...

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FCPA Compliance Report
Day 9 of One Month to 360 Degrees of Communication in Compliance from 2017-11-13T17:00

The life of a Chief Compliance Officer (CCO) can be intense and the one of the most powerful tools you have is persuasion. Jenny O’Brien, CCO at United Health Care, has talked about the techniques ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 357 from 2017-11-13T17:00

What does the release of the Paradise Papers and the corruption crackdown in Saudi Arabia mean for the compliance program of a US or UK company? In this episode I explore some of the compliance rel...

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FCPA Compliance Report
Day 8 of One Month to 360 Degrees of Communication in Compliance from 2017-11-10T17:00

The debate about whether the compliance function should be located in a company’s legal department or in a separate compliance function has largely concluded that it should be independent because o...

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FCPA Compliance Report
This Week in FCPA-Episode 76 from 2017-11-10T17:00

This Week in FCPA is the only weekly FCPA, compliance and ethics podcast show. Find out the top compliance stories in a short 30 minutes listen. Learn more about your ad choices. Visit megaphone.fm...

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FCPA Compliance Report
12 O'Clock High-Episode 65 from 2017-11-10T17:00

It is difficult to imagine today a harder situation than the country faced when FDR came to power in 1933. The task must have seemed overwhelming. Starting a new compliance leadership position at a...

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FCPA Compliance Report
Day 7 of One Month to 360 Degrees of Communication in Compliance from 2017-11-09T17:00

The 360-degree approach to compliance works with all the stakeholders in a compliance program, even the Document Document Document stakeholders; IE., the regulators. Learn more about your ad choic...

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FCPA Compliance Report
Compliance into the Weeds-Episode 59 from 2017-11-08T17:00

What will be the fate of the Justice Department's Evaluation of Corporate Compliance Programs going forward under the Sessions Department of Justice. Learn more about your ad choices. Visit megaph...

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FCPA Compliance Report
Day 6 of One Month to 360 Degrees of Communication in Compliance from 2017-11-08T17:00

One of the more difficult things to predict in a merger and acquisition context is how the cultures of the two entities will merge. Further, while many mergers claim to be a ‘merger of equals’ the ...

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FCPA Compliance Report
Day 5of One Month to 360 Degrees of Communication in Compliance from 2017-11-07T17:00

Why do people share? The answer to that question has important implications for the compliance function. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
FCPA Compliance Report-Episode 356 from 2017-11-06T17:00

In this episode, I visit Lauren Briggerman and Dawn Murphy-Johnson on the Fall 2017 issue of Executives at Risk. It is newsletter put out by the law firm of Miller&Chevalier. Learn more about your ...

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FCPA Compliance Report
Day 4 of One Month to 360 Degrees of Communication in Compliance from 2017-11-06T17:00

I am a huge fan of using social media in your compliance function. I often point to Louis Sapirman, the Vice President, Associate General Counsel and Chief Compliance Officer at Dun&Bradstreet, as ...

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FCPA Compliance Report
This Week in FCPA-Episode 75 the World Series Champs Edition from 2017-11-03T16:02:03

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories for the week ending November 3, 2017. Learn more about your ad choices. Visit megaphone.fm/a...

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FCPA Compliance Report
Day 3 of One Month to 360 Degrees of Communication in Compliance from 2017-11-03T16:00

How does one company and one Chief Compliance Officer (CCO) actively use social media to make more effective the company’s compliance culture. The company is the Dun&Bradstreet (D&B) and its CCO, L...

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FCPA Compliance Report
Across the Board-Episode 9 from 2017-11-02T16:00

In this episode I visit with Stuart Levine. We focus on Board optimization and try to answer the question of why your Board is not optimized. We consider what is an optimized board and are you serv...

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FCPA Compliance Report
Day 2 of 360 Degrees of Communication in Compliance -Social Media Is a Compliance Conversation from 2017-11-02T16:00

What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presen...

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FCPA Compliance Report
Compliance into the Weeds-Episode 58 from 2017-11-01T16:00

In this episode, Matt Kelly and I take a deep dive into the scandal around Harvey Weinstein. We consider it from the compliance perspective, both programatic and for the CCO. We consider the differ...

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FCPA Compliance Report
Day 1 of 360 Degrees of Communication in Compliance from 2017-11-01T16:00

Welcome to Day One of 360-degrees of communication in compliance. This month you will learn about techniques that the CCO can use to provide you not only a well-rounded role as a CCO but also facil...

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FCPA Compliance Report
Day 22 of One Month to More Effective Compliance for Business Ventures from 2017-10-31T16:00

The key insight for this month is that business ventures, whether joint ventures (JVs), partnerships, franchises, team agreements, strategic alliances or one of the myriad types of business relatio...

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FCPA Compliance Report
Day 21 of One Month to More Effective Compliance for Business Ventures from 2017-10-30T16:00

Most franchisors have thorough financial vetting requirements before allowing any person or business to become a franchisee. However, how many of these same businesses perform compliance due dilige...

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FCPA Compliance Report
FCPA Compliance Report-Episode 355 from 2017-10-30T16:00

We consider the recent speech by Deputy Attorney General Rod Rosenstein on the comprehensive review the Justice Department will go through looking at various and sometimes disparate Memos regarding...

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FCPA Compliance Report
Day 20 of One Month to More Effective Compliance for Business Ventures from 2017-10-27T16:00

I am often asked about franchisor liability under the FCPA. Franchising has been a successful model in the US and now many corporations are looking at overseas expansion opportunities. Franchise la...

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FCPA Compliance Report
This Week in FCPA-Episode 74 the Coming Home Tied Edition from 2017-10-27T15:49:14

In this episode of This Week in FCPA, Jay Rosen and I discuss a wide range of FCPA, compliance and ethics related topics. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 19 of One Month to More Effective Compliance for Business Ventures from 2017-10-26T16:00

Many compliance practitioners generally view distributors as a part of their third-party risk management program, with most of their attention to the pre-contract phase of the risk management proce...

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FCPA Compliance Report
Everything Compliance-Episode 20 from 2017-10-26T16:00

In this episode, we report from the SCCE 2017 Compliance and Ethics Institute, which was recently concluded in Las Vegas. We are joined by Roy Snell, the President of SCCE. We all relate some of ou...

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FCPA Compliance Report
Day 18 of One Month to More Effective Compliance for Business Ventures from 2017-10-25T16:00

One area not usually considered around your business venture partner is their financial health. It turns out such an oversight may have some significantly ramifications for an accurate picture of a...

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FCPA Compliance Report
12 O'Clock High-Episode 64 from 2017-10-25T16:00

In this episode, I consider the book Multipliers: How the Best Leaders Make Everyone Smarter. It focuses two different types of leaders, Diminishers and Multipliers. Multipliers are leaders who enc...

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FCPA Compliance Report
Day 17 of One Month to More Effective Compliance for Business Ventures from 2017-10-24T16:00

One area not often considered by the CCO as a key part of any compliance regime is the corporate Controller. The Controller generally has the responsibility to accurately record and report the fina...

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FCPA Compliance Report
Compliance Man Goes Global from 2017-10-24T12:56:36

Welcome to Episode 4 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on typical myths and mistakes regarding compliance trainin...

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FCPA Compliance Report
FCPA Compliance Report-Episode 354 from 2017-10-23T16:00

This podcast continues the theme I have been following on the evolution of best practices compliance program, continually moving away from the simple paper program approach articulated by some. The...

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FCPA Compliance Report
Day 16 of One Month to More Effective Compliance for Business Ventures from 2017-10-23T16:00

Do FCPA considerations come into play for customers? How should you think about your obligations under the FCPA for a group not traditionally associated with FCPA liability or even FCPA risk? Learn...

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FCPA Compliance Report
This Week in FCPA-Episode 73 from 2017-10-20T16:00:18

In this episode, Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 15 of One Month to More Effective Compliance for Business Ventures from 2017-10-20T16:00

As I conclude this section on joint ventures, I want to emphasize again the risk they pose under the FCPA. Mike Volkov has stated, “A joint venture requires the integration of disparate company cul...

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FCPA Compliance Report
Day 14 of One Month to More Effective Compliance for Business Ventures from 2017-10-19T16:00

Joint ventures provide many FCPA risks that other types of business relationships do not bring. This makes the securing of audit rights in the joint venture agreement and exercising these rights cr...

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FCPA Compliance Report
Across the Board-Episode 8 from 2017-10-19T16:00

In this episode, I visit with branding expert Linda Justice. We discuss the role of a Board of Directors in corporate branding. We discuss ‘what is branding?’  Learn more about your ad choices. Vis...

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FCPA Compliance Report
Day 13 of One Month to More Effective Compliance for Business Ventures from 2017-10-18T16:00

Numerous US companies have come to FCPA grief for their overseas joint ventures and the continue to be a bane for many companies under the Act. There are some basic compliance terms and conditions ...

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FCPA Compliance Report
Twelve O'Clock High-Episode 63-Dan Norris from 2017-10-18T16:00

We discuss the work of the Holt Development company and how it interacts with other organizations. He explains what makes the method work for such a disparate group of organizations: from non-profi...

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FCPA Compliance Report
Day 12 of One Month to More Effective Compliance for Business Ventures from 2017-10-17T16:00

When you bring two entities together to operate jointly, there are several difficult issues to analyze. For the US company operating under the FCPA, there must be an adequate business justification...

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FCPA Compliance Report
This Week in FCPA-Episode 72 from 2017-10-16T20:25:25

In this episode, Jay and I are joined by Louis Sapirman, CCO at Dun&Bradstreet for a look the the 2017 SCCE Compliance and Ethics Institute. We discuss the pro-conference events, what we hope to ac...

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FCPA Compliance Report
Day 11 of One Month to More Effective Compliance for Business Ventures from 2017-10-16T16:00

Just as the FCPA enforcement field is covered with actions centering around mergers and acquisitions, there are multiple actions involving joint ventures (JVs). JVs continue to plague many US compa...

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FCPA Compliance Report
FCPA Compliance Report-Episode 353 from 2017-10-16T16:00

In this episode, I visit with Doreen Edelman, a partner at Baker Donaldson on the top FCPA enforcement action of 2017, the Telia Company matter. Learn more about your ad choices. Visit megaphone.fm...

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FCPA Compliance Report
Day 10 of One Month to More Effective Compliance for Business Ventures from 2017-10-13T16:00

One of my favorite words in the context of FCPA enforcement is dis-link. broadly it works on many different levels when discussing the FCPA. This concept of dis-linking was most prominently laid ou...

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FCPA Compliance Report
This Week in FCPA-Episode 71 from 2017-10-06T16:41:02

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 4 of One Month to More Effective Compliance for Business Ventures from 2017-10-05T16:00

What steps can a company take to protect itself from FCPA exposure in the mergers and acquisitions context? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Everything Compliance-Episode 19 from 2017-10-05T16:00

Join the Everything Compliance panel for a discussion of Uber in London, Telia, the NCAA and Equifax. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
12 O'Clock High-Episode 61 from 2017-10-04T16:00

What branding lessons can the business leader draw from Count Dracula? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 3 of One Month to More Effective Compliance for Business Ventures from 2017-10-04T16:00

Why should a company engage in pre-acquisition due diligence in the mergers and acquisition context? There are multiple reasons including legal, compliance and business. Learn more about your ad ...

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FCPA Compliance Report
Day 2 of One Month to More Effective Compliance for Business Ventures from 2017-10-03T16:00

The area of law for mergers and acquisitions under the FCPA has been settled through enforcement actions leading up to the 2012 FCPA Guidance. Learn more about your ad choices. Visit megaphone.fm/...

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FCPA Compliance Report
Compliance into the Weeds-Episode 56 from 2017-10-03T16:00

In this episode, Matt Kelly and I take a deep dive into an article by Todd Haugh, in the most recent issue of the MIT Sloan Management Review entitled, “The Trouble With Corporate Compliance Progra...

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FCPA Compliance Report
Day 1 of One Month to More Effective Compliance for Business Ventures from 2017-10-02T16:00

Today, I begin a one month series on how to have a more effective compliance program involving business ventures. This will include the role of compliance in mergers and acquisitions, the role of c...

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FCPA Compliance Report
FCPA Compliance Report-Episode 351 from 2017-10-02T14:49:09

We discuss how the use of AI can bring a more holistic approach to compliance as a business process rather than simply policies and procedures so that the end of the day a company is more profitabl...

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FCPA Compliance Report
This Week in FCPA-Episode 70 from 2017-09-29T16:16:21

In this episode Jay and I take a look at the week's top FCPA, compliance and ethics related stories. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 20 of One Month of Innovation in Compliance from 2017-09-29T16:00

As I end this section on innovation, I want to conclude by laying out a road map which allows a CCO or compliance practitioner to make more effective and better operationalize a corporate complianc...

