Everything Compliance

Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Jonathan Armstrong, Jay Rosen, Matt Kelly, Jonathan Marks and Mike Volkov for a potpourri of discussions and ending with a veritable mélange of rants and shouts outs.     Jonathan Armstrong critiques the recent SFO conviction of two former Unaoil employees and the controversary the SFO and its Director, Lisa Osofsky now find themselves in regarding their conduct. Armstrong shouts out to the West Indies cricket team for traveling to the UK to play at Lord’s. Jay Rosen considers telemedicine in the time of Covid-19. What does it mean for the practice of medicine? What are the compliance issues involved? Jay rants about the Trump Administration targeting surveillance on journalist in Portland and across the country. Matt Kelly looks at two recent US domestic corruption cases; one in Illinois involving ComEd and one in Ohio involving the Speaker of the Ohio House of Representatives. Matt shouts out to Rebecca Jones the former Florida state employee who left the government to start her own public record of Covid-19 in Florida when the state quit reporting on it. Mike Volkov looks at two recent OFAC enforcement actions. One involved Amazon and defective tracing software. The second Essentra, doing business with North Korea and shell companies. He draws out the lessons learned from both cases. He shouts out to podcasters and the podcasting community for getting their messages out. Jonathan Marks considers parallels he has observed in the development of the compliance profession from those he lived through in the Internal Audit world after Enron and WorldCom. He shouts out to the IIA for beginning the discussion to reconfigure its 3 Lines of Defense but chides them for not going far enough. Tom Fox rants about those attacking fellow Buffalo Wing addicts.  The members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com Jonathan Marks is Partner, Firm Practice Leader - Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at marks@bakertilly.com The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. He can be reached at tfox@tfoxlaw.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Jonathan Armstrong, Jay Rosen, Matt Kelly, Jonathan Marks and Mike Volkov sitting in to discuss various aspects of the Novartis settlements and ending with a veritable mélange of rants and shouts outs.     Jonathan Armstrong critiques the ongoing corruption in the pharma industry and implores the industry to do business differently. Instead of a shout out, he asks that we each reach out to someone who has been laid off during the Coronavirus crisis and check in with them. Jay Rosen considers the Novartis FCPA settlement from the recidivist angle, noting that the Swiss company joins an ignominious list of multiple FCPA offenders. Rosen rants against the Trump Administration’s attempt to strip visas from foreign students who are studying remotely. Matt Kelly considers the data analytics angle from the Novartis enforcement action and how it instructs a compliance professional on how to use data analysis. He shouts out to the new CEO of Wirecard, named 24 hours after taking over the CCO chair at the embattled company. Mike Volkov looks at False Claims Act settlement by Novartis (as opposed to the FCPA settlement). He shouts out to Chief Justice John Roberts who only dissented in two decisions from the court’s most recent term. Jonathan Marks looks at the Novartis settlement from the internal controls and accounting perspective. He also asks if there are any Caremark claims against the Novartis Board of Directors. He shouts out to the genius who invented the phrase “Document Document Document!”  The members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com Jonathan Marks is Partner, Firm Practice Leader - Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at marks@bakertilly.com The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. He can be reached at tfox@tfoxlaw.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. Today, we have a serving of Jonathan Armstrong, Jay Rosen, Matt Kelly, and Tom Fox sitting with a veritable mélange of topics and rants/shouts outs.     Jonathan Armstrong critiques recently released information on the good ship, UK Serious Fraud Office. He shouts out to UK footballer Markus Rash about his campaign to end child. Jay Rosen considers what compliance issues arise in working from home. He rants that the Trump Administration needs to free Dr. Fauci. Matt Kelly considers the US Supreme Court decision in Bostock and what it means for compliance professionals. He shouts out to the new CEO of Wirecard, named 24 hours after taking over the CCO chair at the embattled company. Tom Fox looks at corporate compliance through the lens of characters from the Hundred Acre Wood. He shouts out to Texas Governor Gregg Abbot as winner of the Covidiot Award, Texas division.  The members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com Jonathan Marks is Partner, Firm Practice Leader - Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at marks@bakertilly.com The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. He can be reached at tfox@tfoxlaw.