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FCPA Compliance Report

Tom Fox has practiced law in Houston for 30 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
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Nov 30, 2018

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 cooperation and some of the week’s other top compliance and ethics stories.

  1. DOJ/SEC reaffirm importance of FCPA prosecutions. Christopher Cole reports on regulators remarks at ACI National FCPA Conference in Law360. Going in another direction, Deputy Attorney General John Cronan discusses the importance of the public private partnership in fighting bribery and corruption. Matt Kelly reports on his speech by on Radical Compliance. For full text of speech, see here. Finally Rod Rosenstein announces cut backs to the Yates Memo in a speech.
  2. Facebook woes continue as a cache of its internal documents end up in Britain’s House of Commons immediately before a hearing. Adam Satariano reports in the New York Times. The hearing is held with an empty chair for Mark Zuckerburg who was too busy to drop by. Tom and Jonathan Armstrong have their first emergency podcast on Life with GDPR to explain it all.
  3. How do you establish pace and scope in a SEC investigation? Dan Portnov explains in Grand Jury Target.
  4. FIFA Judge Balks At $116M Restitution Bids In Bribery Case. Stewart Bishop reports in Law360.
  5. Russia’s largest telecom company, MTS reserves $840MM for FCPA resolution. Harry Cassin reports in the FCPA Blog.
  6. Former Venezuelan National Treasurer, Alejandro Andrade sentenced to 10 years in prison for money laundering in accepting over $1bn in bribes. Harry Cassin reports in the FCPA Blog. Sam Rubenfeld reports in the WSJ Risk & Compliance Journal.
  7. What is the role of the human element in internal controls. Tom Gorman explores this interesting issue in SEC Actions.
  8. 11 Latin American laws firms join forces to create a template for best practices in an anti-corruption investigation. Melissa Van Brunnersum reports.
  9. In Houston over the next couple of weeks? Tom will be speaking at the December meeting of the ACFE Houston Chapter on December 11 and leading meetings of the Houston Compliance Roundtable, the midtown group meets at Rowan Drilling on December 12 and the Woodlands group meets on December 13 at Nexio. For information on the Roundtables, contact Tom. To register for the ACFE Houston Chapter event, click here.
  10. Interested in learning some compliance lessons through travel and history? Check out Tom’s 5-part podcast series of compliance lessons from Venice. Part I-Doing Compliance the Old-Fashioned Way; Part II-the Arsenale and Incentives in Compliance; Part III-Selfie Sticks and Risk Assessments; Part IV-the Venetian Gondolier; Part V-Into the Lion’s Mouth. All podcasts are also available on iTunes, JDSupra, YouTubeand Libsyn.

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.

Nov 30, 2018

NOVEMBER 30, 2018 BY TOM FOX

In today’s edition of Daily Compliance News:

  • Deutsche Bank Offices raided in AML investigation. (New York Times)
  • Danske Bank hit with criminal charges.(The Local Denmark)
  • Head of Tenaris Drilling indicted for bribery and corruption in Argentina. (Reuters)
  • South African Parliament accuses McKinsey of possible “criminal wrongdoing” in its work for Gupta-family controlled entity Trillion. (Financial Times)
Nov 29, 2018

In this episode I visit with Jonathan Armstrong on the topic of class action lawsuits involving data privacy and GDPR. Some of the highlights are:

  1. Key differences in UK/EU and US class actions.
  2. We take a deep dive in to the Morrisons data breach.
  3. Why Data Privacy Impact Assessments are critical for companies and their vendors.
  4. How risks can change and be modified during the term of an employee’s work life?
  5. What is the state of class action litigation in the EU?
  6. What does all of this mean for US companies, trying to get data out of the UK and EU?

For more information on Cordery Compliance, go their website here. Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.

Nov 29, 2018

NOVEMBER 29, 2018 BY TOM FOX

In today’s edition of Daily Compliance News:

  • Chi Ping Patrick Ho corruption trial begins. (Courthouse News)
  • Too late for a last minute Christmas present as time expires to bid on the Jho Low $250MM yacht.(Bloomberg)
  • Senate is expected to confirm Kathy Kraninger as head of CFPB. (MarketWatch)
  • Did Les Moonves try to bury an allegation of sexual assault? (NYT)
Nov 28, 2018

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 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 standard FCPA case. It provides some new lessons learned for the compliance professional (and some old ones as well). 

