TRACE Podcast: Bribe, Swindle or Steal

Join host Alexandra Wrage, President & Founder of TRACE, on Bribe, Swindle or Steal as she explores the world of financial crime—corruption, fraud, money laundering and sanctions—and what motivates people to break the law, how wrongdoers cover their tracks and what can be done to put a stop to the looting through interviews with experts in the field. 


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Featured

Extreme Wealth – Episode 8: Walt Pavlo and the Empty Temptations of Fraud

Walt Pavlo went to work at MCI at a time when telecoms were hungry for go-getters. It was the early 2000s, and Walt enjoyed the freedom and aggressive nature of a recently deregulated industry. But soon he realized that MCI’s most lucrative customers were also its flakiest, and the pressure was on to manage millions of bad debt that accumulated on the books. In this episode, Walt explains how he concocted a fake-loan scheme that netted him money far beyond his dreams — and yet how hollow it felt, right up until the moment it all came crashing down. 

Walt Pavlo is a nationally recognized speaker who writes for Forbes and NYU Law School on white-collar crime and criminal justice. He founded the firm Prisonology in 2014 as a consulting firm to support federal criminal defense attorneys by providing experts who have retired from the Federal Bureau of Prisons. He is the co-author of “Stolen Without a Gun: Confessions from Inside History's Biggest Accounting Fraud, the Collapse of MCI WorldCom,” which covers his stint working in the company’s billing department and committing fraud.

Walt Pavlo went to work at MCI at a time when telecoms were hungry for go-getters. It was the early 2000s, and Walt enjoyed the freedom and aggressive nature of a recently deregulated industry. But soon he realized that MCI’s most lucrative customers were also its flakiest, and the pressure was on to manage millions of bad debt that accumulated on the books. In this episode, Walt explains how he concocted a fake-loan scheme that netted him money far beyond his dreams — and yet how hollow it felt, right up until the moment it all came crashing down. 

Walt Pavlo is a nationally recognized speaker who writes for Forbes and NYU Law School on white-collar crime and criminal justice. He founded the firm Prisonology in 2014 as a consulting firm to support federal criminal defense attorneys by providing experts who have retired from the Federal Bureau of Prisons. He is the co-author of “Stolen Without a Gun: Confessions from Inside History's Biggest Accounting Fraud, the Collapse of MCI WorldCom,” which covers his stint working in the company’s billing department and committing fraud.

Retired Canadian Supreme Court Justice Thomas Cromwell joins the podcast to describe the review he was commissioned to undertake of Hockey Canada’s organizational structure in the aftermath of a sexual assault scandal that shook confidence in the sport in 2018.

In his mid-20s, Chuck Collins made a fateful choice. The great-grandson of Oscar Meyer, and thus an heir to part of the meatpacker’s family fortune, Chuck was skeptical of the riches (some $500,000 in 1986 dollars). He didn’t want to perpetuate the imbalances he saw dynastic wealth creating in society. Rather than live off the interest, or to give a portion to charity, Chuck gave away the entire inheritance, and thus embarked on a most unusual sort of normal life.

 

In this episode, Chuck explains what reverberations his decision to give away his inheritance had on his family and in his career, and he lays out his case to other similarly privileged Americans: Why life is better without the insulation that great wealth provides, and how billionaires can rejoin American life.

 

Chuck Collins is the director of the Program on Inequality and the Common Good at the Institute for Policy Studies, where he edits Inequality.org. He is also a founding member of Patriotic Millionaires, a group of high-net-worth Americans who advocate for public policies — including higher taxes on the wealthy — meant to rein in the political power of the richest Americans. His prolific writings focus on inequality, the racial wealth divide, philanthropy, the climate crisis, and billionaire wealth dynasties. His forthcoming book "Burned by Billionaires: How Concentrated Wealth and Power and Ruining Our Lives and Planet" will be published in 2025.

The sudden ascent of Mohammed bin Salman from an obscure royal heir to the Crown Prince of Saudi Arabia — the country’s de facto ruler — has fascinated Jonathan Rugman, an author and longtime correspondent in the Middle East. Jonathan’s latest BBC documentary, “The Kingdom,” traces MBS’s life from an unruly youth to a series of Machiavellian maneuvers to cut ahead of cousins and uncles in the line of royal succession. Jonathan’s reporting illuminates a brash but secretive young autocrat whose wealth and power have few equals anywhere on the planet. After years of high-profile murder, jailings, and crackdowns, a formidable question remains: What more does MBS want?

 

Jonathan Rugman is a Visiting Lecturer in the journalism department at City, University of London, who has reported from some 50 countries during his 30-year journalism career. He is the author of “Ataturk’s Children – Turkey and the Kurds” and “The Killing in the Consulate,” in which he investigated the murder of the Saudi journalist Jamal Khashoggi. His numerous awards include a BAFTA for his coverage of the Paris terror attacks of 2015.

For more than 20 years, Paul Schervish surveyed many of the richest people in America for a long-running study on how the wealthy view the world and themselves. In this episode, another in our series on extreme wealth, Paul explains how his research and his early years spent as a priest inform his understanding of wealth and its potential to improve the world. Applying sociological and religious scholarship to the question of how what to do with money — and by extension, what to do with the rich — he invites haves and have-nots alike to consider the roles that God, human agency, and spiritual fulfillment play in our material lives.

Sir William Browder (“Bill”), a financier turned justice advocate, is our guest for this episode of our ongoing series on extreme wealth. Bill has been the engine behind the Magnitsky Act, a law that for the past 12 years has empowered governments to seize the assets of foreign leaders who abuse human rights — a significant countermeasure against corruption and atrocity that has exasperated Vladimir Putin and oligarchs in Russia, where Bill was once a leading foreign investor. His experience working in (and subsequently abandoning) Russia allowed him to see inside that culture and economy, and have led him to conclude Putin’s military conquests as a dictator’s efforts to protect his unfathomable stolen wealth — and his own neck.

The author and philanthropist Jennifer Risher continues our series on extreme wealth by telling the story of her ear-popping rise from a middle-class Microsoft employee in the early ‘90s to an unexpected multimillionaire. The stock options she accrued with her husband, David — a fellow Microsoft employee who went on to join Amazon and who is now the CEO of Lyft — gave Jennifer immediate entry to a world of privilege that, as the child of a working-class household, she’d never expected to join. Her experience showed her the peculiar nature of personal wealth: an agent of tremendous power that, she finds, does more to amplify people’s character than to alter it.

 

Jennifer Risher is the author of “We Need to Talk: A Memoir About Wealth,” which aims to illuminate discussions of money that are often cloaked in taboo, guilt, and secrecy. She and her husband founded the #HalfMyDAF movement, which seeks to encourage wealthy people to make greater charitable gifts in their lifetimes.

In this episode — another in our series on extreme wealth — the journalist Steve Fishman discusses his reporting on Bernie Madoff and the collapse of Madoff’s $65 billion ponzi scheme. Steve doggedly pursued the story even after the financier was sent to a federal prison in North Carolina. Eventually the two men connected for a series of phone interviews that gave Steve a unique insight into the truths and lies that enabled Madoff to con investors at an industrial scale. Steve explains that greed was but one motivation for Madoff, an apex Manhattan insider who never forgot humiliations he suffered during his youth in Queens.

This week we debut a special project within Bribe, Swindle or Steal: single-topic episodes that focus on extreme wealth. For years Alexandra Wrage has worked on corporate compliance and anti-corruption efforts, a field that provides a front-row view into human corruptibility. In these episodes, she digs into the practical, philosophical, political, and even spiritual roots of why people risk everything—from scandal to criminal charges—for the allure of money, even when all of their material needs are more than covered. She will explore some surprising challenges of wealth alongside the ways in which greed changes people and extreme wealth changes the rules that we all live by.