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FCPA Compliance Report
Across the Board-Episode 3 from 2017-09-28T16:00

Today, I visit with noted fraud examiner, Jonathan Marks, a partner at Marcum LLP on the relationship of the internal auditor, fraud good governance and board governance. Learn more about your ad ...

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FCPA Compliance Report
Day 19 of One Month of Innovation in Compliance from 2017-09-28T16:00

While many compliance departments may have begun more as a command and control function, set up by lawyers to comply with anti-bribery laws such as the FCPA, UK Bribery Act or others; this type of ...

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FCPA Compliance Report
Day 18 of One Month of Innovation in Compliance from 2017-09-27T16:00

Innovative use of videos can improve employee engagement and further operationalize your compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 17 of One Month of Innovation in Compliance from 2017-09-26T16:00

Employees can be your most effective tool to further your compliance program. How well are you utilizing this valuable resource? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Compliance into the Weeds-Episode 55 from 2017-09-26T12:45:34

The Telia FCPA enforcement action is the Number 1 all-time for fines and penalties. What can you learn from it? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 16 Of One Month of Innovation in Compliance from 2017-09-25T16:00

The use of data can help a compliance professional identify internal candidates to move a corporate compliance program forward. This can also give a company a boost by bringing non-compliance profe...

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FCPA Compliance Report
FCPA Compliance Report-Epiosde 350 from 2017-09-25T16:00

Linda Justice bring Nancy Drew to your side to fill all those knowledge gaps in your pursuit of clients. Using her technical background in corporate investigations, brings experience to business de...

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FCPA Compliance Report
This Week in FCPA-Episode 69 from 2017-09-22T16:38:49

Jay Rosen and I review the week's top FCPA, compliance and ethics related stories.Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 15 of One Month to Innovation from 2017-09-22T16:00

Innovation can come in various forms for an organization. Innovation can appear in a structural form. You can move compliance more deeply into your organization with new or different structures. On...

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FCPA Compliance Report
Everything Compliance-Episode 18 from 2017-09-21T16:00

The top roundtable podcast in compliance is back with Part II of the Post Harvey edition. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 14 of One Month of Innovation in Compliance from 2017-09-21T16:00

Operationalizing compliance is usually perceived as a top-down exercise. The reality that the employee base that must execute the compliance strategy is not often considered. Even when there are co...

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FCPA Compliance Report
Day 13 of One Month of Innovation in Compliance from 2017-09-20T16:00

How can you change the perceptions around compliance in your organization? With the Justice Department requirement, set out in the Evaluation of Corporate Compliance Programs, to more fully operati...

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FCPA Compliance Report
Compliance into the Weeds-Episode 54 from 2017-09-20T10:43:32

Matt reports live from TEC 2017, the Workiva user summit Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 12 of One Month of Innovation in Compliance from 2017-09-19T16:00

If it is not clear already this month, innovation does not simply come from a technical or even service perspective but can improve your compliance program from a wide variety of perspectives. We h...

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FCPA Compliance Report
Day 11of One Month of Innovation in Compliance from 2017-09-18T16:00

Innovation can come in form of new ideas or simply fresh ways to consider old problems. The idea of how to use the information available to a CCO is one that can be explored through different avenu...

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FCPA Compliance Report
FCPA Compliance Report-Episode 349, The Chickenshit Club from 2017-09-18T11:00

In this episode, I interview with book author, Jesse Eisinger and Paul Pelletier, a key source for the book. The interview is fascinating and I urge you to take a listen for both the substance and ...

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FCPA Compliance Report
This Week in FCPA-Episode 68 from 2017-09-15T21:31:06

Jay and I return to discuss some of the week's top compliance and ethics related stories, with a special guest rant from Matt Kelly. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 10 of One Month of Innovation in Compliance from 2017-09-15T16:00

What is superforecasting and how can the compliance professional utilize it? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 9 of One Month of Innovation in Compliance from 2017-09-14T16:00

One of the key things the Department of Justice (DOJ) has consistently communicated is the importance of operationalizing rather than having a paper compliance program in place. The Department of J...

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FCPA Compliance Report
Everything Compliance-Episode 17 from 2017-09-14T16:00

The top compliance roundtable podcast is back with another episode of Everything Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 8 of One Month of Innovation in Compliance from 2017-09-13T16:00

Design thinking is another innovation which can help the Chief Compliance Officer (CCO) move forward in a cutting-edge manner to make a compliance program not only more robust but also operationali...

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FCPA Compliance Report
Day 7 of One Month of Innovation in Compliance from 2017-09-12T16:00

I believe one of the most significant innovations in compliance will come through the incorporation of blockchain into compliance. I see great value propositions for the compliance function. Blockc...

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FCPA Compliance Report
Episode 21-Unfair and Unbalanced-the 2017 Compliance and Ethics Institute from 2017-09-12T14:00

In this episode, Roy Snell and I have a wide ranging discussion on the SCCE's Compliance and Ethics Institute. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
FCPA Compliance Report-Episode 348 from 2017-09-11T16:00

The implications to and applications for the anti-corruption compliance profession from data lineage are significant for transparency and accountability in data for sales, third party sales agents ...

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FCPA Compliance Report
Day 6 of One Month of Innovation in Compliance from 2017-09-11T16:00

A kaizen event is uniquely suited to facilitate incremental growth in a compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 5 of One Month of Innovation in Compliance from 2017-09-08T16:00

The only thing constant in compliance is change. Embrace it and embrace agile to help you innovate. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
This Week in FCPA-Episode 67 from 2017-09-08T12:00

After a two week absence, Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories which happened while we were off. Learn more about your ad choices....

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FCPA Compliance Report
Day 4 of One Month of Innovation in Compliance from 2017-09-07T16:00

What will be the role of Artificial Intelligence (AI) in compliance going forward? LawTech had disrupted the legal profession and how it is reshaping many areas of private practice. I found the art...

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FCPA Compliance Report
Across the Board-Episode 6 from 2017-09-07T16:00

What is your Board's protocol for considering climate impact risk and broader strategic risks? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 3 of One Month of Innovation in Compliance from 2017-09-06T16:00

How do you see a pattern in raked leaves which allows you to then step in and take a deeper and broader look at an issue, either through an audit or investigation? This is where compliance practit...

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FCPA Compliance Report
Compliance into the Weeds-Episode 52 from 2017-09-06T16:00

In this episode, Matt Kelly and I take a deep dive into the good, bad and ugly of Hurricane Harvey for the compliance professional. We discuss what lessons may be drawn from the storm and its after...

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FCPA Compliance Report
Day 2 of One Month of Innovation in Compliance from 2017-09-05T16:00

Next we consider the introduction of Artificial Intelligence (AI) into the compliance profession. One thing is certain however and that is technology that will improve the efficiency of compliance ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 347, Adam Turteltaub from 2017-09-05T14:00

We discuss the upcoming 2017 Compliance and Ethics Institute, which is one of the primary education and networking event for professionals working in the Compliance and Ethics profession across all...

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FCPA Compliance Report
Day One of Innovation in Compliance from 2017-09-01T16:00

The key to success for an innovation strategy in compliance is something that every CCO should take to heart; a compliance practitioner must be able to lay out an innovation strategy for complianc...

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FCPA Compliance Report
Day 22 of One Month to More Effective Continuous Monitoring from 2017-08-31T17:01:08

In the August edition of One Month to More Effective Continuous Improvement I have considered some of the techniques to create continuous improvement in your compliance program. Learn more about yo...

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FCPA Compliance Report
Day 21 of One Month to More Effective Continuous Improvement from 2017-08-30T19:05:09

Continuous improvement also requires you to consider the backbone of your compliance program, your written Code of Conduct, policies and procedures. Learn more about your ad choices. Visit megapho...

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FCPA Compliance Report
Day 20 of One Month to More Effective Continuous Improvement from 2017-08-28T16:00

The concept of the Mock Audit is one that can facilitate continuous improvement. As it is a process designed to help your employees do business in a more compliant manner it is a tool that should n...

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FCPA Compliance Report
Day 19 of One Month to More Effective Continuous Improvement from 2017-08-25T16:00

One of the ways that you can engage in continuous improvement for your compliance program is based upon the two-way use of social media. Social media can be used not only to communicate with your e...

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FCPA Compliance Report
Across the Board-Episode 5 from 2017-08-24T16:00

What does a Board of Directors need to facilitate an unstructured dialog with management? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 18 of One Month to More Effective Continuous Improvement from 2017-08-24T16:00

Email sweeps can be a timely and cost effective tool for continuous improvement of your compliance program through ongoing monitoring. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Compliance into the Weeds-Episode 51 from 2017-08-23T16:00

What is the intersection of the PCAOB, auditing and compliance? Matt Kelly and I explore in this week's episode. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 17 of One Month to More Effective Continuous Improvement from 2017-08-23T16:00

Most companies miss a key compliance risk metric by failing to measure and monitor the financial health of their third-parties. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 16 of One Month to More Effective Continuous Improvement from 2017-08-22T16:00

Voluntary monitoring can perform multiple functions in a compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
12 O'Clock High-Episode 56 from 2017-08-22T16:00

What are the leadership lessons to be drawn from the fifth President of the US, James Monroe. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
FCPA Compliance Report-Episode 346, Mike Skopets from 2017-08-21T16:00

In this episode, I visit with Mike Skopets, from Miller&Chevalier on the firm’s Summer 2017 FCPA Report. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 15 of One Month to More Effective Continuous Improvement from 2017-08-21T16:00

Another mechanism for continuous improvement of your compliance program is through risk-based monitoring. Under Prong 5 of the DOJ’s Evaluation of Corporate Compliance Programs, is the following to...

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FCPA Compliance Report
This Week in FCPA-Episode 66 from 2017-08-18T16:00

The week's top FCPA and compliance related events and stories; all in one podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 14 of One Month to More Effective Continuous Improvement from 2017-08-18T16:00

The new by-word from the Evaluation is operationalization but a key in determining operationalization is determining your compliance program effectiveness. Learn more about your ad choices. Visit ...

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FCPA Compliance Report
Day 13 of One Month to More Effective Continuous Monitoring from 2017-08-17T16:00

I continue my discussion of continuous improvement using big data in a best practices compliance program, with some thoughts on how to use it going forward. Learn more about your ad choices. Visit...

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FCPA Compliance Report
Across the Board-Episode 4 from 2017-08-17T13:17:26

In this episode, I explore why Wells Fargo needs a true compliance expert on its Board of Directors.  Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 12 of One Month to More Effective Continuous Improvement from 2017-08-16T16:00

The Hitachi FCPA enforcement action also presented one of the clearest cases for keeping track of current events for continuous improvement I have seen. Learn more about your ad choices. Visit meg...

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FCPA Compliance Report
Compliance into the Weeds-Episode 50 from 2017-08-16T14:00

What is the upside to any US business engaging with the Trump Administration after its tepid response to the events in Charlottesville? Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 11 of One Month to More Effective Internal Controls from 2017-08-15T16:00

The desktop risk assessment can be used to perform ongoing monitoring at low cost with high effectiveness. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
12 O'Clock High-Episode 55 from 2017-08-15T14:00

There are several leadership lessons which I believe can be learned from the British (and German) experiences at Dunkirk. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 10 of One Month to More Effective Continuous Improvement from 2017-08-14T16:00

Continuous improvement requires that you not only audit and monitor but also that you test your controls. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
FCPA Compliance Report-Episode 345 from 2017-08-14T14:00

In this episode, Mike Volkov and I discuss two declinations with disgorgement issued in June 2017 and their significance for the compliance practitioner. Learn more about your ad choices. Visit me...

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FCPA Compliance Report
This Week in FCPA-Episode 65 from 2017-08-11T20:18:35

Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories for the week ending August 11. Learn more about your ad choices. Visit megaphone.fm/ad...

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FCPA Compliance Report
Day 9 of One Month to More Effective Continuous Improvement from 2017-08-11T16:00

In this episode, I consider a fraud audit by using data analytics to help detect or prevent bribery and corruption where the primary sales force used by a company are its FCPA and Chinese domestic ...

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FCPA Compliance Report
Everything Compliance-Episode 16 from 2017-08-10T16:00

In this episode, the Everything Compliance trio of Matt Kelly, Jay Rosen and Tom Fox unpack our first book review. We consider the recently released The Chickenshit Club by Jesse Eisenger and it ma...

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FCPA Compliance Report
Day 8 of One Month to More Effective Continuous Improvement from 2017-08-10T16:00

What is organizational culture? Eric Feldman, SVP at Affiliated Monitors has said it comprises the mission, vision and values of an organization. Learn more about your ad choices. Visit megaphone....