 

Some of the highlights from this podcast are:

  1. What were the unusual facts of this matter?
  2. What is the role of a Board member who is also a supplier to a company?
  3. What were the key lessons learned for the compliance practitioner?

 

For more see Matt’s blog post SEC Dings Vantage  $5M on FCPA Issues and see Tom’s blog post, The Vantage Drilling FCPA Enforcement Action.

Nov 28, 2018

In today’s edition of Daily Compliance News:

  • UK Parliament to release Facebook documents. (New York Times)
  • Former Venezuelan National Treasury Minister sentenced to 10 for corruption.(DOJ Press Release)
  • SFO obtains one guilty verdicts, 3 guilty pleas and sustains 3 acquittals in FH Bertling corruption trial? (Wall Street Journal)
  • NPR announces its best reads for 2018. How many have you read? (NPR)
Nov 27, 2018

NOVEMBER 27, 2018 BY TOM FOX

In today’s edition of Daily Compliance News: 

  • UK Parliament gets confidential Facebook documents. How weird is that? (TheVerge)
  • Lavish spending can get CEOs into trouble.(Wall Street Journal)
  • 22 warrants for arrests issued in Brazil related to corruption at Petrobras? (Associated Press)
  • Was Shell/ENI production deal in Nigeria facilitated by corruption? (BBC)
Nov 26, 2018

In this podcast series, I am reporting on compliance through the prism of the city of Venice. One of the things that has fascinated me about Venice is how so little of the 21st century has impacted it. Take construction for example. All materials have to be brought to the city via boat, off-loaded and then lifted by hand or by a handmade machine to the upper stories of a building where the residences are located as no one lives on the ground floor. If the building is on the water, the ground floor is now underwater. If the building is not on the water, the ground floor is used for a commercial establishment. But unlike other large metropolitan areas, there is no room for cranes or other large mechanical lifting devices. I thought about this today when I saw workmen lifting up materials through a block and tackle pulley system which has been in use since antiquity. Not only were these guys doing it the old fashioned way, they were getting the job done.

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 the basic questions of compliance to and receive an answer from. First, and foremost, there must be the requisite number of resources dedicated to the compliance function. This means that a compliance department must be staffed with an appropriate number of compliance professionals to do the day-to-day basic work of compliance. Head count is always important in any corporation but there must be some minimum number of people in the compliance department to answer the phone or respond to email.

In other words, if someone calls, not only does a compliance person have to be there, someone has to pick up the phone. How many times has a compliance department been called on a Friday afternoon to find that no one is there to answer the phone? But if someone is there, they have to actually pick up the phone and provide an answer. Mike Volkov often inveigles against the compliance function being “The Land of No” starring CCO’s as Dr. No; but the situation I am discussing is where a compliance department does not or will not provide the basic answers to a person working out in the field.

Sometimes the most basic and the most obvious is overlooked. Using an old block and tackle pulley to haul up building materials by hand may seem quaint and old fashioned, and perhaps it is, but it still gets the job done. The same concepts are a part of a best practices compliance program; someone must be around the answer the phone when it rings on Friday afternoon and that person who is around must pick up the phone and provide some answers to the question(s) posed.

Nov 26, 2018

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 one of the main commercial enterprises of the city took place, that being ship building and ship repair. At one point, the Arsenale employed almost 10% of the city’s workforce or 12,000 people. This was in the mid 1200s to the 1400s when Venice was at or near the height of its trading and financial power. The Arsenale developed the first production line for the building of ships, when, of course, it was all done by hand. The equipment developed to drag ships up on shore and repair was simply amazing. Appropriately, the Arsenale is now an Italian and NATO naval facility. 

But I also picked up some interesting compliance insights in learning more about the Arsenale. On the incentive side there were several mechanisms the City of Venice used to help make the Arsenale work force more loyal and desirous to stay in their jobs, all for the betterment of themselves and their city. The first was job security. The Arsenalewas so busy for so many years that lay-offs were unheard of. Even if someone lost their job, through injury, mishap or worse; they received enough of compensation that they could live in the city. Finally, when a worker died, the company provided not only funeral expenses but would assist in taking care of the family through stipends or finding other work for family members.