 

Her first guest in this series is Clay Cockrell, a therapist in New York City whose Walk and Talk Therapy practice specializes in treating very wealthy clients. The problems they bring to therapy give him a unique insight into the privileges, the anxieties, and the perils exclusive to the 1%.

In this episode from 2020, Randall Eliason, law professor and former Assistant U.S. Attorney provides an excellent account of the days leading up to the sentencing of political operative Roger Stone. The Department of Justice’s unprecedented interference in--and reversal of--its prosecutorial team’s recommendation led to the resignation from the case of all four prosecutors. Over 2000 former DOJ officials called on Attorney General Barr to resign in the wake of his interference in the case.

 

This episode was originally published on 4 March 2020.

A 22-year veteran of Treasury and consultant to the Dept of Justice, John Madinger sheds light on some of the money-laundering schemes he has uncovered and why the Breaking Bad car wash scheme probably wouldn’t have worked.

 

This episode was originally posted on 17 December 2017.

Brian Klaas, Associate Professor at University College London and host of the award-winning podcast “Power Corrupts,” joins us to discuss his book “Corruptible: Who Gets Power and How It Changes Us”. Brian describes research on who is drawn to positions of power and how power impacts us, including potentially re-wiring our brains.

 

This episode was originally published on 30 March 2022.

David Jackson, a senior reporter with Injustice Watch, discusses his work exposing corruption, which has led to both indictments and legislative reform.

Jonathan Turner, former Vice President, Ethics & Compliance, at Smith & Nephew in Memphis, discusses the admissions scandal that has rattled several top-tier U.S. universities and ties some of the lessons learned back to the work of compliance professionals.

 

This episode was originally published on 2 October 2019.

Anand Mangnale of the OCCRP joins the podcast to describe his investigation into the practices of the vast and powerful Adnani Group in India, the spyware discovered on his phone as soon as the story began to break and the subsequent efforts to silence him, including bizarre charges of financial support of terrorism.

Declan Hill discusses the pervasive and sinister nature of match-fixing and how we can prevent sport from being turned into theater.

 

This episode was originally posted on 2 August, 2017.

Rob Koehler, WADA veteran and current Director General of Global Athlete, joins the podcast to discuss the epidemic of doping in sports, the imbalance of power between athletes and administrators and the IOC's startling decision to allow Russia to compete in the Paris Games in spite of its invasion of Ukraine.

 

This episode was originally published on 15 February 2023.

My guest today is Melissa Goldin. Melissa is a NY-based news verification reporter with the Associated Press where she analyzes and debunks fake news.

Sally Dennis, former President of Rugby Canada and current Canadian representative on the Council of World Rugby, describes her role in the professionalization of sports governance, where challenges remain—​ and rugby's arguably unique invulnerability to match fixing!

Mahmoud Elsobky, one of the two winners of this year’s TRACE Prize for Investigative Reporting, describes his team’s high risk infiltration of a human smuggling ring that preyed on—and defrauded—those desperate to leave Syria.

Diana Henriques, award-winning journalist and author, discusses the traits of fraudsters and the menace of reputation laundering.

Paul Massaro of the U.S. Helsinki Commission discusses the scope of doping in international sport, the foreign policy implications and the Rodchenkov Anti-Doping Act (RADA) offered in response.

 

This episode was originally published on 20 March 2019.

In recognition of the recent honor of Sir Bill Browder KCMG with the title Knight Commander of the Order of St Michael and St George for his significant contributions to human rights and anti-corruption, we are revisiting a 2017 interview with Bill. He describes the brazen fraud and violence of Putin’s Russia, the death of Sergei Magnitsky, and the passage of the Magnitsky Act.

 

This episode was originally published on 31 May 2017.

Today’s podcast is a recording of a talk given by Drew Sullivan of the OCCRP at the University of Maryland. Drew is the co-founder and editor of the Organized Crime and Corruption Reporting Project (the OCCRP), a global network of journalists working collaboratively to evaluate and mine enormous amounts of data to expose corruption. The OCCRP is also a past winner of the TRACE Prize for Investigative Reporting. Special thanks to the Center for International and Security Studies at Maryland in the School of Public Policy and the Philip Merrill College of Journalism for letting us record the event.

 

(This episode was originally published on 11 May 2022)

Jessica Warwick in Norton Rose's Ottawa office joins the podcast to talk about the Arapakota decision and what it means for anti-bribery enforcement in Canada.

 

This episode was originally published on 21 June 2023.

Pedro Pizano and Jeffrey Smith, with the McCain Institute and Vanguard Africa respectively, discuss the reputation laundering that musicians, actors and athletes facilitate when they agree to perform for dictators and kleptocrats. They also describe how these same artists can use their platforms for good instead and show support for the citizens living under brutal regimes.

 

This episode was originally published 15 September 2020.

Josh Kirschenbaum is a visiting fellow at the German Marshall Fund’s Alliance for Securing Democracy and formerly served as acting director of the Office of Special Measures at Treasury’s Financial Crimes Enforcement Network (FinCEN). He joins the podcast to discuss investment funds and the gaping loophole they create through which vast sums of money can move with no accountability.

 

This episode was originally published on 20 April 2021.

This week’s podcast features an excellent presentation by Misti Mukherjee, founder and managing member of Extensio Law.  Misti addresses the shifting field of diversity, equity and inclusion—including recent changes to the law—and emphasizes the critical importance of this work alongside the need to approach it with intentionality and discipline.

This week’s podcast is a bit off the beaten track.  We speak with Sherub Tharchen in Paro in Bhutan about his country.  We cover some of the basics, including the country’s location between two neighbors with high levels of corruption, and then discuss how the current King of Bhutan tackled corruption in a way that, while probably not replicable in most countries, has nevertheless had great success for the Bhutanese.

Leah Ambler, then Director of Corruption Prevention at the Australian Commission for Law Enforcement Integrity and previously Legal Analyst at the Organisation for Economic Co-operation and Development (OECD), delves—in her personal capacity—into her excellent chapter on whistleblower protections, emphasizes their importance in reducing corruption and highlights the challenges posed by the lack of comprehensive, harmonized legislation. 

 

Originally posted on January 12, 2022.

This week on Bribe, Swindle, or Steal, we listen in on the lively presentation at the 2024 TRACE Forum featuring former enforcement officials, Charles Duross, Partner, Morrison Foerster, David Last, Partner, Cleary Gottlieb, and Mark Mendelsohn, Partner, Paul Weiss. Speaking with TRACE President, Alexandra Wrage, Chuck, David, and Mark discuss their time as Chiefs of the FCPA Unit and their experiences navigating heightened scrutiny and shifting resources, and then they offer their perspectives on what lies ahead.

In this re-posted episode, Prof. Mark Pieth discusses his book, Gold Laundering: The dirty secrets of the gold trade - and how to clean up. He outlines the many problems, including child and trafficked labor, environmental degradation, violence, and corruption. He also addresses some modest steps forward and how, in spite of the considerable challenges, more progress can be made.

This epsiode was originally posted on December 1, 2021.

In light of last week’s sentencing of Sam Bankman-Fried—25 years in prison and an $11 billion forfeiture order—we are re-posting our conversation with Jim Campbell, author of “Madoff Talks” and his comparison of the two men.

 

Originally posted on January 25, 2023

For this week’s podcast, we listen in on the excellent presentation—dense with practical information—by John Davis, member, Miller & Chevalier, at the TRACE Forum in Annapolis.

