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FCPA Compliance Report

Thomas Fox

2
Followers
13
Plays
FCPA Compliance Report

FCPA Compliance Report

Thomas Fox

2
Followers
13
Plays
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About Us

The FCPA Compliance Report is the longest running podcast in the in compliance and business ethics. Join its by its award-winning host, Tom Fox, the Voice of Compliance as he visits with top compliance practitioners, key figures from business, the government and law firms in the top podcast dedicated to all things compliance.

Latest Episodes

Gar Hurst on Biggest Import Issue You Have Never Heard About

In this episode, I visit with Gar Hurst a partner at Givens and Johnston. Gar and the firm specialize on import control issues. Today we take a major issue that is bedeviling companies in the Port of Houston and elsewhere, wood packaging issue. We explore why it is the biggest threat to importations you have never heard about. It turns out that import laws and regulations have substantial impact on export control, AML and ABC compliance. What are wood packaging violations? What is covered by Wood Packaging regulations? What are violations and what are Emergency Actions Notices? What remedies are allowed in the US and when must you go internationally for remediation? What are potential penalties. How can you engage in prevention? See Gar Hurst’s professional profilehere. See the firm of Givens and Johnston’s profilehere. Learn more about your ad choices. Visit megaphone.fm/adchoices

30 min5 d ago
Comments
Gar Hurst on Biggest Import Issue You Have Never Heard About

Carrie Penman on Beyond the Moment

In this podcast, I am joined I am joined by Carrie Penman, Chief Risk and Compliance Officer at NAVEX Global, Inc. We visit about their upcoming 2020 virtual conference, NAVEX Next, which is entitled Beyond the Moment. The theme, Beyond the Moment, defines the 2020 agenda and supports sessions that will help you and your organization move past a defensive stance on current events and trends. The goal is to help everyone be proactive and more holistic in their approach to risk and compliance management. If there is one key message that I have garnered in talking to compliance and other professionals about Coronavirus is that the future demands we be prepared, no matter what comes next. What are some of the key themes for this conference? Obviously the Coivd-19 lockdowns, work from home and remote working environments have changed a large number of risk factors that every Chief Compliance Officer (CCO) needs to consider from a risk perspective and address from a variety of angles; such as data privacy/protection, communications and training and ongoing engagement. Last year, NAVEX’s virtual conference had over 9,000 registrants. Best of all is the cost of the conference, its FREE. That is right, all of the above is available at no charge. NAVEX Global has submitted the conference to the Compliance Certification Board (CCB) and is pending their review for approval of CCB CEUs. It will be held Thursday, October 22, from 10 AM to 4 PM Central Time.I hope that you will plan to join me for this great event. Registration, agenda and other information are availablehere. Learn more about your ad choices. Visit megaphone.fm/adchoices

21 min1 w ago
Comments
Carrie Penman on Beyond the Moment

Wirecard Part 9, Running to Fraud with Hermes

In our continuing series, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors.Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and international law.She is accustomed to working on extremely sensitive and high-profile matters, both nationally and internationally.In this episode, we explore the money laundering Wirecard engaged in via the project dubbed ‘Hermes’. Some of the highlights include: ·Weekly news wrap-up on Wirecard. ·What has this done to the German political scene? ·Any talk about BaFin reforms? ·How do losses reach €20bn? ·How was the investigation “unrelated to the mandate”? ·Money laundering through Hermes. Learn more about your ad choices. Visit megaphone.fm/adchoices

53 min1 w ago
Comments
Wirecard Part 9, Running to Fraud with Hermes

The FinCen Papers

In this podcast, I am joined by Piero Molinario, Senior Managing Director, Head of Financial Crimes Risk and Compliance for EMEA for K2 Intelligence FIN and Joanne Taylor, Managing Director, K2 Intelligence FIN who works with clients investigations and financial crime compliance, including fraud risk management, anti-bribery and corruption, regulatory enforcement, and fraud investigations. Both are located in London. We take a deep dive into the FinCen Papers. Some of the highlights include: What are the FinCen Papers? What is the significance of their release? Does this release hurt financial institutions? Does it hurt the regulators? Do the FinCEN Papers show there is more work to be done? Are there any positive takeaways from the release of the FinCEN papers? For more information on K2 Intelligence FIN, check out their websitehere. For additional reading see the white paper,The FinCEN Files Impatiently Bypasses Government Entities Responsible for Acting on SARs Filings. See also the following policy,Policy Alert: ICIJ Leaked SAR Investigation Highlights Opportunity for BSA/AML Reform, 25 September 2020 Learn more about your ad choices. Visit megaphone.fm/adchoices

