FCPA Compliance Report

The FCPA Compliance Report is the longest running podcast in the in compliance and business ethics. Join its by its award-winning host, Tom Fox, the Voice of Compliance as he visits with top compliance practitioners, key figures from business, the government and law firms in the top podcast dedicated to all things compliance.

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Business News
News Commentary
1
Episode 520, Susan Divers on Evolution in Compl...
I visit with Susan Divers, Senior Advisor at LRN, in my continuing series this year looking back over the past decade of Foreign Corrupt Practices Act enforcement and the evolution of compliance.
23 min
2
Gar Hurst on Biggest Import Issue You Have Neve...
What is the biggest import control issue you have never heard about? Gar Hurst joins the FCPA Compliance Report to explain.
28 min
3
Carrie Penman on Beyond the Moment
In this episode, I am joined I am joined by Carrie Penman. We visit about their upcoming 2020 virtual conference, NAVEX Next, entitled Beyond the Moment.
20 min
4
Wirecard Part 9, Running to Fraud with Hermes
In this episode, Mikhail Reider-Gordon and Tom Fox explore the money laundering Wirecard engaged in via the project dubbed ‘Hermes’.
52 min
5
The FinCen Papers
In this episode, I am joined by Piero Molinario, Senior Managing Director, at K2 Intelligence FIN and Joanne Taylor, Managing Director, K2 Intelligence FIN’s We take a deep dive into the FinCen Papers.
24 min
6
Jonathan Armstrong on Herbalife from a UK Persp...
In this concluding Part 5, I am joined by Jonathan Armstrong and we discuss the enforcement action from the UK perspective under the UK Bribery Act.
13 min
7
Jonathan Marks on the Role of Gatekeepers
In this Part 4, Jonathan Marks and Tom Fox discuss the role of gatekeepers and the lack of skepticism at the Board of Directors.
9 min
8
Compliance Book Club Interview of Robert Chesnu...
In this special edition, I am pleased to cross-post a recent live event hosted by Sean Freidlin, Director Product Marketing at SAI Global. He hosted the third edition of SAI Global’s Compliance Book Club, featuring Robert Chesnut, author of Intentional Integrity.
61 min
9
Wirecard Part 9, Bring Lawyers Guns and Money
Once again, I am joined by Mikhail Reider-Gordon. We explore those other professional service providers who enabled Wirecard in our bring Lawyers Guns and Money episode.
37 min
10
Matt Kelly on the Role of Internal Audit
In this Part 3, Matt Kelly joins me to consider the role internal audit in this matter and the (non) actions of Herbalife’s Board of Directors.
11 min
11
Jay Rosen on the Lack of Monitorship
In this Part 2, Jay Rosen joins me to consider how Herbalife was able to avoid a Monitorship.
8 min
12
Mike Volkov on the Herbalife FCPA Resolution
In this Part 1, Mike Volkov details how he would counsel a company which found itself in a situation similar to Herbalife.
10 min
13
The Miller & Chevalier 2020 Latin American Corr...
In this Episode 5, I am joined by James Tillen and Matt Ellis to take a retrospective look back over the 12 years of Miller & Chevalier’s Latin American Corruption Survey.
23 min
14
The Miller & Chevalier 2020 Latin American Corr...
In this Episode 4, I visit with firm Counsel Greg Bates and we explore some of the Survey’s data on compliance program design and implementation.
13 min
15
Lies, Spies and Wirecard
In this episode of our continuing series on Wirecard, Mikhail Reider-Gordon and Tom Fox explore lies, spies and Wirecard.
44 min
16
The Miller & Chevalier 2020 Latin American Corr...
In this Episode 3, I visit with firm Member Alejandra Almonte and we explore some of the Survey’s high-level findings on compliance trends in the Latin American region.
13 min
17
The Miller & Chevalier 2020 Latin American Corr...
In this Episode 2, I visit with firm Member Matt Ellis on some of the Survey’s findings on country specific corruption issues.
14 min
18
The Miller & Chevalier 2020 Latin American Corr...
In this Episode 1, I visit with firm Member James Tillen on the Survey’s findings on region-wide corruption risks and region-wide perceptions of corruption and effectiveness of local anti-corruption laws.
15 min
19
Wirecard-Part 6, End of Summer Wrap UP
In this episode of Wirecard Part 6, Mikhail Reider Gordon and myself are back from a summer hiatus and wrap up what has been happening on the Wirecard front over the past few weeks.
