It is the scary month of October and I am back with another entry into one of my favorite series: Classic Monster Movie Month. Each year during October I focus on a set of classic monster movies from the Golden Age of Hollywood, the 1930s and ‘40s. This year I am going to focus on the 1940s Frankenstein franchise. These movies were made without Boris Karloff as The Monster and moved the series from Hollywood ‘A’ status to that of ‘B’ movies. However, as with most ‘B’ movies from this era, there were many creative details that make the movies very memorable. Today’s offering is no exception, The Ghost of Frankenstein.

This movie starred Lon Chaney, Jr. in his only appearance as The Monster. Jim Moon said, “Whereas the previous films had character-driven dynamics, Ghost of Frankenstein emphasizes the monster’s exploits and the ghoulish thrills of mad science, with characters being plot devices to further this rather than creating any dramatic tension.” This includes Lionel Atwill’s Dr. Bomar, who was originally Dr. Ludwig Frankenstein’s mentor, until a surgical accident ruined his standing in the medical community and now he finds himself relegated to assisting his former pupil, of which he harbors a degree of resentment. Of course there has to be a Frankenstein to perform the operation and this is Dr. Ludwig Frankenstein, the second son to Dr. Henry Frankenstein, who just happens to have a basement lab full of monster reviving electrical apparatus lying around.

Today’s I am pleased to announce the next offering of my Doing Compliance Master Class. I am partnering with Baker Tilly Virchow Krause, LLP, to put on a two-day class that is unlike any other currently being offered. It will be held in New York City on November 12 & 13, 2018. The class is not just theory or analytical underpinnings of the Foreign Corrupt Practices Act (FCPA) but focuses on the operationalizing of compliance. For it is only in the doing of compliance that companies have a real chance of avoiding FCPA liability. Jonathan Marks, a Partner at Baker Tilly and well-known internal investigation and specialist in root cause analyses, will also join me.

The Master Class provides a unique opportunity for any level of FCPA compliance practitioner, from the seasoned Chief Compliance Officer (CCO) to the practitioner who is new to the compliance profession. If you are looking for a training class to turbocharge your knowledge on the nuts and bolts of a best practices compliance program going forward, this is the class for you to attend. Moreover, as I limit the class to 10 attendees, you will have an intensive focus group of like-minded compliance practitioners with which you can share best practices. It allows us to tailor the discussion to your needs. Mary Shirley, an attendee at the recent Boston Master Class said, “This is a great two day course for getting new folks up to speed on what matters in Compliance programs.”

As one of the leading commentators in the compliance space for several years, I will bring a unique insight of what many companies have done right and many have done not so well over the years. This professional experience has enabled me to put together a unique educational opportunity for any person interested in anti-corruption compliance. Simply stated, there is no other compliance training on the market quite like it. Armed with this information, at the conclusion of the Doing Compliance Master Class, you will be able to implement or enhance your compliance program, with many ideas at little or no cost.

The Doing Compliance Master Class will move from the theory of the FCPA into the doing of compliance and how you must document this work to create a best practices compliance program. Building from the Ten Hallmarks of an Effective Compliance, using the questions posed from the Evaluation of Corporate Compliance Programs and the FCPA Corporate Enforcement Policy as a guide, you will learn the intricacies of risk assessments; what should be included in your policies and procedures; the five-step life cycle of third party risk evaluation and management; tone throughout your organization; training and using other corporate functions to facilitate cost-effective compliance programs.

Highlights of the training include:

  • Understanding the underlying legal basis for the law, what is required for a violation and how that information should be baked into your compliance program;
  • What are the best practices of an effective compliance program;
  • Why internal controls are the compliance practitioners best friend;
  • How you can use transaction monitoring to not only make your compliance program more robust but as a self-funding mechanism;
  • Your ethical requirements as a compliance practitioner;
  • How to document what you have accomplished;
  • Risk assessments – what they are and how you can perform one each year.

You will be able to walk away from the class with a clear understanding of what anti-corruption compliance is and what it requires; an overview of international corruption initiatives and how they all relate to FCPA compliance; how to deal with third parties, from initial introduction through contracting and managing the relationship, what should be included in your gifts, travel, entertainment (GTE) and hospitality policies; the conundrum of facilitation payments; charitable donations and political contributions, and trends in compliance. You will also learn about the importance of internal controls and how to meet the strict liability burden present around this requirement of FCPA compliance.

The Doing Compliance Master Class will be based around my latest book, The Compliance Handbook, published in May 2018. It was No. 1 in Amazon’s Business Ethic’s category when released and it focuses on the creation, implementation and enhancement of a best practicescompliance program.

The Doing Compliance Master Class will be held on November 12 and 13, 2018 at the offices of Baker Tilly, One Penn Plaza, Suite 3000, New York, NY 10119. A Certificate of Completion will be provided to all who attend in addition to the continuing education credits that each state approves. The cost to attend is $1,495 per person. Breakfast, lunch and refreshments will be provided both days. For registration information, click here.


The New Annotated Frankensteinby Mary Shelley and Leslie S. Klinger

Frankenstein, or the Modern Prometheus (Annotated): The original 1818 version with new introduction and footnote annotationsby Mary Wollstonecraft Shelley and Dan Abramson

Frankenstein: Annotated for Scientists, Engineers, and Creators of AllKinds by Mary Shelley and David H. Guston

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© Thomas R. Fox, 2018