25 min1 w ago
Comments
The FinCen Papers

Jonathan Armstrong on Herbalife from a UK Perspective

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own uniqueperspectives to this settlement. In this concluding Part 5, I am joined by Jonathan Armstrong and we discuss the enforcement action from the UK perspective under the UK Bribery Act. Some of the highlights include: ·China is a known high-risk business venue. ·Licenses are required in China for direct sales. ·UK Bribery Act not as concerned with the blurring of public and private officials. ·Scottish cases provide some interesting analogies. Learn more about your ad choices. Visit megaphone.fm/adchoices

14 min2 w ago
Comments
Jonathan Armstrong on Herbalife from a UK Perspective

Jonathan Marks on the Role of Gatekeepers

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own uniqueperspectives to this settlement. In this Part 4, Jonathan Marks and Tom Fox discuss the role of gatekeepers and the lack of skepticism at the Board of Directors. Some of the highlights include: ·Chief Audit Executive and Chief Compliance Officer exits should be 8K events. ·Who guards the gatekeepers? ·The Board is responsible for management override of controls. ·Why was there a lack of skepticism at the Board level? Learn more about your ad choices. Visit megaphone.fm/adchoices

11 min2 w ago
Comments
Jonathan Marks on the Role of Gatekeepers

Compliance Book Club Interview of Robert Chesnut on Intentional Integrity

In this special edition, I am pleased to cross-post a recent live event hosted by Sean Freidlin, Director Product Marketing at SAI Global. He hosted the third edition of SAI Global’s Compliance Book Club, featuring Robert Chesnut, author of Intentional Integrity. Sean's Compliance Book Club is fast becoming one of the most listened to events in the compliance world. His interview with Robert Chesnut is great information for the compliance professional. Sean graciously allowed me to cross-post this interview as a podcast on the Compliance Podcast Network. SAI Global’s Compliance Book Club is a community initiative that brings ethics, compliance, and risk professionals together around a book you’ll love, and invites everyone to participate in a live Q&A and discussion with the author.For the third meeting, and as part of our celebration of the fifth annual International Compliance Officer Day, we present“Intentional Integrity: How Smart Companies Can Lead an Ethical Revolution” by Robert Chesnut. In Intentional Integrity, Chesnut offers a six-step process for leaders to foster and manage a culture of integrity at work. He explains the rationale and legal context for the ethics and practices, and presents scenarios to illuminate the nuances of thinking deeply and objectively about workplace culture. You can check out Sean's original recordinghere. Check out the full panoply of SAI Global Ethical Leadership Articles and Resourceshere. Learn more about your ad choices. Visit megaphone.fm/adchoices

62 min2 w ago
Comments
Compliance Book Club Interview of Robert Chesnut on Intentional Integrity

Wirecard Part 9, Bring Lawyers Guns and Money

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors.Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and international law.She is accustomed to working on extremely sensitive and high-profile matters, both nationally and internationally. In this episode, we explore those other professional service providers who enabled Wirecard in our bring Lawyers Guns and Money episode . Some of the highlights include: Weekly news wrap-up on Wirecard Is EY at its Arthur Anderson moment? Who has potential lawsuits against EY? Is a Bundestag inquiry in the works? Will there be an EU-level inquiry into the German government response? Who were the Enablers? Why is now the time for lawyers to take a stand for the Rule o...

39 min2 w ago
Comments
Wirecard Part 9, Bring Lawyers Guns and Money

Matt Kelly on the Role of Internal Audit

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own uniqueperspectives to this settlement. In this Part 3, Matt Kelly joins me to consider the role internal audit in this matter and the (non) actions of Herbalife’s Board of Directors. Some of the highlights include: Internal Audit as window dressing does not good government make. How high up must internal audit push? What is the Board’s duty? Is there a Caremark claim against the Herbalife Board of Directors? Learn more about your ad choices. Visit megaphone.fm/adchoices

12 min2 w ago
Comments
Matt Kelly on the Role of Internal Audit

Jay Rosen on the Lack of Monitorship

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own uniqueperspectives to this settlement. In this Part 2, Jay Rosen joins me to consider how Herbalife was able to avoid a Monitorship. Some of the highlights include: ·The Benczkowski Memo. ·The need for full disclosure and candor. ·Remediate extensively. ·End of monitorships as we know them? Learn more about your ad choices. Visit megaphone.fm/adchoices