49 min
20
John Fons and Current Issues Facing CCOs
In this episode, I visit with John Fons. Fons provides insights into some of the current issues facing CCOs and CECOs today.
21 min
21
Jordan Arnold and Surjeet Mahant on the DFS Cyb...
In this episode, I take a deep dive into the recent DFS cyber-enforcement action involving 1st American Title, with K2 FIN's Jordan Arnold and Surjeet Mahant.
35 min
22
Special 500th Anniversary Episode
Welcome to the 500th Anniversary episode of the FCPA Compliance Report. Join me as a look back at the podcast, the evolution of compliance and a look ahead into podcast, Liverpool football and buffalo wings.
37 min
23
Jonathan Marks on the Evolution of Compliance T...
In this episode, I visit with Jonathan Marks, a partner at Baker Tilly who talks about the evolution of compliance through the lens of internal audit. We consider how some of the changes in compliance mirror those he saw and lived through in the world of internal audit.
25 min
24
Jay Rosen on Changes from the Compliance Vendor...
In this episode, I visit with Jay Rosen. We consider some of the top changes Rosen has observed in how companies have thought about compliance solutions.    
26 min
25
Jonathan Armstrong on the UKBA, GDPR and Modern...
This week begins a series of podcasts leading up to the 500th anniversary episode of the FCPA Compliance Report. In this episode, I visit with Jonathan Armstrong. We take a look back at the evolution of UK and EU laws around bribery, data privacy/data protection and modern slavery and the compliance response.  
21 min
26
Matt Kelly on Changes Seen by the 4th Estate
This week begins a series of podcasts leading up to the 500th anniversary episode of the FCPA Compliance Report. In this episode, I visit with Matt Kelly, founder of Radical Compliance. We take a look back at the evolution compliance over the past 10 years from the perspective of the 4th Estate.  
20 min
27
Mike Volkov on Changes in FCPA Enforcement
Over this week, I will be joined by Mike Volkov, Matt Kelly, Jonathan Armstrong, Jay Rosen and Jonathan Marks. Each will speak about the evolution of  FCPA enforcement and compliance. In this episode, I visit with Mike Volkov, to look back at the evolution of FCPA enforcement.  
25 min
28
Wirecard and Fraud
In this episode, I am once again joined by I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at AMI. In this episode we take up Wirecard, fraud and BCCI.
55 min
29
Eric Lorber on How the Trade Sanction Sausage i...
28 min
30
Mikhail Reider-Gordon on AML and Wirecard, Part 1
Mikhail Reider-Gordon, Managing Director at AMI, joins me again as we continue our multipart series on the Wirecard accounting fraud. In this episode, we begin a two-part exploration of the role of money-laundering in the Wirecard saga.
58 min
31
James Koukios on the MoFo Top 10 International ...
In the Episode, I visit with James Koukios, partner at Morrison & Foerster. We visit about the firm’s Top 10 International Anti-Corruption Developments for March 2020.
23 min
32
WireCard and Germany Inc.
In this episode, Mikhail Reider-Gordon and myself continue our multipart series on the Wirecard accounting fraud. Today, we consider the role of Germany Inc. in the Wirecard saga.
46 min
33
Mike DeBernardis on 2020 Update to the Evaluati...
In this episode, I welcome back fan fav,  Mike DeBernardis for an exploration of the DOJ's 2020 Update to the Evaluation of Corporate Compliance Programs and joint DOJ/SEC FCPA Resource Guide, 2nd edition.
30 min
34
Wirecard and Short Sellers
In this episode, Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at AMI and myself continue our multipart series on the Wirecard accounting fraud. Today, we consider the roll of short sellers in the Wirecard saga.
46 min
35
Gordon Platt-from Investigative Journalism to W...
In the Episode, I am joined by Gordon Platt. In this episode, we discuss Platt’s return to the full-time practice of law and how the skills he used as investigative journalist enhance his work as a white collar practitioner. 
22 min
36
Wirecard-a podcast series on the scandal, with ...
In this episode of the FCPA Compliance Report, Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors and myself begin a multipart series on the Wirecard accounting fraud.
27 min
37
Eric Young on the Plumbing and Wiring of Compli...
In this episode, I visit with Eric Young, who talks about his 40-year+ career in compliance.
