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Day 18 of One Month to a Operationalizing Your Compliance Program-Through Management of 3rd Party Relationships [Video]

The Department of Justice Evaluation of Corporate Compliance Programs states, in Prong 10, Third Party Relationships: Management of Relationships – How has the company considered and analyzed the third party’s incentive...more

Everything Compliance-Episode 9, DOJ Evaluation of Corporate Compliance Programs, Part II [Video]

This episode is dedicated to the Justice Department’s Evaluation of Corporate Compliance Programs, which was released in February. In this episode, Jay Rosen and Jonathan Armstrong provide next insight. Listen to last week’s...more

FCPA Compliance Report-Episode 316-Kristy Grant-Hart & a debate on ISO 37001 Certification [Video]

In this episode Kristy Grant-Hart, author of How to be a Wildly Successful Compliance Officer, joins me to debate the merits of the ISO 37001 certification. I think the process is worse than useless while Kristy believes it...more

FCPA Compliance Report-Episode 317-Susan Divers on LRN 2016 Compliance Program Effectiveness Report [Video]

In this episode, I visit with Susan Divers on the recently released LRN Ethics and Compliance Program effectiveness report. ...more

Compliance Report-International Edition, Carlos Ayres [Video]

In this episode i visit with Brazilian compliance practitioner Carlos Ayres on recent developments in Brazil and South America in the ongoing fight against bribery and corruption....more

This Week in FCPA-Episode 44-the St. Patrick's Day Edition [Video]

In this episode, Jay and I have a wide-ranging discussion on the intersection of culture and ethics. We discuss: 1. German authorities raid at VW investigation counsel, Jones Day, offices in Germany and what it may portend...more

Everything Compliance-Episode 8, DOJ Evaluation of Corporate Compliance Programs, Part I [Video]

This episode is dedicated to the Justice Department’s Evaluation of Corporate Compliance Programs, which was released in February. In this episode, Matt Kelly and Mike Volkov provide next insight. Next week will be views from...more

Day 11 of One Month Operationalizing Your Compliance Program-Internal Control Objectives [Video]

Today I explore in some detail the first Objective in the COSO 2013 Framework-the Control Environment as a path to operationalize your compliance program. This Objective lays out five steps you can take to put the...more

Compliance into the Weeds-Episode 32 [Video]

In this episode, Matt Kelly and I take a deep dive into a dramatic 48 hours in the life of the FCPA last week, which portends the trend of continued FCPA enforcement. It included the announcement by Kevin Blanco, acting...more

FCPA Compliance Report-Episode 315-James Koukios [Video]

In this episode, I visit with Morrison & Forrester partner James Koukios on the firm's January issue of the top global anti-corruption storylines. ...more

Day 10 of One Month to Operationalizing Your Compliance Program-the Role of Payroll in Compliance  [Video]

The role of global payroll in FCPA compliance is not often considered in operationalizing your compliance program, yet the monies to fund bribes in violation of the FCPA must come from somewhere. Unfortunately, one of those...more

FCPA Compliance Report-Episode 314-John Champion on 50th Anniversary of Star Trek [Video]

In this episode, I have back John Champion, one-half of the podcast duo going through every Star Trek TV episode and movie at missionlogpodcast.com. Today, I visit with John on his reflections on the 50th anniversary of Star...more

Day 9 of One Month to Operationalizing Your Compliance Program-Connected Compliance [Video]

If there is one over-riding theme from the recently released Evaluation of Corporate Compliance programs it is that a corporate compliance program must be operationalized. Indeed that is the theme of this month’s series of...more

Day 7 of One Month to Operationalizing Your Compliance Program-Risk Based Monitoring [Video]

I continue my discussion of operationalizing your compliance program through the risk management process by considering risk-based monitoring. I continue this series based upon interviews with Ben Locwin, Director of Global...more

FCPA Compliance Report-Episode 313-Adam Davidson on Donald Trump's Worst Deal [Video]

In this episode, I visit with New Yorker reporter Adam Davidson, who penned an article in the New Yorker which looked at a hotel deal between the Trump organization and a family of Politically Exposed Persons (PEPs) in...more

Day 6 of One Month to Operationalizing Your Compliance Program-Risk Assessments [Video]

The DOJ Evaluation of Corporate Compliance Programs states: • Risk Management Process – What methodology has the company used to identify, analyze, and address the particular risks it faced? • Information Gathering and...more

FCPA Compliance Report-Episode 312-Ben Locwin on risk based monitoring [Video]

In this part III of a three part series on the risk management process, I continue to visit with risk management process expert Ben Locwin. ...more

French Anti-Corruption Law Reform

Despite signing the OECD anti-corruption Convention in 1997, France has long been perceived as lacking necessary tools for domestic and international anti-corruption enforcement, particularly in comparison to the US Foreign...more

Day 5 of One Month to Operationalizing Your Compliance Program-Forecasting [Video]

In this podcast, I consider the first step in the risk management process, forecasting and how it can work to operationalize your compliance program. ...more

Day 4 of One Month to Operationalizing Your Compliance Program-Root Cause Analysis [Video]

From the DOJ Evaluation of Corporate Compliance Programs 1. Analysis and Remediation of Underlying Misconduct Root Cause Analysis – What is the company’s root cause analysis of the misconduct at issue? What systemic...more

Day 12 of One Month Operationalizing Your Compliance Program-Compliance Oversight Committee [Video]

The operationalization of your compliance programs means how deeply is compliance integrated into the function of your company. Today, I want to consider another way to operationalize compliance through the Compliance...more

This Week in FCPA-Episode 42-the Oscars Edition [Video]

Jay Rosen and I dedicate the entire episode to the FUBAR surrounding the Oscar ceremony where the Best Picture award was given to the wrong picture. We consider the control failures around the incident, look at it from a...more

Day 3 of One Month to Operationalizing Your Compliance Program-DOJ Evaluation on Operationalizing Compliance, Part II [Video]

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section in February. The document is an 11-part list of questions which...more

Day 2 of One Month to Operationalizing Your Compliance Program-DOJ Evaluation on Operationalizing Compliance, Part I [Video]

The Evaluation of Corporate Compliance Programs, most generally, follows the DOJ and Securities and Exchange Commission’s (SEC) seminal Ten Hallmarks of an Effective Compliance Program, released in the 2012 FCPA Guidance. If...more

U.S.’s Announcement on Welcoming Fintech Companies as Special Purpose Banks: Implication on Hong Kong’s Deposit-taking...

On 2 December 2016, the Office of the Comptroller of the Currency (“OCC”) in the U.S. announced its intention to take applications from fintech companies that wish to obtain a special purpose national bank charter (“The...more

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