Everything Compliance-Episode 24

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 top such issues in 2018. 

1. Jay Rosen considers the new Justice Department FCPA Corporate Enforcement Policy and what it will mean for compliance practitioners and compliance programs in 2018 and beyond. 

For Jay Rosen’s post on the new FCPA Corporate Enforcement Policy, see the following:

Jay Rosen’s Most Significant FCPA Event from 2017 - FCPA Corporate Enforcement Policy (or a 5 Min History of How We Got From There to Here)

2. Jonathan Armstrong looks a fascinating couple of cases working their way through the English courts, the Morrison and Carphone Warehouse cases. They each have very interesting angles including the reliability of audit staff, liability of the employer for an employee’s criminal and individual criminal liability in the data breach situation.

For Cordery Compliance’s posts touching on these cases, see the following:

Client Alert: Morrisons Data Breach Litigation Succeeds

Client Alert: Carphone Warehouse fined under data breach

3. Matt Kelly returns to his vendor management soapbox to explore the intersection of FCPA compliance and data security. He considers some of the top data security breaches of 2017, the SEC response from the regulator perspective and most importantly the business response, both up and down the Supply Chain.

For Matt Kelly’s post on this topic, see the following:

Microchip Meltdowns and Vendor Risk

4. Tom Fox sits in for Mike Volkov this week. Tom discusses the continued internationalization of anti-corruption investigations and enforcement which began in earnest in 2016. He details some of the notable cases, including the Rolls-Royce matter, Keppel Offshore, SBM Offshore and the Telia case and explores what these enforcement actions may portend for compliance practitioners and compliance programs going forward. 

For Tom Fox’s post on the continued internationalization of anti-bribery/anti-corruption enforcement, see the following: 

DOJ-Aggressive International Anti-Corruption Enforcement to Continue

Rants follow at the end. 

The members of the Everything Compliance panel include:

• Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at [e-mail]
• 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 [e-mail].
• Matt Kelly – Founder and CEO of Radical Compliance, is the former Editor of Compliance Week. Kelly can be reached at [e-mail]
• Jonathan Armstrong – Rounding out the panel is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at [e-mail]