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FCPA Compliance Report
Day 7 of One Month to More Effective Continuous Improvement from 2017-08-09T16:00

Many companies have yet to begin their audit process for FCPA compliance on vendors in their supply chain. I find this to be a missed opportunity from both the compliance perspective and greater bu...

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FCPA Compliance Report
12 O'Clock High-Episode 54 from 2017-08-09T16:00

The OODA feedback loop provides a framework for the obtaining and consideration of information; then using it going forward. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Compliance into the Weeds-Episode 49 from 2017-08-09T15:00

The Mattis Memo on ethics is so significant that every CCO and compliance practitioner should read it and the Memo's substance into your compliance program. Learn more about your ad choices. Visit ...

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FCPA Compliance Report
Across the Board-Episode 2, Sheila Hooda from 2017-08-08T14:00

In this episode we discuss the key role Board of Directors around oversight of strategy and risk. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 5 of One Month to More Effective Continuous Improvement from 2017-08-07T16:00

Third parties still present the highest risk around FCPA compliance. It is therefore critical that you use monitoring and auditing when it comes to continuous improvement for this high-risk area. T...

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FCPA Compliance Report
This Week in FCPA-Episode 64 from 2017-08-05T18:33:15

In this special Saturday edition, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories. Learn more about your ad choices. Visit megaphone.f...

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FCPA Compliance Report
Day 4 of One Month to More Effective Continuous Improvement from 2017-08-04T16:00

Most Chief Compliance Officers (CCOs) and compliance practitioners understand the need for continuous controls monitoring. Further, while most compliance practitioners are aware of the tools which ...

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FCPA Compliance Report
Across the Board-Episode 1 from 2017-08-03T16:00

This podcast discusses the Holder Report and the role of the Uber Board. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 3 of One Month to More Effective Continuous Improvement from 2017-08-03T16:00

Internal audit is an excellent tool to make continuous improvement in your compliance regime more effective.Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Compliance into the Weeds-Episode 48 from 2017-08-02T16:00

We consider the enforcement action around the issue of internal controls, their effectiveness (or lack thereof) and management over-ride of internal controls. Learn more about your ad choices. Visi...

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FCPA Compliance Report
Day 2 of One Month to More Effective Continuous Improvement from 2017-08-02T16:00

Auditing can take several different forms in an anti-compliance program. As a matter of course, you should audit the compliance program in your own organization. A forensic audit can collect and an...

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FCPA Compliance Report
12 O'Clock High-Episode 53, Margaret Johnson from 2017-08-01T16:00

In this episode, I visit with Margaret Johnson, the author of the book from From SOS to WOW. This book can help you to move your leadership skills to a new level through by helping you bust through...

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FCPA Compliance Report
Day 1 of One Month to More Effective Continuous Improvement from 2017-08-01T16:00

Welcome to the August edition of One Month to More Effective Continuous Improvement. As you know, each month in 2017 I am presenting a series of podcasts on one topic which will allow you to create...

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FCPA Compliance Report
Day 22 of One Month to More Effective Internal Controls from 2017-07-31T15:13:18

I conclude this one month series by considering the recently concluded Securities and Exchange Commission (SEC) resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action...

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FCPA Compliance Report
FCPA Compliance Report-Episode 344, Virginia Suveiu from 2017-07-31T14:00

in this episode, I visit with Virginia Suveiu, who writes upon theories of risk. She also teaches risk management strategies as UC-Irvine. Learn more about your ad choices. Visit megaphone.fm/adch...

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FCPA Compliance Report
Day 21 of One Month to a More Effective Compliance Program from 2017-07-30T16:00

We are now less than six months away from a new Revenue Recognition (“new rev rec”) standard which may significantly impact the compliance profession, compliance pr Learn more about your ad choices...

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FCPA Compliance Report
Day 20 of One Month to More Effective Internal Controls from 2017-07-29T16:00

I conclude this section on the COSO 2013 Internal Controls Framework by considering what COSO says about assessing compliance internal controls. Learn more about your ad choices. Visit megaphone.fm...

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FCPA Compliance Report
This Week in FCPA-Episode 63 from 2017-07-28T16:16:22

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Day 19 of One Month to More Effective Internal Controls from 2017-07-28T16:00

The fifth and final Objective is Monitoring Activities. The Framework Volume says, “Ongoing evaluations, separate evaluations, or some combination of the two are used to ascertain whether each of t...

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FCPA Compliance Report
Day 18 of One Month to More Effective Internal Controls from 2017-07-27T16:00

In its Framework Volume, COSO said, “Information is necessary for the entity to carry out internal control responsibilities to support the achievement of its objectives. Management obtains or gener...

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FCPA Compliance Report
Everything Compliance from 2017-07-27T14:00

We take things a different way in this episode as the commentators throw out five topics for consideration by the group. Last week we had topics from Jay and Matt; this week from Jonathan and Tom. ...

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FCPA Compliance Report
Day 17 of One Month to More Effective Internal Controls from 2017-07-26T16:00

Control activities are performed at all levels of the entity, at various stages within business processes, and over the technology environment. They may be preventive or detective in nature and may...

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FCPA Compliance Report
Compliance into the Weeds-Episode 47 from 2017-07-26T14:00

In this episode, Matt Kelly and I take a deep dive into the Dodd-Frank and Sarbanes-Oxley reform initiatives in the House of Representatives and as articulated by incoming SEC Chairman Jay Clayton....

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FCPA Compliance Report
Day 16 of One Month to More Effective Internal Controls from 2017-07-25T16:00

The Integrated Framework (Framework Volume) recognizes that “every entity faces a variety of risks from external and internal sources.” This objective is designed to provide a company with a “dynam...

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FCPA Compliance Report
Day 15 of One Month to More Effective Internal Controls from 2017-07-24T16:00

The updated Framework retained the core definition of internal controls; those being control environment, risk assessment, control activities, information and communication, and monitoring activiti...

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FCPA Compliance Report
FCPA Compliance Report-Episode 343, James Koukios from 2017-07-24T13:06:51

In this episode I visit with James Koukios, a partner at Morrison and Foerster on the firm’s newsletter, Top Ten International Anti-Corruption Developments for May 2017. Our topics include:  FCP...

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FCPA Compliance Report
Day 14 of One Month to More Effective Internal Controls from 2017-07-23T16:00

This week we turn our attention to COSO, with an introduction to the organization and its framework for internal controls. I will go through the internal controls and how they relate to compliance....

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FCPA Compliance Report
This Week in FCPA-Episode 62 from 2017-07-21T16:22:33

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories, including:  Will Canada approve DPAs for use in anti-corruption prosecut...

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FCPA Compliance Report
Day 13 of One Month to More Effective Internal Controls from 2017-07-21T16:00

Last year, one of the most interesting non-Foreign Corrupt Practices Act (FCPA) enforcement actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo b...

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FCPA Compliance Report
Everything Compliance-Episode 14 from 2017-07-20T16:00

Show Notes for Everything Compliance-Episode 14  Topics from Matt: Trump Administration&FCPA enforcement— we have two declinations now; maybe a compare-and-contrast, and speculation on what a to...

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FCPA Compliance Report
Day 12 of One Month to More Effective Internal Controls from 2017-07-20T16:00

Is a Board of Directors a compliance internal control? I think the clear answer is yes. In the FCPA Guidance, in the Ten Hallmarks of an Effective Compliance Program, there are two specific referen...

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FCPA Compliance Report
Compliance into the Weeds-Episode 46 from 2017-07-19T13:52:56

In this episode, Matt Kelly and I discuss the recent Second Circuit Court of Appeals decision in HSBC v. Moore. In this case a federal district court had ordered the release of redacted monitor’s r...

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FCPA Compliance Report
Episode 51- Andrew Jackson from 2017-07-18T17:50:08

In this episode, I consider the leadership lessons which can be drawn from our 7th President Andrew Jackson. I focus largely on the crisis surrounding the charter of the Second National Bank of the...

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FCPA Compliance Report
Day 10 of One Month to More Effective Internal Controls from 2017-07-18T16:00

   Today I want to look at internal controls for third parties. One of the questions that GSK faced during the bribery and corruption investigation of its Chinese operations is how an allegedly ma...

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FCPA Compliance Report
Day 9 of One Month to More Effective Internal Controls from 2017-07-17T16:00

As they made clear with several FCPA enforcement actions in 2016, the SEC has placed a renewed interest in the accounting provisions of the FCPA, specifically the internal controls provisions. The ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 342, Melanie Johnson from 2017-07-17T13:51:46

In this episode, I visit with Melanie Johnson, co-founder of Elite Online Publishing, which aids entrepreneurs, business leaders, and professional athletes to create, publish, and market their book...

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FCPA Compliance Report
This Week in FCPA-Episode 61 from 2017-07-15T00:34:41

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories, including: HSBC monitor report protected from release. See article in Re...

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FCPA Compliance Report
Day 8 of One Month to More Effective Internal Controls from 2017-07-14T16:00

A gap analysis is a method of assessing the differences in performance between a business' internal controls to determine whether business requirements are being met and, if not, what steps should ...

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FCPA Compliance Report
Day 7 of One Month to More Effective Internal Controls from 2017-07-13T16:00

Today, I consider some ways in which a compliance professional can work to implement internal controls in a multi-national organization. The first step is to convert your company’s compliance risks...

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FCPA Compliance Report
Compliance Report-International Edition-Carlos Ayers from 2017-07-13T11:22:30

In this episode I visit with Carlos Ayers on steps you can take to make your compliance program more effective to employees in Latin America. This includes such things are localizing your training ...

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FCPA Compliance Report
Day 6 of One Month to More Effective Internal Controls from 2017-07-12T16:00

Next, I will review how to use the risk assessment you have performed as a tool to provide a structured approach to establishing effective internal controls. After preparation of the risk assessmen...

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FCPA Compliance Report
Leadership Lessons from John Adams from 2017-07-12T14:00

In an article entitled, 12 Leadership Qualities of An Often-Overlooked President, Matt Myatt, writing in forbes.com online reviewed the leadership qualities of John Adams as laid out in David McCu...

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FCPA Compliance Report
Day 5 of One Month to More Effective Internal Controls from 2017-07-11T16:00

Today, I want to discuss how to assess for your internal controls regime for international operations. It is incumbent that you need to review as much information so you can to understand the finan...

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FCPA Compliance Report
Compliance into the Weeds-Episode 45 from 2017-07-11T14:00

In this episode, Matt Kelly and I take a deep dive into the 4th of July weekend use of the New Jersey beaches by Governor Chris Christie. Governor Christie had closed the beaches in a budget disput...

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FCPA Compliance Report
Day 4 of One Month to More Effective Internal Controls from 2017-07-10T16:00

Next, I want to consider some of the issues around internal controls outside the US and why your company’s internal controls might require changes for different countries across the globe. However,...

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FCPA Compliance Report
FCPA Compliance Report-Episode 341 from 2017-07-10T14:10:50

The issue of beneficial ownership is one which still bedevils many compliance professionals. Today, I visit with Brian Alster, Dun&Bradstreet’s Global Head of Supply and Compliance about the proble...

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FCPA Compliance Report
This Week in FCPA-Episode 60 from 2017-07-07T16:23:40

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance related stories, including:  U.S. charges top Colombia anti-graft prosecutor with money laundering. ...

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FCPA Compliance Report
Day 3 Of One Month to More Effective Internal Controls from 2017-07-07T16:00

There are four significant controls that he would suggest the compliance practitioner implement initially. They are: (1) Delegation of Authority (DOA); (2) Maintenance of the vendor master file; (3...

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FCPA Compliance Report
Day 2 of One Month to More Effective Internal Controls from 2017-07-06T16:00

Today, New York Times columnist David Brooks’ thoughts on building and maintaining order inform our discussion on internal controls. In the area of internal controls, I believe it is incumbent to c...

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FCPA Compliance Report
FCPA Compliance Report-Episode 340 from 2017-07-06T14:00

In this episode, I visit with Patrick Henz, a compliance practitioner and author of Access Granted: Tomorrow’s Business Ethics. Henz has written one of the most fascinating books on compliance goi...

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FCPA Compliance Report
Day 1 of One Month to More Effective Internal Controls from 2017-07-05T16:00

What specifically are internal controls in a compliance program? Internal controls are not only the foundation of a company but are also the foundation of any effective anti-corruption compliance p...

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FCPA Compliance Report
FCPA Compliance Report-Episode 339, Ed Buthusiem of BRG from 2017-07-05T14:03:17

In this episode, I visit with Ed Buthusiem, with BRG Business Transformation. BRG  partners with companies and their stakeholders to deliver sustainable results with speed and transparency through ...

