FCPA Compliance Report

In this special five-part podcast series, hosted by Gan Integrity, we consider the evolution of compliance, from disconnected to connected. Over the next five episodes we will explore why compliance is disconnected and what can be done to connect it, how to build a connected compliance program and technology can help in this endeavor and finally what is the human side of compliance in the context...

In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for December 2018. We look at some of the key international developments.  Highlights from the podcast include: 1.    Serious Fraud Office prosecutions against employees from Alstom subsidiaries. How did the SFO fare in them?2.    SFO also announ...

In this special five-part podcast series, hosted by Gan Integrity, we consider the evolution of compliance, from disconnected to connected. Over the next five episodes we will explore why compliance is disconnected and what can be done to connect it, how to build a connected compliance program, technology can help in this endeavor and finally what is the human side of compliance in the context of...

In this special five-part podcast series, sponsored by Gan Integrity, we have considered the evolution of compliance, from disconnected to connected. We have explored why compliance is disconnected and what can be done to connect it, how to build a connected compliance program and technology can help in this endeavor. The series has been a fascinating exploration of where compliance is in 2019 and...

In this special five-part podcast series, hosted by Gan Integrity, we consider the evolution of compliance, from disconnected to connected. Over the next five episodes we will explore why compliance is disconnected and what can be done to connect it, how to build a connected compliance program and technology can help in this endeavor and finally what is the human side of compliance in the context...

In this special five-part podcast series, hosted by Gan Integrity, we consider the evolution of compliance, from disconnected to connected. Over five episodes we will explore why compliance is disconnected and what can be done to connect it, how to build a connected compliance program, technology can help in this endeavor and finally what is the human side of compliance in the context of connected...

FEBRUARY 2, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      Venezuela is moving towards a divided government. What does it mean for businesses? (Financial Times)·      What is material? (Financial Times) ·      What is credibility? (Financial Times)·       Standard Chartered spanked (yet) again. (Financial Times) Learn more about your ad choices. Visit megaphone.fm/adchoices

The Super Bowl is Sunday. Will the ads be better than the game? Tom and Jay are back and as the pay tribute to the Godfather of compliance bloggers and commentators, Dick Cassin, who turned over Editorship of the FCPA Blog to his son, Harry Cassin. They also look at some of this week’s top compliance and ethics stories which caught their collective eyes.  1.     Why lying to your bank is always a...

FEBRUARY 1, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      Things get worse for PG&E as federal judge slams company. (Wall Street Journal)·      What is due diligence? Foxxconn says it didn’t know. (New York Times) ·      How anti-corruption can pay (and pay and pay). (CNBC)·       Fearsome foes line up to make Danske pay for laundering scandal. (Financial Times) Learn more ab...

In this episode I visit with Jonathan Armstrong on the recent fine levied by British regulators against the insolvent institution Cambridge Analytica for violations of the British privacy law which was in place before GDPR went live. The case involved Cambridge Analytica denying aggrieved parties subject access requests and associated rights. Some of the issues and highlights are: The case demonst...

JANUARY 31, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      Defamation suit under based upon allegations of FCPA violations is dismissed. (Global Investigation Review)·      Why would anyone send their children to MSU? (ESPN)·      Did drug makers conspire, commit fraud or worse to create the opioid crisis? The first cases are about to go to trial. (New York Times)·       Why i...

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 (the coolest guy in compliance) and I take a deep dive into recent blown call in the Saints-Rams NFC. We consider the (non) response from the NFL under the rubric of internal controls.   Some of the...

JANUARY 30, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      US levels new charges at Huawei. (Wall Street Journal)·      US slaps sanctions on PdVSA. (Wall Street Journal)·      Wonder why Apple does manufacture in the US? (Hint-think Supply Chain) (New York Times)·       Wynn Casinos tolerance of sexual harassment comes to an end with the Nevada Gaming Control Board. (Wall Str...

