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 business processes. We discuss: 

1. Why powerful people fail to stop bad behavior by their underlings. Click here for the article.
2. Some policy management lesson, courtesy United Airlines. Click here for Matt Kelly’s article on Radical Compliance.
3. Why you shouldn’t linger too long in the wrong compliance position. See Julie DiMauro’s blog post on the FCPA Blog.
4. Bribe recipient in the Gerald and Patricia Green FCPA case gets 50 years in prison. See article in the FCPA Blog.
5. Using data to operationalize your compliance program. Read Tom’s blog post, by clicking here.
6. What the New York state Department of Financial Services new regulation on cybersecurity for financial services companies means for compliance officers. See Tom’s blog post by clicking here.
7. Jay previews his weekend report. 

Jay Rosen new contact information: 

Jay Rosen, CCEP

Vice President, Business Development

Monitoring Specialist 

Affiliated Monitors, Inc.

Mobile (310) 729-6746

Toll Free (866)-201-0903

JRosen@affiliatedmonitors.com

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 cases in response. For Brandon's blog post on the topic on Linkedin, click here. 

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, a bank must decide on its purpose and core values—or, as Dudley put it, “What are you for?” Second, after this identification of purposes and values, you can measure how well the workforce is striving to achieve that purpose. Third a bank can set its incentives so employees work harder to achieve those goals. As usual, Matt and I take a deep dive into the issue of enhancing corporate culture. For more on the speech, see Matt's blog post on Radical Compliance entitled, "Great Speech About Improving Corporate Culture".

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 the companies disclose to Ethisphere and how the winners consistently demonstrate compliance is good for business. Check out more information on Ethisphere's site by clicking here. 

In this episode, Jay and I have a wide-ranging discussion on why good compliance and is good for business. We discuss: 

1. LRN Ethics and Compliance Program Effectiveness Report. Click here for Report.
2. Ethisphere’s 2017 World’s Most Ethical Companies. Click here for Report.
3. Why good compliance is good for business. See Tom’s blog post.
4. Women in compliance: A key to organizational diversity. See article in the FCPA Blog.
5. ECI Podcast: Engaging With Your Monitor: Best Practices from ECI’s Independent Monitor Benchmarking Group. To listen to the podcast, click here.
6. Jay previews his weekend report.
7. Tom previews a presentation he will give with Jenny O’Brien and Roy Snell at the SCCE European Ethics and Compliance Institute in April. Jay previews a presentation at the same event by Eric Feldman of Affiliated Monitors. For more information on the event, check it out by clicking here. 

Jay Rosen new contact information:

Jay Rosen, CCEP

Vice President, Business Development

Monitoring Specialist 

Affiliated Monitors, Inc.

Mobile (310) 729-6746

Toll Free (866)-201-0903

JRosen@affiliatedmonitors.com

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 insight. Listen to last week’s Episode 8 for commentary from Matt Kelly and Mike Volkov.   

1. Jay Rosen, reporting from the ABA White Collar Conference in Miami, considers the view from the vendor perspective and whether the Evaluation changes a conversation about doing compliance. He reviews the requirements for ongoing monitoring, risk assessments and root cause analysis and the need for companies to explain how something might have fallen through the cracks, leading to a FCPA incident. He points out how CCOs can test a company’s compliance systems.

For Jay Rosen’s post see, Still in the Enforcement Business and Evaluation of Corporate Compliance Programs

2. Jonathan Armstrong provides a detailed analysis of some of the key differences between how compliance is operationalized in the US as opposed to the UK and EU countries. He explains how the enhanced requirements for root cause analysis, risk assessments and investigations and the supplemented requirements to tie back into the ongoing compliance monitoring and updating, could run afoul of UK and EU data protection and data privacy requirements. He also considers what a non-US company, subject to the FCPA what should look to as a best practices compliance program to best protect the organization. Finally explores just how far does all of this go? He provides on statistic that puts a huge bow on the difficulties going forward. 

For the Cordery Compliance article see the following, US Department of Justice on Evaluation of Corporate Compliance : how does it compare to UK Bribery Act 2010?