The 2012 FCPA Guidance is clear that there should be incentives for not only following your own company’s internal Code of Conduct but also doing business the right way, i.e. not engaging in bribery and corruption. The incentives can be burned into the DNA of a company through the hiring and promotion processes. There should be a compliance component to all senior management hires and promotions up to those august ranks within a company. Your Human Resources function can be a great aid to your cause in driving the right type of behavior through the design and implementation of such structures. 

Just as the fathers of Venice viewed the workers of the Arsenale as critical to the well-being of their city, senior managers need to understand the same about their work force. The City of Venice long ago showed how such incentives could help it maintain a commercial advantage. Fortunately the DOJ and SEC still understand those valuable lessons and continue to talk about them as well.

Nov 26, 2018

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. 

One of the first things I noticed in Venice was the large number of selfie-sticks and their use by (obviously) tourists. But the thing that struck me was the street vendors who previously sold all manner of knock-off and counterfeit purses, wallets and otherwise fake leather goods had now moved exclusively to market these selfie-sticks. Clearly these street vendors were responding to a market need and have moved quickly to fill this niche. 

While the economics, inventory, bureaucracy, market-responsiveness of such businesses may be a bit more nimble than the more traditional US entity doing business overseas it does bring up a very good lesson for the compliance practitioner. A risk assessment is a tool for a variety of purposes. Certainly moving into a new geographic area is an important reason to perform a risk assessment. However, it can also be used for a new product offering, such as a selfie-stick. 

What about continued quality control of your new product? If you are in the food product industry this will mean continued inspections of your products to assure they meet government standards. Make sure that you have a hiring process in place to weed out the wives, sons or daughters of any food service inspectors. Of course, do not hire such inspectors for jobs directly either, especially if they do not have to show up or perform any duties to get paid by your company. 

If you are not going to manufacture your selfie-stick equivalent in the country where these new products will be sold, how will you import them? Who will be interfacing with the foreign government on tax issues for importing of products? Will they be there permanently or on a temporary basis? All questions that have gotten US companies into FCPA trouble when they paid bribes to answer, assuage or grease some or all of the answers. 

It turns out the compliance practitioner can learn quite a bit from the selfie-stick; not all of it is simple self-indulgence. Your compliance program must respond to your business initiatives. To do so, you also need to have a seat that the big boy table where such initiatives are discussed. But that is another lesson from Venice for a different day. Until then, ciao.

Nov 26, 2018

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 for a fabled and romantic gondola ride. One thing I notice about the Gondolierthat in addition to having a stout pairs of lungs, they are almost all in very good physical condition. They have to be piloting this very old craft by hand in and around the crowded waters of Venice.

I thought about this as a metaphor for improving your compliance program. As a CCO or compliance practitioner, the more you can get out of the office, into the field and meet the troops the more fit your compliance program will be. Any best practices compliance program should have input from the geographies, cultures, business units and corporate functions within the company. It is well understood that a compliance procedure that works well in the US may not work in Indonesia.

Compliance is about people and that means it is about relationships. But perhaps more importantly, is the development of personal relationships. If you meet with your international sales team, my corporate experience is that they will appreciate that you took the effort to travel to train them or meet with them. They are also more likely to tell you things in persons than they would via email or over the phone. One of the criticisms of anonymous hotlines and other internal reporting mechanisms is this lack of the personal experience that can lead to mis-trust if not distrust. Getting out into the field and meeting folks can go a long way to overcome this frailty of human nature.

Finally, by getting out of the office and working directly with other company personnel, you can set expectations appropriately. This is true for the compliance practitioner whether you are dealing with third party vendors in the Supply Chain, agents and other foreign business representatives, your employee base, senior management or the Board of Directors. You must set the expectation that if something occurs that materially impacts these expectations. By properly managing the expectations of the company’s compliance group with the relationships that you have established in the company, you will make the doing of compliance less stressful for all involved.

