With the Red Sox leading the AL with a 10-2 start and back to brawling with the NY Yankees, Jay Rosen and myself take a look at some of the top compliance stories over the past week.

  1. Is there a new health care focus coming in FCPA enforcement actions? Joseph Spinelli and Lisa Murtha explore this issue in the FCPA Blog.
  2. Mark Zuckerberg testifies before Congress. What are the implications? Sascha Matusak says a wave of litigation is coming on the SCCE Compliance and Ethics.  Ben DiPietro wraps up national coverage on the WSJ Risk and Compliance Journal. Joe Mont explores the potential regulatory aspect in Compliance Week. (Sub Req’d)
  3. The SEC awarded more than $2.1 million to a former company insider “whose information led to multiple successful enforcement actions. Dick Cassin reports in the FCPA Blog.
  4. Do ‘No-Poach’ agreements violate anti-trust law? Jaclyn Jaeger explores in Compliance Week. (sub req’d)
  5. A Navex Global report says that more hotline and whistleblower reports are turning out to be valid after corporate investigations? Henry Cutter reports on the report in the WSJ Risk and Compliance Journal. Carrie Penman considers three key finding on Navex’s Ethics and Compliance Matters
  6. Tom Topolski and Eric Feldman talk about how make the relationship between a corporate monitor and corporation work. Check out the SCCE Compliance Perspectives podcast, hosted by Adam Turteltaub.
  7. FinCen rules on customer due diligence and ultimate beneficial ownership go into effect on May 11. What are the implications for non-financial institutions? Check out FinCen’s FAQs here.
  8. Tom announces presales of his next book, the Complete Compliance Handbook, which will be published by Compliance Week in April 2018. It is available for PreSale here.
  9. Tom will be leading Convercent Roundtables on using data to drive ethics to the center of business on Houston (April 17) and Dallas (April 18). He will lead discussions on using data to drive ethics into the center of business.
  10. The Everything Compliance gang will be back on Thursday April with a deep dive into Mark Zuckerberg’s Facebook testimony, the Michael Cohen subpoena and more. Check it out next Thursday.
  11. AMI’s Eric Feldman will be speaking on How Audits Become Investigations at the 2018 Public Service Internal Audit Conference in Singapore, hosted by The Institute of Internal Auditors Singapore, on April 18, 2018. For information and registration, click here.

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

In the midst of this true madness in the NCAA tournament this year, Jay Rosen and myself take a look at some of the top compliance stories over the past week.

  1. Cambridge Analytica is in a world of trouble after stealing data from Facebook and advising clients to engage in bribery and corruption. See stories in FCPA Blog, good summary of stories by Sam Rubenfeld at WSJ Risk and Compliance Journal, The Guardian reports on what we know so far and Recode summarizes the interplay between Cambridge Analytica and Facebook.
  2. Facebook is not far behind for its tepid response. Zuckerberg responds, reported in the Wall Street Journal, a Whistleblower weighs in, the Washington Post reports that the FTC has opened an investigations, Mark Zuckerberg talks to the New York Times.
  3. In largest whistleblower awards ever, the SEC doles out $83MM to 3 anonymous persons for fraudulent conduct at Merrill-Lynch. Dick Cassin reports in the FCPA Blog, Matt Kelly advises to read the fine print on Radical Compliance and Kevin LaCroix details some interesting points from the award. The award lands the whistleblowers’ attorney, Jordan Thomas on the front page of the NYT.
  4. Catching up on news from the UK: in NYU Compliance and Enforcement Blog considers the first test of Bribery Act’s Adequate Procedures defense, from the WSJ Risk and Compliance Report-(1) Sam Rubenfeld says UK may end Scottish shell companies, (2) Rubenfeld reports that the SFO claws back bribe payment to Chad government official, (3) Mara Lemos Stein reports the Financial Conduct Authority seeks more transparency.
  5. In an unsurprising yet disturbing development, whistleblower retaliation is up. Ben DiPietro reports in the WSJ Risk and Compliance Journal.
  6. Uber Brings in Holder Report Co-Author as Deputy GC, Angela Padilla Out. Stephanie Forshee reports in Corporate Counsel (Sub req’d)
  7. Check out the top new podcast in the compliance field Innovation in Compliance. It is available on the FCPA Compliance Report, iTunes, Libsyn, YouTube and JDSupra.
  8. Tom announces presales of his next book, the Complete Compliance Handbook, which will be published by Compliance Week in April 2018. It is available for PreSale here.
  9. Jonathan Armstrong will be in Houston on April 10 to put on a half-day GDPR workshop. You can find out more and register at the Greater Houston Business and Ethics Roundtable website, org.
  10. Tom will be leading Convercent Roundtables on using data to drive ethics to the center of business in Miami (April 4), Houston (April 17) and Dallas (April 18).
  11. Tom and Everything Compliance panelist Mike Volkov and Matt Kelly named as top contributors in compliance in annual JDSupra Readers 2017-8 Poll. Will Jay take his game up?
  12. Jay details the upcoming presentations by his Affiliated Monitors’ colleagues at the SCCE European Ethics and Compliance Institute and with Convercent.

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

In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week, including some fury.

