FCPA Compliance Report

In this episode, Matt Kelly and I take a deep dive back into the issue of the ZTE monitorship announced recently as a part of the settlement with the Department of Commerce on the death penalty sanctions levied on the company in April.   Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, I visit with Kristy Grant-Hart, founder of Spark Compliance Consulting and author of now three books in the compliance arena. We discuss her most recent book “How to Have a Wildly Successful Career in Compliance", which will be released on Amazon.com on June 19. For those of you who have seen Kristy speak you know she is high energy and very passionate about compliance and the com...

Everything Compliance is the only roundtable podcast in compliance, with four of the top compliance practitioners around. This week the gang returns to its four focused topics on its Four of a Kind edition. After the commentary we follow with rants. Learn more about your ad choices. Visit megaphone.fm/adchoices

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 and I take a deep dive back into the issue of the decline in Initial Public Offerings (IPOs). Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, I visit with Rick Pearl, the Global Corporate Responsibility Officer and Vice President of Corporate Citizenship at State Street Corp. We discuss the 2017 State Street Corporation, Corporate Responsibility Report. Learn more about your ad choices. Visit megaphone.fm/adchoices

With a wild ride of FCPA cases over the past week, Jay Rosen and myself are back in the FCPA saddle  again to take a look at some of the top compliance stories from the past week. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, Matt Kelly and I take a deep dive into the issue of two factor authentication of cloud-based solutions and the intersection with compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices

Today, we discuss some of the convergence between the FCPA and suspension and debarment. The bottom line is that conduct which violates the FCPA can become the basis for a suspension or debarment, even if the conduct is outside a contract with the Federal government. Learn more about your ad choices. Visit megaphone.fm/adchoices

I continue my five-part series on Suspension and Debarment, with Rod Grandon, Managing Director at Affiliated Monitors, Inc., the sponsor of this series. In this episode, we consider the differences between suspension and debarment. Learn more about your ad choices. Visit megaphone.fm/adchoices

Today, we conclude the series with a discussion of remedies and compliance in suspension and debarment. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode I visit with John Torres, the COO of Guidepost Solutions. We discuss the recent SEC enforcement action involving Yahoo and its failure to disclose data breaches in 2014, 2015 and 2016. As this was the first SEC enforcement action involving a public company for the failure to disclose to investors and shareholders information of a data breach which materially impacts an organization...

I continue my five-part series on Suspension and Debarment, with Rod Grandon, Managing Director at Affiliated Monitors. In this episode, we discuss present responsibility and its determination. Learn more about your ad choices. Visit megaphone.fm/adchoices

Today, I begin a five-part series on Suspension and Debarment, with Rod Grandon, Managing Director at Affiliated Monitors, Inc., the sponsor of this series. We start this Part I with introduction to suspension and debarment. Learn more about your ad choices. Visit megaphone.fm/adchoices

With The Complete Compliance Handbook still sitting at the top of the rankings in its first week of sales, Jay Rosen and myself take a look at some of the top compliance stories over the past week, in the we're still no.1 Edition. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, Matt Kelly and I take a deep dive into the travails of Roseanne, her television network ABC and compliance over her vile and racist tweet comparing Obama advisor Valerie Jarrad to an ape. We consider the corporate response in light of corporate ethics, values and priorities. Learn more about your ad choices. Visit megaphone.fm/adchoices

One of the challenges many compliance practitioners face when they move up in their careers is to move from tactical to strategic thinking. It is a requirement for any Chief Compliance Officer (CCO) to be able to think strategically as well as tactically but as you move up the corporate ladder, the strategic becomes more important. Strategic thinking is not something taught in law schools and in m...

Hallmark Nine of Ten Hallmarks of an Effective Compliance Program, as articulated in the 2012 FCPA Guidance, states: "a good compliance program should constantly evolve." Learn more about your ad choices. Visit megaphone.fm/adchoices

As every compliance practitioner is well aware, third-parties still present the highest risk under the FCPA. The Department of Justice Evaluation of Corporate Compliance Programs devotes an entire prong to third-party management. Learn more about your ad choices. Visit megaphone.fm/adchoices

The 2012 FCPA Guidance stated “mergers and acquisitions present both risks and opportunities. A company that does not perform adequate FCPA due diligence prior to a merger or acquisition may face both legal and business risks. Learn more about your ad choices. Visit megaphone.fm/adchoices

One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was the performance of a root cause analysis for any compliance violation which may led to a self-disclosure or enforcement action. Learn more about your ad choices. Visit megaphone.fm/adchoices

Both incentives and discipline are critical in any best practices compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices

The call, e-mail or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin the process which will determine, in many instances, how the company will respond going forward.  Learn more about your ad choices. Visit megaphone.fm/adchoices

With The Complete Compliance Handbooksitting at the top of the rankings in its first week of sales, Jay Rosen and myself take a look at some of the top compliance stories over the past week.  Learn more about your ad choices. Visit megaphone.fm/adchoices

This week the gang sticks a roundtable Q&A, with a focus on the Michael Cohen imbroglio. Jay Rosen considers the lessons to be learned in hiring third-parties. Matt Kelly considers issue from the COSO angle: the control environment v. compliance activities. Mike Volkov weighs in search warrant and Bank Secrecy Act perspective. Jonathan Armstrong adds his own unique British perspective (IE., snark)...

Today we consider Subject Access Requests (SARs) under General Data Protection Regulation (GDPR). As always, I am joined in this exploration by Jonathan Armstrong, a partner in Cordery Compliance in London. SARs may turn out to be one of the most onerous, costly and time-consuming issues for companies after the go-live of GDPR on May 25, 2018. Of all the requirements of GDPR, this may be the singl...