JANUARY 29, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      Did bribery pave the way for the opioid crisis? (ABC News)·      SEC open investigation into Nissan over Carlos Ghosn scandal. (Wall Street Journal)·      1MDB investigation expands to include Deloitte and KPMG. (This Week in Asia)·       Of all the bankers who engaged in fraud during the Financial Crisis, why are 4 Ba...

Next, we consider Measure for Measure. In the age of #MeToothis play has taken on a renewed and frankly disturbing existence. Seeing the play in the past year was a much difference experience for me than the 20 years or so ago when I last saw it. Once again while there are comic elements, largely around the switching out of partners in a bedroom farce and a marriage proposal to end the play, there...

We continue our consideration of Shakespeare’s Problem Plays with today’s offering on Troilus and Cressidaas an introduction to problems in compliance. Today, we consider Troilus and Cressidaand how the title character was portrayed as a fool but the main action is around the death of other characters.  The title characters of this play are not the main story, which takes place during the Trojan W...

Today, I round out the series by discussing the final play considered in this oeuvre, “Timon of Athens”. While the first four Problem Plays are most generally described as a play where the mask of comedy (not the mask of tragedy) ends the plays; i.e. everyone gets married at the end of the day, even though these were really not happy endings. However today’s offering is a Problem Play for yet anot...

Today, we consider The Winter’s Tale. In this play, King Leontes of Sicily and King Polixenes of Bohemia are old friends and Polixenes is about to return home after a six month visit to Sicily. Leontes wants him to remain longer and asks his wife to persuade him to stay. At this point the green-eyed monster of jealously takes hold of Leontes and he becomes obsessed with the idea that his wife has...

JANUARY 28, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      Why the Beatle rooftop (and final) concert still resonate? (Financial Times)·      Has #MeToomade men afraid to mentor women? (New York Times)·      What happens if there is regime change in Venezuela? (BBC)·       Nigerian election thrown into chaos as Buhari suspends country's top judge. (CNN) Learn more about your a...

This podcast opens a five-part podcast series on Shakespeare’s Problem Plays. These are plays where the structure of comedy ends the plays; i.e. everyone gets married at the end of the day. Yet these were really not happy endings. Equally they are not tragedies either. Usually in the middle is some very dark part, which tests the reader, play-goer or listener with some very difficult subjects. The...

In this episode I visit with Hughes Hubbard partner Michael DeBernardis on the Hughes Hubbard 2018FCPA & Anti-Bribery Alert. We look at some of the key DOJ pronouncements, key enforcement actions, key cases and key international developments.  Highlights from the podcast include: 1.    What is the Hughes Hubbard FCPA & Anti-Bribery Alert?2.    The key DOJ policy pronouncements in 2018 around the F...

JANUARY 26, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      What happens when fired CEO is asked to repay expenses? (Wall Street Journal)·      Is Davos elite out to kill compliance? (New York Times)·      Four styles of communication every CCO needs to learn. (Fast Times)·       South Africa withdraws corruption charges against Zuma's son. (Reuters) Learn more about your ad ch...

In this podcast series, recovering screenwriter (and Mr. Monitor) Jay Rosen and myself will indulge in passion for the movies by looking at them through the lens of compliance. Jay is a contemporary movie fan and I am more of a classic movie maven so we present a well-rounded view of the movie fandom. So if you want to indulge in your love for the movies with two guys who are passionate about Holl...

As the Pats and Rams advance, Tom and Jay ask if the NFL even cares about get it right? They also look at some of this week’s top compliance and ethics stories which caught their collective eyes.  1.    Google becomes first US company fined under GDPR. 2.    What is good corporate governance under German law? 3.    Deutsche Bank under US scrutiny for it role in Dansk Bank scandal.  4.    Should so...

In this episode I visit with Jonathan Armstrong and André Bywater on the recent fine levied by the French Data Privacy regulator CNIL against Google for violations under GDPR. Some of the highlights are: The case is the first major GDPR fine against a US company. It demonstrates the lack of forum shopping available to US companies which are looking for a softer regulatory approach. How did the reg...