Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this special edition of the FCPA Compliance Report, we welcome back fan favorite Mary Inman, now at her new firm, Whistleblower Partners LLP, a firm dedicated to assisting whistleblowers navigate various reward programs.

Mary joins Tom Fox to discuss what we know so far about the DOJ Whistleblower Incentive Initiative.

Mary has a positive perspective on the Department of Justice’s (DOJ) White Collar Whistleblower Program. She acknowledges the gaps in existing whistleblower reward programs across multiple agencies and sees the DOJ program as a crucial opportunity to fill these lacunae. Inman’s expertise, particularly in the SEC program, allows her to identify specific gaps, such as the lack of financial protections for whistleblowers reporting Foreign Corrupt Practices Act violations involving companies not publicly listed on US exchanges.

From her perspective, the DOJ program will address serious financial crimes, including domestic corruption. Inman also anticipates that the DOJ will establish its own office of the whistleblower, mirroring similar initiatives in other agencies, hence providing both confidential and anonymous reporting avenues.

Topics Covered in This Episode:

• Specialized Law Firm for Whistleblower Reward Programs
• Financial Crime Reporting Enhancement Initiative
• Establishing a Central Office for Whistleblowers
• Championing Transparency: Grassley’s Whistleblower Advocacy
• Wellness Fund Support for Whistleblowers

Resources:

Mary Inman on LinkedIn

Whistleblower Partners LLP

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this special edition of the FCPA Compliance Report, welcome Sam Silverstein. They take a deep dive into how Boeing can begin to overhaul and reform their toxic culture, which led to the 2024 compliance and ethics failures. They discuss the power of the Culture Audit™, which is the sponsor of this podcast.

Sam Silverstein is a seasoned professional with over three decades of experience in corporate culture. Silverstein believes that a strong leadership role is crucial in driving culture change within an organization. His philosophy is that action follows belief, stressing that leaders must genuinely prioritize creating a culture of quality, compliance, and safety for it to truly thrive.

Silverstein maintains that the CEO’s primary role is to protect the organization’s culture, while the COO should ensure operations align with the board and CEO’s strategic plan. His experiences, particularly his insights drawn from Boeing’s situations, have shaped his belief that prioritizing culture over short-term profits, along with a culture audit and specific implementation plan, can help address systemic issues and foster a high-performance workplace culture. 

Topics Covered in This Episode:

• Transition from Safety to Profit Culture at Boeing
• Measuring Organizational Culture through Employee Engagement
• Creating Accountable Leaders for Organizational Culture Transformation
• Cultivating Sustainable High-Performance Organizational Culture
• Cultivating Employee Trust Through Genuine Leadership Efforts
• Rewarding Ethical Behavior for Organizational Integrity
• Data-Driven Organizational Culture Enhancement Process
• Recognition and Amplification through Personalized Engagement

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special edition of the FCPA Compliance Report, Tom welcomes Ron Karr, long time thought leader in the art of leadership, persuasion and influence. They take a deep dive into the science of influence and persuasion and help the compliance professional understand how they can use this science to move the compliance ball forward in an organization.

Ron Karr is a speaker, and author with over three decades of experience in the sales and consulting industry. His career saw its inception in retail, later transitioning to the computer industry, and eventually culminating in the establishment of his own consulting business. Karr’s perspective on the “Velocity Mindset”, as detailed in his book, revolves around the concept of speed with direction, where goals and aspirations are the key drivers of actions.

His belief that self-imposed limitations can hinder our progress is deeply rooted in his experiences, leading him to emphasize the importance of self-evaluation, proactive approach adjustments, and reshaping our narratives to facilitate our goals. Karr underscores the value of networking and learning from others, seeing it as a vehicle to expedite success and achieve professional velocity.

Topics Covered in this Episode

• Purposeful Reflection for Effective Decision-Making
• Neurochemical Impact on Influencing Others Successfully
• Propelling Success through Adaptive Strategies
• Empowering Personal Growth Through Story Rewriting
• Enhancing Professional Success Through Peer Engagement
• The Velocity Mindset: Achieving Success Through Networking

Resources:

Ron Karr on LinkedIn

Company

Blog

The Velocity Mindset

Tom Fox

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LinkedIn

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this special edition, Tom welcomes Jessica Nall, a partner at Baker McKenzie who leads the firm's West Coast investigations and compliance practice, and Maria Piontkovska, a Senior Associate in the same practice group.

We deeply dive into their article about the recent speeches by Department of Justice representatives at the ABA White Collar Conference on the new DOJ whistleblower program, AI, data protection, and intellectual property protection.

Jessica Nall and Maria Piontkovska are prominent legal professionals specializing in white-collar defense and corporate investigations. Jessica, a seasoned attorney with over 20 years of experience, leads Baker McKenzie’s white-collar practice in California, and Maria is a skilled US white-collar attorney originally from Ukraine.

