FCPA Compliance Report

The top compliance roundtable podcast is back with a wrap up with a review of  the first year of the Trump Administration and its impact on the compliance profession. Stayed tuned to the end for riffs and rants in this edition. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode Matt Kelly and I go meta as we podcast about another podcast that Matt posted this week on his site, Radical Compliance, where he interviewed Paul Sobel, the incoming Chairman of COSO. We discuss how Sobel sees his new role at COSO, some of the initiatives that he has in mind for the organization and how companies can use the various COSO frameworks, including the Internal Controls...

Whether you are ready or not, the EU General Data Protection Regulation (GDPR) goes live on May 25, 2018. It will impact companies doing business in London as much as any other EU legislation. To help US companies prepare, Jonathan Armstrong and myself have started a countdown to GDPR podcast. In this premier episode we discuss what is GDPR and why it is so important that you begin preparing now....

In this episode, podcast favorite James Koukios returns to discuss highlights from international anti-corruption efforts, enforcement actions and developments highlighted in Morrison and Foerster’s December report. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, Jay Rosen and I discuss some of the week's top compliance and ethics stories on the only weekly compliance podcast wrap-up. Learn more about your ad choices. Visit megaphone.fm/adchoices

One of the ongoing questions from members of Board of Directors is how to resolve the tension between oversight and managing. I recently had the opportunity to visit with Joe Howell, the Executive Vice President (EVP) of Workiva, Inc. on this subject. Howell had a short response which I thought was an excellent starting point to understand the role; put sand in the shoes of management. Learn more...

In this episode, Matt Kelly and I go into the weeds on the fascinating subject relating to the intersection of compliance and technology: AI and hotlines. We explore how this phone app can assist the compliance practitioner by using technology to overcome the inherent tension in an anonymous reporting system where the reporter may desire anonymity while the CCO wants and needs as much information...

On of the traditions of this podcast is each February, Richard Lummis and I rewatch Oscar winning movies with an eye towards the leadership lessons that might be drawn from them. It is a great way to honor the Oscars, rewatch some great old movies and garner some interesting perspectives on leadership. We continue that tradition this month as we are back with more leadership lessons from Oscar-win...

In this episode I visit with Carlos Ayres, partner at Medea, Ayres and Sarubbi in Sao Paulo. We visit on the past year in anti-corruption enforcement in Brazil and where it may lead in 2018 Learn more about your ad choices. Visit megaphone.fm/adchoices

Is Jay still in mourning over the Patriots Super Bowl loss? Find out in Episode 89 of This Week in FCPA where Jay 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

In this episode, Matt Kelly and I take a deep dive into the events which led to the resignation of Steve Wynn as the CEO and Chairman of Wynn Casinos for sexual harassment and misconduct. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode I visit with Dr. Marsha Ershaghi Hames, Managing Director, Strategy Development at LRN. We discuss the ongoing national conversation about sexual harassment which has been ongoing from Weinstein to #METOO. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this edition, Jay Rosen and I celebrate the birthdays of daughters, mothers, grandmothers and a great-grandmother in discussing the weeks top compliance and ethics stories. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode Matt Kelly and myself take a deep dive into the weeds of the recent remarks by Neomi Rao, head of the Office for Information and Regulatory Affairs (OIRA), the Administration’s top regulatory review office outlining ambitious plans for more deregulation in 2018 — including efforts to sweep independent federal agencies into her purview and to crack down on the “sub-regulatory” guida...

I next want to take a deep dive and exploration of the levels of due diligence. Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is for you to develop a mechanism to determine the appropriate level of due diligence and then implement that going forward. Learn more about your ad choice...

We previously considered the Prong in the Evaluation of Corporate Compliance Programs which was not present in the Ten Hallmarks of an Effective Compliance Program; that being root cause analysis. This addition was also carried forward as a requirement in the Department of Justice’s new FCPA Corporate Enforcement Policy. I want to consider how you should utilize the results of a root cause analysi...

Welcome to Episode 9 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on things, which actually could kill compliance in the organization. We will explore this matter in a plain language so to say and in the simple game form. Moreover, to make the podcast handy and more appealing we attach respective illustration from the Complia...

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

Your company has just made its largest acquisition ever and your Chief Executive Officer (CEO) says that he wants you to have a compliance post-acquisition integration plan on his desk in one week. Where do you begin? Learn more about your ad choices. Visit megaphone.fm/adchoices

In this special Supplemental edition Jay Rosen reports on Friday’s SCCE Southern California Regional Compliance and Ethics Conference. Learn more about your ad choices. Visit megaphone.fm/adchoices

A company that does not perform adequate FCPA due diligence prior to a merger or acquisition may face both legal and business risks. While most compliance practitioners have been long aware of the requirement in the post-acquisition context, the 2012 FCPA Guidance focused many compliance practitioners for the need to engage in robust pre-acquisition due diligence. Learn more about your ad choices....

One of the new areas articulated in the Evaluation of Corporate Compliance Programs was around payments and payroll. For the both the compliance professional and the corporate payroll function, there is a significant role for a corporate payroll function in the operationalization of a corporate compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices

As the Patriots and Eagles head to Minneapolis for Super Bowl LIII, join Tom and Jay for the week's top compliance related stories. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode I visit again with Rakhi Kumar, the Managing Director, Head of ESG and Asset Stewardship at State Street Global Advisors. We discuss the firm’s role in advocating for greater Board of Director Diversity. With a campaign which began with the ‘Fearless Girl” statue in Wall Street, to pushing companies in the US, UK, England, Canada and Japan to include more female candidates at the B...

The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance (Guidance), under Hallmark Three of the 10 Hallmarks of an Effective Compliance Program (Hallmarks), the focus was articulated by the title Oversight, Autonomy, and Resources. This Hallmark was significantly expanded in both the D...