21 min
38
Compliance Line 2020 Hotline Benchmark Report
In this episode I visit with Nick and Gio Gallo, co-CEOs of Compliance Line. We discuss the firm’s 2020 Ethics and Compliance Hotline Benchmark Report.
28 min
39
Louis Perold on the State of Compliance In Sou...
In the Episode, I am joined by Louis Perold. We visit about his founding of Citadel Compliance, the current state of ABC compliance in South Africa and how Covid-19 has impacted business in South Africa.
22 min
40
Stanley Foodman on the Travel Act and FCPA
In this episode of the FCPA Compliance Report, I visit with Miami CPA Stanley Foodman on the intersection of the Travel Act and FCPA.
17 min
41
Ian McDougall on the Rule of Law
In this podcast, I visit with Ian McDougall, the General Counsel for LexisNexis. We discuss the Rule of Law and how it is the basis for a best practices compliance program.
21 min
42
Loren Steffy with Reflections on the 25th Anniv...
Loren Steffy joins me for his reflections on reporting from Oklahoma City in the 5 days following the bombing of the Alfred P. Murrah Federal Building by Timothy McVeigh.
21 min
43
Kevin Abikoff and Aline Osorio on Distribution ...
Where should the proceeds of government enforcement activity be placed and who should get to decide? It was a fascinating topic that I have long considered and wanted to podcast on. I am joined by Hughes Hubbard's Kevin Abikoff and Aline Osorio to explore.
18 min
44
John Warren on 2020 ACFE Report to the Nations
In the Episode, I am joined by John Warren Vice President and General Counsel at the Association of Certified Fraud Examiners (ACFE). We discuss the 2020 ACFE Report to the Nations, which is the most comprehensive report on the global scourge of fraud.
25 min
45
Joel Androphy on the Role of the FCA in Fightin...
In this podcast we consider the role of the FCA in helping the US government fight fraud, waste and abuse.
24 min
46
Mike DeBernardis on Q1 FCPA Enforcement Highlights
In this podcast, I am joined by Hughes Hubbard Counsel Mike DeBernardis to review the FCPA enforcement highlights from Q1, 2020.
30 min
47
From the Unthinkable to a Culture of Compliance...
In this Part 5 of a special five-part podcast series with lawyers from Azevdo Sette, we consider compliance challenges in Brazil. In this final episode, I visit with Lucas Bianchinni on environmental compliance.
14 min
48
From the Unthinkable to a Culture of Compliance...
In this Part 4 of a special five-part podcast series with lawyers from Azevdo Sette, we consider compliance challenges in Brazil. In this fourth episode, I visit with Ingrid Santos and Guiliana Bohila on #MeToo and Sexual/Moral Harassment
10 min
49
From the Unthinkable to a Culture of Compliance...
In this Part 3 of a special five-part podcast series with lawyers from Azevdo Sette, we consider compliance challenges in Brazil. In this third episode, I visit with Glaucia Ferreira on background investigations in Brazil.
11 min
50
From the Unthinkable to a Culture of Compliance...
In this Part 2 of a special five-part podcast series with lawyers from Azevdo Sette, we consider compliance challenges in Brazil. In this first episode, I visit with Luiz Salles and we discuss key factors in compliance investigations in Brazil and the impacts of these factors on antitrust compliance.
14 min
51
From the Unthinkable to a Culture of Compliance...
In this Part 1 of a special five-part podcast series with lawyers from Azevdo Sette, we consider compliance challenges in Brazil. In this first episode, I visit with Isabel Franco on how CarWash changed an entire culture.
15 min
52
Susan Divers on LRN’s 2020 Compliance Program E...
What does the LRN 2020 Compliance Program Effectiveness Report tell us about the state of compliance and where it may be heading. This week LRN's Susan Divers joins me for a deep dive into the Report.
37 min
53
Pat Harned on ECI’s IMPACT 2020
In this episode, I visit with Pat Harned, President of the Ethics & Compliance Initiative and we discuss ECI’s upcoming virtual conference IMPACT 2020.
19 min
54
James Koukios on the MoFo Top 10 International ...
In the Episode, I visit with James Koukios, partner at Morrison & Foerster. We visit about the firm’s Top 10 International Anti-Corruption Developments for February 2020.
19 min
55
Karen Woody on Profit Disgorgement at the Supre...