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FCPA Compliance Report
This Week in FCPA-Episode 59 from 2017-06-30T19:53:53

In this week which starts the 4th of July holiday weekend, Jay and I return for a wide-ranging discussion on some of the week’s top compliance related stories, including:  The second Declination ...

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FCPA Compliance Report
Day 22 of One Month to Better Investigations and Reporting from 2017-06-30T16:00

Yesterday I considered an article by Ryan Hubbs, entitled “10 Factors Leading to Reporting Mechanism Distrust”, in which he detailed 10 factors leading to hotline distrust. Today I want to pick up ...

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FCPA Compliance Report
Day 21 of One Month to Better Investigations and Report from 2017-06-29T16:00

Today I want to consider some factors which can lead to employees’ distrust of an internal reporting system. Ryan Hubbs wrote an excellent article entitled “10 Factors Leading to Reporting Mechanis...

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FCPA Compliance Report
Everything Compliance-Episode 13 from 2017-06-29T14:00

The top compliance roundtable podcast is back with a wealth of new topics. Stayed tuned to the end where there are some heartfelt and somber rants in this edition.  Matt Kelly opens with a discus...

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FCPA Compliance Report
Day 20 of One Month to Better Investigations and Reporting from 2017-06-28T16:00

In an article entitled “How to Launch and Operate a Legally-Compliant International Workplace Report Channel” or in compliance parlance, a hotline, author Donald Dowling of the law firm of White an...

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FCPA Compliance Report
Compliance into the Weeds-Episode 44 from 2017-06-28T14:00

In this episode, Matt Kelly and I take a deep dive, literally into the weeds of the convergence of the compliance profession and the nascent cannabis industry. While several states have made pot fo...

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FCPA Compliance Report
Day 19 of One Month to Better Investigations and Reporting from 2017-06-27T16:00

Is your hotline working for you? In an article entitled, entitled “Promoting Effective Us of the Compliance Hotline” José Tabuena provided an excellent example of the power of a hotline. He provide...

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FCPA Compliance Report
FCPA Compliance Report-Episode 338, Steven Durham from 2017-06-27T14:00

In this episode, I visit with Steven Durham, a partner in the law firm of Labaton Sucharow. The firm is one of the leaders in the SEC Whistleblower practice. Durham describes his background and how...

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FCPA Compliance Report
Day 18 of One Month to Better Investigations and Hotlines from 2017-06-26T16:00

Today I would like to review some best practices regarding a compliance hotline.  The hotline should be developed and maintained externally. It seems axiomatic that em­ployees tend to trust hotli...

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FCPA Compliance Report
FCPA Compliance Report-Episode 337, James Gellert from 2017-06-26T14:00

In this episode, I visit with James Gellert, CEO of RapidRatings, a company which uses a financial dialogue to determine third party supplier health and viability. Gellert explains what supply chai...

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FCPA Compliance Report
This Week in FCPA-Episode 58 from 2017-06-23T22:19:05

After last week’s guest announcers, Jay and I return for a wide-ranging discussion on some of the week’s top compliance related stories, including:  The first Declination of the Session’s Justice...

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FCPA Compliance Report
Day 17 of One Month to Better Investigations and Reporting from 2017-06-23T16:00

Who to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-te...

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FCPA Compliance Report
Day 16 of One Month to Better Investigations and Reporting from 2017-06-22T16:00

Prior to the Schrems decision by the European Court of Justice, US based law firms could rely on Safe Harbor to use and analyze information from investigations conducted in Europe. However the Schr...

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FCPA Compliance Report
Compliance into the Weeds-Episode 43 from 2017-06-22T14:39:58

On June 16, 2017, the Department of Justice (DOJ) issued a Declination to Linde North American Inc. and Linde Gas North America LLC (collectively “Linde”). This is the first Declination issued by t...

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FCPA Compliance Report
Day 15 of One Month to Better Investigations and Reporting from 2017-06-21T16:00

 The concept of privilege in an internal investigation is critical. Two important privileges are the attorney/client privilege and the work product privilege. Unfortunately both are often miss-unde...

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FCPA Compliance Report
FCPA Compliance Report-Episode 336, James Koukios from 2017-06-21T14:00

In this episode, James Koukios, a partner at Morrison&Foerster returns to discuss the firm's newsletter Top Ten International Anti-Corruption Developments for April 2017. In this episode we highlig...

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FCPA Compliance Report
Unfair and Unbalanced-Episode 20 from 2017-06-20T18:38:35

In this episode, I visit with Roy Snell about his recent announcement that he is stepping down as head of the SCCE. We review the current state of the SCCE and how the Roy has seen the compliance e...

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FCPA Compliance Report
Day 14 of One Month to Better Investigations and Reporting from 2017-06-20T16:00

Day 14-Miranda and Internal Investigations: What Rights Does an  Must an investigator warn an employee that concealing information from company lawyers conducting an internal FCPA investigation co...

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FCPA Compliance Report
FCPA Compliance Report-Episode 335, Mike Volkov from 2017-06-19T16:00

In this episode, Mike Volkov and I discuss how blockchain has the potential to transformation compliance and may facilitate some truly revolutionary modifications in key businesses processes. I see...

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FCPA Compliance Report
Day 13 of One Month to Better Investigations and Reporting from 2017-06-19T16:00

When then Assistant Attorney General Sally Yates, announced the Memo that bears her name, she said the following, “we have revised our policy guidance to require that if a company wants any credit ...

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FCPA Compliance Report
This Week in FCPA-Episode 57 from 2017-06-16T19:38:31

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related sto...

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FCPA Compliance Report
Day 12 of One Month to Better Investigations and Report from 2017-06-16T16:00

What are the characteristics of a good interview in the context of an internal investigation? Is there one technique you can use which will provide you the results you want to achieve? How should y...

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FCPA Compliance Report
Day 11 of One Month to Better Investigations and Reporting from 2017-06-15T16:00

Today, I want to consider some of the challenges you may well face during an investigation.  Beyond the basics, a company must consider the intake process as a starting point, however Marks noted o...

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FCPA Compliance Report
FCPA Compliance Report-Episode 334, Lauren Briggerman from 2017-06-15T15:28:43

In this episode, I visit with Lauren Briggerman, a member at the firm of Miller&Chevalier. She discusses the latest edition of the firm newsletter, Executives at Risk: Navigating Individual Exposu...

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FCPA Compliance Report
Day 10 of One Month to Better Investigations and Reporting from 2017-06-14T16:00

Mara Senn and a colleague, Michelle Albert, published in the FCPA Report, Volume 3, Number 1, entitled “Internal Investigations, How to Conduct an Anti-Corruption Investigation: Developing and Impl...

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FCPA Compliance Report
Compliance into the Weeds-Episode 42 from 2017-06-14T12:00

In this episode, Matt Kelly and I take a deep dive into the corporate governance fiasco which is Uber. We consider the revelations in the failures of corporate governance, culture and internal cont...

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FCPA Compliance Report
Day 9 of One Month to Better Reporting and Investigations from 2017-06-13T16:00

Beginning with the Department of Justice’s (DOJ’s) Yates Memo, its Foreign Corrupt Practices Act (FCPA) Pilot Program and then the release of the Evaluation of Corporate Compliance Programs (Evalua...

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FCPA Compliance Report
Day 8 of One Month to Better Investigations and Reporting from 2017-06-12T16:00

  In the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation), under Prong 7 Confidential Reporting and Investigation asks the following: Properly Scoped Investig...

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FCPA Compliance Report
FCPA Compliance Report-Episode 333 from 2017-06-12T12:00

Today I am joined again by Professor Samuel Buell, from Duke University School of Law to discuss a recent paper he co-authored with Rachel Brewster entitled, "The Market for Global AntiCorruption E...

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FCPA Compliance Report
This Week in FCPA-Episode 56 from 2017-06-10T21:56:09

Show Notes for Episode 56, for the week ending June 9, the Who’s On First Edition  This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We disc...

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FCPA Compliance Report
Day 7 of One Month to Better Investigations and Reporting from 2017-06-09T16:00

  There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to trigger the Board of Directors and senior ma...

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FCPA Compliance Report
Day 6 of One Month to Better Investigations and Reporting from 2017-06-08T16:00

In an article in the Corporate Board magazine, entitled “Successful Board Investigations” by David Bayless and Tammy Albarrán, partners in the law firm of Covington&Burling LLP posited seven consid...

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FCPA Compliance Report
Everything Compliance-Episode 12 from 2017-06-08T14:00

  The dog days of summer are on the horizon and the Houston Astros lead the major leagues in winning percentage. Coincidence that the US pulls out of the Paris Climate Accords the same week the As...

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FCPA Compliance Report
Day 5 of One Month to Better Investigations and Reporting from 2017-06-07T16:00

Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same r...

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FCPA Compliance Report
FCPA Compliance Report-Episode 332 from 2017-06-07T12:00

In the case of Kokesh v. SEC, the US Supreme Court held the profit disgorgements operate as a penalty under the Securities and Exchange Act of 1934, as amended. As such “any claim for disgorgement ...

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FCPA Compliance Report
Day 4 of One Month to Better Investigations and Reporting from 2017-06-06T16:00

One of the things that I learned from the television series M*A*S*H was the need for triage. In the hospital setting, triage is the process of determining the priority of patients’ treatments based...

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FCPA Compliance Report
FCPA Compliance Report-Episode 331, Chris Morton from 2017-06-06T14:00

In this episode, I visit with Chris Morton, the SVP, Marketing and Corporate Development for Navex, about the firm's new resource for the Compliance Community, ComplianceNext.com. It is a free, com...

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FCPA Compliance Report
Day 3 of One Month to Better Investigations and Reporting from 2017-06-05T14:55:47

Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism coul...

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FCPA Compliance Report
FCPA Compliance Report-Episode 330 Robyn Bew and Henry Stoever from 2017-06-05T14:00

In this episode, I visit with Robyn Bew, the Director of Strategic Content Development for the National Association of Corporate Directors (NACD) and Henry Stoever, the Chief Marketing Officer for ...

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FCPA Compliance Report
This Week in FCPA-Episode 55 from 2017-06-02T19:31:30

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:  Brazilian meatpacker JBS agrees to the largest fine ever for fine for briber...

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FCPA Compliance Report
Day 2 of One Month to Better Investigations and Reporting from 2017-06-02T16:00

In an article in the Compliance and Ethics Professional Magazine, entitled “Foxes and henhouses: The importance of independent counsel”, Dan Dunne discussed what he termed a “critical element” in a...

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FCPA Compliance Report
Day 1 of One Month to Better Investigations and Reporting from 2017-06-01T17:09:50

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue fo...

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FCPA Compliance Report
Unfair and Unbalanced-Episode 19 from 2017-06-01T16:00

In this episode, Roy and I consider Sgt. Pepper's at 50; Artificial Intelligence in Compliance and how ComTech will change the face of compliance going forward.  For additional reading on these to...

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FCPA Compliance Report
One Month to Better Compliance through HR from 2017-05-31T16:00

Day 22-10 Questions to Better Operationalized Compliance I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas B...

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FCPA Compliance Report
Compliance into the Weeds-Episode 40 from 2017-05-31T14:57:10

In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integrat...

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FCPA Compliance Report
FCPA Compliance Report-Episode 329, James Koukios from 2017-05-30T14:00

Today I have back with me James Koukios, partner and Morrison Foerster on the firm's March 2017 report on the Top Ten International Anti-Corruption Developments for the month. We highlight the 2nd ...

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FCPA Compliance Report
Day 21 of One Month to Better Compliance Through HR from 2017-05-30T12:45:48

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilit...

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FCPA Compliance Report
Day 20 of One Month to Better Compliance Through HR from 2017-05-26T16:00

The key concept from the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Program (Evaluation) is operationalization. For instance, under the query Shared Commitment is the followin...

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FCPA Compliance Report
This Week in FCPA-Episode 54 from 2017-05-26T15:19:05

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:  Tom reports on Compliance Week 2017. See his articles in Compliance Week, h...

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FCPA Compliance Report
Day 19 of One Month to Better Compliance Through HR from 2017-05-25T16:00

  One of the ways that Human Resources (HR) can help to operationalize compliance is to assist each level of an organization to have a proper tone. While the top of an organization rightly gets mu...

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FCPA Compliance Report
Unfair and Unbalanced-Episode 18 from 2017-05-25T14:05:16

Episode 18 Show Notes  I. Compensation, Incentive and ComplianceIn this episode, Roy Snell and myself discuss how incentives are integral to the compensation plans of a wide range of workers. Many...

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FCPA Compliance Report
Day 18 of One Month to Better Compliance Through HR from 2017-05-24T16:00

The role of Human Resources (HR) in anti-corruption compliance programs, is often underestimated. If your company has a culture where compliance is perceived to be in competition or worse yet antit...

