Welcome to the only roundtable podcast in compliance. In this week’s episode, the gang looks at what 2019 might bring in the ethics and compliance field. Rants follow this week’s episode.   1. Mike Volkov considers what FCPA enforcement may look like in 2019.   2. Jay Rosen considers what 2019 might mean for the compliance practitioner and corporate compliance programs. 3. Jonathan Armstrong considers what may be some of the key developments in data privacy and data protection in the EU and UK in 2019.  4. Matt Kelly considers how the change in the US House of Representatives will increase scrutiny and oversight of companies and what this may mean for compliance professionals.   The members of the Everything Compliance panelist are:•       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. 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] The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. 

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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 (the coolest guy in compliance) and I take a deep dive into some of the difficulties around distributors in anti-corruption compliance.   Some of the highlights include: Ø The recent Polycom FCPA enforcement action highlighted several FCPA enforcement actions from 2018 involving distributors.Ø How do discounts, coupons, rebates, and sales devices circulate among your company, distributors, and end customers? Distributors present these and other issues separate from sales agents and employees.Ø What do the Sanofi and Stryker enforcement actions tell us around compliance?Ø Why does Document Document Document continue to be a mantra for anti-corruption compliance?   For additional reading see Matt’s blog posts Distributors, FCPA, and Internal Controls — Lessons for Anti-Bribery & Corruption Programsin Navex Global’s Ethics and Compliance Matters For more on the Polycom FCPA enforcement action, see Tom’s blog post, “Follow the Money Through Distributors” 

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JANUARY 23, 2019 BY TOM FOX

In today’s edition of Daily Compliance News:

·      Horsemeat scandal opens in France. (BBC)·      Theranos whistleblowers speak for transparency. (The Stanford Daily)·      What should you do (and not do) in an internal investigation Russia? (FCPA Blog)·       MasterCard spanked in Europe (to the tune of $570MM) for restricting competition. (Financial Times) 

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JANUARY 22, 2019 BY TOM FOX

In today’s edition of Daily Compliance News:

·      Google is fine $57 MM for GDPR violations by French regulators. (Washington Post) ·      OECD to evaluate Ireland’s anti-corruption laws. (Irish Times)·      Oxford University turns down research dollars from Huawei. (Houston Chronicle)·       Is the NFL losing the integrity of the game? (Sports Illustrated)

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This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI) I have visited with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We have been reviewing the Department of Justice (DOJ) announcements over the past year and back to the FCPA Corporate Enforcement Policy, announced in November 2017, to consider what strategies companies can use based upon these documents. Over the series we have explored what companies can do both internally and externally to incorporate the Benczkowski Memo (the “Memo”) and other DOJ guidance into their corporate compliance programs. In our concluding episode, we discuss proactive monitoring, which demonstrates the benefits of using a third party to fulfill the compliance mandates that have been laid out by the DOJ

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This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) announcements over the past year and back to the FCPA Corporate Enforcement Policy, announced in November 2017, to consider what strategies companies can use based upon these documents. Over this series we have explored what companies can do both internally and externally to incorporate the Benczkowski Memo (the “Memo”) and other DOJ guidance into their organizations. In Episode 4, we discuss how the new DOJ Guidance from 2018 on Foreign Corrupt Practices Act (FCPA) compliance can be used as both a sword and a shield.  

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This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) announcements over the past year and back to the FCPA Corporate Enforcement Policy, announced in November 2017, to consider what strategies companies can use based upon these documents. Over this series we will explore what companies can do both internally and externally to incorporate the Benczkowski Memo (the “Memo”) and other DOJ guidance into their organizations, show how to use a strong compliance program as both a sword and a shield and the benefits of using a third-party to fulfill the compliance mandate. In Episode 2, I consider with DiCianni how companies can use this information internally to bolster their compliance programs. 

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What is one of the most fulfilling audit assignments of a 30+ year audit professional? His audit at the San Diego Zoo. In this episode of the FCPA Compliance Report, I visit with internal auditor Jim Garcia, whose career has spanned work from the FCPA to fraud to gap analysis of internal controls. He talks about his career and his audit work at the San Diego Zoo.  In this podcast we discuss: Jim’s lengthy professional background in internal audit and fraud prevention.Why was he asked to audit the San Diego Zoo?How does auditing a non-profit, with multiple stakeholders and interest groups differ from auditing a commercial entity?What are the high-risk areas for a zoo?How did the San Diego Zoo remediate its gaps in internal controls. What were some of Jim’s FCPA audits? See Jim Garcia’s professional profile here.

Jim can be reached at [email protected]

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This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) announcements over the past year and back to the FCPA Corporate Enforcement Policy, announced in November 2017, to consider what strategies companies can use based upon these documents. Over the next five podcasts we will explore what companies can do both internally and externally to incorporate the Benczkowski Memo (the “Memo”) and other DOJ guidance into their organizations, show how to use the Memo as both a sword and a shield and the benefits of using a third-party to fulfill the compliance mandate. In Episode 1, we introduce the Memo and new DOJ announcements over the past year and what they mean for the compliance practitioner. 

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This week, in a podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI. We look at the Department of Justice (DOJ) announcements over the past year and back to the FCPA Corporate Enforcement Policy, announced in November 2017, to consider what strategies companies can use based upon these documents. DiCianni and I have considered how companies can use this information internally to bolster their compliance programs and today we consider this same issue from the external perspective.  

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