This week on Bribe, Swindle, or Steal, we listen in on the presentation of Nicola Bonucci, International Lawyer and former Director for Legal Affairs OECD, at the TRACE Forum in Annapolis. Nicola provides context for recent compliance news from the EU and discusses the adoption of the Corporate Sustainability Due Diligence Directive at a gathering of compliance experts just three hours after the news broke!

Tom Cardamone, President and CEO of Global Financial Integrity, joins the podcast to discuss the regulatory and enforcement challenges associated with flags of convenience. These range from trafficked labor to environmental violations and Tom highlights the inherent tension between substantial tax incentives on one hand and accountability on the other.

 

Originally posted September 15, 2021

Pavel Verkhniatsky joins the podcast from Kyiv where he is the Managing Partner of COSA Solutions with particular expertise in sophisticated due diligence and cross-border investigations. We range from the very broad and geopolitical to the very specific as Pavel discusses the impact of sanctions on Russia, as well as common due diligence 'red flags'.

Daniel Treisman, co-author of Spin Dictators: The Changing Face of Tyranny in the 21st Century, discusses the new generation of dictators and how they weaponize information, bully with legal action and mobilize enablers to stay in power.

Originally posted on May 24, 2023

Zeke Faux joins the podcast to talk about the support and credibility provided to oil tankers violating sanctions by the companies that insure them. Zeke, together with Zachary Mider, wrote an excellent Bloomberg article earlier this month about one New York insurance company that insures a disproportionate number of these aged tankers accused of shipping sanctioned Iranian oil.

In honor of the extraordinarily courageous and principled life of Alexei Navalny, first poisoned with Novichuk and killed today in Polar Wolf prison, we are reposting our 2021 conversation with his chief of staff, Leonid Volkov.

 

Leonid Volkov joins the podcast to talk about Putin's obsessive campaign against Navalny, who was first poisoned with Novichok and later imprisoned. Volkov also discusses the deep roots of corruption in Russia and how the west can support Russians determined to end the looting of their country.

Author, academic and former compliance professional, Alison Taylor joins the podcast to talk about her compelling new book. She describes the contradictions inherent in companies that talk about “doing well by doing good” and explains why corporate reputation management can’t be an end in itself and how trying to do less can be the best strategy. “You don’t have to join every conversation”.

Valerie Salembier, former publisher of Harper’s Bazaar and founder of The Authentics Foundation, discusses the true cost of counterfeit luxury items: child labor, trafficked labor and organized crime.

 

This episode originally aired on July 3, 2018.

 

Investigative journalist Erlend Ofte Arntsen of Norwegian newspaper Verdens Gang joins the podcast to discuss his work on the Tinder Swindler story, recently adapted into a Netflix documentary. Erlend and his colleagues broke the story of Shimon Hayut, an Israeli con man who found women on the dating app, impressed them with private jets and bodyguards, concocted stories about being in great personal danger and then drained their bank accounts and left them with extraordinary credit card debt. 

 

This episode originally aired on February 15, 2022.

Tom Firestone, a partner with Squire Patton Boggs in Washington, discusses the new U.S. Foreign Extortion Prevention Act (FEPA). Tom’s perspective is especially interesting as he previously served as the Legal Adviser at the U.S. Embassy in Moscow dealing with financial crime there and, in 2018, he wrote an article on what was needed to tackle the demand side of bribery.

François Valérian joins the podcast to discuss the platform on which he ran in TI's recent election, his priorities and his thoughts on the state of global anti-corruption efforts.

Dan Kahn, former Chief of the DOJ’s FCPA unit and current partner with Davis Polk, talks us through the anti-corruption enforcement actions, trends and highlights of 2023.

Michael Forsythe, co-author with Walt Bogdanich of “When McKinsey Comes to Town”, joins the podcast to talk about McKinsey’s work in support of autocratic regimes, its rampant conflicts of interest and the distance between its stated values and its work on the ground.

 

This episode originally aired on January 18, 2023.

Randall Eliason talks about extortion, conspiracy, cover-up crimes and plea bargains – topics covered in his excellent new 24 lecture course available through Great Courses. He also takes us through some examples from recent headlines.

 

This episode originally aired on September 29, 2020.

Yana Gorokhovskaia of Freedom House joins the podcast to talk about transnational repression, the increasingly common abuse and intimidation by states of their citizens living abroad. Yana discusses Jamal Khashoggi, murdered in the Saudi consulate in Istanbul, and Roman Protasevich, whose plane was forced to land in Belarus where he is still being held, but also refers to the hundreds of other cases that don’t make the news. Freedom House has released an excellent report on this problem that can be found at: https://freedomhouse.org/report/transnational-repression.

 

This episode originally aired January 5, 2022.

Dr. Frank Badua, Associate Professor of Accounting and Business Law at Lamar University College of Business, describes the misconduct from the 1950s through the 1970s by a group of companies that led to widespread support for passage of the US Foreign Corrupt Practices Act.

 

This episode originally aired February 5, 2020.

Federico Masera with the University of New South Wales and the Resilient Democracy Lab in Sydney joins the podcast to discuss his recent research, together with Giorgio Gulino, "Contagious Dishonesty: Corruption Scandals and Supermarket Theft." Their intriguing research uncovers a trend toward substantially increased customer theft at supermarkets in the immediate aftermath of local corruption scandals involving prominent public officials.

 

This podcast was originally published on September 22, 2021.

Nobel Peace Prize winning journalist Maria Ressa joins the podcast to talk about corruption, disinformation and how to stand up to a dictator. We at TRACE are thankful for all of the investigative journalists that work to uncover financial crime, often at considerable personal risk.

 

This podcast was originally published on February 22, 2023.

For today’s podcast, we’re listening in on Pascale Dubois’ excellent and fast-paced review of the international anti-bribery landscape at the recent TRACE Forum in London. Pascale is a leading international executive advisor and independent expert who has been involved with anti-corruption efforts for two decades, including as the World Bank’s VP of the Integrity Vice Presidency.

 

Jessica Tillipman, Associate Dean for Government Procurement Law at George Washington Law School, joins the podcast to give a fantastic, detailed and fast-paced overview of the latest Menendez corruption allegations, interspersed with gold bars, bundles of cash and a Mercedes convertible. In the process, Jessica takes us back to the overturning of Former Virginia Governor Bob McDonnell’s corruption conviction and what we should expect in its wake.

As Russia’s war on Ukraine drags on, we revisit Russian corruption and its weaponization of financial crime in our 2017 interview with Bill Browder. He describes the brazen fraud and violence of Putin’s Russia, the death of Sergei Magnitsky, and the passage of the Magnitsky Act. You can also listen to our most recent  interview with Bill, discussing his excellent book, "Freezing Order." (That episode was originally published in 2017.)

This week, we’re listening in on Jeff Clark’s excellent presentation at the recent TRACE Forum in London. Jeff is a partner in Cadwalader’s Washington office and discusses the DOJ’s revised ECCP, with an emphasis on corporate communications and compensation policies.

This week, we listen in on the presentation of the inimitable Michelle de Kluyver of Addleshaw Goddard at the recent TRACE Forum in London.

Jessica Tillipman of George Washington Law School covers the highlights and key points from the Siemens bribery case of 2008. It was a startling case at the time and divided the international enforcement landscape into the world before and after Siemens.

 

This episode was originally published on 18 March 2020.

Today’s podcast is the fourth and final episode in a four-part guest series produced by the Global Reporting Centre and European Investigative Collaborations. The series tells the fascinating and little-known story about a trove of leaked documents exposing the machinations of a trust company in Jersey, Britain’s notorious tax haven.

