Everything Compliance

The top roundtable podcast in compliance is back with Part II of the Post Harvey edition. 

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The top compliance roundtable podcast is back with another episode of Everything Compliance. 

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In this episode, the Everything Compliance trio of Matt Kelly, Jay Rosen and Tom Fox unpack our first book review. We consider the recently released The Chickenshit Club by Jesse Eisenger and it may mean for the compliance practitioner.

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We take things a different way in this episode as the commentators throw out five topics for consideration by the group. Last week we had topics from Jay and Matt; this week from Jonathan and Tom.  

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Show Notes for Everything Compliance-Episode 14

Topics from Matt:

Trump Administration & FCPA enforcement— we have two declinations now; maybe a compare-and-contrast, and speculation on what a tough Trump Admin enforcement WOULD look like;EU’s GDPR— Do EU regulators really know what they want to do with enforcement of this law; although if they follow the lead of the anti-competition people whacking Google, it could be a big deal; Hui Chen’s departure from Justice Department; both her public rebuke of Trump, and the substance of how she believes her guidance has been mis-interpreted; andEthical leadership and the lack thereof; the menace of abusing perks and privilege, connecting my posts about Uber’s leaders and Chris Christie vacationing on a closed beach.Topics from Jay:

How do the Campaign Finance Laws mirror/or differ from the FCPA?Will the Russian Collusion Investigation reveal the ultimate FCPA violation?Regarding Walter Shaub’s departure from Office of Governmental Ethics (OGE), does it matter? What is OGE supposed to do and why did it work for the past 40+ years, but fell on deaf ears with the Trump administration?Dovetailing with Matt’s question about a slow H1 for FCPA enforcement and in light of the just released Gibson Dunn FCPA Mid-Year Report, does the current climate (and lack of vigorous enforcement) provide a perfect storm for companies to look the other way if they fall off the E&C wagon, or do we think that companies are still being vigilant in spite of a perception of decreased enforcement?Rants are at the end of this week’s episode.

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The top compliance roundtable podcast is back with a wealth of new topics. Stayed tuned to the end where there are some heartfelt and somber rants in this edition. Matt Kelly opens with a discussion on Uber from the policies and procedures framework. Matt rants on the danger of overly legalistic approaches to compliance. For Matt Kelly’s posts on Uber and the intersection of policies and procedures, see the following:

 What Uber Teaches About Culture & Policy Management

 Car Crash Governance at UberMike Volkov considers blockchain and how it will impact compliance going forward. For Mike Volkov’s post on blockchain and compliance, see the following:

Blockchain and the Future of Compliance

For reading on blockchain and compliance, see the following:

Will Blockchain Transform Compliance? by Tom Fox

How Blockchain Will Change Organizations, by Don Tapscott and Alex Tapscott in MIT Sloan Business Review.

Blockchain Explained, by Zach Church in MIT Sloan Management Review. Jonathan Armstrong considers the trend of fake news and mis-information around GDPR. Jonathan most somberly rants on the Grenfell towers disaster. For the Cordery Compliance client alert see the following:

GDPR ‘Fake News’ Jay Rosen brings a detailed discussion FCPA sabermetrics in the context of of the dearth of FCPA cases brought forward under the Trump Administration and Session Justice Department. He considers the numbers, the continuing departures of numerous Justice Department career employees and new political appointees as well. Jay rants on breaking news. For Jay Rosen’s posts see the following:

The members of the Everything Compliance panel include:Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at [email protected]Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at [email protected].Matt Kelly – Founder and CEO of Radical Compliance, is the former Editor of Compliance Week. Kelly can be reached at [email protected]Jonathan Armstrong – Rounding out the panel is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at [email protected]

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The dog days of summer are on the horizon and the Houston Astros lead the major leagues in winning percentage. Coincidence that the US pulls out of the Paris Climate Accords the same week the Astros are playing .700 baseball? The top four commentators in compliance return to talk about what is one their summer radar for consideration. This episode concludes with the panelists’ rants. 

For Matt Kelly’s posts on the COSO ERM Framework, see the following:

More Details on COSO ERM Framework

Update to COSO ERM Framework Update

ERM Framework: Govt. Calls for Unity

More Clues on Draft ERM Framework

Draft ERM Framework is Here: How to Get Started 

For Mike Volkov’s post see on the Haidar enforcement action, see the following:

MoneyGram CCO Pays Civil Penalty

For Cordery Compliance's Client Alert see the following:

Bribery Due Diligence

For Jay Rosen’s posts see the following:

  Compliance as a Competitive Advantage

For Tom Fox’s posts on operationalization of compliance see the following:

 Operationalizing Compliance, starting with Pizza

Operationalizing Compliance by Overcoming Obstacles

 Operationalizing Compliance through Human Resources

Operationalizing Compliance through the Controller’s Office

Operationalizing Compliance through Internal Audit

The members of the Everything Compliance panel include:Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at [email protected]Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at [email protected].Matt Kelly – Founder and CEO of Radical Compliance, is the former Editor of Compliance Week. Kelly can be reached at [email protected]Jonathan Armstrong – Rounding out the panel is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at [email protected]

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In this second of a two-part series, we conclude the panel’s discussion of the first 100 days of the Trump administration as it relates to compliance. This episode concludes with the panelists’ rants.