9 min2 w ago
Comments
Jay Rosen on the Lack of Monitorship

Latest Episodes

Gar Hurst on Biggest Import Issue You Have Never Heard About

In this episode, I visit with Gar Hurst a partner at Givens and Johnston. Gar and the firm specialize on import control issues. Today we take a major issue that is bedeviling companies in the Port of Houston and elsewhere, wood packaging issue. We explore why it is the biggest threat to importations you have never heard about. It turns out that import laws and regulations have substantial impact on export control, AML and ABC compliance. What are wood packaging violations? What is covered by Wood Packaging regulations? What are violations and what are Emergency Actions Notices? What remedies are allowed in the US and when must you go internationally for remediation? What are potential penalties. How can you engage in prevention? See Gar Hurst’s professional profilehere. See the firm of Givens and Johnston’s profilehere. Learn more about your ad choices. Visit megaphone.fm/adchoices

30 min5 d ago
Comments
Gar Hurst on Biggest Import Issue You Have Never Heard About

Carrie Penman on Beyond the Moment

In this podcast, I am joined I am joined by Carrie Penman, Chief Risk and Compliance Officer at NAVEX Global, Inc. We visit about their upcoming 2020 virtual conference, NAVEX Next, which is entitled Beyond the Moment. The theme, Beyond the Moment, defines the 2020 agenda and supports sessions that will help you and your organization move past a defensive stance on current events and trends. The goal is to help everyone be proactive and more holistic in their approach to risk and compliance management. If there is one key message that I have garnered in talking to compliance and other professionals about Coronavirus is that the future demands we be prepared, no matter what comes next. What are some of the key themes for this conference? Obviously the Coivd-19 lockdowns, work from home and remote working environments have changed a large number of risk factors that every Chief Compliance Officer (CCO) needs to consider from a risk perspective and address from a variety of angles; such as data privacy/protection, communications and training and ongoing engagement. Last year, NAVEX’s virtual conference had over 9,000 registrants. Best of all is the cost of the conference, its FREE. That is right, all of the above is available at no charge. NAVEX Global has submitted the conference to the Compliance Certification Board (CCB) and is pending their review for approval of CCB CEUs. It will be held Thursday, October 22, from 10 AM to 4 PM Central Time.I hope that you will plan to join me for this great event. Registration, agenda and other information are availablehere. Learn more about your ad choices. Visit megaphone.fm/adchoices

21 min1 w ago
Comments
Carrie Penman on Beyond the Moment

Wirecard Part 9, Running to Fraud with Hermes

In our continuing series, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors.Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and international law.She is accustomed to working on extremely sensitive and high-profile matters, both nationally and internationally.In this episode, we explore the money laundering Wirecard engaged in via the project dubbed ‘Hermes’. Some of the highlights include: ·Weekly news wrap-up on Wirecard. ·What has this done to the German political scene? ·Any talk about BaFin reforms? ·How do losses reach €20bn? ·How was the investigation “unrelated to the mandate”? ·Money laundering through Hermes. Learn more about your ad choices. Visit megaphone.fm/adchoices

53 min1 w ago
Comments
Wirecard Part 9, Running to Fraud with Hermes

The FinCen Papers

In this podcast, I am joined by Piero Molinario, Senior Managing Director, Head of Financial Crimes Risk and Compliance for EMEA for K2 Intelligence FIN and Joanne Taylor, Managing Director, K2 Intelligence FIN who works with clients investigations and financial crime compliance, including fraud risk management, anti-bribery and corruption, regulatory enforcement, and fraud investigations. Both are located in London. We take a deep dive into the FinCen Papers. Some of the highlights include: What are the FinCen Papers? What is the significance of their release? Does this release hurt financial institutions? Does it hurt the regulators? Do the FinCEN Papers show there is more work to be done? Are there any positive takeaways from the release of the FinCEN papers? For more information on K2 Intelligence FIN, check out their websitehere. For additional reading see the white paper,The FinCEN Files Impatiently Bypasses Government Entities Responsible for Acting on SARs Filings. See also the following policy,Policy Alert: ICIJ Leaked SAR Investigation Highlights Opportunity for BSA/AML Reform, 25 September 2020 Learn more about your ad choices. Visit megaphone.fm/adchoices