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FCPA Compliance Report
Compliance into the Weeds-Episode 39 from 2017-05-24T12:00

In this episode Matt Kelly and I take a deep dive into the question of whether a company has a duty to disclose ransomware attacks. We consider it from the regulatory, legal, ethical, law enforceme...

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FCPA Compliance Report
Day 17 of One Month to Better Compliance Through HR from 2017-05-23T16:00

The Evaluation of Corporate Compliance Programs document makes clear that operationalization of compliance into an organization should be done at multiple levels in a company. Creating an ethical c...

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FCPA Compliance Report
FCPA Compliance Report-Episode 328 from 2017-05-23T12:00

In this episode I visit with Chris McNett, SSGA Head of Environmental, Social and Governance on SSGA's ESG Institutional Investor Survey. Topics include: What was the reason for the State Street ...

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FCPA Compliance Report
Day 16 of One Month to Better Compliance Through HR from 2017-05-22T16:00

The exit interview can be a further mechanism to operationalize compliance. This type of interview is used when someone voluntarily departs from a company, as opposed to a lay-off or reduction in f...

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FCPA Compliance Report
Day 15 of One Month to Better Compliance Through HR from 2017-05-19T16:00

Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of comp...

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FCPA Compliance Report
This Week in FCPA-Episode 53 from 2017-05-19T15:48:33

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:  Brazilian President Temer comes under corruption fire? See article in the N...

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FCPA Compliance Report
Day 14 of One Month to Better Compliance Through HR from 2017-05-18T16:00

What should a company do when it desires to hire a Chief Compliance Officer (CCO).  I sat down and visited with Maurice Gilbert, the Managing Partner at Conselium Partners LP. Gilbert believes that...

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FCPA Compliance Report
Everything Compliance-Episode 11 from 2017-05-18T12:00

In this second of a two-part series, we conclude the panel’s discussion of the first 100 days of the Trump administration as it relates to compliance. This episode concludes with the panelists’ ran...

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FCPA Compliance Report
Day 13 of One Month to Better Compliance Through HR from 2017-05-17T16:00

One of the ways to operationalize compliance and to drive it into the DNA of an organization is through a performance review. Indeed, the 2012 FCPA Guidance states, “DOJ and SEC recognize that posi...

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FCPA Compliance Report
Compliance into the Weeds-Episode 38 from 2017-05-17T12:00

In this episode Matt Kelly and I take a deep dive into the cutting edge topic of artificial intelligence in many areas, including compliance. We discuss the uses of Artificial Intelligence in compl...

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FCPA Compliance Report
Day 12 of One Month to Better Compliance Through HR from 2017-05-16T16:00

Another area where compliance can play a key role is in succession planning. A.G. Lafley and Noel M. Tichy, writing in the Harvard Business Review, in an article entitled “The Art and Science of Fi...

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FCPA Compliance Report
FCPA Compliance Report-Episode 327,Pat Harned from 2017-05-16T12:00

In this episode, I visit with Pat Harned, Chief Executive Officer of the Ethics and Compliance Initiative on the recently concluded annual conference. She discusses the speech of Attorney General J...

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FCPA Compliance Report
Day 11 of One Month to Better Compliance Through HR from 2017-05-15T16:00

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary ...

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FCPA Compliance Report
This Week in FCPA-Episode 52 from 2017-05-12T18:39:47

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:  What is the real risk in a FCPA enforcement action? See Mike Volkov’s post i...

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FCPA Compliance Report
Day 10 of One Month to Better Compliance Through HR from 2017-05-12T16:00

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System –How has the company considered the potential neg...

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FCPA Compliance Report
Day 9 of One Month to Better Compliance Through HR from 2017-05-11T16:00

Today I want to focus on incentives, looking at senior management and compensation. I thought about this inter-connectedness of compensation in a compliance program, focusing up the corporate ladde...

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FCPA Compliance Report
Everything Compliance-Episode 10 from 2017-05-11T12:08:24

This episode is the first of a two-part series of podcasts dedicated to the chaotic (at best) first 100 days of the Trump administration as it related to compliance. Today we have Jonathan Armstron...

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FCPA Compliance Report
Day 8 of One Month to Better Compliance Through HR from 2017-05-10T16:00

One of the areas that many companies have not paid as much attention to in their Foreign Corrupt Practices Act (FCPA) anti-corruption compliance programs is compensation. However the Department of ...

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FCPA Compliance Report
Unfair and Unbalanced-Episode 17 from 2017-05-10T12:00

In this episode, Roy Snell and I discuss the following: Measuring the effectiveness of your compliance program three ways;Why Roy thinks the CO shouldn’t chair the compliance committee – but mayb...

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FCPA Compliance Report
Day 7 of One Month to Better Compliance Through HR from 2017-05-09T16:00

In metrics laid out by former Assistant Attorney General Leslie R. Caldwell, she spoke about the need for compliance program incentives.  She posed it with the following question, “Are there mechan...

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FCPA Compliance Report
FCPA Compliance Report-Episode 326-Paula Long from 2017-05-09T12:10:26

In this episode I caught up with Paula Long, founder and CEO of DataGravity, Inc. at the recently concluded Collision 2017 Conference. Paula has worked in the data and information space for over 30...

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FCPA Compliance Report
Day 6 of One Month to Better Compliance Thru HR from 2017-05-08T16:00

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states:  Incentive System – How has the company incentivized compliance a...

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FCPA Compliance Report
This Week in FCPA-Episode 51 from 2017-05-05T16:01:15

  Over some breakfast tacos and Mexican coffee, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: Uganda considers a demand side response t...

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FCPA Compliance Report
Day 5 of One Month to Better Compliance Through HR from 2017-05-05T15:39:29

Why is hiring so important under for compliance? It is because hiring is important to any company’s health and reputation. At this point, until the US Supreme Court tells us that a corporation is t...

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FCPA Compliance Report
Day 4 of One Month to Better Compliance Through HR from 2017-05-04T17:54:27

One of the theories of conventional wisdom about anti-corruption compliance is that you will never be able to reach 5% of your workforce with compliance training because they are predisposed to lie...

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FCPA Compliance Report
Day 3 of One Month to Better Compliance Through HR from 2017-05-03T16:00

Today, I conclude my review of FCPA enforcement actions that involved the corporate hiring function. From these three cases I have considered, it is clear that HR must be involved in compliance and...

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FCPA Compliance Report
Compliance into the Weeds-Episode 37 from 2017-05-03T12:00

In this episode, Matt Kelly and I take a deep dive into the weeds of the soon-to-be-released the House Financial Services Committee, the Financial Choice 2.0 Act. We consider some of the ideas in t...

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FCPA Compliance Report
Day 2 of One Month to Better Compliance Through HR from 2017-05-02T16:00

  BNY MellonUp until the summer of 2015, hiring practices under the FCPA were not been given much thought or widely discussed. However that began to change in the summer of 2015 when the SEC anno...

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FCPA Compliance Report
FCPA Compliance Report-Episode 325 from 2017-05-02T14:00

In this podcast, Marc Bohn and James Tillen from the firm of Miller&Chevalier, discuss their recent publication entitled, "Evaluating FCPA Pilot Program: Declinations on the Rise" where they review...

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FCPA Compliance Report
Day 1 of One Month to Better Compliance Through HR from 2017-05-01T17:09:33

Day 1-  The Role of Human Resources in Operationalizing Compliance This month, I will consider the role of Human Resources (HR) in operationalizing a best practices compliance program. I have long...

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FCPA Compliance Report
This Week in FCPA-Episode 50 from 2017-04-28T19:16:04

In this episode, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: Trump’s First 100 days end with a decided wimper. What does it mean for...

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FCPA Compliance Report
Day 20 of One Month to Better 3rd Party Management from 2017-04-28T16:00

I end this one month series by taking things a different direction. Today I do not focus on third party risk management but on third parties as a compliance innovation source for your organization....

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FCPA Compliance Report
Unfair and Unbalanced-Episode 16 from 2017-04-27T17:42:24

In this Part I of a two part series recorded at this month's European Compliance and Ethics Institute in Prague, Roy Snell discuss the DOJ's Evaluation of Corporate Compliance Programs in the conte...

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FCPA Compliance Report
Day 19 of One Month to Better 3rd Party Management from 2017-04-27T16:00

One of the areas many companies do not focus on enough is possible corruption in their Supply Chain (SC) for goods and services provided on a company’s behalf. The FCPA risks can be just as great t...

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FCPA Compliance Report
Day 18 of One Month to Better 3rd Party Management from 2017-04-26T16:00

The Foreign Corrupt Practices Act (FCPA) world is littered with cases involving freight forwarders, brokers and agents in the shipping and express delivery arena. Both the Department of Justice (DO...

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FCPA Compliance Report
FCPA Compliance Report-Episode 324 from 2017-04-26T14:00

In this episode I visit with white collar defense and Qui Tam specialist Joel Androphy about prosecution of whistleblower claims at the federal and state level. Androphy explains what type of evide...

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FCPA Compliance Report
Day 17 of One Month to Better 3rd Party Management from 2017-04-25T16:00

One of the issues in any compliance program is the compensation paid to a third party as FCPA exposure arises when companies pay money - either directly or indirectly - to fund bribe payments.  In ...

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FCPA Compliance Report
Compliance into the Weeds-Episode 36 from 2017-04-25T14:00

In this episode, Matt Kelly and I take a very deep dive into two recent speeches by Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden in which he addressed mul...

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FCPA Compliance Report
Day 16 of One Month to Better Third Party Management from 2017-04-24T16:00

At some point, you will be required to terminate a third-party and there will be multiple legal, compliance and business issues to navigate going forward. If you are stuck doing it in the middle of...

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FCPA Compliance Report
This Week in FCPA-Episode 49 from 2017-04-21T20:50:54

In this episode, Jay Rosen returns from a week’s trip to Walt Disney World. Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: DOJ Criminal...

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FCPA Compliance Report
Day 15 of One Month to Better Third Party Management from 2017-04-21T16:00

One area that has bedeviled Chief Compliance Officers (CCOs) and compliance practitioners is how to determine the return on investment (ROI) for your compliance program regarding third parties. Whi...

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FCPA Compliance Report
Day 14 of One Month to Better Third Party Management from 2017-04-20T16:00

When was the last time you considered the health of your company’s third party management program? A good way to test that well-being is to perform a check-up on your third party program. An articl...

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FCPA Compliance Report
Day 13 of One Month to Better Third Party Management from 2017-04-19T16:00

Internal controls are a key tool to operationalize your third party risk management program. Initially, a compliance practitioner should perform an analysis of any third party representative to pro...

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FCPA Compliance Report
FCPA Compliance Report-International Edition from 2017-04-19T12:52:58

In this episode I am joined by Ruth Steinholtz of AretéWork, Jonathan Armstrong of Cordery Compliance and Kristy Grant-Hart of Spark Compliance Consulting and author of How To Be a Wildly Effectiv...

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FCPA Compliance Report
Day 12 of One Month to Better 3rd Party Management from 2017-04-18T16:00

Next I consider at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force used by a company is third parties. A clear majority of Foreign Corr...

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FCPA Compliance Report
FCPA Compliance Report-Episode 323 from 2017-04-18T14:00

In this episode Compliance Week Editor in Chief Bill Coffin discusses the upcoming Compliance Week 2017 Conference May 22-24, 2017 in Washington DC. Coffin highlights the key note speakers and some...

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FCPA Compliance Report
Day 11 of One Month to Better 3rd Party Management from 2017-04-17T16:00

Auditing of third parties is critical to any best practices compliance program and an important tool in operationalizing your compliance program. This is a key manner in which a company can manage ...

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FCPA Compliance Report
This Week in FCPA-Episode 48 from 2017-04-14T18:05:57

In this episode, Matt Kelly pinch hits for a Walt Disney World-vacationing Jay Rosen. Matt and I have a wide-ranging discussion on some of the week’s top FCPA and compliance related stories. We dis...

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FCPA Compliance Report
Day 10 of One Month to Better Third Party Management from 2017-04-14T16:00

The building blocks of any Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program lay the foundations for a best practices compliance program. For instance in the lifecycle managem...

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FCPA Compliance Report
Day 9 of One Month to Better 3rd Party Management from 2017-04-13T16:00

In a speech before the SIFMA Compliance and Legal Society New York Regional Seminar in November 2015, then Assistant Attorney General Leslie Caldwell laid out metrics the Department of Justice woul...

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FCPA Compliance Report
Compliance into the Weeds-Episode 35 from 2017-04-12T14:00

In this episode Matt Kelly and I take a deep dive into the recently released, Public Company Accounting Oversight Board (PCAOB) semi-annual white paper. The white paper providing general informati...

