FCPA Compliance Report

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In the latest episode of FCPA Compliance Report, Maria D'Avanzo from Traliant to returns to discuss the essential role of outside counsel in FCPA investigations and the challenges that a CCO may face. They believe having trusted counsel with business acumen and commercial knowledge is vital, especially when discovering potential violations outside the initial scope of the investigation. Maria shares her experience working with the CEO and chair of the audit committee and offers great tips for compliance professionals learning to trust their gut. Additionally, the speakers talk about the importance of self-disclosure and applying disciplinary actions equally across different jurisdictions in cases of misconduct. This explosive discussion is full of insights, advice, and best practices, making it a must-listen for anyone looking to improve their organization's compliance standards. You won't want to miss it!

Key Highlights

·      Managing Whistleblower Complaints: Next Steps and Importance of Outside Counsel

·      FCPA Investigation Best Practices

·      Navigating investigations outside of initial scope

·      Navigating Compliance Decision-Making

·      Internal Disciplinary Processes and Corporate Compliance

·      Supervised learning and DOJ cooperation challenges

·      The decision (or not) to self-disclose

Resources

Maria D’Avanzo on LinkedIn

Traliant

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In the latest episode of FCPA Compliance Report, Tom Fox speaks with Parijat Jauhari and Susan Divers, both with LRN, about their new tool, Catalyst Reveal, which helps compliance professionals deal with the new DOJ requirements around culture assessment, risk management, monitoring, and improvement. They explain how Catalyst Reveal goes beyond traditional methods of measuring the effectiveness of compliance training and that the platform includes completion data, culture data, and learner sentiment analysis to determine training effectiveness.  

They also discuss the importance of benchmarking, which allows for easy comparison of clients within the same industry and revenue band. Plus, find out about their upcoming additions to their product and how it can provide solutions to challenges posed by the Department of Justice. Tune in now to discover how Catalyst Reveal can help compliance professionals fulfill their obligations under the 2023 Evaluation of Corporate Compliance Programs. 

Key Highlights

·      Measuring Ethical Culture

·      Enhancing Compliance Training Effectiveness 

·      Challenges in measuring training impact

·      Data Analytics in Compliance Training

·      Benchmarking and Data-driven compliance training 

Notable Quotes

“This is the most exciting development in this space in all the time that I've been working in ethics and compliance because it allows companies and chief ethics and compliance officers and their teams to move beyond what I would call dead data.”

“The culture pulse survey that we've included in this which is the ethical culture pulse survey. That's its full title. It asks questions in real time about levels of engagement from the employee base and levels of respect levels of transparency, levels of organizational justice. And that that is a breakthrough.”

“What this tells you is it goes beyond we had a  warm seat. for this training to say, we had people take it, and a lot of people in this group really struggled with facilitation payments or with what is an actual conflict of interest. And this is an area that compliance officers really struggle with.”

“We are really using some new technology, machine learning to mine the data because it's you're accumulating it every day that employees are actually.”

Resources

Parijat Jauhari on LinkedIn

Susan Divers on LinkedIn

LRN

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Join Tom Fox on the FCPA Compliance Report as he discusses with Scott Solomon, the CEO of Operational Security Solutions (OSS), how they manage compliance and ethical considerations around cash management, particularly for high-risk customers.

In this episode, they talk about the importance of compliance in the financial industry and how OSS helps financial institutions manage their portfolio through best practices. The podcast also touches on the challenges faced by legal cannabis businesses and the gaming industry regarding compliance and cash operations. Listeners will get insights into boutique cash and transit providers’ role in navigating licensing and permitting requirements for cannabis-related cash operations. This informative podcast concludes with contact information and an eagerness to continue the conversation. Don’t miss out on the insights shared in this episode. Tune in now to FCPA Compliance Report with Tom Fox and Scott Solomon.

 Key Highlights:

Notable Quotes:

“Our primary customer or partner is a financial institution. So when you look at secure cash management and logistics, it boils down to our specialty is moving cash, and we have the ability in the compliance background to help financial institutions support their high-risk customers.”

“OSS was founded around compliance. A group of former law enforcement personnel, special military operators, and federal regulators got together and saw an opportunity to initially start by consulting.”

“We work with the customer. It doesn’t help us, and it doesn’t help the bank if the customer goes off the rails and becomes non-compliant. So, we want to educate them.”

“I come out of the anti-corruption compliance space; we’ve always looked to the casino world as one of the leaders around AML work simply because it was in their business interest to do.”

Resources

Scott Solomon on LinkedIn

Operational Security Solutions

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This episode features a special episode with guests Lisa Fine and Mary Shirley of the Great Women in Compliance podcast. Great Women in Compliance is coming up on its 200th-anniversary show and will move to GWIC 2.0. I asked the women if they would reflect on where they have been and where GWIC may be going.