My observation that Gondolierstend to be physically fit ties directly to the job they have to do, propelling a gondola. Yet as a CCO or compliance practitioner you can get out of the office and make your compliance program more robust and get it in better shape.  

Nov 26, 2018

This episode concludes my podcast series on how the city of Venice informs your compliance program. Today we consider the internal reporting system the Republic of Venice employed and how it continues to inform your best practices compliance program.  

The symbol of Venice is the Lion of St. Mark. The use of this symbol led to the maxim ‘straight from the lion’s mouth’. This adage came about because the Republic of Venice had its own internal reporting system where citizens could report misconduct. A citizen could write down his concern on paper and literally put the message into the mouth of statues of lion heads placed around the City. This system was originally set up to be anonymous but later changed to require that a citizen had to write his name down when submitting a message.

So, once again, using Venice as inspiration for a compliance topic, I would like to review some best practices regarding a best practices internal reporting system.

Get the word out.Allocate a portion of your time and budget to promoting the corporate hotline through multiple channels. Deliver in-person presentations where possible. Do not think of the promotional initiative as a one-time effort. It is important to remind employees regularly, through in-person communications, via e-mail, or through intranets, newsletters, and so on, that this resource is available to them.

Train all your employees. Getting employees to use the system is one half of the challenge; ensuring they use it properly is the other half. This is where training becomes essential. Make sure people understand what types of activities or observations are appropriate for reporting and which are not. Company leaders also need to understand the role the hotline plays in the organizational culture, and the importance of their visible support for this compliance initiative.

Take a look at the data. Use the data derived from or through the hotline to identify unexpected trends or issues. Isolate the data by location and department to identify micro-trends that could indicate problems within a subset of your corporate culture. Analyzing the data can help you stay a step ahead of emerging issues.

Response is critical to fairness in the system. Seeing a hotline system in action in this way can go a long way toward dispelling employee fears of being ostracized or experiencing retaliation because if they see that their concerns are heard clearly and addressed fairly, they will learn to view the hotline as a valuable conduit. If your compliance group responds promptly and appropriately to hotline complaints, you can ensure robust participation and ongoing success.

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 that the US Founding Fathers drew from to helping to establish a world-wide trade and banking system which still reverberates today. But, if you look closer, ancient Venice had many good government techniques which also still inform the modern world. Straight from the lion’s mouth to your company’s internal reporting system is just one of them.

Nov 26, 2018

The FCPA Compliance Report is the longest running podcast in compliance. 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 hackers, phisher and all manner of nefarious actors who will endeavor to hack into you corporate site.  

In this podcast we discuss: 

  1. What is social engineering the context of data protection?
  2. How the front line of all defenses for a corporation to prevent a data breach is its employees.
  3. What are they types of data protection training, communications and reminders you should be providing to your employees.
  4. What are some of the key lessons learned from recent corporate data breaches?
  5. In this era of digital communications do not forget the human element to ask questions.
  6. A minimum of controls can go a long way toward a strong front line of data protection. 

Check out Brad Davis and the EverSolve website by clicking here.  

Nov 26, 2018

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 through its subpoena of an American executive of the US company Six4Three. This exec just happened to be in London with Facebook documents his company had obtained in unrelated litigation between Six4Three and Facebook. We present the Facebook Files and some of the highlights are: 

  1. How did the chair of the DCMS Committee find out this exec was in the UK and had these Facebook documents?
  2. The documents are under seal by a court in California. Does that have any impact on the UK Parliament’s right to review and release the documents?
  3. Why did the Six4Three exec travel to London with the Facebook documents?
  4. What is the UK Parliamentary Privilege and how does it apply here?
  5. Given the black eye Facebook took in the US last week, will they continue to step in it in the UK as well?
  6. Could you make up a weirder set of facts?

For more information on the background facts, see article by Andrew Liptak in Verge.

The DCMS Committee will live stream its hearing on Tuesday, November 27. You can check it out here.

Nov 26, 2018

In today’s edition of Daily Compliance News:

  • Will corrupt President by brought down by investigations? (in Czech Republic). (New York Times)
  • How is prosecuting war criminals inform compliance? Have lunch with the FT and Louise Arbour to find out.(Financial Times)
  • How much should companies use AI into employee background investigations? (Washington Post)
  • Want to accomplish something in your meetings? Try planning. (Houston Business Journal)
Nov 23, 2018

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. 

