Why A Duck https://compliancepodcastnetwork.com en 2019 From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov bring them into the boardroom to help explain and explore the sometimes chaotic world of governance, risk-management, ethics and compliance. This is Why a Duck, into the Compliance Soup, which is part of the Compliance Podcast Network. https://megaphone.imgix.net/podcasts/e75100aa-ba0d-11e9-8e8d-6332afc87c7f/image/uploads_2F1608824766742-ly6qx9e1p-2451a084bafacb0839f09d79c35ada42_2FCSR_Why_A_Duck.png?ixlib=rails-4.3.1&max-w=3000&max-h=3000&fit=crop&auto=format,compress Why A Duck https://compliancepodcastnetwork.com no episodic The intersection of the Marx Brothers and corporate compliance Tom Fox From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov bring them into the boardroom to help explain and explore the sometimes chaotic world of governance, risk-management, ethics and compliance. This is Why a Duck, into the Compliance Soup, which is part of the Compliance Podcast Network. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov bring them into the boardroom to help explain and explore the sometimes chaotic world of governance, risk-management, ethics and compliance. This is Why a Duck, into the Compliance Soup, which is part of the Compliance Podcast Network.

]]> Tom Fox tfox@tfoxlaw.com FCPA Resource Guide, 2nd Edition From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode Volkov and Fox consider the recently released FCPA Resource Guide, 2nd edition. Highlights from the podcast include: 1.     Is the 2nd edition an update or replacement? 2.     Why was it released now? 3.     What takes precedence; the 2nd Edition or the Evaluation of Corporate Compliance Programs? 4.     What is new in the 2nd Edition? 5.     What are the significant changes from the original FCPA Resource Guide? 6.     The FCPA Resource Guide is the best one volume on all things FCPA. It is a must have for every compliance professional.  Resources Mike Volkov Part 1-Introduction Part 2-New Case Updates Part 3-Updated DOJ Policies Part 4-Legal Issues and Clarifications Part 5-Effective Compliance Programs and Internal Controls Tom Fox Part 1-The New Hallmark Part 2-FCPA Corporate Enforcement Policy Part 3-the Accounting Provisions Part 4-DOJ Policy and Case Law Updates Part 5-Final Thoughts Learn more about your ad choices. Visit megaphone.fm/adchoices Sun, 19 Jul 2020 18:32:47 -0000 FCPA Resource Guide, 2nd Edition full 12 Tom Fox In this episode Mike Volkov and Tom Fox consider the recently released FCPA Resource Guide, 2nd edition. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode Volkov and Fox consider the recently released FCPA Resource Guide, 2nd edition. Highlights from the podcast include: 1.     Is the 2nd edition an update or replacement? 2.     Why was it released now? 3.     What takes precedence; the 2nd Edition or the Evaluation of Corporate Compliance Programs? 4.     What is new in the 2nd Edition? 5.     What are the significant changes from the original FCPA Resource Guide? 6.     The FCPA Resource Guide is the best one volume on all things FCPA. It is a must have for every compliance professional.  Resources Mike Volkov Part 1-Introduction Part 2-New Case Updates Part 3-Updated DOJ Policies Part 4-Legal Issues and Clarifications Part 5-Effective Compliance Programs and Internal Controls Tom Fox Part 1-The New Hallmark Part 2-FCPA Corporate Enforcement Policy Part 3-the Accounting Provisions Part 4-DOJ Policy and Case Law Updates Part 5-Final Thoughts Learn more about your ad choices. Visit megaphone.fm/adchoices From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode Volkov and Fox consider the recently released FCPA Resource Guide, 2nd edition. Highlights from the podcast include:

1.     Is the 2nd edition an update or replacement?

2.     Why was it released now?

3.     What takes precedence; the 2nd Edition or the Evaluation of Corporate Compliance Programs?

4.     What is new in the 2nd Edition?

5.     What are the significant changes from the original FCPA Resource Guide?

6.     The FCPA Resource Guide is the best one volume on all things FCPA. It is a must have for every compliance professional. 

Resources

Mike Volkov

Part 1-Introduction

Part 2-New Case Updates

Part 3-Updated DOJ Policies

Part 4-Legal Issues and Clarifications

Part 5-Effective Compliance Programs and Internal Controls

Tom Fox

Part 1-The New Hallmark

Part 2-FCPA Corporate Enforcement Policy

Part 3-the Accounting Provisions

Part 4-DOJ Policy and Case Law Updates

Part 5-Final Thoughts

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1990 no COVID-19 and Compliance: Part 5-Leadership and Final Thoughts In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this fifth and final episode, we consider the paucity of leadership at the federal level and why this has put businesses at the forefront of leadership during this crisis. Highlights from the podcast include:  Why do we need strong federal leadership? Without federal leadership why is business leadership so important? Will CEOs who signed the Business Roundtable’s Statement on the Purpose of an Organization adhere to those principals in this time of crisis? What time horizons are you considering? Why is trust even more important now? How will the COVID-19 crisis test the mettle of companies in ways never seen in our lifetimes? Resources Mike Volkov Call for Leadership Absence of Federal Leadership  Tom Fox Trust in the Age of Coronavirus  Final Thoughts Mike Cherkasky on Testing Your Mettle Learn more about your ad choices. Visit megaphone.fm/adchoices Fri, 10 Apr 2020 05:07:00 -0000 COVID-19 and Compliance: Part 5-Leadership and Final Thoughts full Tom Fox In this fifth and final episode, we consider the paucity of leadership at the federal level and why this has put businesses at the forefront of leadership during this crisis. In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this fifth and final episode, we consider the paucity of leadership at the federal level and why this has put businesses at the forefront of leadership during this crisis. Highlights from the podcast include:  Why do we need strong federal leadership? Without federal leadership why is business leadership so important? Will CEOs who signed the Business Roundtable’s Statement on the Purpose of an Organization adhere to those principals in this time of crisis? What time horizons are you considering? Why is trust even more important now? How will the COVID-19 crisis test the mettle of companies in ways never seen in our lifetimes? Resources Mike Volkov Call for Leadership Absence of Federal Leadership  Tom Fox Trust in the Age of Coronavirus  Final Thoughts Mike Cherkasky on Testing Your Mettle Learn more about your ad choices. Visit megaphone.fm/adchoices In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this fifth and final episode, we consider the paucity of leadership at the federal level and why this has put businesses at the forefront of leadership during this crisis. Highlights from the podcast include:

  1.  Why do we need strong federal leadership?
  2. Without federal leadership why is business leadership so important?
  3. Will CEOs who signed the Business Roundtable’s Statement on the Purpose of an Organization adhere to those principals in this time of crisis?
  4. What time horizons are you considering?
  5. Why is trust even more important now?
  6. How will the COVID-19 crisis test the mettle of companies in ways never seen in our lifetimes?