For Mike Volkov’s posts on the Evaluation see the following:

            Under the Dark of Night, DOJ Moves the Compliance Ball;

            DOJ’s Compliance Program Evaluation: the Role of the CCO;

            DOJ’s Compliance Program Evaluation: Risk Assessment, Policies and       Procedures and Third-Party Risk Management; and

            DOJ Compliance Expectations Concerning Training, Internal Investigations and     Audits  

For Tom Fox’s posts on these topics see the following:

            New DOJ Evaluation-Valuable Document for the Compliance Practitioner,             Part I; and

            New DOJ Evaluation-Valuable Document for the Compliance Practitioner,

            Part II

 For Matt Kelly’s posts see the following:

            Fresh FCPA Guidance from the Justice Department; and

            Deeper Dive into new DoJ Compliance Guidance  

The members of the Everything Compliance panel include:

• Jay Rosen – Vice President of Business Development and Monitoring Specialist at Affiliated Monitors. Rosen can be reached at JRosen@AffiliatedMonitors.com.
• Mike Volkov – One of the top FCPA commentators and practitioners around, Volkov is the Founder and 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 and former Editor of Compliance Week. Kelly can be reached at mkelly@radicalcompliance.com.
• Jonathan Armstrong – Rounding out this distinguished panel is our UK colleague, a lawyer with Cordery Compliance in London. Armstrong can be reached at armstrong@corderycompliance.com.

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? A summarization of its key findings. Why a focus on structural elements of a compliance program is no longer sufficient. Why a check the box analysis not adequate for judging program effectiveness. Finally the new focus on on ethical culture and behavior and why answering questions around “level of trust” is so critical. For a full copy of the report, you can download it here. 

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 while Kristy believes they are a step forward. 

For our additional written commentary on this issues, see Kristy's post The top five myths about ISO 37001 exposed.

For my views in opposition, see ENI Receives an ISO 37001 Certification and ENI CEO Charged with Corruption

In this episode, Jay and I have a wide-ranging discussion on the intersection of culture and ethics. We discuss: 

1. German authorities raid at VW investigation counsel, Jones Day, offices in Germany and what it may portend for FCPA investigation. See Tom’s article on the FCPA Blog.
2. British cycling team scandal. See Tom’s article on the FCPA Blog.
3. Uber, culture and corporate governance. See FT article, “Crisis inside the cult of Travis”.
4. Venezuela begins to investigate PDVSA for corruption. See article in the Wall Street Journal.
5. Federal reserve seeks lifetime ban for JPMorgan bankers who ran the illegal ‘Sons and Daughters’ hiring program. See article in the FCPA Blog.
6. Tom reveals an exciting new podcast, the Compliance Report-International Edition, which will premier next week. The initial episode will feature Carlos Ayers on recent anti-corruption developments in Brazil and South America.
7. Jay previews his weekend report.
8. Tom reports on a talk about 3rd party ROI at the upcoming Third-Party Risk Management & Oversight Summit, on March 20 & 21 at the Princeton Club in New York City. Listeners to this podcast will receive a 15% discount off of the regular price of the event. To take advantage of this offer enter the Code CMP 161. For more information on the event, check out the website by clicking here. 

Jay Rosen new contact information: 

Jay Rosen, CCEP

Vice President, Business Development

Monitoring Specialist

Affiliated Monitors, Inc.

Mobile (310) 729-6746

Toll Free (866)-201-0903

JRosen@affiliatedmonitors.com

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. Next week will be views from Jay Rosen and Jonathan Armstrong.   

1. Matt Kelly opens by considering the Evaluation as a continuation in a series of pronouncements around ‘operationalizing’ your compliance program. He discusses whether this approach consistent or different with the regulatory requirements of SEC FCPA enforcement and how would this document intersect with SEC ‘regulatory enforcement’ of the FCPA? Finally, he considers whether the Evaluation ties in at all to a control environment under either the COSO 2013 Framework or COSO ERM framework.

For Matt Kelly’s posts see the following:

            Fresh FCPA Guidance from the Justice Department; and

            Deeper Dive into new DoJ Compliance Guidance

2. Mike Volkov discusses why the Evaluation was issued literally in the dead of night and why would the DOJ issue such a significant document with no publicity. He discusses how this might play out during an ongoing FCPA investigation with outside counsel’s interactions with the DOJ and under the Yates Memo. He considers whether the Evaluation draw anything from the Yates Memo or are they really apples and oranges and whether the Evaluation build upon the 2012 FCPA Guidance or does it supplement it.

For Mike Volkov’s posts on the Evaluation see the following:

            Under the Dark of Night, DOJ Moves the Compliance Ball;

            DOJ’s Compliance Program Evaluation: the Role of the CCO;

            DOJ’s Compliance Program Evaluation: Risk Assessment, Policies and       Procedures and Third-Party Risk Management; and

            DOJ Compliance Expectations Concerning Training, Internal Investigations and     Audits 

For Tom Fox’s posts on these topics see the following:

            New DOJ Evaluation-Valuable Document for the Compliance Practitioner,             Part I; and

            New DOJ Evaluation-Valuable Document for the Compliance Practitioner,

            Part II

For Jay Rosen’s post see, Still in the Enforcement Business and Evaluation of Corporate Compliance Programs 

The members of the Everything Compliance panel include:

• Jay Rosen – Vice President of Business Development and Monitoring Specialist at Affiliated Monitors. Rosen can be reached at JRosen@AffiliatedMonitors.com.
• Mike Volkov – One of the top FCPA commentators and practitioners around, Volkov is the Founder and 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 and former Editor of Compliance Week. Kelly can be reached at mkelly@radicalcompliance.com.
• Jonathan Armstrong – Rounding out this distinguished panel is our UK colleague, a lawyer with Cordery Compliance in London. Armstrong can be reached at armstrong@corderycompliance.com.

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 by Kevin Blanco, acting assistant attorney general for the Criminal Division, who speaking at the American Bar Association’s annual white collar crime conference of the extension of the FCPA Pilot Program; the retort by Secretary of State Rex Tillerson to President Trump on the power of the FCPA for US companies doing business overseas, the Justice Department brief and oral argument in the Hoskins appeal where the DOJ continued to press for an expansive view of FCPA jurisdiction as originally preferred by the Obama DOJ; and finally we discuss the summary of all US attorneys by the Trump administration and Matt's proffers an interesting theory on why Preet Bharara was fired.

For more reading, see Matt's piece on Radicalcomplinance.com entitled, "FCPA: Pilot Program Extended, and Much More".

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.

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 buzz around the new Justice Department Evaluation of Corporate Compliance Programs document released in February, we discuss:

1. Adam Davidson’s piece in the New Yorker Magazine entitled, “Donald Trump’s Worst Deal” which looks at a Trump organization transaction in Azerbaijan which raises both FCPA and sanctions issues.
2. The newly revamped Justice Department’s Fraud Section’s website.
3. Highlight the rollout of the International Association of Independent Certified Monitors’ (IAICM) new website.
4. Review the week’s FCPA related issues.
5. Take a deep dive into the blockbuster trade announced between the Houston Texans and Cleveland Browns where the Texans sent their starting QB and a second round pick to the Browns for a fourth round pick in return (who says Texans are not great horse-traders!)
6. Jay previews his weekend report.
7. Tom reports on a talk about 3rd party ROI at the upcoming Third-Party Risk Management & Oversight Summit, on March 20 & 21 at the Princeton Club in New York City. Listeners to this podcast will receive a 15% discount off of the regular price of the event. To take advantage of this offer enter the Code CMP 161. For more information on the event, check out the website by clicking here. 

Jay Rosen new contact information: 

Jay Rosen, CCEP

Vice President, Business Development

Monitoring Specialist 

Affiliated Monitors, Inc.

Mobile (310) 729-6746

Toll Free (866)-201-0903

JRosen@affiliatedmonitors.com

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 Exposed Persons (PEPs) in Azerbaijan. Davidson talks about what intrigued him about the story, his reporting and most troubling, the PEPs alleged ties to funding from the Iranian Revolutionary Guard. It is a cautionary tale about major construction project in countries with a high perception of corruption, the need to understand who your business partners are and the source of their funding. The article is Donald Trump's Worst Deal.  

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 incident, look at it from a compliance program perspective, consider the failures in light of the new Justice Department Evaluation of Corporate Compliance Programs and conclude with the lessons to be learned for the compliance practitioner from the entire fiasco.  