  1. Wells Fargo is having its soul investigated by actual nuns. Alistair Gray reports in the Financial Times; Thorton McEnery notes sometimes the Universe is both hilarious and cruel in Dealbreaker; and Bloomberg says the Nuns want to know the root cause of the illegal conduct at Wells Fargo.
  2. BSRG goes into receivership. Tom reports in the FCPA Blog. For the original sordid story see, the piece in the New Yorker in 2013 by Patrick Radden Keefe.
  3. Bill Coffin continues his string of great posts. This week he says your data breach nightmare is only going to get worse in his Compliance Week
  4. Canada to introduce DPAs. Jaclyn Jaeger reports in Compliance Week.
  5. Kobe Steel CEO resigns amid admission of years of fraudulent reports by the company. Henry Cutter reports in the Wall Street Journal Risk and Compliance Journal.
  6. The FCPA declination program will be extended to other areas by the DOJ. See Tom’s piece in the FCPA Compliance Report and Henry Cutter’s piece in the Wall Street Journal.
  7. Mayhem at the Mavericks? Sports Illustrated broke the story of horrific sexual harassment in the Dallas Mavericks front office. Matt Kelly blogged on it in Radical Compliance. Tom and Matt explored it in a podcast on Compliance into the Weeds. Dick Cassin reports that the Mavericks are looking to hire a first ever CCO in the FCPA Blog.
  8. March 6 was the anniversary of the fall of the Alamo. The lads explore what is means for compliance professionals to be seen as the Alamo. Is compliance the last stand or are they simply slaughtered for standing up for their beliefs? Tom considers both perspectives in the FCPA Compliance Report.
  9. Tom and Jonathan Armstrong are back with Episode 3 of Countdown to GDPR. Tom writes about the policies and procedures you need for GDPR in the FCPA Compliance Report.
  10. Tom announces presales of his next book, the Complete Compliance Handbook, which will be published by Compliance Week in April 2018. It is available for PreSale here.

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit this month’s sponsor Affiliated Monitors at www.affiliatedmonitors.com.

In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week as we celebrate Texas Independence Day.

  1. The fallout and discussion from the Supreme Court decision in Digital Realty v. Somes continues. Tom examines the legal basis of the decision here; the issues raised by the decision here; considers some of the issues from the perspective of the compliance practitioner in a podcast with Roy Snell here; and takes a deep dive into the weeds of the decision in a podcast with Matt Kelly here.
  2. Tetradata and Exterran received declinations. Dick Cassin reports on Tetradata and Exterran in the FCPA Blog.
  3. Bill Coffin continues his string of great posts. He writes about the ethical and compliance lessons from the recently concluded Winter Olympics in his Compliance Week
  4. Want to open a bank account along the Texas-Mexico border? Better hurry as many branches are closing due to AML concerns. Sam Rubenfeld reports in the WSJ Risk and Compliance Journal. Matt Kelly considers it from the ‘derisking risk’ perspective in Radical Compliance.
  5. Fresenius Medical Care reserves €200 million in FCPA enforcement action. Jaclyn Jaeger reports in Compliance Week.
  6. Adam Winkler asks what rights should corporations have, in the Wall Street Journal.
  7. What are the top 5 security and compliance trends to watch for 2018? Anthony West explores in Corporate Compliance Insights.
  8. What is the difference in big data and small data? Ben Locwin explains it in Pharmaceutical Online.
  9. Will there finally be sunshine on sexual harassment settlements? Joe Mont reports on the proposed the Sunlight in Workplace Harassment Act, in Compliance Week.
  10. Jay reports on the ABA White Collar Conference recently concluded in San Diego.
  11. Tom announces presales of his next book, the Complete Compliance Handbook, which will be published by Compliance Week in April 2018. It is available for PreSale here.
  12. Happy Texas Independence Day!

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

In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week.

  1. A very interesting article by T. Markus Funk and Andrew Boutros entitled, “The Evolution and Status of ‘Carbon Copy”. For the full copy go to Bloomberg White Collar Report.
  2. Time to go back to college and take that Econ course as John Bray explores the intersection of sunk costs and third party bribery payments, in the FCPA Blog.
  3. Bill Coffin really nails it this week. He opines that compliance officers are the conscious of a company in his Compliance Week (sub req’d)
  4. Dick Cassin notes that the Justice Department ends its investigation of Core Labs the company’s relationship to Unaoil (here) and Juniper Networks gets a Declination (here). Henry Cutter explains both the WSJ Risk and Compliance Journal.
  5. The PdVSA ‘management team’ in charge of bribes are all indicted over money-laundering based on FCPA violations. Sam Rubenfeld leads the coverage in the WSJ Risk and Compliance Journal.
  6. Sally Afonso explains why you need to get out of our compliance conference comfort zone, in the SCCE Compliance and Ethics Blog.
  7. Joe Mont explores whether businesses misuse NDAs in his article, “Companies twist and abuse non-disclosure agreements”. See article in Compliance Week (sub req’d)
  8. Ethisphere announces its 2018 World’s Most Ethical Companies Awards, see Press Release Matt Kelly explores some of the key similarities in Radical Compliance.
  9. Tom announces presales of his next book, the Complete Compliance Handbook, which will be published by Compliance Week in April 2018. You can find out more on his website by clicking here.