As the Chinese Consulate burns papers after its closure, Tom and Jay brave the surge in covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week.

  1. More compliance guidance from OFAC. Dick Cassin reports in the FCPA Blog.
  2. First ComEd fined $200MM in Illinois, then Speaker of Ohio House charged in massive state corruption probes. Matt Kelly in Radical Compliance on Illinois. Julie Wernau and Katherine Blunt in WSJ on Ohio.
  3. Was Willie Nelson or Patsy Cline crazy? Bill Steinmann says it’s the FCPA year 2020 in the FCPA Blog.
  4. Mike Volkov goes Old Testament about Amazon OFAC sanctions. In Corruption Crime and Compliance.
  5. From 3 Lines of Defense to the 3 Lines Model as the IIA updates its model. Matt Kelly back with a rare double double for This Week in FCPA in Radical Compliance.
  6. Compliance really is a journey. Mary Shirley in CCI.
  7. How is Covid-19 impacting compliance? Jennifer Sun explores in CCI.
  8. The Ethical Revolution in Business. Philip Winterburn and Jane Mitchell in Converge.
  9. This month on The Compliance Life, I am joined by Scott Sullivan, Chief Integrity and Compliance Officer at Newport Mining. In Part 1, we discussed the need for empathy in a CCO. In Part 2, we looked at reading the tea leaves and staying ahead of the (corp) wolf pack. This week in Part 3, we considered who a CCO needs on their compliance team.
  10. On the Compliance Podcast Network, Tom continues the topic of 3rd party risk management this month.This week saw the following offerings: Monday-the ROI of 3rd party compliance (Linda Justice as guest); Tuesday– 3rd parties as innovation partners (Eric Feldman as guest), Wednesday-3rd party risk expansion; Thursday-termination of 3rd parties; and Friday-distributor compensation. The month of July is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.
  11. Great Upcoming Webinars:

K2 Intelligence Fin Webinar with AIBACP: Pandemics to Recession—Finding AML and ABC Synergies in Tough Times, July 30, 2020 at 1:30 PM – 2:30 PM EST; with JoAnn Taylor and Adam Frey. Registration and Information here.

ECI’s Best Practice Forum, a Q&A Session with Brian Rabbitt, Acting Assistant Attorney General for the Criminal Division on the FCPA Resource Guide, 2nd edition, Thursday, July 30, 2:00 – 4:00 p.m. EDT. Registration and Information here.

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

On this episode of The Ethics Experts, we speak with Charles Monk about changing Air Force culture through innovative training.

 Check out more episodes, and don’t forget to subscribe on your favorite podcast platform!

Richard Lummis is on assignment this week so I am pleased to host Paul Mueller, who coaches on leadership. Mueller, a certified business coach, is the owner of Excel Business Coaching and Consulting, Inc, a Focal Point franchise. Paul’s passion is working with business owners to align their organizations around clear vision, mission, and value statements. These statements pave the way for them to achieve their goals for their businesses, families, employees, and communities.

Some of the topics we discuss are Focal Point-Coaching and Training Excellence; the attributes of a broken culture and how Paul sees it sees it in a hierarchy. In an organization, what is the catalyst for change and what is the organizational model for change? Finally, what does the model of a healthy organization look like?


Paul Mueller LinkedIn Page here

Paul Mueller website here

Tom Fox and Lisa Ryan, this week’s guest, are both members of C Suite Radio and the National Speakers Association. Lisa spent 20 years in sales before embarking on her entrepreneurial journey in 2010. She brings a unique perspective to the subject of employee engagement, seeing it as an essential skill that leaders need to have.

An Essential Skill

In Lisa’s view, employee engagement is greater productivity, greater institutional justice, better health and safety, and many other ways of enhancing workers’ lives. As such, leaders should see improving engagement as an essential skill. “When that business owner can make that connection with their employees,” Lisa points out, “that employee is going to give a lot more effort.”

A Critical Part of Compliance and Corporate Culture

Tom comments, “If you focused on employee engagement, you would go a long way towards creating a viable and vibrant speak up culture and creating a two way street of communication.” Lisa agrees. She adds that people want to feel safe and know that if they approach their boss with a problem, their boss is going to take action on it. We’re wired for justice, she says. As such, engagement is a critical part of compliance.

“Company culture took a long time to develop, and it’s not changing overnight,” Lisa says. When a company makes the decision to focus on improving engagement, they must first assess where they are and then be committed to taking strategic steps towards their long-term goal. She shares how she helps clients to make those changes, and emphasizes that culture change must start at the top then go through every department of the organization.

On Curiosity

Tom says that one of the key characteristics compliance professionals must possess is curiosity.

He asks Lisa to talk about her blog post about curiosity around relearning an old skill. She responds, “Sometimes we have so much knowledge of the things that we can do and then we go and chase that next shiny object… that what we were doing before that was totally working, that was totally part of our skill set, just kind of fades off to the background… So there’s always that being a constant student, not only of the new technology, …but also knowing that there was a lot of that foundation that we came from that we don’t necessarily want to leave behind.”


Lisa Ryan on LinkedIn | Facebook | YouTube

In this  episode I visit with Vin DiCianni on how ethical culture is a part of an overall ethics and compliance program assessment and how to go about it. We began with an exploration around the areas assessed to help determine if a company has an ethical culture. DiCianni said you need a framework for such an assessment. DiCianni advocates  starting with the program itself. This means a review of what does the organization’s compliance program look like and does it meet the foundational tenants? He would ask such questions as whether it is educational; does it have a process for detection; and is there some type of remediation when something is found? From this baseline, you might consider what the company is doing for training to educate their staff, are they really touching on the elements of the parts of education that the staff need and is it meaningful to them in their positions? In other words, is the training both focused and effective?

DiCianni concluded with accountability. He said, “I think the other one that I can’t emphasize enough is accountability. You know if there are serious violations of an ethics policy of the company, be it conflicts of interest or code of conduct. If nothing is done about it, everyone in the organization knows about that. It diminishes all of the efforts that have gone into creating this program and trying to have an ethical culture. If you do not do anything to enforce it, when something serious happens, it literally becomes a futile exercise”.