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. Today, we have a serving of Jonathan Armstrong, Jay Rosen, Matt Kelly, and our newest panelist Jonathan Marks with a veritable potpourri of topics and issues. Rants and shouts outs (with commentary) conclude this episode.     Jonathan Armstrong celebrates the anniversary of GDPR by looking back over the past year at some of the key decisions and enforcement actions. Jay Rosen takes a look at a rare release of a monitor’s report, in the Wynn Casino monitorship and data mines it for the compliance professional. Matt Kelly considers the difference in response by Facebook v. Twitter in the incendiary and racist tweets by Donald Trump. Jonathan Marks looks at the DOJ’s 2020 Update to the 2019 Evaluation of Corporate Compliance Programs. Tom Fox talks about how fighting racism and white supremacy is the responsibility of everyone. It is based on piece by Ben DiPietro here. The members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com Jonathan Marks is Partner, Firm Practice Leader - Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at marks@bakertilly.com The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. He can be reached at tfox@tfoxlaw.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. Today, we have a serving of Jonathan Armstrong, Jay Rosen, Matt Kelly, special guest Jonathan Marks and Mike Volkov with a veritable potpourri of topics and issues. Rants and shouts outs follow the commentary for this episode.     Mike Volkov looks at two recent enforcement actions involving food safety goes into his nuts and bolts toolbox to lay some actions a CCO or compliance professional can consider at this point in the Coronavirus health crisis. Jonathan Armstrong considers some of the international corruption risks around Covid-19 and the economies coming out of the health crisis. Jay Rosen explores what monitorships and compliance oversight may look like in the New Normal. Matt Kelly reports on the state of the compliance hiring market. Jonathan Marks looks at Board of Director overconfidence.  Resources: Matt Kelly’s post, The Compliance Jobs Market on Radical Compliance.Jonathan Marks post, Board Overconfidence on Board and Fraud.Cordery Compliance client alert, Covid-19 and Corruption FAQs.Mike Volkov’s posts on Blue Bell and Chipotle, both on Corruption Crime and Compliance.The members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com Today’s special guest Jonathan Marks is Partner, Firm Practice Leader - Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at marks@bakertilly.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. Today, we have a serving of Jonathan Armstrong, Jay Rosen, Matt Kelly, special guest Jonathan Marks and Tom Fox with an episode dedicated to the Coronavirus health crisis and its impact on the compliance profession. Rants and shouts outs follow the commentary for this episode.    Tom Fox goes into his nuts and bolts toolbox to lay some actions a CCO or compliance professional can consider at this point in the Coronavirus health crisis. Jonathan Armstrong reviews data privacy and data protection issues in the time of Coronavirus. Jay Rosen explains why culture assessments are so critical at this point and how to perform them remotely.  Matt Kelly looks at what businesses will need to consider going forward as self-isolation restrictions ease.  Jonathan Marks considers crisis management in the time of Coronavirus and the role of the Board of Directors. The members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com Today’s special guest Jonathan Marks is Partner, Firm Practice Leader - Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at marks@bakertilly.com The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. He can be reached at tfox@tfoxlaw.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. We devote our entire episode to the Airbus international corruption enforcement actions. Today, we have a serving of Jonathan Armstrong, Jay Rosen, Matt Kelly and Mike Volkov with a potpourri of topics. Rants and shouts outs follow the commentary for this episode.    Mike Volkov considers the enforcement action from the trade sanction/ITAR perspective. Jonathan Armstrong reviews the SFO’s role in this matter. Jay Rosen sets up the background facts under the US Deferred Prosecution Agreement and Criminal Information released by the DOJ and considers the FCPA angle of the case.  Matt Kelly looks at some policy angles and compares Airbus to recent scandals involving Wells Fargo and Boeing.  The members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. Today, we close out the year with Part 2 of a two-part series on our fan favorite year-end wrap up on the state of compliance under the Trump Administration. We have been following this topic since Trump was elected in 2016 and it one of the most anticipated podcast releases for the year. Today, we have a triple serving of Sarah Hadden, Jonathan Armstrong and Mike Volkov with a potpourri of topics. Rants and shouts outs follow the commentary for this episode.     Mike Volkov reviews the FCPA enforcement year. Volkov shouts out to the Justice Department’s FCPA trial team which secured several guilty verdicts at year’s end in individual prosecutions under the FCPA. Jonathan Armstrong discusses the year in antibribery enforcement from the UK perspective by reviewing the SFO’s successes and failures. Armstrong shouts out to Sir Rod Stewart for a compliance related project. Sarah Hadden takes a look back over her first year as CCI Publisher and highlights some of the top features, stories, news items and new voices in compliance. She shouts out to James Bone and Columbia University’s risk management survey.  