As the enjoy the Astros continue their decimation of their AL West opponents and the lads celebrate finally getting their own iTunes show, they return to discuss both events some of this week’s top compliance and ethics stories which caught their collective eyes.

  1. Complexity and compliance, how do you deal with this in your compliance program. Tom and Matt Kelly explore in separate blog posts on the FCPA Compliance Reportand Radical Compliance, both relating to the Boeing 737 Max disaster. They debate it into the week’s on Compliance into the Weeds. Tom has a solution to siloes with horizontal communications.
  2. The SEC gives two whistleblowers a premium for reporting internally before disclosing to regulators. Harry Cassin reports in the FCPA Blog. Matt Kelly weighs in on Radical Compliance.
  3. Wither CITGO? Tom predicts things will go downhill quickly in a FCPA kind of way in the FCPA Blog. The next day the government announces a subpoena to CITGO for potential FCPA violations. Sam Rubenfeld (yes that Sam Rubenfeld) and Daniel Harris report in the Kharon Brief.
  4. The Malaysian Anti-Corruption Commission on extending the commitment of management to do business in compliance and ethically. Jerrod Baker in the FCPA Blog.
  5. Managing Anticorruption Compliance Under the EU’s General Data Protection Regulation. An article by Ruta Mrazauskaite in the Global AntiCorruption Blog.
  6. Is Exxon evil? Jaclyn Jaeger thinks so and explains why in an Op-Ed piece in Compliance Week.
  7. Mike Volvok follows his 3-part series on auditing your investigative protocol with a 4-part series on a sanctions compliance program; all on his blog site Corruption, Crime and Compliance. (Part 1, Part 2, Part 3 and Part 4) If. You prefer the audio format of a podcast, click here.
  8. Why is compliance is critical in the daily changing Trump trade wars against everyone. Paul Ziobro reports on FedEx in theWSJ.
  9. Why a ‘necessary evil’ does not constitute effective compliance. Mary Bennett explains on Navex Global’s Ethics and Compliance Matters
  10. ESG Screening Underscores Challenges in Third-Party Risk Management. Brian Alster considers in Corporate Compliance Insights.
  11. This week Tom had a special 5-part podcast series sponsored by AMI on the new Justice 2019 Guidance featuring Eric Feldman. Check out the following: Part 1-Introduction;Part 2-Well-designed;Part 3– Effectively Implemented; Part 4-Working in Practice; Part 5-Final Thoughts. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone ,YouTube,  Spotifyand Corporate Compliance Insights. The Compliance Podcast Networkjoins C-Suite Radio.
  12. Join Tom in Boston for his industry leading Compliance Master Class on June 11 & 12. Listeners who attend will receive a complimentary copy of The Compliance Handbook. Registration and Information is here. Join Tom, Eric Feldman, Vin DiCianni and Jay at the AMI Roundtable in Boston on June 13 for a deep dive into the DOJ’s new Evaluation of Corporate Compliance Programs-2019 Guidance. Information and registration is here.
  13. Looking to use the 2019 DOJ Compliance Guidance to help create a best practices compliance program. Check my new eBook published by CCI. Best of all it’s free.

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

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at