  1. Vantage Drilling settles FCPA enforcement action. Sam Rubenfeld reports in the Wall Street Journal Risk & Compliance Journal. Harry Cassin reports in the FCPA Blog. Matt Kelly takes a swing in Radical Compliance.
  2. Facebook admits it hired oppo research firm to dig up dirt on opponents. What’t next?  Jack Nicas reports in the New York Times. Facebook give a mea culpaafter denying everything in a Press Release.
  3. What is an ‘ethical bricolage’? John Rausch explains in his Dipping Through Geomotries
  4. French bank Société Générale SA agreed to pay $1.34 billion in penalties for sanctions violations but claims its compliance program is now first rate. Dick Cassin reports on the former in the FCPA Blog. Sam Rubenfeld and Mengqi Sun report on the latter in WSJ Risk & Compliance Journal.
  5. Think things can't get worse for Goldman, think again. Emily Flitter, Matthew Goldstein and Kate Kelly report in the New York Times.
  6. What is the intersection of behavioral sciences and compliance? Mike Volkov considers in Corruption, Crime and Compliance.
  7. Should the President or anyone else answer written questions from prosecutors? Sara Kropf weighs in on Grand Jury Target.
  8. Danske Bank whistleblower reveals money-laundering ties to Deutsche Bank, Bank of America and JPMorgan. Kayleena Makortoff reports in The Guardian.
  9. SEC Whistleblower program has record year. So why does SEC want to cut back on the program. Mengi Sun reports in the WSJ Risk and Compliance Journal.
  10. Nissan Chairman arrested, removed from Board and fired. All in 48 hours. Motoko Rich reports in the New York Times.

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.

Nov 23, 2018

In today’s edition of Daily Compliance News:

  • Think things can’t get worse for Goldman, think again. (New York Times)
  • First ever Pentagon audit finds bureaucratic ‘non-compliance’.(Washington Post)
  • In its Happy Thanksgiving message, Facebook admits to using Oppo research against detractors. (New York Times)
  • In some good news, NY branch of Standard Chartered will end corporate monitorship at end of this year. (The Guardian)
Nov 23, 2018

In today’s edition of Daily Compliance News:

  • Think things can’t get worse for Goldman, think again. (New York Times)
  • First ever Pentagon audit finds bureaucratic ‘non-compliance’.(Washington Post)
  • In its Happy Thanksgiving message, Facebook admits to using Oppo research against detractors. (New York Times)
  • In some good news, NY branch of Standard Chartered will end corporate monitorship at end of this year. (The Guardian)
Nov 21, 2018

In today’s edition of Daily Compliance News:

  • Vantage Drilling settles FCPA charges. (SEC Press Release)
  • Phishing for executives and the SEC.(FCPA Blog)
  • FT Editorial Board warns against high-flying CEO hubris (again). (Financial Times)
  • Danske Bank whistleblower reveals money-laundering ties to Deutsche Bank, Bank of America and JPMorgan. (The Guardian)
Nov 20, 2018

NOVEMBER 20, 2018 BY TOM FOX

In today’s edition of Daily Compliance News:

Nov 19, 2018

In today’s edition of Daily Compliance News:

  • Very strange deaths surround allegations of bribery and Odebrecht in Colombia. (Wall Street Journal)
  • Why do employees cut corners and what does it mean for compliance.(Fast Times)
  • The reputational damage to Facebook from the NYT exposé continues. (New York Times)
  • Can you do business when a culture is corrupt? GE is about to find out when selling turbines into Iraq. (Wall Street Journal)
Nov 16, 2018

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. 