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FCPA Compliance Report
Day 8 of One Month to Better 3Rd Party Management from 2017-04-12T12:44:05

What is satisfactory due diligence under the Foreign Corrupt Practices Act (FCPA)? That question seems to be more important after story on Unaoil and the subsequent release of the Panama Papers. Ho...

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FCPA Compliance Report
Day 7 of One Month to Better 3rd Party Management from 2017-04-11T16:00

The Justice Department Evaluation of Corporate Compliance Programs states in Prong 10, Appropriate Controls – What was the business rationale for the use of the third parties in question? What mech...

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FCPA Compliance Report
FCPA Compliance Report-Episode 322, Eric Feldman SVP of Affiliated Monitors from 2017-04-11T12:00

In this episode, I am joined by Eric Feldman, SVP at Affiliated Monitors. Eric is a long time US government employee who now helps to provide companies with monitorship services, in a wide range of...

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FCPA Compliance Report
Day 6 of One Month to Better 3rd Party Management from 2017-04-10T16:00

An important part of the job duties of any compliance practitioner is clearing red flags which might appear for a proposed third-party relationship during the due diligence process. It is mandatory...

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FCPA Compliance Report
This Week in FCPA-Episode 47 from 2017-04-07T19:54:54

Show Notes for Episode 47, for the week ending April 7, the Season Opener Edition In this episode, Jay and I have a wide-ranging discussion on some of the week’s top FCPA and compliance related st...

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FCPA Compliance Report
Day 5 of One Month to Better 3Rd Party Management from 2017-04-07T16:00

Yesterday I considered the need for due diligence in the management of third parties. Today, I want to take a deeper dive and explore the levels of due diligence. Due diligence is generally recogni...

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FCPA Compliance Report
Day 4 of One Month to a Better 3rd Party Management from 2017-04-06T16:00

Most companies fully understand the need to comply with the FCPA requirements around third parties as they represent the greatest risks for an FCPA violation. However, most companies are not create...

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FCPA Compliance Report
FCPA Compliance Report-Episode 321 from 2017-04-06T16:00

In this episode, I visit with Adelle Berger, who recently became the Chief Integrity Officer at Louis Berger. Some of the topics we discuss are: Why is her title “Chief Integrity Officer” as oppo...

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FCPA Compliance Report
Day 3 of One Month to a Better 3rd Party Management from 2017-04-05T16:00

The next step in the five-step process is the Questionnaire. The term ‘questionnaire’ is mentioned several times in the 2012 FCPA Guidance. It is generally recognized as one of the tools that a com...

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FCPA Compliance Report
Compliance into the Weeds-Episode 34 from 2017-04-05T14:00

In this episode Matt Kelly and I take a deep dive into the recent kerfuffle involving United Airlines and its policy which prevented to teenaged girls from boarding a flight wearing leggings. Was U...

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FCPA Compliance Report
Day 2 of One Month to Better 3rd Party Management from 2017-04-04T16:00

The Evaluation, in Prong 10, Third Part Management asks, “What was the business rationale for the use of the third party in question?” This question is one of the most basic tools to operationalize...

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FCPA Compliance Report
FCPA Compliance Report-Episode 320, John Hanson from 2017-04-04T12:00

In this episode I visit with John Hanson (AKA 'the Fraud Guy') who is also the founder of the International Association of Independent Corporate Monitors (IAICM). He discusses why he founded the gr...

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FCPA Compliance Report
Day 1 of One Month to Better Third Party Management from 2017-04-03T16:00

Day 1- The Third-Party Risk Management Process This month, I will consider the risk management of third parties in an operationalized compliance program. As every compliance practitioner is well a...

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FCPA Compliance Report
Day 23 of One Month to Operationalizing Your Compliance Program from 2017-03-31T16:00

I conclude my One Month to Operationalizing your Compliance Program series by discussing how you can put your compliance program at the center of corporate strategy. An article in the Harvard Busin...

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FCPA Compliance Report
This Week in FCPA-Episode 46 from 2017-03-31T15:01:16

Show Notes for Episode 46, for the week ending March 31, the On the Road to Prague Edition  In this episode, Jay and I have a wide-ranging discussion on operationalizing compliance through busines...

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FCPA Compliance Report
Day 22 of One Month to Operationalizing Your Compliance Program from 2017-03-30T16:00

The Evaluation of Corporate Compliance Programs, Prong 6, Incentives and Disciplinary Measures states:  Incentive System – How has the company incentivized compliance and ethical behavior? How has...

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FCPA Compliance Report
FCPA Compliance Report-Episode 319, Brandon Essig from 2017-03-30T14:00

In this episode I visit with Brandon Essig, a former DOJ prosecutor when the Yates Memo was released. He discusses the impact of the Yates Memo inside the DOJ and the triage that prosecutors use on...

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FCPA Compliance Report
Day 21 of One Month to Operationalizing Your Compliance Program from 2017-03-29T16:00

Even with a great Tone-At-the-Top and in the middle, you cannot stop. One of the greatest challenges of a compliance practitioner is how to affect the ‘tone at the bottom’. In an article in the Spr...

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FCPA Compliance Report
Day 20 of One Month to Operationalizing Your Compliance Program from 2017-03-28T16:00

The Evaluation of Corporate Compliance Programs makes clear, a company must have more than simply at good ‘Tone-at-the-Top’; it must move it down through the organization from senior management dow...

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FCPA Compliance Report
Compliance into the Weeds-Episode 33 from 2017-03-28T14:00

In this episode, we take a look at a recent speech given by NY Fed Chairman William Dudley in London where he addressed improving corporate culture. Dudley provided three recommended steps. First, ...

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FCPA Compliance Report
Day 19 of One Month to Operationalizing Your Compliance Program from 2017-03-27T16:00

Under the Evaluation of Corporate Compliance Programs, Prong 2, it states: Senior and Middle ManagementConduct at the Top – How have senior leaders, through their words and actions, encouraged or...

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FCPA Compliance Report
FCPA Compliance Report-Episode 318, Erica Salmon Byrne from 2017-03-27T14:00

In  this episode, I visit with Erica Salmon Bryne, EVP at Ethisphere on the 2017 World's Most Ethical Companies honorees. Erica goes into how the corporate compliance programs are evaluated, what t...

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FCPA Compliance Report
This Week in FCPA-Episode 45 from 2017-03-24T16:40:48

  In this episode, Jay and I have a wide-ranging discussion on why good compliance and is good for business. We discuss: LRN Ethics and Compliance Program Effectiveness Report. Click here for Repo...

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FCPA Compliance Report
Day 18 of One Month to Operationalizing Your Compliance Program from 2017-03-24T16:00

The Department of Justice Evaluation of Corporate Compliance Programs states, in Prong 10, Third Party Relationships:  Management of Relationships – How has the company considered and analyzed the...

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FCPA Compliance Report
Day 17 of One Month to Operationalizing Your Compliance Program from 2017-03-23T16:00

The Evaluation, in Prong 10, Third Part Management asks, “What was the business rationale for the use of the third party in question?” This question is one of the most basic tools to operationalize...

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FCPA Compliance Report
Everything Compliance-Episode 9 from 2017-03-23T12:00

This episode is dedicated to the Justice Department’s Evaluation of Corporate Compliance Programs, which was released in February. In this episode, Jay Rosen and Jonathan Armstrong provide next ins...

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FCPA Compliance Report
Day 16 of One Month to Operationalizing Your Compliance Program from 2017-03-22T16:00

From the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs:  Autonomy and Resources Stature – How has the compliance function compared with other strategic functions in th...

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FCPA Compliance Report
FCPA Compliance Report-Episode 317, Susan Diver from 2017-03-22T14:00

In this episode I visit with Susan Divers from LRN on the firm's 2016 Ethics and Compliance Program Effectiveness Report. Highlights include:Why did LRN do the report? What did it hope to determine...

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FCPA Compliance Report
Day 15 of One Month to Operationalizing Your Compliance Program from 2017-03-21T16:00

Prong 6, Training and Communication, of the Justice Department’s Evaluation of Corporate Compliance Programs reads, in part:  Form/Content/Effectiveness of Training – Has the training been offered...

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FCPA Compliance Report
FCPA Compliance Report-International Edition with Carlos Ayres from 2017-03-21T12:00

In this inaugural episode of the FCPA Compliance Report-International Edition, I have Carlos Ayres, a partner in Madea, Ayres and Sarubbi in Sao Paulo. We discuss an  interesting development from t...

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FCPA Compliance Report
Day 14 of One Month to Operationalizing Your Compliance Program from 2017-03-20T16:00

The Justice Department Evaluation of Corporate Compliance Programs states the following around training: Training and CommunicationsRisk-Based Training – What training have employees in relevant ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 316 Kristy Grant-Hart from 2017-03-20T12:00

In this episode Kristy Grant-Hart, author of How to be a Wildly Successful Compliance Officer joins me to debate the merits of the ISO 37001 certification. I think the process is worse than useless...

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FCPA Compliance Report
This Week in FCPA-Episode 44 from 2017-03-17T19:02:13

In this episode, Jay and I have a wide-ranging discussion on the intersection of culture and ethics. We discuss:  German authorities raid at VW investigation counsel, Jones Day, offices in German...

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FCPA Compliance Report
Day 13 of One Month to Operationalizing Your Compliance Program from 2017-03-17T16:00

Another way to operationalize compliance is to have oversight moved out into regions. Such an approach can more effectively ensure employee and third party compliance with your Code of Conduct thro...

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FCPA Compliance Report
Day 12 of One Month to Operationalization of Your Compliance Program from 2017-03-16T16:00

The operationalization of your compliance programs means how deeply is compliance integrated into the function of your company. Today, I want to consider another way to operationalize compliance th...

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FCPA Compliance Report
Everything Compliance-Episode 8 from 2017-03-16T14:00

This episode is dedicated to the Justice Department’s Evaluation of Corporate Compliance Programs, which was released in February. In this episode, Matt Kelly and Mike Volkov provide next insight. ...

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FCPA Compliance Report
Day 11 of One Month to Operationalization of Your Compliance Program from 2017-03-15T16:00

  Today I want to explore in some detail the first Objective in the COSO 2013 Framework-the Control Environment as a path to operationalize your compliance program. This Objective lays out five ste...

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FCPA Compliance Report
Compliance into the Weeds-Episode 32 from 2017-03-15T14:00

In this episode, Matt Kelly and I take a deep dive into a dramatic 48 hours in the life of the FCPA last week, which portends the trend of continued FCPA enforcement. It included the announcement b...

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FCPA Compliance Report
Day 10 of One Month to Operationalizing Your Compliance Program from 2017-03-14T16:00

Under the Prong entitled “Policies and Procedures” subtexted Operational Integration, the Evaluation states:  Payment Systems – How was the misconduct in question funded (e.g., purchase orders, em...

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FCPA Compliance Report
Day 9 of One Month to Operationalizing Your Compliance Program from 2017-03-13T16:00

  If there is one over-riding theme from the recently released Evaluation of Corporate Compliance programs it is that a corporate compliance program must be operationalized. Indeed that is the them...

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FCPA Compliance Report
FCPA Compliance Report-Episode 314, John Champion from 2017-03-13T14:00

In this episode, I have back John Champion, one-half of the podcast duo going through every Star Trek TV episode and movie at missionlogpodcast.com. Today, I visit with John on his reflections on t...

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FCPA Compliance Report
FCPA Compliance Report-Episose 315, James Koukios from 2017-03-12T22:06:31

In this episode, I visit with Morrison and Forrester partner James Koukios, on the firm's publication "Top Ten International Anti-Corruption Developments for January 2017.  Learn more about your ad...

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FCPA Compliance Report
This Week in FCPA-Episode 43 from 2017-03-10T21:08:51

In this episode, Jay Rosen reports live from the ABA White Collar Conference at the Fontainebleau Hotel in Miami.  In addition to providing his insights on the highlights of the conference and the ...

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FCPA Compliance Report
Day 8 of One Month to Operationalizing Your Compliance Program from 2017-03-10T17:00

Operationalizing your compliance program can take many shapes and forms. Using the entire risk management process to embed your compliance program within the contours of your organization is an imp...

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FCPA Compliance Report
Day 7 of One Month to Operationalizing Your Compliance Program from 2017-03-09T17:00

I continue my discussion of operationalizing your compliance program through the risk management process by considering risk-based monitoring. I continue this series based upon interviews with Ben ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 313, Adam Davidson from 2017-03-09T14:04:49

In this episode, I visit with New Yorker reporter Adam Davidson, who penned an article in the New Yorker which looked at a hotel deal between the Trump organization and a family of Politically Expo...