Today’s podcast is the third in a four-part guest series produced by the Global Reporting Centre and European Investigative Collaborations. The series tells the fascinating and little-known story about a trove of leaked documents exposing the machinations of a trust company in Jersey, Britain’s notorious tax haven.

Today’s podcast is the second in a four-part guest series produced by the Global Reporting Centre and European Investigative Collaborations. The series tells the fascinating and little-known story about a trove of leaked documents exposing the machinations of a trust company in Jersey, Britain’s notorious tax haven.

Today’s podcast is the first in a four-part guest series produced by the Global Reporting Centre and European Investigative Collaborations. The series tells the fascinating and little-known story about a trove of leaked documents exposing the machinations of a trust company in Jersey, Britain’s notorious tax haven.

Yuliia Hnat, Co-Founder of the Museum of Contemporary Art NGO and Ukrainian Emergency Art Fund, and Irina Tarsis, Founder and Managing Director at the Center for Art Law, join the podcast to talk about all that is being done to preserve Ukraine’s tangible heritage during the Russian invasion and to catalog art and antiquities to ensure that they can’t easily be traded on the international market and can eventually be restored to Ukraine.

Patrick Alley, co-founder of Global Witness and author of Very Bad People: The Inside Story of the Fight Against the World’s Network of Corruption, joins the podcast to discuss the early days of his Global Witness investigations, how their efforts gained momentum and where we should be focusing our attention next.

 

This episode was originally published on 10 August 2022.

Scott Greytak of Transparency International U.S. joins the podcast to talk about the many loopholes that permit U.S. lawyers to work for criminal actors as they exploit the U.S. financial system. He brings us up-to-date on the ABA’s recent change to its Model Rules of Professional Conduct and when we’ll see the ENABLERS Act revisited.

Robert Worth, a journalist previously based in Baghdad with the New York Times and author of A Rage for Order: The Middle East in Turmoil from Tahrir Square to ISIS, describes the deadly and intractable problem of corruption in Iraq. He discusses the role the United States and its pallets of cash played in this, but also the enforced sectarian apportionment of power—the Muhasasa—that ensures each group protects its fiefdom rather than acting in the best interest of the whole country.

 

This episode was originally published on 25 May 2022.

Oliver Bullough joins the podcast again to discuss his book, Butler to the World. The book addresses how the UK went from a colonial power dominating the world to a service provider—or butler or perhaps consigliere—to the world’s oligarchs.

 

This episode was originally published on 15 June 2022.

Kelly Richmond Pope, Professor of Forensic Accounting at DePaul University, joins the podcast to talk about her new book: Fool Me Once: Scams, Stories and Secrets from the Trillion-Dollar Fraud Industry. She describes the three types of fraud perpetrators and why we blame the victims of fraud for their gullibility and I ask her whether lawyers or accountants are more at fault for rampant fraud!

Jennifer Taub, author, legal scholar, professor and advocate, joins the podcast to talk about her book: Big Dirty Money: The Shocking Injustice and Unseen Cost of White Collar Crime. Jennifer focuses, in particular, on how much more gently we treat corporate financial crime than we do very petty financial crime, in spite of the fact that the former costs taxpayers far more money.

 

This episode was originally published on 16 December 2021.

Hans Greimel and William Sposato, journalists and authors, join the podcast to discuss their new book: Collision Course: Carlos Ghosn and the Culture Wars That Upended an Auto EmpireThey cover Ghosn’s rise to hero status in Japan, his ultimate fall—arrest, detention and escape from the country—and the many compliance challenges raised by this strange story. (This episode was originally published in 2021.)

The first episode of a two-part series, Chaim Gelfand, Vice President, Compliance, at NSO Group talks about managing compliance for a product that has, baked into its design, complex privacy, corruption and human rights implications. Because of the controversial nature of spyware, we hear from journalist Khadija Ismayilova in the second episode about the allegation that spyware was installed on her cell phone and her concerns about abuse of the technology.

 

This episode was originally published on 8 March 2023.

This podcast is the second episode in a two-part discussion of the compliance and human rights implications of spyware. After hearing from Chaim Gelfand at NSO Group, we asked Khadija Ismayilova, an investigative journalist in Azerbaijan who is alleged to have been monitored for four years by spyware installed on her phone, to speak to the privacy and human rights issues. (The first half of the conversation has some IT issues, but it clears up in the second half, so please stay with us!)

 

This episode was originally published on 15 March 2023.

 

Peter Humphrey and his wife were well-respected compliance professionals active in China when they were arrested, tried and imprisoned unjustly for two years.

 

This episode was originally published on 4 October 2017.

Jessica Warwick in Norton Rose’s Ottawa office joins the podcast to talk about the Arapakota decision and what it means for anti-bribery enforcement in Canada.

Jesse Eisinger of ProPublica joins the podcast to discuss their investigation into the gifts, travel, tuition, rent and other benefits lavished on Justice Thomas directly—or indirectly for the benefit of family members—by right-wing billionaire, Harlan Crow. Jesse discusses the initial article, the tips they received with additional information after publishing it, and the political backlash to their reporting.

Data scientist, whistleblower and now author, Frances Haugen, joins the podcast to discuss her book, which comes out today. Frances describes her journey through tech as an algorithmic product manager, her growing understanding of the risk of radicalization and political violence that Facebook posed and her ultimate decision to blow the whistle when it became clear that Facebook, profiting from outrage, wasn’t going to fix itself.

New York Times reporter Ian Urbina discusses his excellent but grim series about crime and impunity on the high seas.

 

This episode was originally published on 25 October 2017.

Daniel Treisman, co-author of Spin Dictators:  The Changing Face of Tyranny in the 21st Century, discusses the new generation of dictators and how they weaponize information, bully with legal action and mobilize enablers to stay in power.

Journalist and author Nicolas Niarchos discusses the current state of compliance in battery metal mining, political and regional challenges in the industry, and his forthcoming book on the topic.

Chuck Duross, former head of the DOJ’s FCPA unit and now a partner with Morrison & Forester, walks us through the many compliance challenges associated with employee use of messaging apps, together with a few suggestions on how best to manage the risk.

James Heinzen joins the podcast to talk about his book, The Art of the Bribe: Corruption Under Stalin 1943-1953 and how bribery, extortion and embezzlement in Russia have changed—or not—over the last 70 years.

Kevin G. Hall, the Organized Crime and Corruption Reporting Project’s North America editor, reflects on how the Panama Papers have shaped investigative journalism over the past six years and the biggest challenges journalists face today.

Paul Massaro of the U.S. Helsinki Commission provides an animated overview of current policy initiatives, U.S. support for Ukraine and what’s next in the fight against global kleptocracy.

Jared Bibler joins the podcast to discuss his lively book about the complete meltdown of Iceland’s banking sector and, as a result, its economy. It was a brazen scheme equal in size to three Enrons and, although it happened in 2008, it remains a timely cautionary tale for the banking sector and regulators today.

Investigative reporter Sam Cooper describes the waves of drugs and laundered money from China crashing on Canada’s shores. Sam's book is "Wilful Blindness: How a Network of Narcos, Tycoons, and CCP Agents Infiltrated the West."

 

This episode was originally published on 7 July 2021.

With new foreign bribery charges announced against Sam Bankman-Fried this week, we’re revisiting our discussion with Jim Campbell, author of “Madoff Talks.” Having studied both men, he compares what we know about Bankman-Fried and Madoff.

Olivia Swaak-Goldman, Executive Director of the Wildlife Justice Commission, joins the podcast to discuss the impact of corruption and the role of organized crime in the illicit trade in wildlife.