In this podcast, Mary and Lisa reflect on their podcast journey, discussing their impact on their audience and themselves. They talk about their interview style, attempts to get Dolly Parton’s permission to use her song, and upcoming episodes, including adding a co-host. The podcast highlights the importance of diverse voices and perspectives and aims to make guests comfortable while maintaining a professional yet relaxed tone. Join these dynamic hosts as they share memories and tease new ideas, including a book release and round table discussions with women. Take advantage of this engaging and authentic conversation about success, imposter syndrome, and making a difference!

Key Highlights:

Notable Quotes

“As a true supporter of women, you looked at us and said, ‘Why don’t you do it?’ And suddenly, right away, it went from this thing we talked about into something bigger than both of us and turned into a book where the people interested in this shared their stories.”

“The podcast started as a hobby but has become an intricate part of our lives, not only as individuals but at least as in my life as cohosts and friends.”

“And what I think was an honor for Lisa and myself as people who aren’t necessarily on the speaking circuit, that we wanted to get the diversity of thought and new voices on the show.”

“Everybody is a thought leader. I’m talking to you because I think you’re a thought leader, and I think you’re bringing something to the table that, again, in a way, which not to make somebody feel pressured into doing it But I also think that’s how I connect with people. Whether they like it or not, this is the conversation. And this is who I am.”

Resources

Mary Shirley

Lisa Fine

Great Women in Compliance

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, Tom visits Brad Hibbert, COO/CSO at Prevalent, as they discuss the surprising findings of Prevalent’s annual third-party risk management study. Discover why so many organizations still rely on spreadsheets and manual processes for managing third-party risks. Brad recommends an integrated approach to third-party risk management that considers the entire lifecycle of the relationship with third parties.

The podcast highlights the top five key findings of the report, including data breaches as the top concern, security driving the program, and the increased involvement of IT in the process. Learn how to minimize cyber exposure and risks associated with third-party management by breaking down silos, automating processes, and focusing on reducing risks associated with third parties. Listen to Brad’s practical advice on how to prioritize risks and plan your risk management program and visit prevalent.net for more compliance mandates and best practices. With exciting insights and actionable advice, this podcast is a must-listen for anyone interested in managing third-party risks.

Key Highlights:

·      Prevalent’s annual third-party risk management study

·      Integrated Third Party Risk Management

·      Top Challenges for Organizations in Data Security

·      Third Party Risk Management Survey and Findings

·      Minimizing Cyber Breaches

·      Effective Response to Breaches and Third-Party Programs

·      Managing Business Risks for Compliance

Notable Quotes:

“The top concern driving third-party risk management programs is security, with 71 percent indicating it as their main priority.”

“Data breaches continue to be a top concern, with 41 percent of the respondents indicating that they were impacted by a third-party data breach in the last 12 months and had to perform some remedial activity.”

“About 70 percent reported increased involvement from the IT group, while 71 percent indicated that infosec owns the program.”

“Identifying and mitigating risks before the company is impacted.”

“Customs put together this enforcement dashboard that contains all of these statistics on how they’ve been enforcing the UFLPA.”

Resources

Brad Hibbert on LinkedIn

Prevalent

3Rd Party Risk Management Report

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Join Tom Fox, the host of FCPA Compliance Report, as he visits with Maria D’Avanzo, from Traliant. Maria shares invaluable insights on how companies can think through their whistleblowing policies and protocols, stressing the importance of triage in the whistleblowing process. She also reveals how they created a triage document to manage complaints of violations within the company and maintained consistency in the investigation process across different geographical areas and business units. Maria emphasizes the need for transparency and communication in dealing with situations of retaliation for whistleblowers and educating senior management on the value of whistleblowers in improving compliance programs. This episode is a must-listen for building effective whistleblowing policies and protocols. Don’t miss out on this opportunity to learn from a seasoned compliance expert. Tune in now!

 Key Highlights:

Resources

Maria D’Avanzo on LinkedIn

Traliant

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In the latest episode of FCPA Compliance Report, Tom Fox visits Virginia Newman from Miller & Chevalier, an expert on the Uyghur Forced Labor Prevention Act (UFLPA) and supply chain ESG work. Together, they discuss the UFLPA, its affirmative obligation on companies to comply with US import laws, and the burden of proof on businesses to prove their goods were not made using forced labor. Virginia shares valuable insight into the CBP’s enforcement efforts and how companies can exercise reasonable care to avoid having their goods detained. They also delve into trade compliance and third-party screening, predictive mapping, and the long-term changes companies must make to their compliance and sourcing programs. Thomas recommends Virginia as a source of knowledge on the subject because of her passion. Listen to this engaging and informative podcast to better understand the UFLPA and its impact on businesses.

