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 topics see:

Compliance Lessons from Sgt. Pepper's 

AI and Compliance Going Forward: Welcome to ComTech

AI for Risk Management in Compliance 

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 integration of the COSO ERM Framework into functional business units moving to operationalize ERM in organizations and we consider how the ERM Framework differs yet is complimentary to the COSO Internal Controls Framework. 

For additional information, see Matt's Blogs posts on the COSO ERM Framework:

More Details on COSO ERM Framework

Update to COSO ERM Framework Update

ERM Framework: Govt. Calls for Unity

More Clues on Draft ERM Framework

Draft ERM Framework is Here: How to Get Started

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 Circuit Court of Appeals oral argument in the Hoskins case and the OCED Phase 4 reports on Finland and the UK. For a copy of the firm's report, click here.

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 

1. Tom reports on Compliance Week 2017. See his articles in Compliance Week, here and here.
2. If the DOJ releases new information in the form of the Evaluation of Corporate Compliance Programs, does anyone read it. See article in GIR (sub req’d).
3. Jay discusses the SCCE event he attended last week in San Francisco. See Jay’s recap in his article I Left My #SCCE Heart in San Francisco or I Love It When A Plan Comes Together!
4. Was the individual enforcement against the MoneyGram CCO significant or much ado about nothing? See article by Dick Cassin in the FCPA Blog and by Sara Kropt in her Grand Jury Blog.
5. DOJ will embed prosecutors overseas. See article by Sam Rubenfeld in WSJ Risk and Compliance Journal. See full text of speech by Deputy AG Trevor McFadden by clicking here.
6. Warriors and Cavs meet in the first time, three consecutive title match run. Tom and Jay consider from the compliance perspective.
7. Tom announces the release of his new book 2016 – The Year in Corporate FCPA Enforcement. For more information and to purchase, click here.

 Jay Rosen can be reached:

 Mobile (310) 729-6746

Toll Free (866)-201-0903

JRosen@affiliatedmonitors.com

Tom Fox can be reached:

       Phone: 832-744-0264

       Email: tfox@tfoxlaw.com

Episode 18 Show Notes

 I. Compensation, Incentive and Compliance

In this episode, Roy Snell and myself discuss how incentives are integral to the compensation plans of a wide range of workers. Many experts point to their value in rewarding behavior that is in the interest of the organization and for keeping workers focused on activities that help the bottom line. At the same time, however, the incentives can pose great risks. 

Many corporate scandals have shown that workers and corporate leaders may give in to the temptation to cheat to make their numbers, doing whatever they can to achieve their goals and reap the rewards. As a consequence, incentive plans may turn out to be a roadmap for compliance risk. 

This danger argues for the compliance department having a role in reviewing incentive plans, if nothing else than to develop controls that ensure the numbers are hit properly, without violating policies, procedures, the law, and ethical norms. 

To better assess the role of the compliance team in reviewing incentive plans, in April 2017 the Society of Corporate Compliance and Ethics and the Health Care Compliance Association fielded a survey among compliance professionals. The results indicate that, despite the risks, compliance rarely plays a role in evaluating incentive programs. For the recent SCCE/HCCA survey on this issue, click here.

For additional writings by Tom see the following blog posts: 

Incentivizing Compliance

Executives and Compliance Compensation Incentives

Sales Incentives and Compliance

II. Compliance and the Board of Directors

On a second topic, Roy and I discuss the need that a true compliance expert sit on a company’s Board of Directors. The presence of a such a compliance professional with subject matter expertise on the Board sends a strong message about the organization’s commitment to compliance, provides a valuable resource to other Board members, and helps the Board better fulfill its oversight obligations.

Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar background and often times these are also the Audit Committee members of the Board. Such a background brings a level of sophistication, training and subject matter expertise that can help all companies with their financial reporting and other finance based issues. So why is there not such compliance subject matter expertise at the Board level? 

Roy sees it through the prism of the compliance profession and has said, “If you ask most companies if they have compliance expertise on their Board… most would say yes. When asked who the compliance expert is they typically point to a lawyer, auditor, risk manager, or an ethicist. None of these professions are automatically compliance experts. All lawyers have different specialties.” He goes on to state that what regulators want to see is specific compliance expertise at the Board level. He noted, “the government is looking for is not generic compliance expertise. They are looking for compliance program management expertise. 

For Roy’s further thoughts on this issues, see his blog post, “Compliance Expertise Needed on Your Board”. 

For Tom’s writing on the subject see his blog post, “Compliance Expertise Needed on the Board”.

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 enforcement, business, PR and some other angles. What may seem to be a straight-forward answer to a regulatory obligations turns out to be anything but. 

For additional research, see Matt Kelly's blogpost, "Ransomware: To Disclose or Not".

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 

1. Brazilian President Temer comes under corruption fire? See article in the New York Times.
2. The turmoil at FIFA continues as FIFA’s ethics watchdogs quit in protest after their chairman was fired. See article in Bloomberg.
3. Should compliance and ethics be wedded? New report by Institute of Business Ethics and the Ethics Institute considers the issues. See article in WSJ Risk and Compliance Journal.
4. The Fat Leonard scandal lands U.S. Navy Rear Admiral Robert Gilbeau with a prison sentence of 18 months. See article in the FCPA Blog.
5. Almost one-third of all open FCPA investigations involve Brazil. Only 17% involve China. See article in the FCPA Blog.
6. Astros lead the MLB with the best record in baseball. Will they regress to the mean?
7. ComTech is here. Are you ready? See Tom’s article in the FCPA Compliance and Ethics Blog.
8. Jay previews his Weekend Report.
9. It is not too late to join me at Compliance Week 2017. Listeners to this podcast can received a discount to Compliance Week 2017. Go to registrationand enter discount code CW17TOMFOX.

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’ rants.

1. Matt Kelly opens with a discussion of regulatory enforcement under the Trump administration, how the ‘Trump Effect’ is negatively impacting corporations, industry responses to deregulation issues and lays down some markers around compliance issues under the new administration.

For Matt Kelly’s posts see the following:

Compliance in the Trump Era: More Markers Placed

Trump Administration Whacks Telco Firm for $892 Million

Drone Industry Pan Trump’s Regulatory

Trump Risk Disclosures Start Rolling In

First SEC Whistleblower Award of Trump Era

Sessions Dodges, Weaves, Promises on FCPA

2. Mike Volkov rounds out the discussion with a review of where the DOJ is currently under AG Sessions, remarks by DOJ officials on FCPA enforcement, the future of the Pilot Program and DOJ Compliance Counsel, Hui Chen. 

For Mike Volkov’s posts see the following:

Yates, AG Sessions and Individual Criminal Prosecutions

New E-Book — Moving the Goalposts: The Justice Department Redefines Effective Compliance

FCPA Remediation Focus on Supervisory Personnel

FPCA Pilot Program Motors On

For the Cordery Compliance client alerts see the following:

EU conflicts minerals compliance legislation 

DOJ Evaluation of Corporate Compliance: how does it compare to UK Bribery Act 2010?

For Jay Rosen’s posts see the following:

 Still in the Enforcement Business and Evaluation of Corporate Compliance Programs

“It Was the Best of Times, It was the Worst of Times,” or “Ignorance is Strength”

For Tom Fox’s posts see the following:

The Trump Administration-Kaos is Bad for Business

The Trump Administration-Failures in Leadership and Management

The Trump Administration-Preparing for a Catastrophe

The Trump Administration-the Business Response

DOJ Enforcement of the FCPA and the International Fight against Corruption in the Trump Administration

 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 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, is the former Editor of Compliance Week. 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

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 Jeff Sessions and the panel of former Deputy Attorney Generals, as well as some of the other Key Note speaking session highlights. She also details some of the upcoming ECI events for 2017. 

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 

1. What is the real risk in a FCPA enforcement action? See Mike Volkov’s post in Corruption, Crime and Compliance.
2. FIFA fires its lead internal investigators for doing their job investigating. See Tom’s article in Compliance Week.
3. ECI Report Finds Use of Corporate Monitors is on the Rise. For a copy of report, click here. For a webinar replay with Affiliated Monitors’ Eric Feldman and Nasdaq’s Michael Kallens click here.
4. Why the judgment of CEOs and their actions really do matter. See James Stewart considers Barclays’ Jes Staley in his Common Sense column in the New York Times.
5. What role do incentives play in a compliance program? See Tom’s two podcasts on the issue, incentives for executives and incentives in sales programs.
6. Astros lead the MLB with the best record in baseball. The Rockets gag on the big one.
7. Jay previews his Weekend Report, compliance lessons from a trip to the zoo.
8. Listeners to this podcast can received a discount to Compliance Week 2017. Go to registrationand enter discount code CW17TOMFOX.