25 min1 w ago
Comments
The FinCen Papers

Jonathan Armstrong on Herbalife from a UK Perspective

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own uniqueperspectives to this settlement. In this concluding Part 5, I am joined by Jonathan Armstrong and we discuss the enforcement action from the UK perspective under the UK Bribery Act. Some of the highlights include: ·China is a known high-risk business venue. ·Licenses are required in China for direct sales. ·UK Bribery Act not as concerned with the blurring of public and private officials. ·Scottish cases provide some interesting analogies. Learn more about your ad choices. Visit megaphone.fm/adchoices

14 min2 w ago
Comments
Jonathan Armstrong on Herbalife from a UK Perspective

Jonathan Marks on the Role of Gatekeepers

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own uniqueperspectives to this settlement. In this Part 4, Jonathan Marks and Tom Fox discuss the role of gatekeepers and the lack of skepticism at the Board of Directors. Some of the highlights include: ·Chief Audit Executive and Chief Compliance Officer exits should be 8K events. ·Who guards the gatekeepers? ·The Board is responsible for management override of controls. ·Why was there a lack of skepticism at the Board level? Learn more about your ad choices. Visit megaphone.fm/adchoices

11 min2 w ago
Comments
Jonathan Marks on the Role of Gatekeepers

Compliance Book Club Interview of Robert Chesnut on Intentional Integrity

In this special edition, I am pleased to cross-post a recent live event hosted by Sean Freidlin, Director Product Marketing at SAI Global. He hosted the third edition of SAI Global’s Compliance Book Club, featuring Robert Chesnut, author of Intentional Integrity. Sean's Compliance Book Club is fast becoming one of the most listened to events in the compliance world. His interview with Robert Chesnut is great information for the compliance professional. Sean graciously allowed me to cross-post this interview as a podcast on the Compliance Podcast Network. SAI Global’s Compliance Book Club is a community initiative that brings ethics, compliance, and risk professionals together around a book you’ll love, and invites everyone to participate in a live Q&A and discussion with the author.For the third meeting, and as part of our celebration of the fifth annual International Compliance Officer Day, we present“Intentional Integrity: How Smart Companies Can Lead an Ethical Revolution” by Robert Chesnut. In Intentional Integrity, Chesnut offers a six-step process for leaders to foster and manage a culture of integrity at work. He explains the rationale and legal context for the ethics and practices, and presents scenarios to illuminate the nuances of thinking deeply and objectively about workplace culture. You can check out Sean's original recordinghere. Check out the full panoply of SAI Global Ethical Leadership Articles and Resourceshere. Learn more about your ad choices. Visit megaphone.fm/adchoices

62 min2 w ago
Comments
Compliance Book Club Interview of Robert Chesnut on Intentional Integrity

Wirecard Part 9, Bring Lawyers Guns and Money

In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors.Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and international law.She is accustomed to working on extremely sensitive and high-profile matters, both nationally and internationally. In this episode, we explore those other professional service providers who enabled Wirecard in our bring Lawyers Guns and Money episode . Some of the highlights include: Weekly news wrap-up on Wirecard Is EY at its Arthur Anderson moment? Who has potential lawsuits against EY? Is a Bundestag inquiry in the works? Will there be an EU-level inquiry into the German government response? Who were the Enablers? Why is now the time for lawyers to take a stand for the Rule o...

39 min2 w ago
Comments
Wirecard Part 9, Bring Lawyers Guns and Money

Matt Kelly on the Role of Internal Audit

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own uniqueperspectives to this settlement. In this Part 3, Matt Kelly joins me to consider the role internal audit in this matter and the (non) actions of Herbalife’s Board of Directors. Some of the highlights include: Internal Audit as window dressing does not good government make. How high up must internal audit push? What is the Board’s duty? Is there a Caremark claim against the Herbalife Board of Directors? Learn more about your ad choices. Visit megaphone.fm/adchoices

12 min2 w ago
Comments
Matt Kelly on the Role of Internal Audit

Jay Rosen on the Lack of Monitorship

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcasts Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their own uniqueperspectives to this settlement. In this Part 2, Jay Rosen joins me to consider how Herbalife was able to avoid a Monitorship. Some of the highlights include: ·The Benczkowski Memo. ·The need for full disclosure and candor. ·Remediate extensively. ·End of monitorships as we know them? Learn more about your ad choices. Visit megaphone.fm/adchoices

9 min2 w ago
Comments
Jay Rosen on the Lack of Monitorship
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