Resources:Participate in the Columbia University risk management project headed by James Bone, here.The members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com Sarah Hadden –Publisher at Corporate Compliance Insights. Hadden can be reached at Sarah@corporatecomplianceinsights.com The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. Today, begin a two-part series on our fan favorite year-end wrap up on the state of compliance under the Trump Administration. We have been following this topic since Trump was elected in 2016 and it one of the most anticipated podcast releases for the year. Today, we have a triple serving of Jay Rosen, Matt Kelly and with a potpourri of topics. Rants and shouts outs follow the commentary for this episode.    Matt Kelly looks at what the SEC has accomplished (or not) over the past year as I pose the question “has Jay Clayton actually done anything?” Kelly rants about Attorney General Bill Barr’s theory of the unitary executive and blaming the Secular Left for the ills under Trump. Jay Rosen discusses compliance programs from the Benczkowski Memo to Evaluation of Corporate Compliance beyond, what does it mean for the compliance practitioner. Rosen rants about the cultural morass in Boston which led to the Patriots signing Antonio Brown and then shouts out to them for not only cutting him but not resigning him as they clearly need a competent receiver. Tom Fox sits in this episode to discuss the policy announcements which promoted corporate compliance programs this year; including the Criminal Division’s Guidance on compliance programs, the Antitrust Division’s Guidance on compliance programs and the OFAC Compliance Framework. Fox provides advice to Elon Musk that if you are unveiling a bullet proof car on live TV, then make sure the windows are actually bullet proof before you throw metal balls at them and they shatter. Resources:From Tom Fox, white papers on each of the three topics, all available on CCI:OFAC FrameworkAntitrust Division Compliance ProgramCriminal Division Compliance ProgramThe members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com Sarah Hadden –Publisher at Corporate Compliance Insights. Hadden can be reached at Sarah@corporatecomplianceinsights.com The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the only roundtable podcast in compliance. Today, we have a quintet of Jay Rosen, Matt Kelly, Sarah Hadden, Jonathan Armstrong and Mike Volkov with a potpourri of topics and commentary on current events from the compliance perspective. Rants and shouts outs follow the commentary for this episode, with one public service announcement from across the pond.    Mike Volkov takes a deep dive into the debate on whether a Chief Compliance Officer should report to the GC or not. Volkov shouts out to Harvard Law Professor Matthew Stephenson for his great blog site Global Anti-Corruption Blog and specifically his recent blog post, If You Don’t Think Conflicts of Interest Matter, Consider the Kurds.  Jay Rosen discusses the role ethics and compliance in the Mergers and Acquisition process. Rosen shouts out General James Mattis’ and his remarks at the Alfred Smith Dinner where accepted Trump’s claim he was the ‘most-overrated general’ by noting Trump had said 3-time Oscar winner Meryl Streep was the ‘most-overrated actress.’ Sarah Hadden takes things a different direction by reading the eBook Trump and Compliance which was published in late 2016 and was based on the Everything Compliance gang’s predictions of how compliance would fare under the Trump Administration. Hadden shouts out to a new section of CCI which will focus on those persons early in their compliance careers. It is certainly a welcome addition to the compliance discussion.  Matt Kelly provides breaking news by discussing the SEC proposed changes to its Whistleblower Program. Kelly shouts out to Boston Celtic Enes Kantor for calling out the NBA on its hypocrisy on China. Jonathan Armstrong discusses the growing tide of US-style class actions coming to the UK and EU around the issue of data breaches under GDPR. Armstrong provides a public service announcement around the perils of using Apple Pay and the failure to Document Document Document. Tom Fox rants about the surreal news conference given by Acting Chief of Staff Mick Mulvaney where he (1) admitted the President violated US law in requiring a quid pro quo from Ukraine for the Congressionally mandated US aid package, claiming it was ‘just politics’ and (2) admitted the President violated the Emoluments Clause of the US Constitution by announcing the President had ordered the 2020 G-7 Summit to be held at Trump properties. The members of the Everything Compliance are: Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com. Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com Sarah Hadden –Publisher at Corporate Compliance Insights. Hadden can be reached at Sarah@corporatecomplianceinsights.com The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network. Learn more about your ad choices. Visit megaphone.fm/adchoices