Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, I welcome back Mary Inman, Partner at Whistleblower Partners LLC to discuss the new DOJ Whistleblower Incentive Program. 

Tom and Mary discuss the DOJ's New Whistleblower Incentive Program's aim to fill gaps in existing reward programs and its focus areas, including financial institution violations, foreign and domestic corruption, and healthcare offenses. Mary highlights some criticisms of the program, such as lack of a reward floor and the cap on rewards, and the potential challenges and impacts on corporate compliance. They also talk about the interplay between whistleblowers, DOJ, and corporate investigations, and the potential for adaptation of the program based on stakeholder feedback.

Highlights in this Episode

·       DOJ Whistleblower Incentive Program Overview

·       Four Focus Areas of the New Program

·       Challenges and Criticisms of the Program

·       Concerns About Reward Mechanisms

·       Race to DOJ: Whistleblowers vs. Corporations

·       Implications for Corporate Compliance

Resources

Mary Inman on LinkedIn

Whistleblower Partners

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. We take things in a different direction today as Tom Fox reposts the recent webinar with Sam Silverstein and Mike Volkov, where we took a deep dive into the Boeing Plea Agreement, the Monitorship, and why culture is the key to a Boeing turnaround.

We explore the recent plea agreement filed by Boeing, the outrage among victims’ families over the proposed penalties, and the appointment of an independent compliance monitor. Key issues discussed include the necessity of a culture overhaul at Boeing, the implications of excluding court jurisdiction over the monitorship, and the role of the board in fostering a culture of compliance and safety. The discussion highlights the critical need to focus on values, accountability, and transparent processes to rebuild trust and ensure long-term organizational integrity.

Highlights of this episode:

Resources:

Sam Silverstein

Mike Volkov

The Culture Audit

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this edition of the FCPA Compliance Report, Tom Fox conclude this two-part episode with Bob Tarun and Peter Tomczak from Baker & McKenzie who discuss the latest edition of their book the Foreign Corrupt Practices Act Resource Handbook.

This episode provides an in-depth exploration of Delaware law’s Caremark duties and their evolution, particularly in anti-corruption compliance. The discussion highlights the challenges boards face in implementing and overseeing compliance programs. Additionally, it delves into the intricacies of defending FCPA investigations, with insights into recent high-profile cases such as those involving Walmart, Glencore, and Goldman Sachs.

The conversation also covers the international trends in anti-bribery and corruption enforcement, particularly focusing on regions like China, Southeast Asia, and the Middle East. Key compliance strategies and the importance of cross-border data privacy considerations in investigations are discussed, along with a critical look at the DOJ’s sophistication in evaluating corporate compliance programs.

Highlights in this Episode:

Resources:

Foreign Corrupt Practices Act Handbook

Bob Tarun

Email: [email protected]

Phone: 312-714-0225

Peter Tomczak

LinkedIn

Baker & McKenzie

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox welcomes Bob Tarun and Peter Tomczak from Baker & McKenzie in Part 1 of a two-part podcast series to discuss the latest edition of their book, The Foreign Corrupt Practices Act Handbook.

The conversation covers their professional backgrounds, motivations for updating the book, and significant changes in FCPA enforcement and compliance practices. Bob and Peter provide detailed insights into their writing process and some of the key defenses for FCPA investigations. Key trends in international anti-bribery and corruption enforcement, the evolving role of corporate compliance programs, and strategies for dealing with DOJ expectations are also addressed. The episode concludes with discussions on future prognostications for FCPA enforcement and how listeners can connect with the authors.

Highlights in this Episode

Resources:

Foreign Corrupt Practices Act Handbook

Bob Tarun

Email: [email protected]

Phone: 312-714-0225

Peter Tomczak

LinkedIn

Baker & McKenzie

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox welcomes back Erica Salmon Byrne to discuss the recently released Ethisphere 2024 Ethical Culture Report: Closing the Speak Up Gap.

They explore the genesis and findings of the report, focusing on the eight pillars of ethical culture and significant insights derived from data collected since 2020. Key topics include the importance of equipping managers to handle employee concerns, generational and tenure-based discrepancies in reporting misconduct, and the persistent issues of retaliation and employee dissatisfaction with the current reporting mechanisms. Additionally, Erica shares practical strategies for compliance teams to address these challenges and enhance their ethical culture.

Highlights in this Episode

Resources:

Erica Salmon Bryne on LinkedIn

2024 Ethical Culture Report: Closing the Speak Up Gap

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom Fox welcome Jonathan Armstrong to discuss the seismic shift in the UK’s political landscape following the election last week.