Key Highlights:

Notable Quotes:

“The US government had an import prohibition for any goods made in whole or in part with forced labor.

“The US import prohibition is one of the longstanding ones that has had the most effect on companies, but it wasn’t enforced too much until about 3 years ago.”

“If your goods are coming from Xinjiang, and you accept that they’re coming from Xinjiang, Then, really, the burden is on you to prove that they’re not made with any forced labor, which is an incredibly high burden and to our knowledge importers have not been trying meet it.”

“Customs put together this enforcement dashboard that contains all of these statistics on how they’ve been enforcing the UFLPA.”

Resources

Virginia Newman on LinkedIn

Miller & Chevalier

 Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. Join Tom Fox, the host of FCPA Compliance Report, as he speaks with Candice Tal, founder and CEO of Infortal. Get ready to boost your compliance program in this exciting episode of FCPA Compliance Report. In this episode, Tom and Candice discuss the three levels of due diligence typically used to investigate joint venture partners and senior executives and the significance of conducting thorough due diligence. Level one is for low-risk situations, level two is for moderate-risk situations, and level three is for high-risk situations that require deep dark web searches. The key takeaways are to never skimp out on basic due diligence and to consider level three due diligence for high-risk areas or key executives. Don't miss out on this informative episode of FCPA Compliance Report hosted by Tom Fox and featuring Candice Tal!

 Key Highlights

·      Introduction of Candice Tal

·      What are the 3 levels of due diligence.

·      What is deep dive due diligence.

·      Finding reputational issues.

·      Evaluating due diligence.

Notable Quotes

“Due diligence typically is sorted out into 3 general levels or tiers.”

“If you're not doing deep dive due diligence, you're not finding reputational issues.”

“You just can't find reputational issues on database searches.”

Resources

Candice Tal on LinkedIn

Infortal

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Join Tom Fox, the host of FCPA Compliance Report, as he speaks with Maria D'Avanzo, Chief Evangelist Officer at Traliant about privacy issues in the US and around the world. Discover the challenges businesses face due to the lack of national law in the US, with multiple state laws led by California. Compare this to the EU, where GDPR has been in place since 2018, and similar laws have been implemented in other countries such as Singapore, Australia, and Brazil. Learn how GDPR has changed the way businesses handle privacy by making it a part of business processes. Discover the importance of consulting with a good outside counsel, especially for global privacy policy implementation.

Explore how to handle cybersecurity incidents and disclosure of information, as regulations on this topic are still developing. Hear from Maria on how to address these incidents internally and the importance of an incident response plan. Find out how collaborating with the Chief Information Security Officer is crucial in developing a specific plan for these incidents, including a group effort from various departments.

Hear about instances where organizations share confidential information or data, leading to legal backlash and damage to reputation. This section discusses the Tesla case and suggests that a broader conversation about company culture may be necessary to prevent such privacy infringements. Take advantage of this insightful podcast and tune in now to get important insights into privacy and cybersecurity from two industry experts!

Key Highlights:

·   The Evolution of Privacy Issues Post-GDPR

·   Navigating Privacy Laws and Meeting Legal Standards

·   Cybersecurity Incident Disclosure Decision Making

·   Importance of Cybersecurity Incident Response Plan

·   The Impact of Sharing Sensitive Information

Resources

Maria D’Avanzo on LinkedIn

Traliant

Tom Fox

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LinkedIn

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Join Tom Fox, the host of FCPA Compliance Report, as he speaks with Adrienne Bellehumeur, a consultant specializing in business analysis, audit, internal control programs, and effective documentation. In this episode of the FCPA Compliance Report, they discuss the secrets to smarter organizations and the importance of the 24-hour rule for documenting and retaining information. Adrienne, author of “The 24-Hour Rule,” provides practical and comprehensive techniques for dynamic documentation and pushes individuals and organizations forward through a six-step process. The discussion also covers the challenges of managing information in communication tools like Slack and WhatsApp and the need for clear repositories for future value and legal purposes. Take advantage of this informative episode and get your hands on Adrienne’s book now!

Key Highlights:

· The 24-Hour Rule: Importance of Documentation

· Dynamic documentation for managers and directors

· Mastering Successful Documentation: The Six Steps

· Effective Documentation and Data Governance

· Effective Information Management in Communication Tools

Notable Quotes:

“The 24-hour rule is what I think is the golden rule of documentation, and it’s very simple.”

“All documentation should drive back to actually pushing you personally or your organization or your team forward into a forward state to take forward action.”

“Documentation is about, and I actually believe, it’s a problem-solving technique.”

“My book is effectively a framework for better documentation where companies can assess where they’re at, look through what they have, look at I have standards I’ve developed as well.”

Resources

Adrienne Bellehumeur on LinkedIn

The 24-Hour Rule

Tom Fox

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