Will the Supreme Court reward fraudsters by allowing them to keep their ill-gotten gains? Karen Woody joins me to discuss the Lui case and what it means for the SEC and profit disgorgement.
22 min
56
James Koukios on the MoFo Top 10 International ...
In the Episode, I visit with James Koukios. We visit about the firm’s Top 10 International Anti-Corruption Developments for January 2020.
24 min
57
Quyen Truong on California’s Proposed Mini-CFPB...
What is the the national impact of this proposed California mini-CFPB? Quyen Truong joins the FCPA Compliance Report to explain.
27 min
58
Bryan Sillaman on the French Airbus Enforcement...
In this episode I am joined by Hughes Hubbard partner Bryan Sillaman to take a deep dive into the PNF portion of the Airbus international anticorruption enforcement action.
20 min
59
Tony Charles on Managing a 3rd Party Process
In this Episode, I visit with Tony Charles and we discuss the firm’s recent article 3rd Party Due Diligence: Creating a Credible and Defensible Program. We use it as an entrée into the topic of 3rd party due diligence. 
26 min
60
Erica Salmon Byrne on Ethisphere’s 2020 WME Hon...
In the Episode, I visit with Erica Salmon Byrne, EVP at Ethisphere, Governance and Compliance and Chair of the Business Ethics Leadership Alliance, on Ethisphere’s 2020 World’s Most Ethical company honorees.
18 min
61
Airbus-Part 5, Tom Fox with some final thoughts...
In this concluding Part 5 of a special five-part series on the Airbus international anti-corruption enforcement action, Tom Fox provides some final thoughts.
11 min
62
Airbus-Part 4, Cecilia Fellouse-Guenkel on the ...
In today’s Episode 4 of this special five-part podcast series, Cecilia Fellouse-Guenkel discusses what the Airbus enforcement means for compliance in France, French companies and French compliance practitioners.
12 min
63
Airbus-Part 3, Jonathan Armstrong on the UK-SFO...
In today’s Episode 3 of this special five-part series, Jonathan Armstrong considers the UK’s Serious Fraud Office role in the enforcement involving Airbus.
15 min
64
Airbus-Part 2 Mike Volkov on ITAR and Trade San...
In today’s Episode 2 of this special five-part series not the Airbus international anti-corruption enforcement action, Mike Volkov considers that US trade sanction enforcement involving Airbus.
15 min
65
Airbus, Part 1-Jay Rosen on the FCPA Enforcement
In today’s Episode 1, Jay Rosen considers the FCPA enforcement involving Airbus.
12 min
66
Joanne Taylor on the UK Airbus Enforcement Action
In this episode I visit with Joanne Taylor, Managing Director at K2 Intelligence in London on the UK portion of the Airbus anti-corruption enforcement action.
20 min
67
James Koukios on the MoFo Top 10 International ...
James Koukios, partner at Morrison & Foerster and Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Development returns to talk about the firm’s Top 10 International Anti-Corruption Developments for December 2019.
21 min
68
James Koukios on the MoFo Top 10 International ...
James Koukios joins me to talk about highlights from the MoFo November 2019 Top 10 International Anti-Corruption Developments Newsletter.
22 min
69
Day 31 | Levels of due diligence
What are the 3 levels of due diligence you should employ? Find out in Day 31 of 31 Days to a More Effective Compliance Program.
9 min
70
Day 30 | Using a root cause analysis for remedi...
How can you use a root cause analysis to lead your remediation efforts? Find out on Day 30 of 31 Days to a More Effective Compliance Program.
7 min
71
Day 29 | What is a root cause analysis?
What is a root cause analysis and what is its role in a compliance program? Find out in Day 29 of 31 Days to a More Effective Compliance Program.
7 min
72
Day 28 | Post-acquisition integration plan
What should go into your post-acquisition integration plan? Find out in Day 28 of 31 Days to a More Effective Compliance Program.
7 min
73
Day 27 | Pre-acquisition due diligence in merge...
What is the role of pre-acquisition due diligence in mergers and acquisitions? Find out in Day 27 of 31 Days to a More Effective Compliance Program.
7 min
74
Philip Urofsky on the Shearman & Sterling 2020 ...