Resources

Mike Volkov

Call for Leadership

Absence of Federal Leadership 

Tom Fox

Trust in the Age of Coronavirus 

Final Thoughts

Mike Cherkasky on Testing Your Mettle

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 891 no COVID-19 and Compliance: Part 4-the Role of the CCO In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this fourth episode, we consider the role of the Chief Compliance Officer and why compliance must step up to the corporate forefront to meet these challenges. Highlights from the podcast include:  Why compliance must NEVER sleep during the coronavirus crisis. What are some of the specific tactics a CCO can employ during the coronavirus crisis? What technological solutions can a CCO bring to bear? What time horizons are you considering? Why the COVID-19 crisis should force you to be creative? Why culture assessments are a key tool for a CCO during this crisis. How will enforcement view the coronavirus crisis three to five years from now? Resources Mike Volkov Business Response Tom Fox Getting Started Specific Tactics a CCO Can Employ A Video Isn’t Just a Video Eric Feldman on Culture Assessments During Coronavirus Crisis According to Frank Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 09 Apr 2020 17:07:00 -0000 COVID-19 and Compliance: Part 4-the Role of the CCO full Tom Fox In this fourth episode, we consider the role of the CCO and why compliance must step up to the corporate forefront to meet these challenges. In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this fourth episode, we consider the role of the Chief Compliance Officer and why compliance must step up to the corporate forefront to meet these challenges. Highlights from the podcast include:  Why compliance must NEVER sleep during the coronavirus crisis. What are some of the specific tactics a CCO can employ during the coronavirus crisis? What technological solutions can a CCO bring to bear? What time horizons are you considering? Why the COVID-19 crisis should force you to be creative? Why culture assessments are a key tool for a CCO during this crisis. How will enforcement view the coronavirus crisis three to five years from now? Resources Mike Volkov Business Response Tom Fox Getting Started Specific Tactics a CCO Can Employ A Video Isn’t Just a Video Eric Feldman on Culture Assessments During Coronavirus Crisis According to Frank Learn more about your ad choices. Visit megaphone.fm/adchoices In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this fourth episode, we consider the role of the Chief Compliance Officer and why compliance must step up to the corporate forefront to meet these challenges. Highlights from the podcast include:

  1.  Why compliance must NEVER sleep during the coronavirus crisis.
  2. What are some of the specific tactics a CCO can employ during the coronavirus crisis?
  3. What technological solutions can a CCO bring to bear?
  4. What time horizons are you considering?
  5. Why the COVID-19 crisis should force you to be creative?
  6. Why culture assessments are a key tool for a CCO during this crisis.
  7. How will enforcement view the coronavirus crisis three to five years from now?

Resources

Mike Volkov

Business Response

Tom Fox

Getting Started

Specific Tactics a CCO Can Employ

A Video Isn’t Just a Video

Eric Feldman on Culture Assessments During Coronavirus Crisis

According to Frank

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 864 COVID-19 and Compliance: Part 3-Why Compliance Never Sleeps In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this third episode, we consider some of the various laws and regulations impacted by the coronavirus health crisis. Highlights from the podcast include: What new or special challenges are there in the Supply Chain during the COVID-19 crisis? What are changes in employment laws that impact corporations during the coronavirus health crisis? What are some of the employee risks faced during this crisis? What are some of the challenges around data privacy/data protection? What is the Bank Secrecy Act and how does it come into play during COVID-19? How can a corporate monitor help during this crisis? Why compliance must NEVER sleep during the coronavirus crisis. Resources Mike Volkov COVID-19 Supply Chain Risk Lessons COVID-19: Important Changes to Employment Law COVID-19: Employee Risks and Privacy Bank Secrecy Act Compliance During the COVID-19 Crisis Tom Fox Boeing Needs a Monitor Jared Connors on Supply Chain During Coronavirus Joanne Taylor on Financial Crimes Compliance During Coronavirus Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Apr 2020 05:07:00 -0000 COVID-19 and Compliance: Part 3-Why Compliance Never Sleeps full Tom Fox In this third episode, we consider some of the various laws and regulations impacted by the coronavirus health crisis and the role of compliance. In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this third episode, we consider some of the various laws and regulations impacted by the coronavirus health crisis. Highlights from the podcast include: What new or special challenges are there in the Supply Chain during the COVID-19 crisis? What are changes in employment laws that impact corporations during the coronavirus health crisis? What are some of the employee risks faced during this crisis? What are some of the challenges around data privacy/data protection? What is the Bank Secrecy Act and how does it come into play during COVID-19? How can a corporate monitor help during this crisis? Why compliance must NEVER sleep during the coronavirus crisis. Resources Mike Volkov COVID-19 Supply Chain Risk Lessons COVID-19: Important Changes to Employment Law COVID-19: Employee Risks and Privacy Bank Secrecy Act Compliance During the COVID-19 Crisis Tom Fox Boeing Needs a Monitor Jared Connors on Supply Chain During Coronavirus Joanne Taylor on Financial Crimes Compliance During Coronavirus Learn more about your ad choices. Visit megaphone.fm/adchoices In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this third episode, we consider some of the various laws and regulations impacted by the coronavirus health crisis. Highlights from the podcast include:

  1. What new or special challenges are there in the Supply Chain during the COVID-19 crisis?
  2. What are changes in employment laws that impact corporations during the coronavirus health crisis? What are some of the employee risks faced during this crisis?
  3. What are some of the challenges around data privacy/data protection?
  4. What is the Bank Secrecy Act and how does it come into play during COVID-19?
  5. How can a corporate monitor help during this crisis?
  6. Why compliance must NEVER sleep during the coronavirus crisis.