For some additional reading see, Jay’s piece on Linkedin, “David vs. Goliath; Ethics & Compliance Lessons to be Learned from the Oscars” and Matt Kelly look at the control failures and other issues in his blog post on Radical Compliance, “And the Oscar for Control Failures Goes to…”

Jay Rosen new contact information:

Jay Rosen, CCEP

Vice President, Business Development

Monitoring Specialist

Affiliated Monitors, Inc.

Mobile (310) 729-6746

Toll Free (866)-201-0903

JRosen@affiliatedmonitors.com

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 at the event and I hope that you can join me. I have had the previously had the opportunity to do a podcast with the Event Chair, Melissa Evans, Lead Quality Systems, Supply Chain Management, Royal Caribbean Cruises (Episode 307). Today I visit with  Forrest Deegan, the Chief Ethics and Compliance Officer for Abercrombie & Fitch.

Forrest detailed How to Perform an ROI analysis of a third-party program for both the sales and supply chain side of things, drawing from his experience at A&F. He related some of the costs for getting it wrong in the short-term, along with smart money investments and cost-cutting ideas and then provided some insight into the cost-benefit analysis on A&F third-party programs.

The best part is listeners to this podcast will receive a discount to the event. You can receive a 15% discount off the regular price by entering the Code CMP 161. For more information on the event, check out the website by clicking here.

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 speakers. We also discuss the impact of the recently released DOJ Evaluation of Corporate Compliance Programs. Finally we have a guest appearance by Jim Moore, recently installed as SVP at Trust Point International. For a copy of the Evaluation of Corporate Compliance Programs, click here. For my two blog posts on the Evaluation, Part I and Part I

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 visit about some of the lesser known highlights from the month of December 2016 in the global enforcement of anti-corruption. 

This episode is dedicated to the chaotic (at best) first three weeks of the Trump administration. 

1. Jonathan Armstrong leads a discussion of the Trump administrations devolution towards Privacy Shield and what it may portend for American companies doing business in the UK and EU. He highlights the recent opening of a new trial in Ireland brought by Max Schrems and also discussed the putative Muslim refugee ban in the context of broader business implications.

For the Cordery Compliance client alert on Privacy Shield, see here

2. Jay Rosen considers what companies the intersection of business and politics under the Trump administration, the Tech sector response to the Muslim refugee ban and the more general business response to the first few weeks of the Trump administation.

For Jay’s post see, Where Do Politics End and Ethics & Compliance Begin?

3. Matt Kelly opens with a discussion of the management process practices of the Trump administration in issuing Executive Orders and lays down some markers around compliance and regulatory issues under the new administration.

For Matt Kelly’s posts see the following:

Compliance in the Trump Era: More Markers Placed

Five Questions for SEC Nominee Jay Clayton

Yes Government Ethics is Happening

Dodd-Frank Reform Starts Coming into View

 For Tom Fox’s posts on these topics see the following:

The Trump Administration-Kaos is Bad for Business

The Trump Administration-Part II, Failures in Leadership and Management

The Trump Administration-Part III-Preparing for a Catastrophe

The Trump Administration-Part IV-the Business Response

The members of the Everything Compliance panel include:

• Jay Rosen (Mr. Translations) – Jay is Vice President of Legal & Corporate Language Solutions at United Language Group. Rosen can be reached at rosen@ulgroup.com.
• Mike Volkov – One of the top FCPA commentators and practitioners around and is the Chief Executive Officer (CEO) and owner of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com.
• Matt Kelly – Founder and CEO of Radical Compliance, is the former Editor of the noted Compliance Week Kelly can be reached at mkelly@radicalcompliance.com
• Jonathan Armstrong – Rounding out is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com

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 when Federal Judge Lynn Hughes unsealed details about the extent of the illegal conduct. For all his efforts, Correa was severely punished by Judge Hughes at this sentencing. Hughes accepted the US government’s recommendation in sentencing Correa to 46 months of incarceration and fining him some $300,000. Correa was also banned from Major League Baseball (MLB) for life by Commissioner Rob Manfred. 

Matt and I have both blogged on this matter. Matt takes a look at some of the lessons to be garnered by the compliance professional in his post, Two Compliance Lessons from the Baseball World. I delved into the facts to mine some interesting tidbits and consider how to compensate a business when you have stolen their IP, in blog post Of Greek Gods and Data Breaches. 

Rather amazingly the Greek gods make an appearance proving once again that the fall of man is always related to hubris. 

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. 

