As the Pats and Rams advance, Tom and Jay ask if the NFL even cares about get it right? They also look at some of this week’s top compliance and ethics stories which caught their collective eyes.

  1. Google becomes first US company fined under GDPR. See Cordery Complaince Client Alert. Tom, AndréBywater and Jonathan Armstrong discuss on Life with GDPR. David Banks weighs in on Navex’s Ethics and Compliance Matters
  2. What is good corporate governance under German law? Ulrike Binder, Jan Kraayvanger and Burkhard Fassbach tell us in a guest post on the D&O Diary.
  3. Deutsche Bank under US scrutiny for it role in Dansk Bank scandal. Jesse Hamilton and Sonali Bossick report in Bloomberg.
  4. Should some parts of a compliance program be kept secret? Dick Cassin explores on the FCPA Blog.
  5. Academic evidence that frauds mar a firm’s reputational value is even greater than previously thought. Christos A. Makridis and Yuqing Zhou in NYU’s Crime and Enforcement Blog.
  6. Siloed compliance and how to overcome it. Mike Volkov explains on his blog Corruption, Crime and Compliance.
  7. Matt Kelly looks at some of the specific corruption issues around distributors, in Navex’s Ethics and Compliance Blog. He and Tom take a deep dive into the issue in Episode 108 of Compliance into the Weeds.
  8. Where will Bribery Act enforcement head in 2019? Sam Tate speculates in the FCPA Blog.
  9. How to handle an internal investigation in Russia. Hannes Lubitzsch reports in the FCPA Blog.
  10. This Week Tom was joined by AMI’s Vin DiCianni and Eric Feldman for a 5-part sponsored podcast series on the Benczkowski Memo and related DOJ guidance on compliance programs from 2018. Check out the following: Part 1-Introduction;Part 2-Internal Use; Part 3– External Resources; Part 4-a Sword and Shield; Part 5-Using an Independent for Proactive Monitoring. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Panoplyand YouTube. Soon to be on Spotify and Corporate Compliane Insights.
  11. What is arrogance in leadership? The lads debate how the NFL can be so incompetent and seemingly not care one iota about it.

Tom Fox is the Compliance Evangelist and can be reached at Jay Rosen is Mr. Monitor and can be reached at

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