 Jay Rosen can be reached:

 Mobile (310) 729-6746

Toll Free (866)-201-0903

JRosen@affiliatedmonitors.com

Tom Fox can be reached:

       Phone: 832-744-0264

       Email: tfox@tfoxlaw.com

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 Armstrong and Jay Rosen. Next week Matt Kelly and Mike Volkov. 

1. Jonathan Armstrong leads a discussion of the Trump administrations devolution of Privacy Shield, GDPR and what they mean for American companies doing business in the UK and EU. He discusses the key differences in the DOJ’s Evaluation of Corporate Compliance Programs in an FCPA analysis and under the Bribery Act, differences in the EU approach to conflict minerals and under the Trump Administration and concludes by giving us his thoughts on what Brexit means for compliance.

For the Cordery Compliance client alerts see the following:

EU conflicts minerals compliance legislation 

DOJ Evaluation of Corporate Compliance: how does it compare to UK Bribery Act 2010?

BREXIT Glossary

2. Jay Rosen considers what companies the intersection of business and politics under the Trump administration, the business response he has observed to Trump administrations steps and miss-steps, the comments made by DOJ representatives at Q1 conferences and the vibe of compliance conference attendees.

For Jay’s post see,

 Still in the Enforcement Business and Evaluation of Corporate Compliance Programs

“It Was the Best of Times, It was the Worst of Times,” or “Ignorance is Strength”

For Matt Kelly’s posts see:

Compliance in the Trump Era: More Markers Placed

Trump Administration Whacks Telco Firm for $892 Million

Drone Industry Pan Trump’s Regulatory

Trump Risk Disclosures Start Rolling In

First SEC Whistleblower Award of Trump Era

Sessions Dodges, Weaves, Promises on FCPA

For Mike Volkov’s posts see the following:

Yates, AG Sessions and Individual Criminal Prosecutions

New E-Book — Moving the Goalposts: The Justice Department Redefines Effective Compliance

FCPA Remediation Focus on Supervisory Personnel

FPCA Pilot Program Motors On

For Tom Fox’s posts on the Trump administration’s first 100 days see the following:

The Trump Administration-Kaos is Bad for Business

The Trump Administration-Failures in Leadership and Management

The Trump Administration-Preparing for a Catastrophe

The Trump Administration-the Business Response

DOJ Enforcement of the FCPA and the International Fight against Corruption in the Trump Administration

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 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, is the former Editor of Compliance Week. 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

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 to corruption. See Tom’s article in Compliance Week. What are the rationales for anti-corruption legislation? See Tom’s post on the rationales underlying the FCPA on the FCPA Compliance Report.

1. Why due diligence investigations still need the human element. See Scott Shaffer’s article in FCPA Blog.
2. Kara Brockmeyer joins Debevoise & Plimpton LLP. See Tom’s article in the FCPA Blog.
3. What has been the fate of whistleblowers at Wells Fargo. See James Stewart considers in his Common Sense column in the New York Times.
4. Federal jury convicts former Guinea mining minister of laundering bribes. See article in the FCPA Blog.
5. Astros lead the AL with the second best record in baseball. What does Tony Parker’s injury mean for the Spurs/Rockets playoff series?
6. The Financial Reporting Council (FRC) investigates KPMG on its audits of Rolls Royce for the firm’s failure to detect bribes paid by the company. See article in the FCPA Blog.
7. Listeners to this podcast can received a discount to Compliance Week 2017. Go to registrationand enter discount code CW17TOMFOX.

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 the legislation which Matt thinks are bad including:

1. Repeal of the Chevron deference repealed. 

2. Attempts to clip the SEC rule making authority.

3. Exempting more companies which desire to go public from SOX 404(b) requirements and reporting. 

4. (Matt's most particular bad idea) The exemption of more filers exempted from XBRL reporting.

We also discuss some of the potential benefits from the legislation and where it may all go in the Senate.