1. Jonathan Armstrong leads a discussion the UK side of the enforcement action.

For the Cordery Compliance client alert on Rolls-Royce, see Rolls-Royce case sends a strong signal

2. Jay Rosen considers what companies which did business with RR should do now or even companies in the same or similar industries should consider in the face of the enforcement action.

For Jay’s post on Rolls-Royce, see Rolls-Royce Takes Global Anti-Corruption to New International Heights + Potential Next Steps for a CCO Whose Company has Bid/Worked with Rolls-Royce

3. Mike Volkov talks about the types of resolution documents used in anti-compliance enforcement and some of the key strategy used by RR during the process to achieve their positive result.

For Mike Volkov’s post on Rolls-Royce, see Serious Fraud Office Makes Big Splash with UK Bribery Act Resolution with Rolls Royce

4. Matt Kelly brings it all home and ties it together by walking us through the global implications of this settlement. 

For Tom Fox’s posts on these topics see the following:

1. Part I
2. Part II
3. Part III

 Rants will return next week. 

The members of the Everything Compliance panel include:

• Jay Rosen (Mr. Translations) – Jay is Vice President of Legal & Corporate Language Solutions at United Language Group. Rosen can be reached at rosen@ulgroup.com.
• Mike Volkov – One of the top FCPA commentators and practitioners around and is the Chief Executive Officer (CEO) and owner of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com.
• Matt Kelly – Founder and CEO of Radical Compliance, is the former Editor of the noted Compliance Week Kelly can be reached at mkelly@radicalcompliance.com
• Jonathan Armstrong – Rounding out is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com.

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 it might mean for the Serious Fraud Office going forward and how the judicial review of the UK DPA process adds a level of transparency not seen in the United States DPA practice. 

For more on the Rolls-Royce settlement see:

1. Cordery Compliance client alert, click here. 
2. FCPA Compliance Blog articles on the settlement, Part I and Part II

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 and data privacy issues the past year.

Mike Volkov relates what he saw as the top enforcement highlights from 2016, the block-buster year for FCPA fines and penalties and the growing trend of globalization of enforcement. Matt Kelly discusses the arrival of front pay, and general escalation of retaliation risk for company’s vis-a-vis whistleblowers, ideas on auditing corporate culture and what types of data and information should go on a compliance dashboard.

 For Matt’s posts on these topics see the following:

1. Another Front in Retaliation Risk: Front Pay
2. Ideas on Auditing Organizational Culture
3. What Goes on a Compliance Dashboard?

 Rants will return next week. 

The members of the Everything Compliance panel include:

• Jay Rosen (Mr. Translations) – Jay is Vice President of Legal & Corporate Language Solutions at United Language Group. Rosen can be reached at rosen@ulgroup.com.
• Mike Volkov – One of the top FCPA commentators and practitioners around and is the Chief Executive Officer (CEO) and owner of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com.
• Matt Kelly – Founder and CEO of Radical Compliance, is the former Editor of the noted Compliance Week Kelly can be reached at mkelly@radicalcompliance.com
• Jonathan Armstrong – Rounding out is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com.

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 and the continued issues around pre-taliation. We connect these enforcement actions to broader issues involving the COSO 2013 Framework, the DOJ mandated expertise in compliance, a speak-up culture and remedial actions. For additional information, check out Matt's blog posts on these topics:

1. Lessons Galore in New SEC Internal Controls Case; and
2. SEC Dings BlackRock for Pre-Taliation Clauses.

Show Notes for Episode 35, week ending January 13, the Friday the 13th edition 

1. Hernandez and Beech FCPA guilty pleas. Hernandez Criminal Information, Beech Criminal Information.
2. VW guilty plea in emissions-testing scandal. Link to article in New York Times.
3. VW executive Oliver Schmidt arrested in US. See article on FCPA Compliance and Ethics Blog.
4. Zimmer Bio-Met in follow-up FCPA enforcement action. See article on FCPA Blog.
5. Mondelez FCPA enforcement action. See SEC Cease and Desist Order and article on FCPA Compliance and Ethics Blog.
6. Supreme Court to take up 5 year statute of limitations for profit disgorgement under Securities Act, which applies to FCPA enforcement actions brought by SEC. Article in Law360.
7. NFL Playoff update on Patriots, Cowboys and Texans.