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FCPA Compliance Report
Day 6 of One Month to Operationalizing Your Compliance Program from 2017-03-08T17:00

The DOJ Evaluation of Corporate Compliance Programs states: Risk Management Process – What methodology has the company used to identify, analyze, and address the particular risks it faced?Informa...

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FCPA Compliance Report
Compliance into the Weeds-Episode 30 from 2017-03-08T15:00

The Justice Department Fraud Section recently revamped its website and it is quite an upgrade. I do not know when the Fraud Section did this update but as with the Evaluation of Corporate Complianc...

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FCPA Compliance Report
Day 5 of One Month to Operationalizing Your Compliance Program from 2017-03-07T17:00

At its heart, every business tries to plan for its future. It is a critical aspect of any management of any organization, non-profits, privately owned for profits and, of course, publicly traded co...

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FCPA Compliance Report
FCPA Compliance Report-Episode 312, Ben Locwin from 2017-03-07T15:00

In this Part III to a three part podcast series, I visit with noted risk management expert, Ben Locwin on risk-based monitoring as a adjunct to forecasting and risk assessments. We discuss how to a...

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FCPA Compliance Report
Day 4 of One Month to Operationalizing Your Compliance Programs from 2017-03-06T17:00

Analysis and Remediation of Underlying Misconduct Root Cause Analysis – What is the company’s root cause analysis of the misconduct at issue? What systemic issues were identified? Who in the comp...

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FCPA Compliance Report
This Week in FCPA-Episode 42 from 2017-03-03T22:16:37

Jay Rosen and I dedicate the entire episode to the FUBAR surrounding the Oscar ceremony where the Best Picture award was given to the wrong picture. We consider the control failures around the inci...

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FCPA Compliance Report
Day 3 of One Month to Operationalizing Your Compliance Program from 2017-03-03T17:00

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section in February. The document is an 11-pa...

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FCPA Compliance Report
Day 2 of 30 Days to Operationalize Your Compliance Program from 2017-03-02T17:00

The Evaluation, most generally, follows the DOJ and Securities and Exchange Commission’s (SEC) seminal Ten Hallmarks of an Effective Compliance Program, released in the 2012 FCPA Guidance. If there...

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FCPA Compliance Report
FCPA Compliance Report-Episode 311, Forrest Deegan from 2017-03-02T15:00

One event which promises to be most excellent is the upcoming Third-Party Risk Management&Oversight Summit, on March 20&21 at the Princeton Club in New York City. I will be attending and speaking a...

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FCPA Compliance Report
Day One of One Month to Operationalizing Your Compliance Program from 2017-03-01T17:00

Last month, the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of Corporate Compliance Programs” (Evaluation), on the Fraud Section website. The document is an 1...

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FCPA Compliance Report
Day 20 of One Month to a Better Board from 2017-02-28T17:00

I end my One Month to a Better Board series with a discussion from the recently released Justice Department Evaluation of Corporate Compliance Programs as it relates to a Board of Directors. In an ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 310 from 2017-02-28T15:50:08

This podcast considers the differences between forecasting and risk assessment is that risk assessment attempts to consider things which forecasting either did not reliably predict for, or those th...

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FCPA Compliance Report
Day 19 of One Month to a Better Board from 2017-02-27T19:31:15

There are three core areas upon which Directors should focus their attention regarding to help establish and maintain an effective compliance program. They are: (1) structure, (2) culture and (3) r...

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FCPA Compliance Report
Day 18 of One Month to a Better Board from 2017-02-24T17:00

Where does “Tone at the Top” start. With any public and most private US companies, it is at the Board of Directors. But what is the role of a company’s Board in FCPA compliance? We start with sever...

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FCPA Compliance Report
This Week in FCPA-Episode 41 from 2017-02-24T12:18:57

In this special live, on location episode, Jay Rosen and I discuss the recent SCCE 2017 Utilities and Energy Conference held in Washington DC. He hit on the highlights, topics, vendors and key note...

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FCPA Compliance Report
FCPA Compliance Report-James Koukios from 2017-02-23T17:00

In this episode I visit with Morrison Forrester partner James Koukios on the firm's December newsletter on the Top Ten International Anti-Corruption Developments for December 2016. James and I visi...

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FCPA Compliance Report
Day 17 of One Month to a Better Board from 2017-02-23T17:00

In this final five days of my One Month to a Better Board series, I will look at inquiries and questions a Board can take to help the organization actually do compliance going forward. I begin with...

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FCPA Compliance Report
FCPA Compliance Report-Ben Locwin from 2017-02-22T17:00

In this episode, I begin a three-podcast series on risk management in compliance with Ben Locwin, Director of Global R&D at BioGen and an operational strategist in pharma and healthcare, to explore...

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FCPA Compliance Report
Day 16 of One Month to a Better Board from 2017-02-22T17:00

Yesterday, I considered the Board of Director’s role in hiring of senior executives and in other key positions and corporate positions and corporate relationships. Today I want to consider the Boar...

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FCPA Compliance Report
Day 15 of One Month to a Better Board from 2017-02-21T17:00

What is the role of a Board of Directors in hiring senior executives, Chief Compliance Officers and even other Board members? I recently explored this issue with Candice Tal, founder and CEO of Inf...

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FCPA Compliance Report
Compliance into the Weeds-Episode 29 from 2017-02-21T13:00

In this episode, Matt Kelly and myself take a deep dive into the Department of Justice (DOJ) recent release, entitled “Evaluation of Corporate Compliance Programs” (Evaluation), which went up on th...

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FCPA Compliance Report
Day 14 of One Month to a Better Board from 2017-02-20T17:00

The bribery and corruption case of GlaxoSmithKline PLC (GSK) resonated across the corporate globe. While many questions are still unanswered, one that seems to be at the forefront of the inquiry wa...

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FCPA Compliance Report
Day 13 of One Month to a Better Board from 2017-02-17T17:00

Today I want to consider a couple of failures at the Board level around bribery and corruption.    VimpelCom Board of Directors and Senior Management Involvement  VimpelCom sought to enter the ...

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FCPA Compliance Report
Day 12 of One Month to a Better Board from 2017-02-16T17:00

What are metrics for a Board around compliance? Former Assistant Attorney General Leslie Caldwell laid out some that the Justice Department would consider in a review of compliance programs. These ...

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FCPA Compliance Report
Everything Compliance-Episode 7 from 2017-02-16T13:00

This episode is dedicated to the chaotic (at best) first three weeks of the Trump administration.  Jonathan Armstrong leads a discussion of the Trump administrations devolution towards Privacy Sh...

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FCPA Compliance Report
Day 11 of One Month to a Better Board from 2017-02-15T17:00

In an article in the Corporate Board magazine, entitled “Successful Board Investigations” by David Bayless and Tammy Albarrán, partners in the law firm of Covington&Burling LLP posited seven consid...

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FCPA Compliance Report
Day 10 of One Month to a Better Board from 2017-02-14T17:00

Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same r...

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FCPA Compliance Report
FCPA Compliance Report-Episode 306 from 2017-02-14T13:00

In this episode, I visit with Linda Lattimore, developer of Cross Sector law which assists lawyer and companies in developing expertise around corporate social responsibility.  Learn more about you...

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FCPA Compliance Report
Day 9 of One Month to a Better Board from 2017-02-13T17:00

One of the ongoing questions from members of Board of Directors is how to resolve the tension between oversight and managing. I recently had the opportunity to visit with Joe Howell, the Executive ...

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FCPA Compliance Report
Day 8 of One Month to a Better Board from 2017-02-10T17:00

James Doty, Acting Commissioner of the Public Company Accounting Oversight Board (PCAOB) was once asked if the Board or its sub-committee which handles audits was a part of a company’s internal fin...

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FCPA Compliance Report
Day 7 of One Month to a Better Board from 2017-02-09T17:00

The basic framework for internal controls is derived from the COSO Model developed by the Committee of Sponsoring Organizations of the Treadway Commission in 1992 (COSO). This model has become the ...

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FCPA Compliance Report
Compliance into the Weeds-Episode 27 from 2017-02-09T13:00

In this episode, Matt and I take a look at the sorry story of Chris Correa, the St. Louis Cardinal executive convicted of hacking into the Houston Astros computer system, which expanded last month ...

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FCPA Compliance Report
Day 6 of One Month to a Better Compliance Program from 2017-02-08T17:00

Where does “Tone at the Top” start. With any public and most private US companies, it is at the Board of Directors. But what is the role of a company’s Board in FCPA compliance? We start with sever...

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FCPA Compliance Report
Day 5 of One Month to a Better Board from 2017-02-07T17:00

The Office of Inspector General (OIG), Department of Health and Human Resources, issued a paper entitled “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (the OIG Guida...

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FCPA Compliance Report
Day 4 of One Month to a Better Board from 2017-02-06T17:00

Every Board of Directors need a true compliance expert sitting on their Board. Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar...

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FCPA Compliance Report
Day 3 of One Month to a Better Board from 2017-02-03T17:00

Under the US Sentencing Guidelines, the Board must exercise reasonable oversight on the effectiveness of a company’s compliance program. The US Department of Justice (DOJ) Prosecution Standards pos...

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FCPA Compliance Report
Day 2 of 30 Days to a Better Board from 2017-02-02T17:00

What are the obligations of a Board member regarding the FCPA? Are the obligations of the Compliance Committee under the FCPA at odds with a director’s “prudent discharge of duties to shareholders”...

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FCPA Compliance Report
Everything Compliance-Episode 6 from 2017-02-02T17:00

Show Notes for Episode 6, the Rolls-Royce Global Corruption Enforcement Action This episode is dedicated exclusively to the Rolls-Royce global corruption enforcement action. Jonathan Armstrong lea...

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FCPA Compliance Report
Day 1 of One Month to a Better Board from 2017-02-01T17:00

Case Law As to the specific role of ‘Best Practices’ in the area of general compliance and ethics, one can look to Delaware corporate law for guidance. The case of In Re Caremark International In...

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FCPA Compliance Report
Day 30 of 30 Days to a Better Compliance Program from 2017-01-31T17:00

John MacKessy, writing in the Finance Professionals’ Post, in a piece entitled “Knowledge of Good and Evil: A Brief History of Compliance”, noted that the FCPA and Environmental Protection Act (EPA...

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FCPA Compliance Report
Day 29 of 30 Days to a Better Compliance Program from 2017-01-30T17:00

Today is the penultimate day of my 30 days to a better compliance program. Just as compliance programs sprang up, grew and began to evolve and mature in the middle of the last decade; the sophistic...

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FCPA Compliance Report
Day 27 of 30 Days to a Better Compliance Program from 2017-01-28T17:00

Employment separations can be one of the trickiest maneuvers to manage in the spectrum of the employment relationship. Even when an employee is aware layoffs are coming it can still be quite a shoc...

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FCPA Compliance Report
Day 26 of 30 Days to a Better Compliance Program from 2017-01-27T17:00

As they made clear with several FCPA enforcement actions in 2016, the SEC has placed a renewed interest in the accounting provisions of the FCPA, specifically the internal controls provisions. The ...

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FCPA Compliance Report
Day 25 of 30 Days to a Better Compliance Program from 2017-01-26T17:00

Many Chief Compliance Officers (CCOs) and compliance practitioners struggle with metrics to demonstrate revenue generation. Most of the time, such functions are simply viewed as non-revenue generat...

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FCPA Compliance Report
Day 24 of 30 Days to a Better Compliance Program from 2017-01-25T17:00

Today, I the Holy Grail of compliance –Return on Investment—for your compliance program. In a very interesting article by Paul Healy and George Serafeim entitled, “An Analysis of Firms’ Self-Report...

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FCPA Compliance Report
Day 23 of 30 Days to a Better Compliance Program from 2017-01-24T17:00

I often write about the nuts and bolts of an effective compliance program but one of the most basic things that an effective compliance program must have is a compliance department present to ask t...

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FCPA Compliance Report
Day 19 of 30 Days to a Better Compliance Program from 2017-01-20T17:00

Every Board of Directors need a true compliance expert sitting on their Board. Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar...

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FCPA Compliance Report
FCPA Compliance Report-Episode 301, Jonathan Armstrong from 2017-01-19T19:22:38

In this episode I visit with Jonathan Armstrong about the UK portion of the Rolls-Royce global anti-corruption settlement. We discuss the UK Deferred Prosecution Agreement, how it came about, what ...

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FCPA Compliance Report
Day 18 of 30 Days to a Better Compliance Program from 2017-01-19T17:00

Continuous improvement requires that you not only audit third parties but also monitor whether employees are staying with the compliance program. In addition to the language set out in the FCPA Gui...