Both regard the ABA White Collar Conference as an essential platform for the defense bar, government investigators, and compliance leaders to gather for discussions and networking. Nall sees the conference as vital for disseminating new compliance expectations and enforcement trends announced by government officials. At the same time, Piontkovska highlights the importance of the direct line of communication with these officials, providing insights straight from the source.

Their perspectives on the conference are shaped by their extensive experiences in the field and drive their contributions to the discussions and policies related to white-collar defense and compliance.

Topics Covered in This Episode:

• Key Figures Discussing Trends in Compliance
• Corporate Transparency Incentive Initiative
• Financial Incentives for Anti-Corruption Self-Disclosure
• Navigating Risks: AI in Corporate Compliance
• Data Mapping for International Data Security

Resources:

Jessica Nall on LinkedIn

Maria Piontkovska on LinkedIn

Compliance Steps After ABA White Collar Crime Conference

United States: Department of Justice announces new corporate compliance directives for AI along with increased penalties for AI-related misconduct

Baker McKenzie

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special edition of the FCPA Compliance Report, Tom welcomes back Jason Meyer, founder of LeadGood LLC. In this episode, Jason Meyer and Tom Fox continue the annual tradition begun by Jason of Ethics Madness, a show where we look at the intersection of sports and ethics during March Madness.  

Topics Covered in this Episode

·      College Athletes' Earning Opportunities in NCAA

·      Adapting to Evolving Sports Rules for Success

·      Temple Basketball: Impact of Sports Betting

·      Balancing Player Safety and Sporting Entertainment Ethics

·      Ethical Compliance Protocols in Sports Organizations

·      Embracing Neurodiversity: Athletes' Personal Stories

·      Sports Ethics: Second Chances and Compliance

Resources

Jason Meyer on LinkedIn

LeadGood LLC

Anthem for this Podcast

Winning by Santana

Compliance Anthem of the Week Playlist on Spotify

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this edition of the FCPA Compliance Report, Tom welcomes back Mary Inman, partner at the newly formed Whistleblower Partners LLP. They talk about the new Department of Justice (DOJ) initiative to pay a bounty to whistleblowers.

Mary Inman is a well-recognized authority in the realm of whistleblowing programs. In this episode, she focuses on DOJ whistleblower program. Her perspective on the program is cautiously optimistic, acknowledging the potential gains in encouraging whistleblowers to disclose information about financial crimes and corruption. However, she has expressed concerns about certain aspects of the program’s design, such as excluding culpable whistleblowers and limiting the type of information that can be provided.

These viewpoints stem from her extensive experience and deep understanding of the complexities involved in implementing effective whistleblower programs. Drawing from her expertise, Inman also emphasizes the need for confidentiality and anonymity for whistleblowers, similar to the SEC program, suggesting that while the DOJ program is a positive step, careful consideration and potential revisions are required to ensure its effectiveness and fairness.

Key Highlights:

• Financial Crime Whistleblower Reward Initiative
• Promoting Transparency Through Compliance Officer Resignations
• Whistleblower Protection for Mental Well-being

Resources:

Mary Inman on LinkedIn

Whistleblower Partner LLP

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance.

In this edition of the FCPA Compliance Report, Tom welcomes back Jonathan Wilson, one of the country’s top experts on the Corporate Transparency Act. We dissect the court decision in the case of the National Small Business Union, which invalidated the CTA and what it might mean for the law going forward.

Jonathan Wilson is a well-respected figure in corporate transparency and has established an impressive body of work around the Corporate Transparency Act. He is the founder of FinCEN Report, a company that helps businesses and others comply with the CTA.

Wilson’s perspective on the Act hinges on his understanding of its legal implications and practical considerations, warning companies that, despite a recent district court decision, they are still required to meet filing obligations. We take a deep dive into the court opinion, how it applied (or misapplied) US law and explain the need for continued compliance with the law.

Even with this court decision, Wilson’s advice is clear, companies must continue with compliance efforts and fulfill their reporting requirements, as delays will not alter the facts or obligations of the Act. The invalidation of the CTA is only applicable to the named plaintiff in the Northern District of Alabama so all others must continue to comply with the law.

Key Highlights:

• CTA Overturned—Is Interstate Commerce Affected?
• What is the US National Security Interest?
• Beneficial Owner Disclosure in Money Laundering
• Senate Ratification of International Treaties
• Navigating Legal Compliance in Competitive Business Environment

Resources:

Jonathan Wilson on LinkedIn

FinCEN Report

National Small Business Union decision

Tom Fox

Instagram

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LinkedIn

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this edition of the FCPA Compliance Report, Tom welcomes back Mike Lindsey to discuss the Corporate Transparency Act. In a first for the FCPA Compliance Report, after the episode was recorded but before it was posted, the CTA was declared unconstitutional by a Trump appointed US District Judge. We recorded an addendum to consider this court decision invalidating the law.

