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Eric Feldman Media

Eric Feldman Contributes to SCCE’S CEP Magazine — “Recent DOJ compliance policy makes the case for proactive monitoring”

By AMI News, Eric Feldman Featured, Eric Feldman Media, Media
Recent DOJ compliance policy makes the case for proactive monitoring

By Eric R. Feldman, CCEP-I, CFE

On June 1, 2020, the Department of Justice (DOJ), without any fanfare, quietly slipped out its 2020 revision of the Evaluation of Corporate Compliance Programs guidance.[1] As with its predecessors in 2017 and 2019, this update further refines the DOJ’s guidance to companies about how often they should review the structure of their ethics and compliance programs, the importance of a compliance officer’s access to data, and greater clarity on how companies should integrate mergers and acquisitions into their existing programs and corporate culture.

This third installment of the guidance underscores why and how law enforcement pays such close attention to a company’s ethics, compliance, and anti-fraud activities.

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Eric Feldman Joins ACFE Board of Regents Colleagues to Offer Encouragement to Members: Sep/Oct issue of FRAUD Magazine

By AMI News, Eric Feldman Featured, Eric Feldman Media, Media

"January of this year now seems like a quaint time. Since then, the world has stretched in bizarre ways, and it probably won’t ever resume its previous shape. The Board of Regents want to encourage you as your organizations need your anti-fraud skills more than ever."

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Transforming corporate cultures by placing CFEs in top echelons — ACFE Board of Regents Interview for Fraud Magazine

By AMI News, Eric Feldman Featured, Eric Feldman Media, Media

AMI’s Eric Feldman sat down with the other members of ACFE’s Board of Regents to discuss the importance of CFE’s in fostering corporate culture. This conversation appears in the September/October issue of FRAUD Magazine.

CFEs can trumpet the age-old “tone at the top” concept, but if top executives aren’t working to transform corporate cultures throughout organizations then fraud prevention and deterrence will continually run up against roadblocks. The members of the ACFE Board of Regents know this from their years of consulting with C-suite execs who want to tackle fraud but also have to wrestle with timid general counsels, fluctuating quarterly reports and concerned stakeholders.

The Board gathered at the beginning of the recent 30th Annual ACFE Global Fraud Conference to opine on the latest anti-fraud issues during a 90-minute Fraud Magazine interview.

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5-Part FCPA Podcast Series feat. Eric Feldman: DOJ 2019 Guidance

By AMI News, Archive, Eric Feldman Featured, Eric Feldman Media

In a podcast series sponsored by Affiliated Monitors, Inc. (AMI), Tom Fox visits with Eric Feldman, Senior Vice President of AMI. They look at the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, (the “2019 Guidance”), which was released in April 2019. Over the next five podcasts we will explore what the 2019 Guidance changes are from the Evaluation of Corporate Compliance Program (2017 Guidance), released in February 2017, the structure and emphasis of the 2019 Guidance and what it means for the compliance practitioner going forward.

Listen to the full series below, or wherever you listen to podcasts.

Day 1:

In this first episode, they begin with some of Feldman’s observations on the 2019 Guidance. The 2019 Guidance asks three fundamental questions prosecutor should ask; all other questions are divided into these categories: (1) “Is the corporation’s compliance program well designed”; (2) “Is the program being applied earnestly and in good faith?”

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Eric Feldman featured on the SCCE Compliance Perspectives Podcast — the Benczkowski Memo & Corporate Monitors

By AMI News, Archive, Eric Feldman Featured, Eric Feldman Media
via Adam Turteltaub at SCCE

In October 2018 Assistant Attorney General Brian Benczkowski of the US Department of Justice issued a memo entitled “Selection of Monitors in Criminal Division Matters.”  Some took the memo to herald the end of corporate monitorships.

Not so, says Eric Feldman of Affiliated Monitors.  In this podcast he explains that, instead, the memo was designed to improve both the selection of monitors and the process for determining whether having a monitor is appropriate.

Over the years it had become the default to have a monitor when a Deferred Prosecution Agreement was put in place.  Now a cost/benefit analysis will be conducted before going down this often long road.  The DOJ will be examining factors such as who was involved in the wrongdoing and what progress the company has made on its own to strengthen its compliance efforts.

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FCPA Compliance & Ethics Podcast on the Benczkowski Memo — Full 5-Part Series

By Archive, Eric Feldman Featured, Eric Feldman Media, Press, Vin DiCianni Media, Vin Featured

Day 1: In part 1 of this 5-part series on mergers and acquisitions, Eric Feldman and Tom Fox introduce the Benczkowski Memo and new DOJ announcements over the past year and what they mean for the compliance practitioner. Listen below, or on the FCPA Compliance Report

Day 2: Vin DiCianni joins Fox to consider how companies can use this information internally to bolster their compliance programs. Listen below, or on the FCPA website.

Day 3: In the previous episode in a podcast series on the DOJ’s Benczkowski Memo, Tom Fox and Vin DiCianni considered how companies can use this information externally to bolster their compliance programs. In this third episode, they consider this same issue from the external perspective.

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FCPA Compliance & Ethics Blog Series on the Benczkowski Memo

By Archive, Eric Feldman Featured, Eric Feldman Media, Press, Vin DiCianni Media, Vin Featured

In conjunction with the 5-part podcast series that Tom Fox hosted in January with Eric Feldman and Vin DiCianni on the DOJ announcements over the past year, Feldman joined Fox for a blog post to consider what strategies companies can use based upon these guidelines. The podcast series will explore how the Benczkowski Memo (the “Memo”) and other DOJ guidance into compliance programs can be used by compliance professionals to create more robust compliance programs. Feldman believes the Memo can be used as both a sword and shield in furtherance of more effective compliance programs.

Read part 1 HERE

In this second blog post, DiCianni emphasizes that the DOJ now mandates companies which come before them have an effective compliance program. Companies must demonstrate they had an effective compliance program, not a paper compliance program.

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FCPA Compliance & Ethics Podcast featuring Eric Feldman — 5-Part Series on the Benczkowski Memo: Ep. 4

By Archive, Eric Feldman Media

In this 5-part series, Tom Fox brings on Eric Feldman and Vin DiCianni to discuss DOJ announcements over the past year and back to the FCPA Corporate Enforcement Policy announced in November 2017 to consider what strategies companies can use based upon these documents. In episode 4, Fox and Feldman chat about how the new DOJ Guidance from 2018 on FCPA compliance can be used as both a sword and a shield. Listen below, on iTunes, or on the FCPA website

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FCPA Compliance & Ethics Podcast featuring Eric Feldman — 5-Part Series on the Benczkowski Memo: Ep. 1

By Archive, Eric Feldman Media

This week, in a podcast series sponsored by Affiliated Monitors, Inc. Tom Fox visits with Vincent DiCianni and Eric Feldman. They look at the DOJ announcements over the past year and back to the FCPA Corporate Enforcement Policy, announced in November 2017, to consider what strategies companies can use based upon these documents. Over the next five podcasts they will explore what companies can do both internally and externally to incorporate the Benczkowski Memo and other DOJ guidance into their organizations. In Episode 1, they introduce the Memo and new DOJ announcements over the past year and what they mean for the compliance practitioner. Listen below, or on the FCPA Compliance Report

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