  1. Why Goldman’s ‘tick the box’ compliance program not good enough. FT editorial board. sub req’d What are 4 questions the DOJ is likely to ask and what are 4 areas of inquiry under the FCPA Corporate Enforcement. Tom explores in Part Iand Part II. Mike Volkov asks ‘what about respondent superior’?; in his blog Crime, Corruption and Compliance. Richard Bistrong explained what happened during his guilty plea hearing for his FCPA criminal action, in the FCPA Blog.  
  2. Richard Bistrong explained what happened during his guilty plea hearing for his FCPA criminal action, in the FCPA Blog.
  3. How can ISO 37001 be fixed? Joe Murphy lists 44 ways on the FCPA Blog.
  4. MoneyGram spanked again as it’s DPA is extended. John Rausch reports in his Dipping Through Geomotries
  5. Tesla names new Board Chair. Will she be able to rein in Elon Musk? Tom Krisher reports in the Washington Post.
  6. Has your company assess the impact of Brexit? If not, the SEC says you should do so. Tatyana Shumsky reports in the WSJ Risk & Compliance Journal.
  7. Why 2019 may well be a challenging year for internal audit. Rafael Go and Leslee McKnight write in Corporate Compliance Insights.
  8. Are companies meeting their human rights requirements? Sam Rubenfeld explores in WSJ Risk & Compliance Journal.
  9. What is the business impact of bribery and corruption in Venezuela? Chevron weighs pulling out. Kejal Vyas and Bradley Olson report in the WSJ.
  10. Chuck Duross says cutting back on compliance programs would be both short-sighted and foolish. Adam Dobrik reports in GIR.
  11. How has GDPR impacted M&A deals? Nina Trentmann reports in the WSJ Risk & Compliance Journal.
  12. In a sponsored podcast, Tom visits with Vin DiCianni and Eric Feldman of Affiliated Monitors on the impact of culture, compliance and monitoring for non-US companies in countries outside the US. Part I-Introduction, Part II-International Enforcement Trends, Part III-Spain, Part IV-Development of Monnitoring in International Enforcement and Part V-International Challenges for Monitors. 

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.

Nov 16, 2018

NOVEMBER 16, 2018 BY TOM FOX

In today’s edition of Daily Compliance News:

Nov 15, 2018

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 Spares Corporate Wrongdoers Billions in Penalties”. Each panelist considers the piece and its underlying principals from their own perspective. 

  1. Jonathan Armstrong considers whether or not the US is losing its role as the global anti-corruption policeman? If it is, will another country step up to take its place? Jonathan rants about UK politicians meddling in UK criminal prosecutions and criminal procedure.
  1. Mike Volkov considers what, if anything does the article tell you about DOJ enforcement priorities? How do priorities change from administration to administration? What does that mean for line and career prosecutors? Mike gives a shout out to US voters who turned out in record numbers in the recent mid-term elections.
  1. Matt Kelly considers the enforcement angle from the SEC or other regulatory bodies notably the Federal Reserve and Office of the Currency. Matt give a very large tip of the hat in his shout out to shareholder activist extraordinaire Evelyn Davis who recently passed away.
  1. Jay Rosen who works as a vendor during in the ethics and compliance space, considers the article from his perspective. He explores such questions as are companies spending less because of enforcement or is corporate compliance is as robust as ever? Jay has a heavy heart this week in remembering the victims of the massacres at the Tree of Life Synagogue in Pittsburg and the Borderline Bar & Grill in Thousand Oaks, CA.

For additional reading see the following from Cordery Compliance:

http://www.corderycompliance.com/client-alert-rolls-royce-case-sends-a-strong-signal/

http://www.corderycompliance.com/new-sfo-director-assumes-office-2-2/

http://www.corderycompliance.com/brexit-and-compliance-2/

http://www.corderycompliance.com/client-alert-skansen-linked-executives-jailed-for-bribery-in-uk/

The members of the Everything Compliance panelist are:

  • Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com
  • Mike Volkov– One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com.
  • Matt Kelly– Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com
  • Jonathan Armstrong– Rounding out the panel is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com

The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network.

Nov 15, 2018

NOVEMBER 15, 2018 BY TOM FOX

In today’s edition of Daily Compliance News:

  • How has GDPR impacted M&A deals? (Wall Street Journal)
  • AstroBall nominated as one of the best business books of 2018.(Amazon)
  • What is a public spanking? Goldman Sachs finds out as the FT Editorial Page calls out its check the box compliance function. (Financial Times)
  • Why cutting back on compliance programs would be short-sighted and foolish. (GIR)
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