Resources

Mike Volkov

COVID-19 Supply Chain Risk Lessons

COVID-19: Important Changes to Employment Law

COVID-19: Employee Risks and Privacy

Bank Secrecy Act Compliance During the COVID-19 Crisis

Tom Fox

Boeing Needs a Monitor

Jared Connors on Supply Chain During Coronavirus

Joanne Taylor on Financial Crimes Compliance During Coronavirus

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 845 no COVID-19 and Compliance: Part 2-Board of Directors and Crisis Management In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this second episode, we consider the role of the Board of Directors and crisis management. Highlights from the podcast include:  Companies have three significant initial hurdles in the COVID-19 context: (a) Can the business continue to operate while protecting health and safety of employees and stakeholders? (b) If so, how can business continue and operate efficiently? (c) What will be impact on business from discontinuation of related industries? Are you assessing your risks in an ongoing and (almost) daily updating manner? What are your scenario-based financial analyses relating to capital, liquidity, financial health and survival? What is your succession planning? Security, data protection and privacy protocols. Resources Mike Volkov Board Governance Challenges in COVID-19 Crisis COVID-19: Crisis Management Tom Fox Peter Eyre on Navigating the Waters Mike Cherkasky on Testing Your Mettle Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 07 Apr 2020 05:07:00 -0000 COVID-19 and Compliance: Part 2-Board of Directors and Crisis Management full Tom Fox In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives. In this second episode, we consider the role of the Board of Directors and crisis management. In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this second episode, we consider the role of the Board of Directors and crisis management. Highlights from the podcast include:  Companies have three significant initial hurdles in the COVID-19 context: (a) Can the business continue to operate while protecting health and safety of employees and stakeholders? (b) If so, how can business continue and operate efficiently? (c) What will be impact on business from discontinuation of related industries? Are you assessing your risks in an ongoing and (almost) daily updating manner? What are your scenario-based financial analyses relating to capital, liquidity, financial health and survival? What is your succession planning? Security, data protection and privacy protocols. Resources Mike Volkov Board Governance Challenges in COVID-19 Crisis COVID-19: Crisis Management Tom Fox Peter Eyre on Navigating the Waters Mike Cherkasky on Testing Your Mettle Learn more about your ad choices. Visit megaphone.fm/adchoices In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this second episode, we consider the role of the Board of Directors and crisis management. Highlights from the podcast include:

  1.  Companies have three significant initial hurdles in the COVID-19 context: (a) Can the business continue to operate while protecting health and safety of employees and stakeholders? (b) If so, how can business continue and operate efficiently? (c) What will be impact on business from discontinuation of related industries?
  2. Are you assessing your risks in an ongoing and (almost) daily updating manner?
  3. What are your scenario-based financial analyses relating to capital, liquidity, financial health and survival?
  4. What is your succession planning?
  5. Security, data protection and privacy protocols.

Resources

Mike Volkov

Board Governance Challenges in COVID-19 Crisis

COVID-19: Crisis Management

Tom Fox

Peter Eyre on Navigating the Waters

Mike Cherkasky on Testing Your Mettle

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 902 no COVID-19 and Compliance: Part 1-Business Ethics Matters Even More Now In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this first episode, we consider the why compliance and ethics are even more important during coronavirus health crisis and what it may all mean going forward. Highlights from the podcast include: Businesses must lead from the top. Ethical decision making must be the guidepost for all decisions. Who are all the stakeholders which need to be considered? There are a variety of stakeholders which must be considered but health and safety should be the Number 1 consideration. Should employees be the No. 1 consideration? How will Gen Z view your company’s actions? Resources Mike Volkov-Ethical Business Decisions in the COVID-19 Crisis Tom Fox-Company Responses Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 06 Apr 2020 17:07:00 -0000 COVID-19 and Compliance: Part 1-Business Ethics Matters Even More Now full Tom Fox In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives. In this first episode, we consider the why compliance and ethics are even more important during coronavirus health crisis and what it may all mean going forward. In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this first episode, we consider the why compliance and ethics are even more important during coronavirus health crisis and what it may all mean going forward. Highlights from the podcast include: Businesses must lead from the top. Ethical decision making must be the guidepost for all decisions. Who are all the stakeholders which need to be considered? There are a variety of stakeholders which must be considered but health and safety should be the Number 1 consideration. Should employees be the No. 1 consideration? How will Gen Z view your company’s actions? Resources Mike Volkov-Ethical Business Decisions in the COVID-19 Crisis Tom Fox-Company Responses Learn more about your ad choices. Visit megaphone.fm/adchoices In this five-part series, Mike Volkov and Tom Fox consider COVID-19 from a variety of angles and perspectives; from the Board of Directors, the CCO, the ethical company, new laws and regulations, crisis management and leadership. In this first episode, we consider the why compliance and ethics are even more important during coronavirus health crisis and what it may all mean going forward. Highlights from the podcast include:

  1. Businesses must lead from the top.
  2. Ethical decision making must be the guidepost for all decisions.
  3. Who are all the stakeholders which need to be considered?
  4. There are a variety of stakeholders which must be considered but health and safety should be the Number 1 consideration.
  5. Should employees be the No. 1 consideration?
  6. How will Gen Z view your company’s actions?

Resources

Mike Volkov-Ethical Business Decisions in the COVID-19 Crisis

Tom Fox-Company Responses

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 776 no A Night at the Opera, Part 3 and Compliance into 2020 From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they begin a three-part series where they discuss the movie A Night at the Opera and how it informs the 2019 in Compliance, FCPA enforcement actions and Compliance into 2020 and beyond.  In this episode we put on our prognosticator’s turbans and looked into the veiled land of 2020 and beyond in compliance. Highlights from the podcast include: 1.     Why data will become more important in compliance? 2.     You have an ABC compliance program. What about Anti-Trust and Trade Compliance? 3.     How do the OFAC Compliance Framework and Anti-Trust Division Guidance inform ABC compliance? 4.     Where will compliance convergence go in 2020? 5.     Will 2020 be the year of the ‘Ethical Edge’? 6.     What will happen to FCPA enforcement numbers in 2020? What about individual prosecutions. Resources Mike Volkov-FCPA Predictions for 2020 Tom Fox-Compliance Insights for 2020 and Beyond Marx Brothers-The Sanity Clause Scene-YouTube Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 10 Feb 2020 06:07:00 -0000 A Night at the Opera, Part 3 and Compliance into 2020 full Tom Fox In this Part 3 of a three-part series on A Night at the Opera, Mike Volkov and Tom Fox look at the some of the top issues for Compliance Professionals in 2020 and beyond. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they begin a three-part series where they discuss the movie A Night at the Opera and how it informs the 2019 in Compliance, FCPA enforcement actions and Compliance into 2020 and beyond.  In this episode we put on our prognosticator’s turbans and looked into the veiled land of 2020 and beyond in compliance. Highlights from the podcast include: 1.     Why data will become more important in compliance? 2.     You have an ABC compliance program. What about Anti-Trust and Trade Compliance? 3.     How do the OFAC Compliance Framework and Anti-Trust Division Guidance inform ABC compliance? 4.     Where will compliance convergence go in 2020? 5.     Will 2020 be the year of the ‘Ethical Edge’? 6.     What will happen to FCPA enforcement numbers in 2020? What about individual prosecutions. Resources Mike Volkov-FCPA Predictions for 2020 Tom Fox-Compliance Insights for 2020 and Beyond Marx Brothers-The Sanity Clause Scene-YouTube Learn more about your ad choices. Visit megaphone.fm/adchoices From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they begin a three-part series where they discuss the movie A Night at the Opera and how it informs the 2019 in Compliance, FCPA enforcement actions and Compliance into 2020 and beyond.  In this episode we put on our prognosticator’s turbans and looked into the veiled land of 2020 and beyond in compliance. Highlights from the podcast include:

1.     Why data will become more important in compliance?

2.     You have an ABC compliance program. What about Anti-Trust and Trade Compliance?

3.     How do the OFAC Compliance Framework and Anti-Trust Division Guidance inform ABC compliance?

4.     Where will compliance convergence go in 2020?

5.     Will 2020 be the year of the ‘Ethical Edge’?

6.     What will happen to FCPA enforcement numbers in 2020? What about individual prosecutions.

Resources

Mike Volkov-FCPA Predictions for 2020

Tom Fox-Compliance Insights for 2020 and Beyond

Marx Brothers-The Sanity Clause Scene-YouTube

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1828 no A Night at the Opera, Part 2 and 2019 FCPA Enforcement Year in Review From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they begin a three-part series where they discuss the movie A Night at the Opera and how it informs the 2019 in Compliance, FCPA enforcement actions and Compliance into 2020 and beyond.  In this episode we review the 2019 FCPA year in enforcement. Highlights from the podcast include: 1.     What were the key lessons learned from SEC enforcement actions in 2019? 2.     What were the key lessons learned from DOJ enforcement actions in 2019? 3.     Why was the Ericsson enforcement action such a stunning resolution? 4.     What was the state of monitorships in 2019? 5.     Why did ‘follow the money’ continue to be critical in 2019? 6.     Did the Yates Memo achieve full expression in 2019? Resources Mike Volkov-FCPA Enforcement Highlights Tom Fox SEC Enforcement Actions from 2019 Five DOJ Enforcement Actions in 2019 Marx Brothers The Statement Room Scene-YouTube Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 03 Feb 2020 06:07:00 -0000 A Night at the Opera, Part 2 and 2019 FCPA Enforcement Year in Review full Tom Fox In this Part 2 of a three-part series on A Night at the Opera, Mike Volkov and Tom Fox look at the 2019 FCPA enforcement year in review. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they begin a three-part series where they discuss the movie A Night at the Opera and how it informs the 2019 in Compliance, FCPA enforcement actions and Compliance into 2020 and beyond.  In this episode we review the 2019 FCPA year in enforcement. Highlights from the podcast include: 1.     What were the key lessons learned from SEC enforcement actions in 2019? 2.     What were the key lessons learned from DOJ enforcement actions in 2019? 3.     Why was the Ericsson enforcement action such a stunning resolution? 4.     What was the state of monitorships in 2019? 5.     Why did ‘follow the money’ continue to be critical in 2019? 6.     Did the Yates Memo achieve full expression in 2019? Resources Mike Volkov-FCPA Enforcement Highlights Tom Fox SEC Enforcement Actions from 2019 Five DOJ Enforcement Actions in 2019 Marx Brothers The Statement Room Scene-YouTube Learn more about your ad choices. Visit megaphone.fm/adchoices From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they begin a three-part series where they discuss the movie A Night at the Opera and how it informs the 2019 in Compliance, FCPA enforcement actions and Compliance into 2020 and beyond.  In this episode we review the 2019 FCPA year in enforcement. Highlights from the podcast include:

1.     What were the key lessons learned from SEC enforcement actions in 2019?

2.     What were the key lessons learned from DOJ enforcement actions in 2019?

3.     Why was the Ericsson enforcement action such a stunning resolution?

4.     What was the state of monitorships in 2019?

5.     Why did ‘follow the money’ continue to be critical in 2019?

6.     Did the Yates Memo achieve full expression in 2019?

Resources

Mike Volkov-FCPA Enforcement Highlights

Tom Fox

SEC Enforcement Actions from 2019

Five DOJ Enforcement Actions in 2019

Marx Brothers

The Statement Room Scene-YouTube

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]]> 1967 no A Night at the Opera, Part 1 and 2019 Compliance Year in Review From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they begin a three-part series where they discuss the movie A Night at the Opera and how it informs the 2019 in Compliance, FCPA enforcement actions and Compliance into 2020 and beyond.  In this episode we review the year in compliance. Highlights from the podcast include: 1.     Why do many people consider A Night at the Opera the greatest of all Marx Brothers movies? What makes it AFI 100 worthy? 2.     What were some of the key regulatory pronouncements in 2019? 3.     How do the OFAC Compliance Framework and Anti-Trust Division Guidance inform ABC compliance? 4.     Why were the enforcement numbers so great in 2019? 5.     How did the role of compliance professionals strengthen in 2019? 6.     How successful was the DOJ in trying individuals in 2019? Resources Mike Volkov-A Record Year in Enforcement and Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 27 Jan 2020 06:08:00 -0000 A Night at the Opera, Part 1 and 2019 Compliance Year in Review full Tom Fox Today, Mike Volkov and I begin a 3-part series on A Night at the Opera and consider the 2019 year in compliance. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they begin a three-part series where they discuss the movie A Night at the Opera and how it informs the 2019 in Compliance, FCPA enforcement actions and Compliance into 2020 and beyond.  In this episode we review the year in compliance. Highlights from the podcast include: 1.     Why do many people consider A Night at the Opera the greatest of all Marx Brothers movies? What makes it AFI 100 worthy? 2.     What were some of the key regulatory pronouncements in 2019? 3.     How do the OFAC Compliance Framework and Anti-Trust Division Guidance inform ABC compliance? 4.     Why were the enforcement numbers so great in 2019? 5.     How did the role of compliance professionals strengthen in 2019? 6.     How successful was the DOJ in trying individuals in 2019? Resources Mike Volkov-A Record Year in Enforcement and Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they begin a three-part series where they discuss the movie A Night at the Opera and how it informs the 2019 in Compliance, FCPA enforcement actions and Compliance into 2020 and beyond.  In this episode we review the year in compliance. Highlights from the podcast include:

1.     Why do many people consider A Night at the Opera the greatest of all Marx Brothers movies? What makes it AFI 100 worthy?

2.     What were some of the key regulatory pronouncements in 2019?

3.     How do the OFAC Compliance Framework and Anti-Trust Division Guidance inform ABC compliance?

4.     Why were the enforcement numbers so great in 2019?

5.     How did the role of compliance professionals strengthen in 2019?

6.     How successful was the DOJ in trying individuals in 2019?

Resources

Mike Volkov-A Record Year in Enforcement and Compliance

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]]> 1004 no Ericsson FCPA Enforcement Action From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the recently announced FCPA enforcement action involving the Swedish telecom company, Ericsson.  Highlights from the podcast include: 1.     What are the underlying facts? 2.     Why didn’t the company obtain full credit under the FCPA Corporate Enforcement Policy? 3.     Was the $1 bn+ fine warranted? 4.     What are the key takeaways for the white-collar defense practitioner? 5.     What are the lessons learned for the compliance practitioner? 6.     Why third-parties continue to be the highest FCPA risk? Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 09 Dec 2019 06:03:00 -0000 Ericsson FCPA Enforcement Action full Tom Fox In this episode of Why a Duck?, Tom Fox and Mike Volkov take a deep dive into the Ericsson FCPA enforcement action. It is a hot take on the enforcement action announced last Friday. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the recently announced FCPA enforcement action involving the Swedish telecom company, Ericsson.  Highlights from the podcast include: 1.     What are the underlying facts? 2.     Why didn’t the company obtain full credit under the FCPA Corporate Enforcement Policy? 3.     Was the $1 bn+ fine warranted? 4.     What are the key takeaways for the white-collar defense practitioner? 5.     What are the lessons learned for the compliance practitioner? 6.     Why third-parties continue to be the highest FCPA risk? Learn more about your ad choices. Visit megaphone.fm/adchoices From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the recently announced FCPA enforcement action involving the Swedish telecom company, Ericsson.  Highlights from the podcast include:

1.     What are the underlying facts?

2.     Why didn’t the company obtain full credit under the FCPA Corporate Enforcement Policy?

3.     Was the $1 bn+ fine warranted?

4.     What are the key takeaways for the white-collar defense practitioner?

5.     What are the lessons learned for the compliance practitioner?

6.     Why third-parties continue to be the highest FCPA risk?

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]]> 1356 no Coconuts and SEC Year End FCPA Enforcement Actions From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Coconuts and how it informs the three SEC fiscal year end FCPA enforcement actions. Highlights from the podcast include: What can we learn from Quad/Graphics and sham 3rd parties? Beware of over expansion without appropriate FCPA controls. Why does control override inform the enforcement action involving Westport Fuels Systems? The M&A implications of Westport Fuels Systems? Why does the Barclays FCPA enforcement action get back to FCPA basics? How effective is your training program? Resources From Tom Fox Westport Fuels Barclays Quad/Graphics   From Mike Volkov Barclays Quad Graphics Marx Brothers Coconuts-the full movie on YouTube. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Nov 2019 06:03:00 -0000 Coconuts and SEC Year End FCPA Enforcement Actions full 7 Tom Fox In this episode of Why a Duck, Mike Volkov and I highlight some of our favorite scenes from The Coconuts and discuss the 3 SEC FCPA enforcement actions delivered at fiscal year end. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Coconuts and how it informs the three SEC fiscal year end FCPA enforcement actions. Highlights from the podcast include: What can we learn from Quad/Graphics and sham 3rd parties? Beware of over expansion without appropriate FCPA controls. Why does control override inform the enforcement action involving Westport Fuels Systems? The M&A implications of Westport Fuels Systems? Why does the Barclays FCPA enforcement action get back to FCPA basics? How effective is your training program? Resources From Tom Fox Westport Fuels Barclays Quad/Graphics   From Mike Volkov Barclays Quad Graphics Marx Brothers Coconuts-the full movie on YouTube. Learn more about your ad choices. Visit megaphone.fm/adchoices From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Coconuts and how it informs the three SEC fiscal year end FCPA enforcement actions. Highlights from the podcast include:

  1. What can we learn from Quad/Graphics and sham 3rd parties?
  2. Beware of over expansion without appropriate FCPA controls.
  3. Why does control override inform the enforcement action involving Westport Fuels Systems?
  4. The M&A implications of Westport Fuels Systems?
  5. Why does the Barclays FCPA enforcement action get back to FCPA basics?
  6. How effective is your training program?

Resources

From Tom Fox

  1. Westport Fuels
  2. Barclays
  3. Quad/Graphics  

From Mike Volkov

  1. Barclays
  2. Quad Graphics

Marx Brothers

Coconuts-the full movie on YouTube.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 998 no Coconuts and the OFAC Compliance Framework From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Coconuts and how it informs the OFAC Compliance Framework. Highlights from the podcast include: Why has Mike Volkov called the OFAC Compliance Framework a ‘game-changer’? How does the OFAC Framework illustrate regulatory convergence? What are some of the highlights of the OFAC Framework? What are some of the key lessons learned for the ABC compliance professional? How does data analytics as mandated in the OFAC Framework inform ABC compliance programs going forward? What are the mandates built into the OFAC Framework? How can an ABC compliance practitioner use the OFAC Framework if their company is under FCPA scrutiny? Resources From Tom Fox-see articles on the OFAC Compliance Framework. Introduction Management Commitment Risk Assessment Internal Controls Testing, Training and Auditing From Mike Volkov-See article on the OFAC Compliance Framework. Introduction Risk Assessments and Internal Controls Testing and Auditing and Training Review of Lessons Learned Download a copy of the OFAC Compliance Framework, here. Marx Brothers Coconuts-the full movie on YouTube. Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 21 Oct 2019 17:00:00 -0000 Coconuts and the OFAC Compliance Framework full 6 Tom Fox In this episode of Why a Duck, Tom Fox and Mike Volkov use the zaniness of the Coconuts as an introduction into the OFAC Compliance Framework. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Coconuts and how it informs the OFAC Compliance Framework. Highlights from the podcast include: Why has Mike Volkov called the OFAC Compliance Framework a ‘game-changer’? How does the OFAC Framework illustrate regulatory convergence? What are some of the highlights of the OFAC Framework? What are some of the key lessons learned for the ABC compliance professional? How does data analytics as mandated in the OFAC Framework inform ABC compliance programs going forward? What are the mandates built into the OFAC Framework? How can an ABC compliance practitioner use the OFAC Framework if their company is under FCPA scrutiny? Resources From Tom Fox-see articles on the OFAC Compliance Framework. Introduction Management Commitment Risk Assessment Internal Controls Testing, Training and Auditing From Mike Volkov-See article on the OFAC Compliance Framework. Introduction Risk Assessments and Internal Controls Testing and Auditing and Training Review of Lessons Learned Download a copy of the OFAC Compliance Framework, here. Marx Brothers Coconuts-the full movie on YouTube. Learn more about your ad choices. Visit megaphone.fm/adchoices From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Coconuts and how it informs the OFAC Compliance Framework. Highlights from the podcast include:

  1. Why has Mike Volkov called the OFAC Compliance Framework a ‘game-changer’?
  2. How does the OFAC Framework illustrate regulatory convergence?
  3. What are some of the highlights of the OFAC Framework?
  4. What are some of the key lessons learned for the ABC compliance professional?
  5. How does data analytics as mandated in the OFAC Framework inform ABC compliance programs going forward?
  6. What are the mandates built into the OFAC Framework?
  7. How can an ABC compliance practitioner use the OFAC Framework if their company is under FCPA scrutiny?

Resources

  1. From Tom Fox-see articles on the OFAC Compliance Framework.
  2. Introduction
  3. Management Commitment
  4. Risk Assessment
  5. Internal Controls
  6. Testing, Training and Auditing
  7. From Mike Volkov-See article on the OFAC Compliance Framework.
  8. Introduction
  9. Risk Assessments and Internal Controls
  10. Testing and Auditing and Training
  11. Review of Lessons Learned
  12. Download a copy of the OFAC Compliance Framework, here.

Marx Brothers

Coconuts-the full movie on YouTube.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1047 no Horsefeathers and the Juniper Networks FCPA Enforcement Action From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Horsefeathers and how it informs the recent Juniper Networks FCPA enforcement action.  Highlights from the podcast include:Why was this enforcement action so significant (or not)?Why does third-party management continue to bedevil so many companies?Why AP is a key gatekeeper for a best practices compliance program?What are some of the key lessons learned for the compliance professional?How does data analytics from this enforcement action inform compliance programs going forward?Why is GTE such a low hanging fruit for compliance programs?Why are slush funds so problematic under the FCPA?ResourcesFrom Tom Fox-see article Juniper Networks FCPA Enforcement Action: Speak Sternly and Enhance Controls, click here.From Mike Volkov-See article Juniper Networks Settles FCPA Violations with SEC or $11.7 Million, click here.Download a copy of the SEC Cease and Desist Order, here.Marx Brothers Horsefeathers-the full movie on YouTube. Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 14 Oct 2019 17:00:00 -0000 Horsefeathers and the Juniper Networks FCPA Enforcement Action full 5 Tom Fox In this episode of Why a Duck, Tom Fox and Mike Volkov use the zaniness of Horsefeathers as a framework to consider the Juniper Networks FCPA enforcement action. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Horsefeathers and how it informs the recent Juniper Networks FCPA enforcement action.  Highlights from the podcast include:Why was this enforcement action so significant (or not)?Why does third-party management continue to bedevil so many companies?Why AP is a key gatekeeper for a best practices compliance program?What are some of the key lessons learned for the compliance professional?How does data analytics from this enforcement action inform compliance programs going forward?Why is GTE such a low hanging fruit for compliance programs?Why are slush funds so problematic under the FCPA?ResourcesFrom Tom Fox-see article Juniper Networks FCPA Enforcement Action: Speak Sternly and Enhance Controls, click here.From Mike Volkov-See article Juniper Networks Settles FCPA Violations with SEC or $11.7 Million, click here.Download a copy of the SEC Cease and Desist Order, here.Marx Brothers Horsefeathers-the full movie on YouTube. Learn more about your ad choices. Visit megaphone.fm/adchoices From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Horsefeathers and how it informs the recent Juniper Networks FCPA enforcement action.  Highlights from the podcast include:Why was this enforcement action so significant (or not)?Why does third-party management continue to bedevil so many companies?Why AP is a key gatekeeper for a best practices compliance program?What are some of the key lessons learned for the compliance professional?How does data analytics from this enforcement action inform compliance programs going forward?Why is GTE such a low hanging fruit for compliance programs?Why are slush funds so problematic under the FCPA?ResourcesFrom Tom Fox-see article Juniper Networks FCPA Enforcement Action: Speak Sternly and Enhance Controls, click here.From Mike Volkov-See article Juniper Networks Settles FCPA Violations with SEC or $11.7 Million, click here.Download a copy of the SEC Cease and Desist Order, here.Marx Brothers

Horsefeathers-the full movie on YouTube.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1350 no Horsefeathers and the DOJ Antitrust Compliance Program Guidance From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Horsefeathers and the recently released DOJ Antitrust Division compliance guidance.  Highlights from the podcast include:Why is this document so significant?How will the Evaluation be used at the Charging Phase? At the Sentencing Phase?What is different in this Guidance from the ABC Guidance issued in April by the Criminal Division?What are some of the key lessons learned for the ABC compliance professional?How does data analytics from the Antitrust Division Guidance inform ABC compliance programs going forward?How does the Antitrust Guidance, working in conjunction with OFAC’s Sanctions Enforcement Guidelines and the Criminal Division’s 2019 Compliance Guidance demonstrate the need to break down the silos around compliance?Where does compliance go from here?Resources New Antitrust Compliance GuidanceFrom Tom Fox-eBook on The Antitrust Division Guidance on an Effective Compliance Program, available on CCI, here at no cost.From Mike Volkov-Two-part series on DOJ’s Antitrust Division Announces New Policy for Crediting Corporate Compliance Programs. Part Iand Part 2.Download a copy of the new Antitrust Division Guidance, here.Marx Brothers Horsefeathers-the full movie on YouTube. Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 09 Sep 2019 05:00:00 -0000 Horsefeathers and the DOJ Antitrust Compliance Program Guidance full Tom Fox In this episode of Why a Duck, we discuss the movie Horsefeathers and the recently released DOJ Antitrust Division compliance guidance. From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Horsefeathers and the recently released DOJ Antitrust Division compliance guidance.  Highlights from the podcast include:Why is this document so significant?How will the Evaluation be used at the Charging Phase? At the Sentencing Phase?What is different in this Guidance from the ABC Guidance issued in April by the Criminal Division?What are some of the key lessons learned for the ABC compliance professional?How does data analytics from the Antitrust Division Guidance inform ABC compliance programs going forward?How does the Antitrust Guidance, working in conjunction with OFAC’s Sanctions Enforcement Guidelines and the Criminal Division’s 2019 Compliance Guidance demonstrate the need to break down the silos around compliance?Where does compliance go from here?Resources New Antitrust Compliance GuidanceFrom Tom Fox-eBook on The Antitrust Division Guidance on an Effective Compliance Program, available on CCI, here at no cost.From Mike Volkov-Two-part series on DOJ’s Antitrust Division Announces New Policy for Crediting Corporate Compliance Programs. Part Iand Part 2.Download a copy of the new Antitrust Division Guidance, here.Marx Brothers Horsefeathers-the full movie on YouTube. Learn more about your ad choices. Visit megaphone.fm/adchoices From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Horsefeathers and the recently released DOJ Antitrust Division compliance guidance.  Highlights from the podcast include:Why is this document so significant?How will the Evaluation be used at the Charging Phase? At the Sentencing Phase?What is different in this Guidance from the ABC Guidance issued in April by the Criminal Division?What are some of the key lessons learned for the ABC compliance professional?How does data analytics from the Antitrust Division Guidance inform ABC compliance programs going forward?How does the Antitrust Guidance, working in conjunction with OFAC’s Sanctions Enforcement Guidelines and the Criminal Division’s 2019 Compliance Guidance demonstrate the need to break down the silos around compliance?Where does compliance go from here?Resources

New Antitrust Compliance GuidanceFrom Tom Fox-eBook on The Antitrust Division Guidance on an Effective Compliance Program, available on CCI, here at no cost.From Mike Volkov-Two-part series on DOJ’s Antitrust Division Announces New Policy for Crediting Corporate Compliance Programs. Part Iand Part 2.Download a copy of the new Antitrust Division Guidance, here.Marx Brothers

Horsefeathers-the full movie on YouTube.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1537 no Microsoft FCPA Enforcement Action Tom begins this episode by summarizing his favorite Marx Brothers movie Duck Soup. The scene where Pinky and his cohort report to Trentino is a fitting metaphor for surveillance and aptly introduces Microsoft’s FCPA Enforcement Action of July 2019. Microsoft’s Hungarian subsidiary admitted to 3rd party vendors engaging in bribery and corruption. Discounts of up 28-32% were granted without documentation to support their justification. This money was routed to corrupt foreign officials as bribes. As part of their remediation, Microsoft has taken steps to increase its capability to prevent violations by using Machine Learning to help identify transactions and automatically flag those that pose heightened risk. A compliance team then applies scrutiny to these flagged transactions. Microsoft devised a Transaction Monitoring system into which Business Development employees have to input information about business opportunities. This information is run through the Machine Learning tool which assigns it a risk rating. The tool is prepopulated with risk management strategies and techniques which salespeople can implement right away. Transaction monitoring is done pre-contract, which allows Microsoft to respond in a quicker and more expeditious manner. It also positively impacts the company's profitability. A similar compliance solution is an efficient way for a company to come up with bids, respond to true market forces, and protect against third-party misconduct, says Mike. Control persons and gatekeepers are key players in such a solution and therefore, need to be trained to give them the tools to raise compliance issues. Data analytics would make the process even more effective. ResourcesDuck Soup - full movieBrad Smith’s email to Microsoft employees Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 26 Aug 2019 05:01:00 -0000 Microsoft FCPA Enforcement Action full 3 Tom Fox Why a Duck? It's a new podcast by two of the top compliance commentators around wrapped around their love for the Marx Brothers. In this episode they consider the Microsoft FCPA Enforcement action for compliance lessons. Tom begins this episode by summarizing his favorite Marx Brothers movie Duck Soup. The scene where Pinky and his cohort report to Trentino is a fitting metaphor for surveillance and aptly introduces Microsoft’s FCPA Enforcement Action of July 2019. Microsoft’s Hungarian subsidiary admitted to 3rd party vendors engaging in bribery and corruption. Discounts of up 28-32% were granted without documentation to support their justification. This money was routed to corrupt foreign officials as bribes. As part of their remediation, Microsoft has taken steps to increase its capability to prevent violations by using Machine Learning to help identify transactions and automatically flag those that pose heightened risk. A compliance team then applies scrutiny to these flagged transactions. Microsoft devised a Transaction Monitoring system into which Business Development employees have to input information about business opportunities. This information is run through the Machine Learning tool which assigns it a risk rating. The tool is prepopulated with risk management strategies and techniques which salespeople can implement right away. Transaction monitoring is done pre-contract, which allows Microsoft to respond in a quicker and more expeditious manner. It also positively impacts the company's profitability. A similar compliance solution is an efficient way for a company to come up with bids, respond to true market forces, and protect against third-party misconduct, says Mike. Control persons and gatekeepers are key players in such a solution and therefore, need to be trained to give them the tools to raise compliance issues. Data analytics would make the process even more effective. ResourcesDuck Soup - full movieBrad Smith’s email to Microsoft employees Learn more about your ad choices. Visit megaphone.fm/adchoices Tom begins this episode by summarizing his favorite Marx Brothers movie Duck Soup. The scene where Pinky and his cohort report to Trentino is a fitting metaphor for surveillance and aptly introduces Microsoft’s FCPA Enforcement Action of July 2019.

Microsoft’s Hungarian subsidiary admitted to 3rd party vendors engaging in bribery and corruption. Discounts of up 28-32% were granted without documentation to support their justification. This money was routed to corrupt foreign officials as bribes.

As part of their remediation, Microsoft has taken steps to increase its capability to prevent violations by using Machine Learning to help identify transactions and automatically flag those that pose heightened risk. A compliance team then applies scrutiny to these flagged transactions.

Microsoft devised a Transaction Monitoring system into which Business Development employees have to input information about business opportunities. This information is run through the Machine Learning tool which assigns it a risk rating. The tool is prepopulated with risk management strategies and techniques which salespeople can implement right away. Transaction monitoring is done pre-contract, which allows Microsoft to respond in a quicker and more expeditious manner. It also positively impacts the company's profitability.

A similar compliance solution is an efficient way for a company to come up with bids, respond to true market forces, and protect against third-party misconduct, says Mike. Control persons and gatekeepers are key players in such a solution and therefore, need to be trained to give them the tools to raise compliance issues. Data analytics would make the process even more effective.

