Jay Rosen featured on the SCCE Compliance Perspectives Podcast — Working With Vendors

By AMI News, Jay Rosen Featured, Jay Rosen Media, Media

via Adam Turteltaub at

If you have a compliance and ethics program of any size, odds are good that you need a solution provider to help your program function fully.  Manage the vendor search and relationship well, and if you’ve done yourself and your program a great service.  Manage it badly, and you’ve created a nightmare.

Jay Rosen of Affiliated Monitors knows the challenge well, having been a buyer of solutions and currently as a vendor to the compliance and ethics community.

In this podcast – a preview of his session at the 2019 Compliance & Ethics Institute — he outlines how to make the vendor relationship a healthy one, beginning even before you begin a search.  He advises that buyers reach out to their peers to learn what is working for them and the options in the marketplace.

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FCPA Podcast featuring Jay Rosen

5-Part FCPA Podcast Series feat. Jay Rosen — Everything You Wanted to Know About Monitors But Were Afraid To Ask

By AMI News, Jay Rosen Featured, Jay Rosen Media, Media

In this special five-part podcast series, sponsored by Affiliated Monitors, Inc., Tom Fox visits with AMI’s Jay Rosen. In this series they introduce the role of independent integrity monitors and corporate monitorships; discuss both pre-settlement and post- resolution monitorships and their different applications; considerations a company should take in hiring a monitor and cost reflections for monitorships.. Listen to the full series below, or wherever you listen to podcasts.

Day 1:

In Part 1, we introduce the role of independent integrity monitors and corporate monitorships.

Day 2:

In this Episode 2, we consider the use of monitors in the post-resolution phase. Some of the highlights from this podcast include:

What is a monitorship in the FCPA Context? Complying with Consent Decrees When does post-resolution monitorship have the impact of a pre-settlement monitorship?
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Jay Rosen, Mr. Monitor

Jay Rosen’s Weekly Series on CCI: Monitoring in the Health Care Sector – Part I

By AMI News, Jay Rosen Event, Media

Jay Rosen begins a deep dive into health care monitoring and how the proactive use of a health care monitor can positively impact all stakeholders: the regulators, the industry itself and the consumers of health care services, the public.

Independent integrity monitoring can be particularly valuable and important in the health care sector because in many ways, health care is the perfect storm for significant compliance risks – but it also has a greater opportunity to mitigate those risks. Using an independent third-party compliance expert or monitor can be one strategy to help mitigate risks.

Health care occupies a unique space in the American business world.

The size of the health care industry accounts for almost 20 percent of our economy.

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Jay Rosen, Mr. Monitor

Jay Rosen’s Weekly Series on CCI: Suspension vs. Debarment – Part V

By AMI News, Jay Rosen Media, Media

Jay Rosen’s miniseries on suspension and debarment concludes with this look into the remedies federal agencies seek when misconduct is identified, and where the ultimate focus will lie: compliance.

The defense community largely led the process of putting together an effective ethics and compliance program. There were defense industry initiatives where the contractors got together and talked about what it takes to promote ethics and compliance; the defense industry been doing this for years. Unfortunately, nongovernmental commercial industries were not as far along as the defense industry.

Lately, there has been tremendous growth in the understanding that E&C is critical for any company.

read the full post here
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Jay Rosen’s Weekly Series on CCI: Suspension vs. Debarment – Part IV

By AMI News, Jay Rosen Media, Media

Every compliance professional should be familiar with the concept of present responsibility. Jay Rosen discusses the term and its place in suspensions and debarments.

Present responsibility has become sort of a buzzword. It’s the underlying basis for action involving excluding a party from the federal marketplace through suspension or department.

Unfortunately, the phrase itself is not defined anywhere in the regulatory structure. This means its determination comes down to the discretion of the federal officials who have been empowered to exercise the suspension and debarment authority.

Yet even with this lack of a statutory or regulator definition, there are some common factors and guidelines out there that can help the compliance community understand some of the elements of suspension and debarment as they relate to this issue.

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Jay Rosen’s Weekly Series on CCI: Suspension vs. Debarment – Part III

By AMI News, Archive, Jay Rosen Event, Media

Jay Rosen, “Mr. Monitor,” continues a series on suspension and debarment, discussing where these actions meet with FCPA enforcement.

Debarment may be based on actions so serious or compelling that it affects the present responsibility of the contractor or subcontractor. There is some fairly broad language as to what the basis for a suspension and debarment can be. This means that in the context of anti-corruption laws, it can be the basis of a suspension or debarment.

Under the FCPA, the conduct to incur a violation does not require actual bribery or corruption read the full post here
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