For more see Matt's blog post House GOP Regulatory Reform Axe, on his site Radical Compliance. 

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 the state of Department of Justice's Foreign Corrupt Practices Act  declinations after one year of the agency's enforcement Pilot Program, which sought to promote greater accountability for companies and individuals who violate the FCPA, while rewarding those who voluntarily self-disclose violations and cooperate with investigations and remediation efforts. They discuss the following issues:

1. Do the numbers show any increase in declinations in 2016 over the past few years?
2. What are the conditions to obtain a declination? Is any one as more important or are they of equal importance?
3. Is there any reason not to publicize all declinations?
4. They discuss how SEC enforcement is a factor in DOJ calculus in determining whether or not to grant a declination. 
5. In 2016 there were two declinations which involved privately held companies and hence no SEC prosecution. They explain how the DOJ got to profit disgorgement.
6. They prognosticate the tea leaves, on what might be the fate of the the Pilot Program going forward. 

For additional reading on FCPA enforcement in 2017, see Miller & Chevalier's FCPA Spring Review 2017. 

In this episode, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:

1. Trump’s First 100 days end with a decided wimper. What does it mean for compliance?
2. Novartis gets into corruption trouble in South Korea. See article in FCPA Blog.
3. Shell and ENI are in a big corruption mess in Nigeria. See Tom’s article in the FCPA Blog.
4. United Airlines tries to clean up its act. See articles in the New York Times and Wall Street Journal.
5. Jay reports on the ECI conference and tells us what’s in his coloring book.
6. Tom details his speaking engagements in May. For details and registration information click here.
7. KBR under investigation by UK SFO for allegations around the company’s use of Unaoil. See article in the Wall Street Journal.
8. Listeners to this podcast can received a discount to Compliance Week 2017. Go to registrationand enter discount code CW17TOMFOX.
9. Jay previews his weekend post, which is now up, "It Was the Best of Times, It Was the Worst of Times" or "Ignorance is Strength"

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 context of cavemen and Plato's Analogy of the Cave. We review some of the new information and Roy discusses how it is a compilation of many differing strands of compliance thought over the past 20 year. We then discuss the HCCA-OIG Resource Guide on Measuring Compliance Program Effectiveness. As always we go off on tangents and dive deeply into issues relating to the the compliance profession. 

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 multiple topics and issues around the Foreign Corrupt Practices Act (FCPA). The first set of remarks were made in Washington DC at the Anti-Corruption, Export Controls & Sanctions (ACES) 10th Compliance Summit (the “DC speech”). The second set of remarks were made at the American Conference Institute (ACI) 19th Conference on the FCPA in New York City (the “NYC speech”). We consider the evolving rationale for FCPA enforcement which has changed in the 40 years since it was enacted, the mandatory corporate response to FCPA compliance requirements, and how McFadden sees Justice Department enforcement of the FCPA going forward in the Trump administration. 

For Matt Kelly blog post on McFadden's remarks, click here. For Tom Fox's segments of a three part series, click here for Part I, Part II and Part III. 

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:

1. DOJ Criminal Division's Acting Principal Deputy Assistant Attorney General remarks on the FCPA and its enforcement. - See text of speech by clicking here. See Matt Kelly’s blog post by clicking here.
2. Whistleblowers in the news. See Tom’s article on the Barclay’s CEO and Amtrust in FCPA Blog and on KPMG in Compliance Week. Mike Volkov weighs on whistleblowing as indicia of corporate culture here.
3. One year reports note that declinations are on the rise under the on the now one-year old FCPA Pilot Program. For Miller & Chevalier report click here (sub. req’d). For the Stanford University FCPA Clearinghouse Report in the Wall Street Journal, click here.
4. Tribute to Kara Brockmeyer, retiring as head of the SEC’s FCPA Unit. See Tom’s article in Compliance Week.
5. Jay details his upcoming conference schedule and weekend report on ethics and compliance observations from the Florida version of the Magic Kingdom.
6. Listeners to this podcast can received a discount to Compliance Week 2017. Go to registrationand enter discount code CW17TOMFOX.

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 Effective Compliance Officer for a roundtable discussion of the recently concluded SCCE European Compliance and Ethics Institute. We discuss some of the highlights, the changes this group of compliance practitioners has seen and where compliance may be headed in 2017 and beyond.