ResourcesDuck Soup - full movieBrad Smith’s email to Microsoft employees

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1137 no The Race to Effective Compliance Mike's favorite Marx Brothers movie Day at the Races is a fitting analogy for the race to effective compliance. Mike shares his favorite lines from the movie after which the discussion focuses on 3 Best Practices Compliance programs from the Criminal Division of the Department of Justice and OFAC. Tom points out that each guidance document has a different focus depending on who released it. The Antitrust Guidance for example, is focused on criminal antitrust behavior: that is, the intention to defraud the market based on market fixing, cartel behavior or other intentional acts by more than one group or person. Each one of the documents gives greater insight to anti-corruption practitioners to incorporate into their compliance program. There are elements that are common to all three documents. Mike says this emphasizes the importance of operationalizing your program to cut through the silos that exist in compliance. Compliance now has a reason to bring together all these elements into one comprehensive training program. The Criminal Division of the Department of Justice asks for continuous monitoring of the compliance program. We need to take the data and loop it back into the compliance program to continually improve. Antitrust monitoring takes a statistical look at contract data over long periods of time to discover indications of cartel or price-fixing behavior. Anti-corruption monitoring shows the need for overall transaction monitoring from a compliance perspective so that red flags or anomalies are detected early on. Once you have a database of contracts you can now have effective business analysis. You can analyze discounts given to customers over time and compare and contrast profit margins of contracts by geographical area or business unit. This is going to put the Compliance at the table for business discussions going forward. Compliance now becomes part of the business plan. Resources OFAC Compliance document Criminal Division Compliance document Antitrust Division Compliance document Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 12 Aug 2019 05:01:00 -0000 The Race to Effective Compliance full 2 Tom Fox Why a Duck? It's a new podcast by two of the top compliance commentators around wrapped around their love for the Marx Brothers. Today they consider recent DOJ and OFAC pronouncements on best practices in compliance. Mike's favorite Marx Brothers movie Day at the Races is a fitting analogy for the race to effective compliance. Mike shares his favorite lines from the movie after which the discussion focuses on 3 Best Practices Compliance programs from the Criminal Division of the Department of Justice and OFAC. Tom points out that each guidance document has a different focus depending on who released it. The Antitrust Guidance for example, is focused on criminal antitrust behavior: that is, the intention to defraud the market based on market fixing, cartel behavior or other intentional acts by more than one group or person. Each one of the documents gives greater insight to anti-corruption practitioners to incorporate into their compliance program. There are elements that are common to all three documents. Mike says this emphasizes the importance of operationalizing your program to cut through the silos that exist in compliance. Compliance now has a reason to bring together all these elements into one comprehensive training program. The Criminal Division of the Department of Justice asks for continuous monitoring of the compliance program. We need to take the data and loop it back into the compliance program to continually improve. Antitrust monitoring takes a statistical look at contract data over long periods of time to discover indications of cartel or price-fixing behavior. Anti-corruption monitoring shows the need for overall transaction monitoring from a compliance perspective so that red flags or anomalies are detected early on. Once you have a database of contracts you can now have effective business analysis. You can analyze discounts given to customers over time and compare and contrast profit margins of contracts by geographical area or business unit. This is going to put the Compliance at the table for business discussions going forward. Compliance now becomes part of the business plan. Resources OFAC Compliance document Criminal Division Compliance document Antitrust Division Compliance document Learn more about your ad choices. Visit megaphone.fm/adchoices Mike's favorite Marx Brothers movie Day at the Races is a fitting analogy for the race to effective compliance. Mike shares his favorite lines from the movie after which the discussion focuses on 3 Best Practices Compliance programs from the Criminal Division of the Department of Justice and OFAC.

Tom points out that each guidance document has a different focus depending on who released it. The Antitrust Guidance for example, is focused on criminal antitrust behavior: that is, the intention to defraud the market based on market fixing, cartel behavior or other intentional acts by more than one group or person. Each one of the documents gives greater insight to anti-corruption practitioners to incorporate into their compliance program.

There are elements that are common to all three documents. Mike says this emphasizes the importance of operationalizing your program to cut through the silos that exist in compliance. Compliance now has a reason to bring together all these elements into one comprehensive training program.

The Criminal Division of the Department of Justice asks for continuous monitoring of the compliance program. We need to take the data and loop it back into the compliance program to continually improve. Antitrust monitoring takes a statistical look at contract data over long periods of time to discover indications of cartel or price-fixing behavior. Anti-corruption monitoring shows the need for overall transaction monitoring from a compliance perspective so that red flags or anomalies are detected early on.

Once you have a database of contracts you can now have effective business analysis. You can analyze discounts given to customers over time and compare and contrast profit margins of contracts by geographical area or business unit. This is going to put the Compliance at the table for business discussions going forward. Compliance now becomes part of the business plan.

Resources OFAC Compliance document Criminal Division Compliance document Antitrust Division Compliance document

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]]> 893 no Favorite Marx Brothers Movies Hosts Tom Fox and Mike Volkov launch their new podcast series by talking about their favorite Marx Brothers movies and how it leads to a broader description of compliance. The title Why a Duck comes from a line in the famous 1929 Marx Brothers film Coconuts: “ Why a duck? Why no chicken? Why no horse?” Duck Soup is Tom’s favorite Marx Brothers movie. The film depicts a series of farcical efforts where rivals try to overthrow Rufus T. Firefly. It is political chaos at its finest. Tom especially enjoys the mirror scene. Mike's favorite Marx Brothers movie is Day at the Races. Hugo Hackenbush is a vet posing at a doctor at Standish Sanatorium to take care of his wealthy patient Emily Upjohn. The sanatorium is in financial trouble. The film shows his hilarious schemes to get a horse to win a race so that he can pay off the sanatorium debts. Mike shares a funny story of how the Marx brothers cornered Irving Thalberg into a meeting. Resources Duck Soup - The Mirror Scene  Learn more about your ad choices. Visit megaphone.fm/adchoices Mon, 12 Aug 2019 05:01:00 -0000 Favorite Marx Brothers Movies full 1 Tom Fox Why a Duck? It's a new podcast by two of the top compliance commentators around wrapped around their love for the Marx Brothers. Hosts Tom Fox and Mike Volkov launch their new podcast series by talking about their favorite Marx Brothers movies and how it leads to a broader description of compliance. The title Why a Duck comes from a line in the famous 1929 Marx Brothers film Coconuts: “ Why a duck? Why no chicken? Why no horse?” Duck Soup is Tom’s favorite Marx Brothers movie. The film depicts a series of farcical efforts where rivals try to overthrow Rufus T. Firefly. It is political chaos at its finest. Tom especially enjoys the mirror scene. Mike's favorite Marx Brothers movie is Day at the Races. Hugo Hackenbush is a vet posing at a doctor at Standish Sanatorium to take care of his wealthy patient Emily Upjohn. The sanatorium is in financial trouble. The film shows his hilarious schemes to get a horse to win a race so that he can pay off the sanatorium debts. Mike shares a funny story of how the Marx brothers cornered Irving Thalberg into a meeting. Resources Duck Soup - The Mirror Scene  Learn more about your ad choices. Visit megaphone.fm/adchoices Hosts Tom Fox and Mike Volkov launch their new podcast series by talking about their favorite Marx Brothers movies and how it leads to a broader description of compliance. The title Why a Duck comes from a line in the famous 1929 Marx Brothers film Coconuts: “ Why a duck? Why no chicken? Why no horse?”

Duck Soup is Tom’s favorite Marx Brothers movie. The film depicts a series of farcical efforts where rivals try to overthrow Rufus T. Firefly. It is political chaos at its finest. Tom especially enjoys the mirror scene.

Mike's favorite Marx Brothers movie is Day at the Races. Hugo Hackenbush is a vet posing at a doctor at Standish Sanatorium to take care of his wealthy patient Emily Upjohn. The sanatorium is in financial trouble. The film shows his hilarious schemes to get a horse to win a race so that he can pay off the sanatorium debts.

Mike shares a funny story of how the Marx brothers cornered Irving Thalberg into a meeting.

Resources Duck Soup - The Mirror Scene 

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