The election was literally one for the ages. It led to a significant Labor victory over the Conservatives. They delve into the implications for compliance and governance in both the UK and globally. Topics include the new government’s proactive approach, anticipated shifts in bribery enforcement, and fiscal policies.

They also explore potential changes in AI regulation, employment law, data protection, and international relations, especially concerning Russia and China. The conversation highlights Labor’s balanced strategy, aiming for sensible, centrist policies while addressing key issues like corruption, AI, and data privacy.

Highlights in this Episode:

 Resources:

Jonathan Armstrong on LinkedIn

UK General Election 2024 – What Might This Mean for Compliance?

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this edition of the FCPA Compliance Report, Tom Fox welcomes back Adrienne Bellehumeur, a chartered accountant and expert in internal controls and documentation.

Adrienne discusses her recent article on design-centric internal control and emphasizes the importance of focusing on design as the foundation for effective control programs. She outlines five key principles for improving control design and details her approach to challenging processes and governance systems. The conversation also touches on the necessity of continuously updating controls to adapt to evolving business and regulatory environments.

Adrienne shares tips on fostering better design through workshops, effective interviewing, and continuous improvement, while also addressing new developments such as AI and ESG. The episode finishes with insights into how internal controls can support whistleblower programs and the importance of back-to-basics documentation and information management.

Highlights in this Episode:

 Resources:

Adrienne Bellehumeur on LinkedIn

Risk Oversight

New Approaches to Control Design

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report,  I have a take a deep dive into the Prevalent 2024 Third Party Risk Management Report with Brad Hibbert, the Chief Strategy Officer and COO at Prevalent.

Hibbert drives Prevalent’s product vision and strategy development, which draws from the Third Party Risk Management Report. The Prevalent Report outlines  the complexities of managing third-party vendor relationships, highlighting the various phases involved such as onboarding, contracting, and offboarding. It examines the inefficiencies and risks that arise from fragmented processes and technologies handled by different teams. Our conversation explores how these challenges impact risk visibility and resource management, emphasizing the downstream effects on program scalability and decision-making.

Highlights in this Episode

·       Introduction to Vendor Relationship Phases

·       Challenges in Managing Vendor Relationships

·       Inefficiencies and Risks in Vendor Management

·       Impact on Risk Visibility and Decision Making

·       Pressure on Teams and Resource Implications

Resources 

Brad Hibbert on LinkedIn

Prevalent

Prevalent’s 2024 Third Party Risk Management Report

 Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this edition of the FCPA Compliance Report, Tom Fox has a fascinating visit with Iveta (Evie) Wentink, a 15-year compliance veteran. Evie has worked in the public and private sectors and has expertise in compliance training, hotlines, government contract compliance, data privacy, reporting, & due diligence.

Evie has one of the most unique opening lines for hotline training, which is ‘Do You Know Your Hotline Number?” This simple yet incredibly important question encapsulates Evie’s approach to compliance training: make it simple, direct, and practical for the listeners. (Or, as Carsten Tams would say, ‘It’s all about the UX’).

Our conversation focuses on the critical role of hotline numbers in corporate compliance programs, emphasizing the need for employees to know and trust the hotline. Evie shares insights from her career, highlights the significance of marketing compliance hotlines effectively, and discusses the broader culture of compliance and non-retaliation in organizations. She shares practical tips for improving hotline awareness and usage, making this episode a valuable resource for compliance professionals and organizations alike.

Highlights in this Episode:

Resources

Evie Wentink on LinkedIn

Evie’s Top 10 Compliance Back to Basics

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report,  I welcome Professor Andy Spalding, an expert in anti-corruption law, to discuss his extensive work with the Paris Olympic Committee in preparation for the 2024 Olympic Games. 

Spalding shares insights about his involvement with the French Anti-Corruption Agency (AFA) and elaborates on how anti-corruption and human rights reforms are being integrated into the Olympic preparations. The discussion also delves into the historical significance of these reforms and their potential to leave a lasting positive impact. Furthermore, Fox and Spalding explore the groundbreaking work done by Qatar during the FIFA World Cup and its implications for future mega sporting events. The episode concludes with thoughts on how the accumulated knowledge and best practices from different countries could shape the future of global sporting events, emphasizing the importance of collaboration among stakeholders.

Highlights in this Episode

·       Involvement with Paris 2024 Olympics

·       Role and Impact of French Anti-Corruption Agency (AFA)

·       Innovative Compliance Measures for Paris Olympics

·       Comparison with Qatar's World Cup Reforms

·       Future of Anti-Corruption in Mega Sporting Events

Resources 

Andy Spalding at University of Richmond – School of Law

CCI Webinar on A New Era in Megasports Anti-Corruption

Tom Fox

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