For Matt Kelly’s posts see the following:

Compliance in the Trump Era: More Markers Placed

Trump Administration Whacks Telco Firm for $892 Million

Drone Industry Pan Trump’s Regulatory

Trump Risk Disclosures Start Rolling In

First SEC Whistleblower Award of Trump Era

Sessions Dodges, Weaves, Promises on FCPA

For Mike Volkov’s posts see the following:

Yates, AG Sessions and Individual Criminal Prosecutions

New E-Book — Moving the Goalposts: The Justice Department Redefines Effective Compliance

FCPA Remediation Focus on Supervisory Personnel

FPCA Pilot Program Motors On

For the Cordery Compliance client alerts see the following:

EU conflicts minerals compliance legislation

DOJ Evaluation of Corporate Compliance: how does it compare to UK Bribery Act 2010?

For Jay Rosen’s posts see the following:

Still in the Enforcement Business and Evaluation of Corporate Compliance Programs

“It Was the Best of Times, It was the Worst of Times,” or “Ignorance is Strength”

For Tom Fox’s posts see the following:

The Trump Administration-Kaos is Bad for Business

The Trump Administration-Failures in Leadership and Management

The Trump Administration-Preparing for a Catastrophe

The Trump Administration-the Business Response

DOJ Enforcement of the FCPA and the International Fight against Corruption in the Trump Administration

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This episode is the first of a two-part series of podcasts dedicated to the chaotic (at best) first 100 days of the Trump administration as it related to compliance. Today we have Jonathan Armstrong and Jay Rosen. Next week Matt Kelly and Mike Volkov.

For Matt Kelly’s posts see:

Compliance in the Trump Era: More Markers Placed

Trump Administration Whacks Telco Firm for $892 Million

Drone Industry Pan Trump’s Regulatory

Trump Risk Disclosures Start Rolling In

First SEC Whistleblower Award of Trump Era

Sessions Dodges, Weaves, Promises on FCPA

For Mike Volkov’s posts see the following:

Yates, AG Sessions and Individual Criminal Prosecutions

New E-Book — Moving the Goalposts: The Justice Department Redefines Effective Compliance

FCPA Remediation Focus on Supervisory Personnel

FPCA Pilot Program Motors On

For Tom Fox’s posts on the Trump administration’s first 100 days see the following:

The Trump Administration-Kaos is Bad for Business

The Trump Administration-Failures in Leadership and Management

The Trump Administration-Preparing for a Catastrophe

The Trump Administration-the Business Response

DOJ Enforcement of the FCPA and the International Fight against Corruption in the Trump Administration

The members of the Everything Compliance panel include:Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at [email protected]Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at [email protected].Matt Kelly – Founder and CEO of Radical Compliance, is the former Editor of Compliance Week. Kelly can be reached at [email protected]Jonathan Armstrong – Rounding out the panel is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at [email protected]

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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 Episode 8 for commentary from Matt Kelly and Mike Volkov.   

Still in the Enforcement Business and Evaluation of Corporate Compliance ProgramsUS Department of Justice on Evaluation of Corporate Compliance : how does it compare to UK Bribery Act 2010?

For Mike Volkov’s posts on the Evaluation see the following:

Under the Dark of Night, DOJ Moves the Compliance Ball;

DOJ’s Compliance Program Evaluation: the Role of the CCO;

DOJ’s Compliance Program Evaluation: Risk Assessment, Policies and       Procedures and Third-Party Risk Management; and

DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits

For Tom Fox’s posts on these topics see the following:

New DOJ Evaluation-Valuable Document for the Compliance Practitioner, Part I; and

New DOJ Evaluation-Valuable Document for the Compliance Practitioner, Part II

For Matt Kelly’s posts see the following:

Fresh FCPA Guidance from the Justice Department; and

Deeper Dive into new DoJ Compliance Guidance  

The members of the Everything Compliance panel include:Jay Rosen – Vice President of Business Development and Monitoring Specialist at Affiliated Monitors. Rosen can be reached at [email protected] Volkov – One of the top FCPA commentators and practitioners around, Volkov is the Founder and Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at [email protected].Matt Kelly – Founder and CEO of Radical Compliance and former Editor of Compliance Week. Kelly can be reached at [email protected].Jonathan Armstrong – Rounding out this distinguished panel is our UK colleague, a lawyer with Cordery Compliance in London. Armstrong can be reached at [email protected].

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