FCPA Compliance Report

In this episode I visit with white collar defense and Qui Tam specialist Joel Androphy about prosecution of whistleblower claims at the federal and state level. Androphy explains what type of evidence...

26 Apr 201731min

One of the issues in any compliance program is the compensation paid to a third party as FCPA exposure arises when companies pay money - either directly or indirectly - to fund bribe payments.  In the...

25 Apr 201713min

In this episode, Matt Kelly and I take a very deep dive into two recent speeches by Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden in which he addressed multip...

25 Apr 201723min

At some point, you will be required to terminate a third-party and there will be multiple legal, compliance and business issues to navigate going forward. If you are stuck doing it in the middle of a ...

24 Apr 201712min

In this episode, Jay Rosen returns from a week’s trip to Walt Disney World. Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: DOJ Criminal Di...

21 Apr 201735min

One area that has bedeviled Chief Compliance Officers (CCOs) and compliance practitioners is how to determine the return on investment (ROI) for your compliance program regarding third parties. While ...

21 Apr 201712min

When was the last time you considered the health of your company’s third party management program? A good way to test that well-being is to perform a check-up on your third party program. An article e...

20 Apr 201713min

Internal controls are a key tool to operationalize your third party risk management program. Initially, a compliance practitioner should perform an analysis of any third party representative to provid...

19 Apr 201713min