Today’s podcast is the second episode in a two-part discussion of the compliance and human rights implications of spyware. After hearing from Chaim Gelfand at NSO Group last week, we asked Khadija Ismayilova, an investigative journalist in Azerbaijan who is alleged to have been monitored for four years by spyware installed on her phone, to speak to the privacy and human rights issues. (The first half of the conversation has some IT issues, but it clears up in the second half, so please stay with us!)

Chaim Gelfand, Vice President, Compliance, at NSO Group joins the podcast to talk about managing compliance for a product that has, baked into its design, complex privacy, corruption and human rights implications. Because of the controversial nature of spyware, we will hear from journalist Khadija Ismayilova next week about the allegation that spyware was installed on her cell phone and her concerns about abuse of the technology.

Hentie Dirker, Chief ESG and Integrity Officer with SNC-Lavalin, speaks to Jonathan Drimmer of Paul Hastings about building a culture of compliance in the aftermath of a bribery scandal.

 

This episode was originally published on 7 August 2019.

Nobel Peace Prize winning journalist Maria Ressa joins the podcast to talk about corruption, disinformation and how to stand up to a dictator.

Rob Koehler, WADA veteran and current Director General of Global Athlete, joins the podcast to discuss the epidemic of doping in sports, the imbalance of power between athletes and administrators and the IOC's startling decision to allow Russia to compete in the Paris Games in spite of its invasion of Ukraine.

Laura Harth with Safeguard Defenders joins the podcast to talk about the more than 50 illegal Chinese police stations operating around the world, including in the United States and Canada. These violate both the sovereignty of the inadvertent ‘host’ countries and the rights of the Chinese citizens abroad who are stalked and coerced to comply with government demands to return to China or risk the persecution of their families. Laura discusses her organization’s excellent report 110 Overseas: Chinese Transnational Policing Gone Wild. (The title is based on the emergency number for the police in China - 110.) 

Listen to the riveting first-hand story of a Unaoil executive who found himself at the center of a bribery scheme.

 

This episode was originally published on 16 August 2017.

Jim Campbell, author of “Madoff Talks” and featured in the recently released Netflix documentary, “Madoff: Monster of Wall Street,” joins the podcast to talk about FTX. Having studied both men, he compares what we know about Bankman-Fried and Madoff.

Michael Forsythe, co-author with Walt Bogdanich of “When McKinsey Comes to Town”, joins the podcast to talk about McKinsey’s work in support of autocratic regimes, its rampant conflicts of interest and the distance between its stated values and its work on the ground.

Diana Henriques describes Madoff’s Ponzi scheme, discusses how difficult it is to uncover fraud by those who prey on the trust of others and addresses the simple, consistent controls that saved some investors from losses. Diana is featured in the new Netflix series MADOFF: The Monster of Wall Street.

 

This episode was originally published on 14 August 2019.

Ruth Ben-Ghiat joins the podcast to discuss her book Strongmen: Mussolini to the Present, which examines 100 years of authoritarian rule. She describes the characteristics of a strongman and the strange virility cult surrounding these leaders before turning to the central role of corruption in the autocrat’s playbook.

 

This episode was originally published on 3 November 2021.

Reflecting on the year as it draws to a close, we note with great sadness the recent loss of sports journalist, author and inimitable soccer analyst Grant Wahl. We’re replaying today our podcast with Grant from 2017. He was generous with his time, happy to share his expertise and invariably good humored. He is missed.

As we near the end of the year, we asked nine experts in the field to provide us with their compliance predictions for 2023. Surprisingly, no prediction was duplicated. We hope you enjoy these prognostications and we wish you all a wonderful holiday season and all the very best in the year ahead!

Dan Kahn, former Chief of the FCPA Unit, joins the podcast to discuss the September Monaco Memo now that the compliance community has had some time to debate it. Dan discusses the good news, and some concerns, associated with cooperation credit, voluntary disclosure, recidivist companies, monitors and ongoing concerns about personal devices and ephemeral apps.

 

Casey Michel with the Hudson Institute's Kleptocracy Initiative joins the podcast for a very lively discussion about his book, American Kleptocracy: How the U.S. Created the World’s Greatest Money Laundering Scheme in History. Casey discusses America’s role in the problem of global kleptocracy and shares some optimism about the path ahead.

 

This episode was originally published on 13 October 2021.

Dr. Magnus Öhman of the International Foundation for Electoral Systems (IFES) joins the podcast to discuss how corruption undermines free and fair elections. He discusses his recent publication: “Vote for Free: A Global Guide for Citizen Monitoring of Campaign Finance,” which provides an eight-step model for civil society organizations seeking to monitor campaign finance.

Mykola Murskyj with Razom for Ukraine joins the podcast to discuss the organization’s work in Ukraine, the anti-corruption climate there prior to the invasion and steps that can be taken now. Mykola also discusses the Enablers Act.

This week, we’re listening in on Alexandra Wrage’s recent keynote presentation at a Whistleblowers and Public Integrity conference hosted by the Vancouver Anti-Corruption Institute (VACI). She addresses the incredible personal price that whistleblowers pay when they’re driven to expose misconduct, explores how we can begin to shift the tone of the discussion around reporting and notes how difficult it is to uncover financial crime without whistleblowers.

As we approach the 2022 World Cup, we’re revisiting our 2018 episode with Ken Bensinger, who discusses his fascinating book, Red Card, and the decades of misconduct by FIFA eventually uncovered by the FBI. We play “violation bingo” as Ken describes the bribery, self-dealing, conflicts of interest and money laundering that were business as usual at FIFA. 

 

Speaking at the TRACE London Forum, Oliver Bullough, author of Butler to the World, discusses the UK’s role as an enabler of financial crime, efforts toward accountability, the balance between transparency and privacy, and the weaponization of lawsuits in British courts to silence journalists.

Investigative journalist Dorothee Myriam Kellou tells the story of the Lafarge plant in Syria that was ultimately taken over by ISIS.

 

This episode was originally published on 14 March 2018.

 

Paul Caruana Galizia, a journalist with Tortoise media, joins the podcast to talk about the work of his mother, Daphne, the growing danger she perceived as her investigations reached the highest circles of power in Malta, and now the criminal proceedings against the two men who killed her. Paul also discusses the Daphne Foundation and the incredible journalistic community that worked together, again, to prove that killing a journalist won’t kill their story.

This week, we hear from Leonid Volkov who spoke at the recent TRACE London Forum. Leonid is Alexei Navalny’s Chief of Staff and Political Director of the Anti-Corruption Foundation. He discusses the role of corruption in Putin’s Russia as well as the impact of sanctions and the toll that rampant corruption is taking on Russia.

This week, we’re listening in on our conversation with Bill Browder at the TRACE London Forum. Bill discusses his new book, Freezing Order, and his ongoing quest for accountability and justice following the abuse and murder of his lawyer, Sergei Magnitsky.

 

Jonathan Drimmer of Paul Hastings describes how to create and sustain a culture of compliance.

 

This episode was originally published on 3 July 2019.

Leonid Volkov joins the podcast to talk about Putin’s obsessive campaign against Navalny, who was first poisoned with Novichok and later imprisoned. Volkov also discusses the deep roots of corruption in Russia and how the west can support Russians determined to end the looting of their country. (This episode was originally published in 2021.)

In light of recent news about Leonard Glenn Francis' escape from house arrest ahead of his U.S. sentencing, we're revisiting our episode with Doyle Hodges, Commander, USN, ret., and Stephen Wrage, Professor, U.S. Naval Academy. They describe how "Fat Leonard" of Glenn Defense Marine Asia organized and executed a scheme that corrupted at least 30 officers and compromised over 400 others. (This episode was originally published in 2019.)

