As we begin the dog days of summer and the long spell between July 4thand Labor Day, the Everything Compliance gang returns to its four focused topics. After the commentary we follow with rants.

  1. Matt Kelly considers Trump’s move to politicize the selection process for administrative law judges what this might mean for agency enforcement going forward? 
  1. Tom Fox explores three FCPA settlements incorporating the new FCPA Corporate Enforcement Policy and anti-piling on policy. (D&B, Panasonic and Credit Suisse) He considers them in light of some of the following questions: Do these matters increasing the incentive for companies to self-disclose? Will these and similar resolutions increase compliance or will it go the other way and cause companies to take compliance less seriously?
  1. Jonathan Armstrong discusses GDPR at six weeks post go-live. Where are we? What is the difference between public pronouncements by regulators and private actions by EU individuals? Where are we going?
  1. Jay Rosen considers the pro-active uses of monitoring in areas outside anti-corruption compliance. Here I am thinking about uses to satisfy anti-trust agreements with the FTC/DOJ and hospital conversions.

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
  • 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
  • Matt Kelly– Founder and CEO of Radical Compliance. Kelly can be reached at
  • Jonathan Armstrong– Rounding out the panel is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at

The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist.