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Aaron Allen
Aaron Allen

[S2E3] I've Seen The Other Side Of You



So if you could just like, move the dial and help a little bit, that's an amazing thing. And that's why I think we've seen this really big surge of podcasts in the podcasting world of people solving mysteries and trying to solve crimes. And I can understand both sides from the law enforcement perspective, a lot of people are weary of this. They're like, you're not professionals. You could be making waves or doing more harm. And on the other side, I see the perspective of, look, if you aren't able to do it, and this is a mystery or something has happened to a loved one or a friend or someone I know, and I want to get this solved.




[S2E3] I've Seen The Other Side Of You



Lisa Snart (aka Golden Glider) goes to Cisco for help when she believes her brother Leonard/Captain Cold has been kidnapped. It turns out he's actually been forced to help his father, Lewis, with a heist. Lewis is a very bad man, one of the most vile villains we've seen in the show. He's inserted a bomb into Lisa's neck---one that can't be removed since it will activate if it comes into contact with oxygen.


But Barry is also convinced that Snart can come over to the light side of the Force. "There's good in you," he says, channeling Luke Skywalker. And I agree, though partly that's because I've seen the trailer for Arrow/Flash spin-off Legends of Tomorrow. I've also always kind of liked Captain Cold and his deadpan sarcasm.


I'm curious to see if this trend of killing off the bad guys continues as the season pushes forward, though. That's a bit of a disappointment to me. I actually thought Arrow dispensed with killing a bit too early (though only Oliver seems beholden to that credo, as everyone else kills with reckless abandon) but Barry is almost the other side of that coin, killing far too easily in the start of Season 2.


While the scene was being set up I wondered off and spoke with one of the volunteers on the other side of the mill. I was interested in the huge steam kettle, which was actually the boiler. This kettle is used to boil water creating steam to run the saws. No gas flames here, the boiler had to be filled with wood, which typically comes from the scraps of lumber being cut. And talk about hot!


My view is that it's two sides of the same coin. You need both, and you'll see in the various guidances from the U.S. government, that they agree with that too in principle. And so, an organization has to decide what their ethical position is. And often that's through a code of conduct and needs to be represented by tone at the top with their leadership and also needs to be compliant, which really is the floor. It's really the minimum you should do. But includes policies and procedures and investigations and also remediation for things that might go wrong. And I guess that's the other side of the coin. So, in an effective program, you want to address both. And I think if you don't, it's to your peril. For instance, you could have the very best compliance program, but if you don't have the cultural and ethical backbone to support that, it's really not going to help you and vice versa.


But what are those elements basically? Well, the way I break them down or the building blocks as I call them is, what is your board oversight? So, how does the governing authority, as the sentencing guidelines say, view the program, become involved with the program, and oversee its in effectiveness and enforcement, as well as its resourcing? The next one is what I called responsibility. So, who, separate from the board, within the organization is responsible for overseeing compliance? It doesn't mean they're responsible for compliance with the law. It means they oversee the program to make sure that things that need to occur within the organization are happening. You then have your risk assessment. And this is one of the common denominators across all of those guidances that I mentioned. And when I teach my students and when I've implemented programs, that's the one that I handle first is assessing the risks within the relative risk areas of compliance or overall, for the organization. You need to have policies and procedures and controls. You need to provide training and communications around those policies and procedures and controls and the organization's code of conduct generally. You also need to offer incentives for those that do the right thing and comply with the various policies and procedures, controls, code of conduct. As well as a way to effectively investigate and discipline those employees that do not. It's also important to screen employees, and this is more at the programmatic level, to make sure you're hiring those people that are prone to do the right thing and then, through their employment with the company, use mechanisms to assess and reward them and promote them based on their conduct. One of the things we learned from Enron, and this is really manifest in the sentencing guidelines, is that many of the wrongdoers that basically brought the company down were known to have committed unethical or potentially criminal acts really early in their careers, but nobody checked them on them. And because they were high producers or maybe because they were effective in moving themselves forward and advancing with the organization, those things were kind of put to the side and the company might have looked the other way. So that's important.


So how do you structure a program? Well, I think number one, you start with the risk assessment, as I said earlier, and any organization, regardless of their size, needs to complete some level of objective, to extent you can, risk assessment to understand where your risks are. That way you're spending your money and your time addressing the risks that are highest to the organization. In other words, you don't want to be spending your precious resources on things that aren't the most risky. So that's the first thing it comes out in other areas. So structurally, how do you want to put together a governance mechanism? Do you have the resources to put together a program with a dedicated ethics and compliance officer? And how do you handle helpers or assistants or resources to that compliance function when you're out in the field and when you're in other countries? And to what extent can you have dedicated resources, or do you need to use borrowed or shared resources, maybe within internal audit, maybe with HR, to oversee your program? It would also include how much you're able to spend on outside counsel and would also determine how much you could utilize audit and monitoring functions to be able to look at the effectiveness of your program.


Then finally, you just need to monitor your program. Maybe you need to implement software to know your customer, and then you need to modify it based on issues that come up. And you're not going to get a pass just because you're a small organization. And I would say, never would I want to see, either as in-house outside counsel or even teaching a class in compliance, an organization that did not have a written program. In other words, in my opinion, if you don't have a written program, you really don't have a program. And that's certainly not one that you could defend if there was any sort of problem where you were being investigated or ultimately enforced against or indicted in the worst-case scenario.


Eric Hinton: That's a good question. And as I said, even in the area of trade, it's pretty diverse as to what the risks are and also the regulatory regimes. And I don't practice trade law from day to day anymore, so I'll caveat with that. What I would say, and this is I think clear to everybody, is you definitely need to understand and keep up to date, if this is an area of exposure for you with regard to the Russia sanctions and things that relate to that. And you'll realize too that, more than most sanctions programs, this one's more global. So, you have to look at what's going on in the United States, but also in the EU and other countries. So, that's definitely a dynamic situation and can have pretty significant effects. And I would encourage those that are in-house to become familiar, but also utilize outside counsel to really give some specialist expertise on that. So, that was the first one.


From a global perspective, there are a few things that I think are emerging and I mentioned this recent Monaco memo and as I said, it's new, but it still remains to be seen how that plays out. But there's some important elements that relate to that, a couple things I'll throw out. One was the compensation issue. But there's also some other questions that relate to what extent individuals versus entities are going to be prosecuted and held responsible for compliance failures. I think the trend over time has been to go after more individuals and that certainly could be the case within the international trade sector. And also, certainly it would be the case potentially with sanctions and with export control violations. The other thing that's come out of that memo is, once you settle a case, what does that look like? And to what extent will prior misconduct factor into how the department decides the resolution of your case? And also, whether or not they would appoint a monitor to oversee compliance with any sort of agreements that you would have with the Department of Justice. So I think it's important to remember that, even though trade is a specific regulatory scheme, it ultimately could be subject to enforcement and resolution under the rules that you see that apply through the DOJ. Absolutely.


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