International sports expert, Declan Hill, returns to the podcast to discuss the FIFA trial that concluded in late December 2017 and the outlook for meaningful reform.

Freelance journalist Nicolas Niarchos joins the podcast to discuss his excellent piece in the New Yorker: The Dark Side of Congo’s Cobalt Rush. He also describes his recent incarceration and that of his Congolese colleague, Jeef Kazadi, during their ongoing investigation in the DRC.

Tom Wright joins the podcast to discuss the latest developments in the ‘Fat Leonard’ story, summarized from his lively podcast series by the same name.  Tom recorded hours of interviews with Leonard Glenn Francis and so brings fresh insight to this lengthy saga as we await Leonard’s sentencing in response—seven years later—to his 2015 guilty plea.

Patrick Alley, co-founder of Global Witness and author of Very Bad People: The Inside Story of the Fight Against the World’s Network of Corruption, joins the podcast to discuss the early days of his Global Witness investigations, how their efforts gained momentum and where we should be focusing our attention next.

Bradley Hope discusses his excellent book about the rise of Crown Prince Mohammed Bin Salman and key milestones like the “Ritz Carlton Prison”, the kidnapping of Prime Minister Hariri of Lebanon and the murder of Jamal Khashoggi. He also discusses some of MBS’s modernization efforts and what the Kingdom might look like if he hadn’t risen to a position of power.

Paul Holden of Shadow World Investigations joins the podcast to discuss the South African Judicial Commission of Inquiry into Allegations of State Capture (“Zondo Commission”). He describes the extensive corruption and money-laundering enabled by banks and international corporations and makes a prediction about whether the Gupta brothers, recently arrested in Dubai, will be extradited to South Africa.

 

At the TRACE Prize for Investigative Reporting award ceremony last month, former prosecutor and National Observer columnist Sandy Garossino led a conversation with ICIJ’s Spencer Woodman, Bellingcat’s Aric Toler, and 2022 Prize winners Hans Peterson Hammer of Göteborgs-Posten and Lilia Saúl Rodriguez of the OCCRP. They discuss the evolution, impact and future of cross-border collaborative investigative journalism.

 

Omar Alshogre, refugee, political activist and Georgetown University student, shares the wrenching story of his three years as a political prisoner in the worst of Syria’s prisons. He discusses the role that extortion plays there, simultaneously delegitimizing the regime further and propping it up financially. (This episode was originally published in June 2021.)

Jim Wasserstrom spoke at the TRACE Prize for Investigative Reporting in Vancouver last month, describing his own experience as a whistleblower and his commitment to building an Integrity Sanctuary where whistleblowers can recover and flourish in safety.

Khadija Ismayilova speaks at the TRACE Prize for Investigative Reporting in Vancouver last week, describing the risks to whistleblowers and what we can do to encourage and protect them.

Oliver Bullough, Tom Burgis and Sarah Chayes, authors of three of the best books on global corruption, gather for a panel at the Annapolis Book Festival for a fascinating discussion about how the corrupt operate, often with impunity, and what can be done to slow the pace of looting.

Oliver Bullough joins the podcast again to discuss his latest book, out this week: Butler to the World. The book addresses how the UK went from a colonial power dominating the world to a service provider—or butler or perhaps consigliere—to the world’s oligarchs.

Craig Whitlock of the Washington Post describes the sleaze and corruption that compromised the top ranks of the Seventh Fleet.

 

This episode was originally published in May 2017

This week, we're revisiting our 2017 interview with Bill Browder. He describes the brazen fraud and violence of Putin’s Russia, the death of Sergei Magnitsky, and the passage of the Magnitsky Act. Listen to our latest interview with Bill on his new book, Freezing Order.

Robert Worth, a journalist previously based in Baghdad with the New York Times and author of A Rage for Order: The Middle East in Turmoil from Tahrir Square to ISIS, describes the deadly and intractable problem of corruption in Iraq. He discusses the role the United States and its pallets of cash played in this, but also the enforced sectarian apportionment of power—the Muhasasa—that ensures each group protects its fiefdom rather than acting in the best interest of the whole country.

Matt Sarnecki joins the podcast today. Matt is a senior producer with the OCCRP and the direct of a new documentary about the murders in Slovakia of Jan Kuciak and Martina Kušnírová. The Killing of a Journalist explores the public outrage, the criminal investigation that was based in part on leaked phone records, and the political fall-out from this tragedy.

Bill Browder joins the podcast again to talk about his fascinating new book, the many successes of the Global Magnitsky Act which he promoted with energy and ingenuity and where he is turning his attention now.

Mary Lawlor joins the podcast to discuss her role as the United Nations Special Rapporteur on the situation of human rights defenders and her determination that anti-corruption activists should be included as--and offered the protection of--human rights defenders.

Bektour Iskender, journalist, co-founder of Kloop and TED Fellow, joined me at TED2022 to discuss his investigative reporting in Kyrgyzstan and the impact that his team’s work had there.

This week, we’re listening in on remarks from Kenneth Polite, Jr., Assistant Attorney General for the Criminal Division at the U.S. Department of Justice, at our annual TRACE Forum. He discusses recent changes in the DOJ’s approach to white collar crime, priorities for compliance teams, and the new KleptoCapture initiative.

 

This week, Kara Brockmeyer, partner in Debevoise & Plimpton’s Washington, D.C. office, discusses the impact of the U.S. Anti-Money Laundering Act on anti-corruption compliance and enforcement. This podcast was recorded at TRACE’s 2022 Forum, which brings together compliance professionals for meaningful discussions.

Drago Kos, Chair of the OECD’s Working Group on Bribery, and Dan Kahn, former head of the DOJ’s FCPA Unit and now a partner in Davis Polk’s DC office, wrap up our series on the OECD revised Recommendation with a focus on the very practical implications for companies. 

Bill Steinman of Steinman & Rodgers joins the podcast to discuss the recent Opinion Procedure Release addressing extortionate demands. Bill also reviews the substantial grey area of emergencies involving the detention of personnel and confiscation of property that are arguably legal under local law.

Michelle de Kluyver, partner in Addleshaw Goddard’s Global Investigations group, joins the podcast to discuss the UK’s history with the OECD convention and what impact the revised Recommendation might have.

Cheryl Scarboro presents TRACE’s annual FCPA Year in Review webinar and we listen in for today’s podcast. Cheryl was Associate Director in the SEC’s Division of Enforcement for almost twenty years and served as its first ever Chief of the FCPA Unit.  She is now a partner in Simpson Thacher & Bartlett’s Washington DC office.

Jan Dunin-Wasowicz, counsel in Hughes Hubbard & Reed’s Paris office, joins the podcast to discuss France’s performance to date as a party to the OECD Anti-Bribery Convention and what impact the revised Recommendation might have there.

Investigative journalist Erlend Ofte Arntsen of Norwegian newspaper Verdens Gang joins the podcast to discuss his work on the Tinder Swindler story, recently adapted into a Netflix documentary. Erlend and his colleagues broke the story of Shimon Hayut, an Israeli con man who found women on the dating app, impressed them with private jets and bodyguards, concocted stories about being in great personal danger and then drained their bank accounts and left them with extraordinary credit card debt. 

Peter Solmssen joins the podcast to talk about his work, together with a group of experts, in support of the OECD Working Group on Bribery’s revised Recommendation relating to settlements. He discusses how “individual heroism” by prosecutors should not be required to reach settlements, and he shares his thoughts on the benefits the revised Recommendation will bring not only to companies, but also to prosecutors and to the larger goal of reducing corruption.