Mike Lindsey, a distinguished corporate and transactional lawyer based at Steinbrecher & Span, has built a solid reputation as an authority on the CTA. Lindsey’s insights into the CTA are influenced by his emphasis on privacy and data security, highlighting the risks correlated with a centralized database potentially accessible via the dark web. From his perspective, the CTA serves as a critical federal law designed to increase transparency around beneficial ownership of corporations and inhibit illegal activities such as money laundering, tax evasion, and fraud. However, Lindsey also questions its effectiveness in disclosing ownership by entities like the Iran Revolutionary Guard. Despite this, he sees the CTA as a ground-breaking move for privately held companies, requiring them to report beneficial owners, something uncommon among small businesses in the United States. Ultimately, Lindsey views the CTA as an essential measure towards impeding financial crimes and enhancing accountability in corporate structures.

We also discuss the trial court decision in the case of the National Small Business Union, which invalidated the CTA and what it might mean for the law going forward. 

Key Highlights:

• Beneficial Ownership Disclosure Law
• Key Players in Corporate Decision-Making
• CTA Compliance Impact on Small Businesses
• Federal Database Security Concerns
• Illicit Financial Activities and National Security Measures
• National Small Business Union decision

Resources:

Mike Lindsey on LinkedIn

Steinbrecher & Span

National Small Business Union

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this special Thursday edition of the FCPA Compliance Report, Tom welcomes Erica Salmon Byrne, Chief Strategy Officer and Executive Chair, at Ethisphere to discuss the announcement of the 2024 World’s Most Ethical Companies Designations and the new Ethics Premium.

Erica Salmon Byrne is a renowned figure in ethical business practices, recognized for her significant role in the annual announcement and recognition of the world’s most ethical companies. Byrne views this list as a crucial acknowledgment of companies globally that are making a positive impact, with representation across 20 countries and 44 industries. Her experiences in leading changes to the program’s methodology, such as introducing a third-party management category and a heightened focus on governance and culture, have shaped her perspective on the continuous evolution and improvement of the evaluation process. She sees the list as a valuable tool for companies to demonstrate their commitment to ethics and compliance and as a source of inspiration for others in the compliance community to strive for ethical excellence.

Key Highlights:

• Global Recognition for Ethical Business Practices
• Enhanced Scoring System Emphasizing Governance and Culture
• Global Representation of Ethical Industry Leaders
• Ethics Quotient Evaluation for Recognized Companies

Resources:

Erica Salmon Byrne on LinkedIn

Ethisphere

World’s Most Ethical Companies for 2024

Tom Fox

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom Fox welcomes Seth Whitelaw who has worked in life sciences compliance for over 30 years.  

Seth Whitelaw is a seasoned lawyer and compliance officer with a specialization in drug law, particularly within the life sciences industry. He has a unique perspective on regulatory guidance updates in healthcare compliance, shaped by his experiences in developing compliance programs and teaching law. Whitelaw believes that despite technological advancements in healthcare compliance, the role of compliance officers remains crucial. He views them as a necessary check and balance within companies, akin to the role of government in society. Whitelaw emphasizes the importance of addressing industry criticisms and regulatory updates to prevent distractions and ensure companies can focus on their primary objectives. He is a strong advocate for compliance officers, recognizing their vital role in helping companies bring safe and effective products to market, thereby adding value to the companies they serve.

 Key Highlights

·      Tailored Compliance Consulting for Mid-Sized Companies

·      Evolutionary Alignment for Effective Compliance Programs

·      Data-Driven Healthcare Compliance Updates and AI Integration

·      Enhancing Life Science Compliance with AI

Resources

Seth Whitelaw on LinkedIn

Whitelaw Compliance Group

Tom Fox

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LinkedIn

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Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom Fox welcomes back Michael Volkov as they take a deep dive into the ABB, Albemarle and SAP FCPA enforcement actions to try and unpack the DOJ’s pivot away from heavy penalties for recidivists to prioritizing self-disclosure above all else.  

Volkov's perspective on the Department of Justice's (DOJ) FCPA enforcement actions is both critical and analytical, shaped by his extensive experience. He underscores the necessity of transparency and explanation in the factors considered by the DOJ, highlighting its significance to practitioners in the field. Volkov also recognizes the shift in DOJ policy towards data-driven compliance, requiring companies to provide data to substantiate their conclusions and demonstrate their compliance efforts. He further notes the evolving landscape of voluntary disclosure and remediation, suggesting these areas are now pivotal in the DOJ's enforcement approach. Volkov's insights reflect a nuanced understanding of the changing dynamics in FCPA enforcement and the imperative for companies to adapt to these shifts.

 Key Highlights:

• Importance of Cooperation in Corporate Enforcement Cases
• Incentivizing Self-Disclosure in DOJ's FCPA Enforcement
• Increased Penalty Reduction for Voluntary Self-Disclosure
• DOJ's Evolving Approach to Corporate Penalties
• Benefits of Voluntary Self-Disclosure in Enforcement

Resources:

Volkov Law Group

Corruption, Crime and Compliance

Tom Fox

Instagram

Facebook

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LinkedIn

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