FCPA Compliance Report

In this episode, I am joined by Don Stern, Managing Director at Affiliated Monitors and former US Attorney for Massachusetts. We discuss the 93 US Attorneys offices across the US; how they work, how are cases worked up and their interaction with Main Justice in Washington.  Some of the highlights include: What is the Dept of Justice structure including the US Attorneys? What is the role of a US At...

In this episode, I am joined by Eric Young, recently retired long-time compliance professional. We explore an under-looked aspect of the Goldman Sachs FCPA enforcement action; the independent enforcement actions by the Federal Reserve Bank and state of New York’s Department of Financial Services.  Some of the highlights include:                             Why was the Fed involved in the Goldman S...

The week of Thanksgiving is the time of our annual trip to the most beautiful and unique city on earth-Venice, Italy. With travel to Italy shut down this year due to Covid-19, I am visiting Venice virtually and mining this rich city for compliance lessons. This episode concludes my podcast series on how the city of Venice informs your internal reporting system. The symbol of Venice is the Lion of...

The week of Thanksgiving is the time of our annual trip to the most beautiful and unique city on earth-Venice, Italy. With travel to Italy shut down this year due to Covid-19, I am visiting Venice virtually and mining this rich city for compliance lessons. Today's lesson come from the Arsenale and incentives in compliance. This is not a precursor to that famous north London football club, the Arse...

In this episode, I am joined by Mike Lindsey, a partner in the Los Angeles law firm of Steinbrecher and Span. Lindsay specializes in cyber risk issues. He joins me to discuss those legal issues around cyber security, e-commerce, internal communications and ephemeral messaging. Some of the highlights include:                             The nature of Lindsey’s practice. Description of legal work on...

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 Gondolier that in addition to having a stout pairs of lungs, they are almost all in very good physical condition. They have to be pilot...

In the episode, I take things in a different direction as I visit with Compliance Week Editor-in-Chief Dave Lefort. We reflect on the life and meaning of the recently deceased Tommy Heinsohn. We talk about Heinsohn the player, the coach, the announcer and the man. We discuss leadership and why Heinsohn was a figure beloved by all of New England.   Some of the highlights include: The basketball res...

In the Episode, I visit with Mike DeBernardis, Counsel and Hughes Hubbard. We take a look back at the FCPA world in Q3. It started off with a bang and never slowed down.  Some of the highlights include: The quarter started off with a bang-Novartis US and never slowed down.  How and why did Novartis US, First Energy in Ohio and Commonwealth Ed in Illinois change the discussion around domestic corru...

In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for April 2020.  Some of the highlights include: DOJ Announces Repatriation of $300 Million to Malaysia in Connection With 1MDB. Colombia Officially Enters the OECD. W...

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and interna...

In this episode, I visit with Susan Divers, Senior Advisor at LRN. It is part of my continuing series this year looking back over the past decade of Foreign Corrupt Practices Act enforcement and the evolution of compliance. Some of the topics we consider are: How the heavy emphasis on enforcement by the DOJ led to organizations investing in compliance. How did companies begin to evolve their compl...

In this episode, I visit with Gar Hurst a partner at Givens and Johnston. Gar and the firm specialize on import control issues. Today we take a major issue that is bedeviling companies in the Port of Houston and elsewhere, wood packaging issue. We explore why it is the biggest threat to importations you have never heard about. It turns out that import laws and regulations have substantial impact o...

In this podcast, I am joined I am joined by Carrie Penman, Chief Risk and Compliance Officer at NAVEX Global, Inc. We visit about their upcoming 2020 virtual conference, NAVEX Next, which is entitled Beyond the Moment.  The theme, Beyond the Moment, defines the 2020 agenda and supports sessions that will help you and your organization move past a defensive stance on current events and trends. The...

In our continuing series, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors.  Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector...

In this podcast, I am joined by Piero Molinario, Senior Managing Director, Head of Financial Crimes Risk and Compliance for EMEA for K2 Intelligence FIN and Joanne Taylor, Managing Director, K2 Intelligence FIN who works with clients investigations and financial crime compliance, including fraud risk management, anti-bribery and corruption, regulatory enforcement, and fraud investigations. Both ar...

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own unique perspectives to this settlement. In this concluding Part 5, I am joined by Jonathan Armstrong and we discuss the enforcement action from the UK perspective under the...

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own unique perspectives to this settlement. In this Part 4, Jonathan Marks and Tom Fox discuss the role of gatekeepers and the lack of skepticism at the Board of Directors.  So...

In this special edition, I am pleased to cross-post a recent live event hosted by Sean Freidlin, Director Product Marketing at SAI Global. He hosted the third edition of SAI Global’s Compliance Book Club, featuring Robert Chesnut, author of Intentional Integrity. Sean's Compliance Book Club is fast becoming one of the most listened to events in the compliance world. His interview with Robert Chesn...

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and interna...

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own unique perspectives to this settlement. In this Part 3, Matt Kelly joins me to consider the role internal audit in this matter and the (non) actions of Herbalife’s Board of...

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own unique perspectives to this settlement. In this Part 2, Jay Rosen joins me to consider how Herbalife was able to avoid a Monitorship.  Some of the highlights include: ·    ...

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own unique perspectives to this settlement. In this Part 1, Mike Volkov details how he would counsel a company which found itself in a situation similar to Herbalife.  Some of...

Welcome to a special five-part podcast series where I take a deep dive into the Miller & Chevalier Chartered Latin American Corruption Survey. Over this five-part series I will visit with firm lawyers James Tillen, Matt Ellis, Alexandra Almonte and Greg Bates. Miller & Chevalier and 14 partner firms have tracked perspectives on anti-corruption issues in the region since 2008. It is the most compre...

Welcome to a special five-part podcast series where I take a deep dive into the Miller & Chevalier Chartered Latin American Corruption Survey. Over this five-part series I will visit with firm lawyers James Tillen, Matt Ellis, Alexandra Almonte and Greg Bates. Miller & Chevalier and 14 partner firms have tracked perspectives on anti-corruption issues in the region since 2008. It is the most compre...

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and interna...