Mark Morrison, National Practice Group Leader of Blakes Business Crimes, Investigations & Compliance group, joins the podcast to discuss Canada’s performance to date as a party to the OECD Anti-Bribery Convention and what the revised Recommendation might mean for Canada.

Ryan Murphy, a partner at PricewaterhouseCoopers’ Cyber, Risk & Regulatory Platform and lead on PwC's U.S. Investigations & Forensics Services Practice, joins the podcast to discuss audits: what the term means, what assurance they should and should not provide, and how they can be used for nefarious purposes.

Wendy Wysong of Steptoe & Johnson, TRACE’s Partner Law Firm in Hong Kong, joins the podcast to discuss recent new guidance from China’s Central Commission for Discipline Inspection (CCDI). Applying only to bribes paid within China’s borders, the guidance highlights some challenges for companies operating in China, particularly with respect to multi-country settlements.

Leah Ambler, Director of Corruption Prevention at the Australian Commission for Law Enforcement Integrity and former Legal Analyst at the Organisation for Economic Co-operation and Development (OECD), joins the podcast—in her personal capacity—to discuss her excellent chapter on whistleblower protections. Leah discusses the importance of whistleblower protections to reducing corruption and the challenges inherent in these protections in the absence of comprehensive, harmonized legislation.

This week on Bribe, Swindle or Steal, Yana Gorokhovskaia of Freedom House joins the podcast to talk about transnational repression, the increasingly common abuse and intimidation by states of their citizens living abroad. Yana discusses Jamal Khashoggi, murdered in the Saudi consulate in Istanbul, and Roman Protasevich, whose plane was forced to land in Belarus where he is still being held, but also refers to the hundreds of other cases that don’t make the news. Freedom House has released an excellent report on this problem: Out of Sight, Not Out of Reach.

As is holiday tradition, we're revisiting our podcast with Peter Hellman, who describes Rudy Kurniawan’s audacious scheme to defraud wine collectors in his excellent book, In Vino Duplicitas: The Rise and Fall of a Wine Forger Extraordinaire. (This episode was originally published in 2019.)

Penelope Kyritsis, Assistant Director of Research at the Worker Rights Consortium, discusses the detention of China’s Uyghur Moslem minority in internment camps. Uyghurs have been compelled to work in these camps, primarily in Xinjiang. But they are now also separated from their families and relocated to factories across China, making it difficult for companies to undertake meaningful due diligence on forced labor in their Chinese supply chains. (This episode was originally published in September 2020.)

Nicola Bonucci, former Legal Director at the OECD and now a partner at Paul Hastings in Paris, joins the podcast to discuss the 2021 OECD Anti-Bribery Recommendation announced in November. We also chat about the challenge of advancing an international consensus on anti-corruption enforcement amongst Working Group on Bribery members hailing from different legal systems.

As part of the many events marking International Anti-Corruption Day this week, The Vancouver Anti-Corruption Institute (VACI) will launch 9 December in Vancouver. Peter German, president of VACI—and of its host organization, the International Centre for Criminal Law Reform & Criminal Justice Policy—joins the podcast to discuss the need for this initiative, its focus and some of its goals.

Prof. Mark Pieth joins the podcast to discuss his recent book, Gold Laundering: The dirty secrets of the gold trade - and how to clean up. He outlines the many problems, including child and trafficked labor, environmental degradation, violence, and corruption. He also addresses some modest steps forward and how, in spite of the considerable challenges, more progress can be made.

Duncan Smith of the European Investment Bank discusses his book, Promoting Integrity in the Work of International Organisations: Minimising Fraud and Corruption in Projects. He talks about the unique role of multinational development banks, the progress that remains and the cost of getting it wrong.

Acclaimed investigative journalist Khadija Ismayilova describes her efforts to uncover corruption in Azerbaijan and the state-sponsored blackmail, and then imprisonment, she suffered. Khadija has been represented by an international coalition of lawyers: Amal Clooney (Doughty Street Chambers), Alinda Vermeer (Media Legal Defence Initiative), Yalchin Imanov and Fariz Namazov. (This episode was originally published in March 2018.)

 

The Caviar Connection, a documentary featuring Khadija, is screening this week in person and online at the DOC NYC Film Festival

Dan Kahn joins the podcast to discuss his time at the U.S. Department of Justice, including as Chief of the FCPA Unit, and his recent transition back to private practice as a partner in the White Collar Defense and Investigations practice in Davis Polk’s Washington office. Dan discusses recent trends, the new guidance announced by Deputy Attorney General Lisa Monaco and some approaches to pursuing demand-side bribery.

Ruth Ben-Ghiat joins the podcast to discuss her book Strongmen: Mussolini to the Present, which examines 100 years of authoritarian rule. She describes the characteristics of a strongman and the strange virility cult surrounding these leaders before turning to the central role of corruption in the autocrat’s playbook.

Etelle Higonnet with the National Wildlife Federation takes us through the complex and intersecting problems raised by the cocoa industry: environmental degradation, child labor and extreme financial disparities that prevent most cocoa farmers from ever tasting the chocolate they grow. (This episode was originally published in February 2021.)

Drago Kos joins the podcast to talk about the work of the OECD Working Group on Bribery, its ambitious Revised Recommendation, what he hopes the group will accomplish in his final year with the WGB and the search to find his replacement.

Casey Michel with the Hudson Institute's Kleptocracy Initiative joins the podcast for a very lively discussion about his new book, American Kleptocracy: How the U.S. Created the World’s Greatest Money Laundering Scheme in History. Casey discusses America’s role in the problem of global kleptocracy and shares some optimism about the path ahead.

Michael Sallah, senior investigations editor with the Pittsburgh Post-Gazette, joins the podcast to talk about his “Dirty Dollars” investigation into how foreign corruption swamped the very center of America where huge sums were laundered at the expense of the local community.

Note: While the sound quality of this episode isn't ideal, we hope you'll stick with the interview for Michael's extremely important insight. 

Federico Masera with the University of New South Wales and the Resilient Democracy Lab in Sydney joins the podcast to discuss his recent research, together with Giorgio Gulino, "Contagious Dishonesty: Corruption Scandals and Supermarket Theft." Their intriguing research uncovers a trend toward substantially increased customer theft at supermarkets in the immediate aftermath of local corruption scandals involving prominent public officials.

Tom Cardamone, President and CEO of Global Financial Integrity, joins the podcast to discuss the regulatory and enforcement challenges associated with flags of convenience. These range from trafficked labor to environmental violations, and Tom highlights the inherent tension between substantial tax incentives on one hand and accountability on the other.

Leonid Volkov joins the podcast to talk about Putin’s obsessive campaign against Navalny, who was first poisoned with Novichok and later imprisoned. Volkov also discusses the deep roots of corruption in Russia and how the West can support Russians determined to end the looting of their country.

Listen to the riveting first-hand story of a Unaoil executive who found himself at the center of a bribery scheme. (This episode was originally published in August 2017.)

Walt Pavlo discusses the accounting fraud at MCI that led to his two-year prison sentence, his book Stolen Without a Gun: Confessions From Inside History’s Biggest Accounting Fraud, and his second career with Prisonology. (This episode was originally published in November 2017.)

Peter Elkind tells the story of the Enron financial scandal: a timely refresher on that corporate disaster. (This episode was originally published in 2017.)

Sarah Chayes, author of Thieves of State, draws on her time in Afghanistan to explain the systemic corruption that contributed to the rapid crumbling of the state.