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 of the other key topics for the event. He discusses how Compliance Week is an entire experience for attendees, exhibitors, speakers and guests. Best of all, listeners to this podcast can receive a discount to this year's event. Go to registration and enter discount code CW17TOMFOX.

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 discuss: 

1. Shearman & Sterling issues its Report to the Wells Fargo Board on the fraudulent account scandal. For Tom’s three-part series see Part I, Part II and Part III.
2. United Airlines is at it again. Click here for Matt’s article on Radical Compliance. Click here for Tom’s article in Compliance Week.
3. Interesting judicial decision on restitution from Judge Posner. See article in the Grand Jury Target blog.
4. Barclay’s CEO penalized for trying to unmask internal and anonymous whistleblower by using corporate security and US law enforcement. See Tom’s article in Compliance Week.
5. Matt reports on Oracle’s Modern Finance Experience conference. Click here for Matt’s blog post on Radical Compliance.

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 information about certain characteristics of emerging growth companies (EGCs). Matt and I discuss some of the PCAOB's key findings:

• There were 1,951 companies that identified themselves as EGCs in at least one SEC filing since 2012 and have filed audited financial statements with the SEC in the 18 months preceding the measurement date (“EGC filers”). The PCAOB staff observe that the number of EGC filers has grown since the enactment of the Jumpstart Our Business Startups (JOBS) Act, but has stabilized recently.
• There were 742 EGC filers (or 38 percent) that have common equity securities listed on a U.S. national securities exchange (“exchange-listed”). 
• The five most common industries for EGC filers as of November 16, 2016, are pharmaceutical preparations, blank check companies, real estate investment trusts, prepackaged software, and surgical/medical instruments and apparatus.
• Many EGC filers that were not exchange-listed had limited operations. Approximately 50 percent of the non-listed EGC filers reported zero revenue in their most recent filing with audited financial statements and 23 percent of non-listed EGCs that filed periodic reports disclosed that they were shell companies.
• Approximately 51 percent of EGC filers, including 74 percent of those that were not exchange-listed, received an explanatory paragraph in their most recent auditor’s report expressing substantial doubt about the company’s ability to continue as a going concern.
• Among the 1,951 EGC filers, 1,262 provided a management report on internal control over financial reporting in their most recent annual filing. Of those 1,262 companies, approximately 47 percent reported material weaknesses.
• Approximately 96 percent of EGC filers were audited by accounting firms that also audited issuers that are not EGC filers, including 39 percent of EGC filers that were audited by firms that provided audit reports for more than 100 issuers and were required to be inspected on an annual basis by the PCAOB.

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 stories. We discuss: 

1. Wrap up from the SCCE European Compliance and Ethics Institute.
2. SEC Unit Chief Kara Brockmeyer announces her retirement. Click here for Matt Kelly’s article on Radical Compliance.
3. Wal-Mart announces its 2016 spend on its FCPA investigation and remediation of $99MM. Click here for Matt Kelly’s article on Radical Compliance.
4. Upjohn warnings after the Yates Memo. See article the Grand Jury Target blog.
5. Report on OECD Integrity Forum. Allison Taylor writes in the FCPA Blog.
6. Astros, Red Sox and Dodgers all lead their divisions.
7. Jay previews his weekend report.

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 opposed to Chief Compliance Officer or Chief Ethics and Compliance Officer?;
• What is the role of a CCO around integrity or how does she see her role at Louis Berger different that a traditional CCO?;
• Does she have any specific initiatives around ‘integrity’?;
• How can a Chief Integrity Officer help drives the values and culture in an organization;
• Her academic background is not the usual one for a compliance professional, what took her in the field; and
• How a Chief Integrity Officer is the most recent iteration of the compliance function, to Compliance 3.0.

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 United within its rights to exclude the passengers for inappropriate dress? Is the policy valid? Did the gate agent receive appropriate training to make their decision? In the world of today, social media accelerates the ability to judge, without improving the ability to judge. For ethics & compliance officers, that means every compliance risk is now magnified into a reputation risk. Finally, we consider Matt's closing sentence, "Training, values, culture, judgment. Funny how those four things keep cropping up, isn’t it?" and what it means for compliance. 

For more insight, read Matt's blog post, "United's Policy Management Lessons"