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FCPA Compliance Report
Everything Compliance-Episode 5 from 2017-01-19T15:22

Show Notes for Episode 5, Year End Review, Part II  We turn to the 2016 year in review, in this Part II of a two-part series.  Jonathan Armstrong leads a discussion on Privacy Shield, information ...

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FCPA Compliance Report
Day 17 of 30 Days to a Better Compliance Program from 2017-01-18T17:00

One of the more prescient authors I know is Ryan C. Hubbs, who in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. Shell companies can come in different shapes and sizes. Shelf com...

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FCPA Compliance Report
Compliance into the Weeds-Episode 25 from 2017-01-18T16:53:25

In this episode Matt Kelly and I take a deep dive into a couple of recent SEC enforcement actions. The first involved L-3 Technologies and accounting irregularities. The second involves BlackRock a...

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FCPA Compliance Report
Day 16 of 30 Days to a Better Compliance Program from 2017-01-17T17:00

Many compliance practitioners often inquire how to set up a data analysis program and how to use it to help monitor for a compliance program. I draw from Joe Oringel, co-founder of Visual Risk IQ f...

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FCPA Compliance Report
FCPA Compliance Report-Episode 300, Matt Ellis from 2017-01-17T13:00

In this episode, I visit with Matt Ellis, a partner at Miller&Chevalier. Ellis has recently published his first book The FCPA in Latin America. Ellis' discusses why he wrote the book, some of the k...

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FCPA Compliance Report
Day 15 of 30 Days to a Better Compliance Program from 2017-01-16T17:00

What if you want to take you post-training analysis to a higher level and begin to consider the effectiveness through your return on investment (ROI)? Joel Smith, the founder of Inhouse Owl, a trai...

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FCPA Compliance Report
Day 14 of 30 Days to a Better Compliance Program from 2017-01-15T14:15:45

For compliance training to be effective its needs to risk-based in its focus. This means employees with highest risk of exposure to bribery and corruption need to receive the highest levels of trai...

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FCPA Compliance Report
Day 13 of 30 Days to a Better Compliance Program from 2017-01-14T17:00

You should work to create an action plan to use your data. But never forget you need to get  your digital information right. That means several sources of data to help you choose the best course of...

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FCPA Compliance Report
This Week in FCPA-Episode 35 from 2017-01-14T02:15:54

Show Notes for Episode 35, week ending January 13, the Friday the 13th edition  Hernandez and Beech FCPA guilty pleas. Hernandez Criminal Information, Beech Criminal Information.VW guilty plea ...

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FCPA Compliance Report
Day 12 of 30 Days to a Better Compliance Program from 2017-01-13T17:00

You should work to create a culture of data in your compliance program. This comes from an understanding that data is a product, which you can consume internally in the compliance function. Your da...

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FCPA Compliance Report
Day 11 of 30 Days to a Better Compliance Program from 2017-01-12T17:00

You should employ a 6-step process to revising your Code of Conduct. Get buy-in from decision makers at the highest level of the companyYour company’s highest level must give the mandate for a re...

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FCPA Compliance Report
FCPA Compliance Report-Episode 299, Philip Urofsky from 2017-01-12T13:00

In this episode, I visit with Sherman&Sterling partner Phillip Urofsky who leads a team which produced the the 2017 FCPA Digest, one of the top annual compendium of annual FCPA reviews of the prior...

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FCPA Compliance Report
Compliance into the Weeds-Episode 24 from 2017-01-11T20:29:27

In this episode Matt Kelly and myself take a deep dive into the compliance weeds by looking at a paper written by then SEC General Counsel James Doty (later head of the PCAOB) in 2007 where he prop...

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FCPA Compliance Report
Day 10 of 30 Days to a Better Compliance Program from 2017-01-11T17:00

A company that does not perform adequate due diligence prior to a merger or acquisition may face both legal and business risks. Perhaps, most commonly, inadequate due diligence can allow a course o...

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FCPA Compliance Report
Day 9 of 30 Days to a Better Compliance Program from 2017-01-10T17:00

No area has become more challenging in compliance than continuous improvement. The FCPA Guidance specifies that “a good compliance program should constantly evolve. A company’s business changes ove...

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FCPA Compliance Report
FCPA Compliance Report-Episode 298, Leona Lewis from 2017-01-10T16:19:49

In this episode I visit with Leona Lewis, the founder and host of the podcast Masters of Disaster. She reflects on her experiences over the past 18 months of podcasting; what she learned, what surp...

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FCPA Compliance Report
Day 8 of 30 Days to a Better Compliance Program from 2017-01-09T17:00

The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should includ...

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FCPA Compliance Report
Day 7 of 30 Days to a Better Compliance Program from 2017-01-08T20:45:28

There are five steps in the life cycle of third party management. Business Justification and Business Sponsor;Questionnaire to Third Party; Due Diligence on Third Party;Compliance Terms and Cond...

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FCPA Compliance Report
30 Days to a Better Compliance Program-Day 6 from 2017-01-07T17:00

The FCPA Guidance states, that “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­...

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FCPA Compliance Report
This Week in FCPA-Episode 34 from 2017-01-07T16:31:19

In this episode Jay Rosen and I take a dive into the General Cable FCPA enforcement action, consider the 'Invisible Hand' of regulatory enforcement, corporate response and innovation. We explain ho...

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FCPA Compliance Report
30 Days to a Better Compliance Program-Day 5 from 2017-01-06T15:00

Welcome to Day 5 of 30 Days to a Better Compliance Program. Today, I focus on training, ongoing communications and the use of social media in a best practices compliance program.  TrainingThe comm...

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FCPA Compliance Report
30 Days to a Better Compliance Program-Day 4 from 2017-01-05T15:00

Welcome to Day 4 of 30 Days to a Better Compliance Program. Today we tackle risk assessments. One cannot really say enough about risk assessments in the context of anti-corruption programs. The FCP...

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FCPA Compliance Report
Compliance into the Weeds-Episode 23 from 2017-01-05T13:00

In this episode Matt Kelly and I take a deep dive into 6 compliance issues you should keep an eye on in 2017. They include the Wal-Mart FCPA resolution, the future of the FCPA Pilot Program, the SE...

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FCPA Compliance Report
30 Days to a Better Compliance Program-Day 3 from 2017-01-04T15:00

Welcome to Day 3 of 30 Days to a Better Compliance Program. Today I want to consider the Chief Compliance Officer (CCO) in your organization, through three prisms: access, resources and opportuniti...

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FCPA Compliance Report
Everything Compliance-Episode 4 from 2017-01-04T13:00

Show Notes for Episode 4, Year End Review, Part I  We turn to the 2016 year in review, in this Part I of a two-part series.   Jonathan Armstrong leads a discussion on a very interesting UK Bribery...

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FCPA Compliance Report
30 Days to a Better Compliance Program-Day 2 from 2017-01-03T15:00

Welcome to Day 2 of 30 Days to a Better Compliance Program. Today I consider written protocols, which are the foundation upon which an effective compliance program is built. Written protocols consi...

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FCPA Compliance Report
FCPA Compliance Report-Episode 297 from 2017-01-03T13:00

In this episode Mike Volkov and I take a look at the most significant enforcement actions from 2016, the most significant compliance related issues from 2016 and the issues and cases that may be th...

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FCPA Compliance Report
30 Days to a Better Compliance Program-Day 1 from 2017-01-02T15:00

Welcome to Day 1 of 30 days to a better compliance program. Together with a podcast each day, I will be giving you tip to help you create a best practices compliance program in 2017. At the end of ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 296 from 2016-12-29T18:16:05

In this episode Mike Volkov and myself take a deep dive into the Odebrecht/Braskem and Teva FCPA enforcement actions. We review the underlying facts, the conduct of the parties, the results obtaine...

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FCPA Compliance Report
This Week in FCPA-Episode 33 from 2016-12-23T17:09:15

Show Notes for Episode 33, week ending December 23, 2016-Holiday edition Odebrecht/Braskem FCPA enforcement action. Braskem Information, Braskem Plea Agreement, Odebrecht Information, Odebrecht P...

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FCPA Compliance Report
FCPA Compliance Report-Episode 295, Juliet Lui from 2016-12-21T13:00

In this episode I visit with Juliet Lui as we discuss how to best handle small and medium investigations in an efficient and cost effective manner. We discuss how such matters often slip through th...

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FCPA Compliance Report
Unfair and Unbalanced-Episode 14 from 2016-12-21T13:00

In this episode SCCE CEO Roy Snell and I continue are exploration of issues of import to the compliance profession. We consider the penalty assessed by the NCAA on Notre Dame for it use of two inel...

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FCPA Compliance Report
Unfair and Unbalanced-Episode 13 from 2016-12-15T13:00

In this episode SCCE CEO Roy Snell and I take a deep dive into corporate governance and compliance, the public skewering of former Wells Fargo CEO John Stumpf and ask if a CEO should be involved in...

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FCPA Compliance Report
Compliance into the Weeds-Episode 22 from 2016-12-14T13:00

In this episode Matt Kelly and I take deep dive into the United Airlines SEC enforcement action for violation of internal controls around its reinstitution of a route from Newark to South Carolina ...

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FCPA Compliance Report
FCPA Compliance Report-Episode 294-Chris Tomlinson from 2016-12-13T13:00

In this episode, I visit with Houston Chronicle business columnist Chris Tomlinson about his time working internationally for the Associated Press. He relates his first hand view of the invidiousne...

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FCPA Compliance Report
This Week in FCPA-Episode 32 from 2016-12-09T22:21:23

Show Notes for Episode 32, week ending December 9, 2016-the Fly the Not So Friendly Skies edition:  United Airlines SEC enforcement action for domestic; the Chairman’s Flight and the US Corrupt P...

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FCPA Compliance Report
Everything Compliance-Episode 3 from 2016-12-08T13:00

We are back to our more rounded format for this episode on a variety of topics including anti-corruption enforcement across the globe, the new French anti-corruption law, Sapin II, the Agricultural...

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FCPA Compliance Report
FCPA Compliance Report-Episode 292 from 2016-11-29T17:00

Show Notes Introduction What is the FARWhat’s the differences with DFARs What types of companies should be concernedWhat are some examples of covered with these regs (eg. Ozone depleting substa...

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FCPA Compliance Report
Everything Compliance-Episode 2 from 2016-11-21T13:00

This episode is dedicated exclusively to where FCPA enforcement, SEC enforcement, the compliance profession and compliance programs may be headed under the Trump administration, with a dash of anti...

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FCPA Compliance Report
Everything Compliance-Episode 1 from 2016-11-10T12:00

Show Notes for Episode 1 At the SCCE 2016 Compliance and Ethics Institute, I sat down with four of the top compliance commentators in the field for my first roundtable-style podcast. It was so suc...

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FCPA Compliance Report
Episode 276-Regulator Evolution from 2016-09-10T17:10:25

In this episode I welcome back Red Flag Group CEO Scott Lane. We discuss the evolution of regulator thinking around what constitutes a best practices compliance program.  Learn more about your ad c...

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FCPA Compliance Report
Episode 275-Key Energy Enforcement Action from 2016-09-10T16:59:53

In this episode, I take a deep dive into the Key Energy FCPA enforcement action. Learn more about your ad choices. Visit megaphone.fm/adchoices

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FCPA Compliance Report
Episode 274-Holistic Approach to 3rd Party Management from 2016-09-10T16:50:20

In this episode, Red Flag Group CEO Scott Lane and myself discuss the evolution of regulators when evaluating compliance programs for effectiveness. Learn more about your ad choices. Visit megaphon...

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FCPA Compliance Report
Hallmark 10 from 2016-09-10T16:43:25

In this episode I review Hallmark 10-Mergers and Acquisitions: Pre-Acquisition Due Diligence and Post-Acquisition Integration under the FCPA. To read more, check out my blog post series on Hallmar...

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FCPA Compliance Report
Series on the Ten Hallmarks of an Effective Compliance Program from 2016-09-10T16:37:59

In this episode I review Hallmark 9 - Continuous Improvement: Periodic Testing and Review. This podcast series is produced in a 10 article series. To read more, check out my blog post series on Ha...

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FCPA Compliance Report
Series on the Ten Hallmarks of an Effective Compliance Program from 2016-09-10T16:37:59

In this episode I review Hallmark 9 - Continuous Improvement: Periodic Testing and Review. This podcast series is produced in a 10 article series. To read more, check out my blog post series on Ha...

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FCPA Compliance Report
Series on the Ten Hallmarks of an Effective Compliance Program from 2016-09-10T16:37:59

In this episode I review Hallmark 9 - Continuous Improvement: Periodic Testing and Review. This podcast series is produced in a 10 article series. To read more, check out my blog post series on Ha...

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