In the Episode, I visit with Philip Urofsky, partner at Shearman & Sterling, Editor-in-Chief of the firm’s most excellent FCPA Digest. We visit about the firm’s 2020 FCPA Digest, Recent Trends and Patterns in the Enforcement of the FCPA and consider some of the highlights from the report.
35 min
75
Day 26 | Operationalizing compliance through pa...
What is the role of payroll in a best practices compliance program? Find out in Day 26 of 31 Days to a More Effective Compliance Program
7 min
76
Day 25 | Compliance function in an organization
What is is the role of a compliance function in an organization? Find out in Day 25 of 31 Days to a More Effective Compliance Program
7 min
77
Day 24 | CCO authority and independence
What is evidence of CCO authority and independence ? Find out in Day 24 of 31 Days to a More Effective Compliance Program
7 min
78
Day 23 | Updates and feedback
How can you incorporate updates and feedback into a compliance program? Find out in Day 23 of 31 Days to a More Effective Compliance Program
7 min
79
Day 22 | Assessing compliance internal controls
How can you assess compliance internal controls? Find out in Day 22 of 31 Days to a More Effective Compliance Program
7 min
80
Day 21 | Continuous improvement in a compliance...
How to engage in continuous improvement in a best practices compliance program? Find out in Day 21 of 31 Days to a More Effective Compliance Program
7 min
81
Day 20 | Responding to investigative findings
How should you respond to investigative findings? Find out in Day 20 of 31 Days to a More Effective Compliance Program.
8 min
82
Dave Lefort on 10 Stories CW Will Follow in 2020
In the Episode, I visit with Dave Lefort, Editor in Chief for Compliance Week. I asked him to come on the podcast and discuss his 10 predictions on what will dominate compliance headlines in 2020.
33 min
83
Day 19 | The investigation protocol
What is your investigation protocol? Find out why you need one and how to create one in 19 of 31 Days to a More Effective Compliance Program
7 min
84
Day 18 | Internal reporting and the triaging of...
What is your triaging of claims? Do you have a triage protocol? Find out why you should on Day 18 of 31 Days to a More Effective Compliance Program.
7 min
85
Day 17 | Managing your third parties
How can you best manage your 3rd parties? Find out in Day 17 of 31 Days to a More Effective Compliance Program
8 min
86
Day 16 | The third-party risk management process
What is the third party risk management process? Find out in today's episode of 31 Days to a More Effective Compliance Program.
8 min
87
Day 15 | How do you evaluate a risk assessment?
The evaluation of any risk assessment is a critical step for every compliance professional.
8 min
88
Day 14 | Risk Assessments
What is the role of risk assessments in a best practices compliance program?
8 min
89
Day 13 |Institutional Justice and The Fair Proc...
What is the role of institutional justice in a best practices compliance program?
8 min
90
André H. Paris on the Brazilian Compliance Scene
In the Episode, I visit with André H. Paris, a Brazilian Compliance Consultant and Lawyer. He is the author of the recently released book Compliance - Ethics and Transparency as the Way Forward.
18 min
91
Day 12 | Financial Incentives for Compliance
What financial incentives should be used in a best practices compliance program?
8 min
92
Day 11 | What is Effective Compliance Training?
How can you determine effective compliance training?
8 min
93
Day 10 | The use of social media in compliance
In today's episode of 31 Days to a More Effective Compliance Program, I discuss the use of social media in a best practices compliance program.
8 min
94
Day 9 | 360 degrees of compliance communications
A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times.
8 min
95
Day 8 | Internal controls and compliance
What is the role of internal controls in a best practices compliance program? Find out in Day 8 of 31 Days to a More Effective Compliance Program.
8 min
96
Day 7 | Policies and Procedures
Compliance policies lay out your expectations and compliance procedures set out the details of how to do so.
7 min
97
Day 6 | The Code of Conduct
The Code of Conduct is one of the foundational pieces in your compliance program.
7 min
98
Fry Wernick on the Hoskins Jury Instructions
In this episode of the FCPA Compliance Report, I visit with Fry Wenrick on the Hoskins jury instructions.
23 min
99
Day 5 | The Board and operationalizing compliance
In Day 5 of 31 days to a more effective compliance program, I consider the role of the Board of Directors in both oversight and operationalizing compliance.
8 min
100
Day 4 | Moving compliance tone down through an ...
In Day 4 of 31 days to a more effective compliance program, I consider how best to move tone downward into the middle and lower ranks of a corporation.
7 min