As Jim Crane apologizes for the Astro cheating by announcing to the world the Astros were the best team in 2017 so go pound sand if you don’t like it, Jay and Tom are back to consider some of the top compliance articles and stories which caught our eye this week.

  1. Trump orders DOJ to cut Roger Stone sentence recommendation. Eileen Sullivan in the NYT. Sara Kropf considers the legal angle for defense attorney’s in Grand Jury Target.
  2. Is data privacy a lifestyle? Jessica Wilburn explores in Navex Global’s Ethics and Culture Matters blog.
  3. Compliance budgets are getting tighter. Matt Kelly considers in Radical Compliance. Tom and Matt take a deep dive in Compliance into the Weeds.
  4. Britain and France’s cooperation in the Airubs investigation and enforcement action. Branislav Hock in Risk and Compliance.
  5. Game changes in compliance training. Jaclyn Jaeger in Compliance Week. (sub req’d)
  6. What is the power of proactive monitoring? Jay explores in CCI.
  7. Worried about CCO liability? Matt Kelly explores on Radical Compliance.
  8. Wistful thinking that FCPA enforcement going away. Bill Steinman in the FCPA Blog.
  9. Why Board governance around compliance must change. Mike Volkov on Corruption Crime and Compliance.
  10. On the Compliance Podcast Network, Tom begins a one month look at the role of HR in compliance on 31 Days to a More Effective Compliance Program.This week saw the following offerings: Monday-6 core principles for compliance incentives; Tuesday-designing comp to incentivize compliance; Wednesday-exec comp and compliance incentives; Thursday-sales incentives and compliance; Friday-instituional justice and fair process. 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.

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

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the Compliance Podcast Network to explore these issues. Today’s episode is about creative ways to use internal social media tool to improve your compliance communications.

Some of the highlights include:

  • Stretching you compliance messaging by using tactics for reaching more employees. -Using internal social media sites like Chatter, Yammer, Jive, Workplace to reach employees in new ways.  These are used by other departments to connect groups. Why doesn’t the compliance function use them as well?
  • This is another channel outside of an LMS push to reach more people
  • These channels work like social media. The key is that you need to present something interesting for people to choose to access. Many have #hashtags and are interactive
    • Post interesting videos
    • Post interesting Graphics & GIFs
    • Post contests
    • Ask for feedback
  • This is a way to increase visibility and promote your main messaging
    • Compliance is here to help advice and coach
    • Speak Up Culture
    • Here is where you go for more info
  • Ethics and Compliance needs more visibility – so increase access through these channels. And if you want to use these channels, it should be interesting or fun or you won’t get access.


Ronnie Feldman

Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)

Learnings & Entertainments (Website)

60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.

Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.

Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.

FEBRUARY 14, 2020 2019 BY TOM FOX

In today’s edition of Daily Compliance News:

  • Huawei indicted on racketeering charges. (WSJ)
  • Judge puts brakes on Microsoft cloud computing contract. (Washington Post)
  • Astros owner tell everyone to pound sand. (com)
  • Barclays CEO under investigation yet again? (NYT)

In the DOJ’s 2019 Guidance, Incentives and Disciplinary Measures it stated:

Incentive System – Has the company considered the implications of its incentives and rewards on compliance? How does the company incentivize compliance and ethical behavior? Have there been specific examples of actions taken (e.g., promotions or awards denied) as a result of compliance and ethics considerations? Who determines the compensation, including bonuses, as well as discipline and promotion of compliance personnel?

When considering how a company could use incentives to further a compliance program and the role of HR in this process, we should also consider how incentives might lead to the converse, as they did in the now-infamous Wells Fargo fraudulent-accounts scandal. When you misalign these two concepts with a faulty sales strategy it can lead to a catastrophic failure, literally costing the company millions of dollars in fines, loss of business and depreciation of shareholder value. Whatever your incentive structure, there will be employees who try to game the system. Some will do it with the tacit or explicit approval of management. You, as the CCO, may be required to act.

Three key takeaways:

  1. Even a benign sales incentive program came become skewed.
  2. A sales incentive program can become high risk or illegal if not properly monitored.
  3. If there is alignment between the strategy, purpose and structure of an incentive system, it often makes the difference between a good and a bad one.


Welcome to a special series of Trekking Through Compliance, the podcast series inspired by my review of Star Trek, the Original Series. In this special series I am joined by another uber Star Trek maven, Megan Dougherty. In this series we will review the new television show Picard which is currently streaming on CBS.

SPOILER ALERT-Although we will review each episode after it appears, we will discuss each episode in depth.

Episode 2, Maps and Legends. A flashback shows a normal day on Mars Utopia Planitia Shipyards followed by the deadly attack on Mars 14 years ago by the synthetics. Following Dahj’s death, Picard seeks to track her twin Soji down. With the help of Laris, he investigates Dahj’s apartment and finds the place completely scrubbed. Laris suggests that the assassins may have been part of the Zhat Vash, an organization even more secretive than the Tal Shiar that holds a deep-rooted hatred of synthetics. At the Romulan reclamation site, a relationship between Soji and Narek is flourishing. Picard appeals to Starfleet for a ship but is denied by Admiral Kirsten Clancy. Picard attempts to assemble his own crew, inviting Agnes Jurati and the estranged Raffi Musiker. Meanwhile, Clancy informs Commodore Oh of Picard’s request and asks her to look into it. Oh notifies the (secretly Romulan) Lt. Rizzo to have her undercover operative “stay on mission”. Via holo-communicator, Rizzo speaks to Narek, her operative and brother. Rizzo warns Narek that if he does not persuade Soji to reveal the location of other synthetics, she would be forced to take more extreme measures.

Highlights include: 

  1. Is Picard mentally fit to go into space?
  2. How did the Romulans infiltrate Star Fleet leadership?
  3. Does Picard think the Romulans have breached Star Fleet security?
  4. What about the tech?
  5. What are the ethics around the Borg reclamation project?
  6. What was the former relationship between Picard and Raffi?