 

This episode was originally published in June 2017.

Jack Ewing of the New York Times in Frankfurt discusses his excellent book, “Faster, Higher, Farther: The Volkswagen Scandal”, and the outrageous fraud and cover-up uncovered by a handful of WVU students. (This episode was originally published in November 2017.)

Craig Whitlock of the Washington Post describes the sleaze and corruption that compromised the top ranks of the Seventh Fleet.

 

This episode was originally published in May 2017.

Will Fitzgibbon of the International Consortium of Investigative Journalists (ICIJ) joins the podcast with an update on last year’s FinCEN Files story, including a prison sentence for the whistleblower who leaked the information.

 

The FinCEN Files project won the 2021 TRACE Prize for Investigative Reporting and was a Pulitzer Prize finalist.

Author and business radio host Jim Campbell discusses his recent book about Bernie Madoff, his Ponzi scheme and his lack of remorse, based on extraordinary access to Madoff and members of his family and team. Jim's book is "Madoff Talks: Uncovering the Untold Story Behind the Most Notorious Ponzi Scheme in History."

Joel Bakan joins the podcast to discuss his books, and the films based on them. He outlines the fundamental conflict inherent in companies ostensibly committed to ESG principles while simultaneously driven by a legal requirement to maximize shareholder value.

Investigative reporter Sam Cooper describes the waves of drugs and laundered money from China crashing on Canada’s shores. Sam's new book is "Wilful Blindness: How a Network of Narcos, Tycoons, and CCP Agents Infiltrated the West."

Tom Burgis, investigations correspondent at the Financial Times and author of "Kleptopia", discusses the increasingly disturbing influence that kleptocrats exert internationally, who enables them and the flaws in our efforts to contain them.

The golden passports and visas industry boomed during the pandemic and attracted the attention of policymakers. This week, we’re reposting our interview with Oliver Bullough, author of “Moneyland”, on this shady industry and how it operates. (This episode was originally published in May 2019.)

John Heathershaw of the University of Exeter discusses the working paper he co-authored for the National Endowment for Democracy: “Paying for a World Class Affiliation: Reputation Laundering in the University Sector of Open Societies.” He shows how vulnerable universities are to abuse by kleptocrats seeking to shape the conversation, often quite subtly, about their governments and their legacies. This research was undertaken for NED and under the Global Integrity Anti-Corruption Evidence project.

Omar Alshogre, refugee, political activist with the Syrian Emergency Task Force, and first year Georgetown University student, shares the wrenching story of his three years as a political prisoner in the worst of Syria’s prisons. He discusses the role that extortion plays there, simultaneously delegitimizing the regime further and propping it up financially.

Josh Rudolph at the Alliance for Securing Democracy at the German Marshall Fund discusses how we should approach corruption and kleptocracy from a policy perspective and why Treasury needs to ‘get with the program.’

Hayley Smith with the Los Angeles Times discusses the story she broke about the sale of phony COVID-19 vaccination cards out of the Old Corner Saloon in California.

Amy McDougal of CLEAResources discusses the rapidly shifting cannabis landscape and how to prepare for the many employment and compliance issues it raises.

Renee Dudley of ProPublica discusses her fascinating research into the unsettling world of ransomware: how it works, the role that “recovery services” play, and where the ransom money ends up. (This episode was originally published in October 2019.)

Ike Sorkin, lawyer to both Bernie Madoff and Jordan Belfort, talks through their criminal financial schemes and how regulatory safeguards failed. (This episode was originally published in June 2017.)

Oliver Bullough, Tom Burgis and Sarah Chayes, authors of three of the best books on global corruption, gather for a panel at the Annapolis Book Festival for a fascinating discussion about how the corrupt operate, often with impunity, and what can be done to slow the pace of looting.

Josh Kirschenbaum is a senior fellow at the German Marshall Fund’s Alliance for Securing Democracy and formerly served as acting director of the Office of Special Measures at Treasury’s Financial Crimes Enforcement Network (FinCEN). He joins the podcast to discuss investment funds and the gaping loophole they create through which vast sums of money can move with no accountability.

Diana Henriques drew on her years of financial journalism and extraordinary access to the title character to write the definitive book about Bernie Madoff. It was turned into an HBO movie in early 2017 starring Robert De Niro, Michelle Pfeiffer and Diana, playing herself. (This episode was originally published in September 2017.)

Ariel Meyerstein, Senior Vice President, Sustainability & ESG at Citi, shares his insight into human rights, climate change and social justice challenges and the new momentum propelling ESG in the private sector.

Jodi Vittori, with the Democracy, Conflict and Governance Program at the Carnegie Endowment for International Peace and Research, discusses the UN Security Council’s March report on Libya.

Mandy Patinkin and Kathryn Grody describe with passion their work with the International Rescue Committee and tell us what America as a haven means to them. (This episode was originally published in October 2020.)

Jeff Wright, managing partner of Actium Capital, shares a rare private investor perspective on compliance in international deals.

Bill Steinman of Steinman & Rodgers provides a primer on offsets and the compliance challenges they present. (This episode was originally published in March 2018.)

Illya Antonenko, TRACE’s Director of Compliance Resources, joins the podcast to talk about his perception of Eastern European corruption through an American lens. Illya grew up in the former Soviet Union and, as an adult, moved to the United States, where he began his legal and compliance career.

Hentie Dirker, Chief Integrity Officer with SNC Lavalin, speaks to Jonathan Drimmer of Paul Hastings about building a culture of compliance in the aftermath of a bribery scandal. (This episode was originally published in August 2019.)

Julia Yansura, Program Manager with Global Financial Integrity, joins the podcast to discuss the role that gold plays in illicit financial flows worldwide, exacerbating problems from money laundering to sanctions violations.

Professor Katharine Abernethy discusses the dramatic and illegal overhunting and subsequent smuggling of pangolins, the most trafficked animal in the world, to supply the Asian market with their scales believed—without evidence—to cure cancer. (This episode was originally published in April 2018.)

Tom Burgis discusses his latest book: “Kleptopia: How Dirty Money is Conquering the World.” Tom joins Alexandra for a webinar hosted by Tom Keatinge of RUSI in London.

Marcus Stern, the Pulitzer Prize winning investigative reporter who broke the story, describes the bribery scheme that landed then Congressman “Duke” Cunningham in jail for seven years. (This episode was originally published in July 2018.)

Michael Johnston joins the podcast to discuss his new book with co-author Scott Fritzen: The Conundrum of Corruption. Michael is the Charles A. Dana Professor of Political Science Emeritus at Colgate University and has written extensively on the underlying causes of corruption and how best to tackle it. In this podcast, he urges a new approach to the problem.

Nicola Bonucci and Nat Edmonds, in Paul Hastings’ Paris and Washington offices respectively, discuss the OECD Anti-Bribery Convention and the Working Group and its recent Phase 4 review of the United States. They wrap up with some recommendations for multinational corporations.

Tom Best, a partner in Paul Hastings’ Washington office, joins the podcast to review sanctions policy under the Trump administration and then makes some predictions about what we should expect from President Biden in 2021. Download TRACE's white paper "Does Your Sanctions Compliance Program Align with OFAC’s 2019 Compliance Framework?", written by Paul Hastings.

Robert Cribb of the Toronto Star discusses the emails and documents turned over to the media in furtherance of a family feud that spans continents and exposes financial schemes that are both complex and well-documented.

Rupert Younger of Oxford’s Center for Corporate Reputation and Alexandra discuss some novel bribery schemes at Berkeley’s 2019 “Fraudfest”.  (The sound quality reflects the conference setting.)

Jennifer Taub, author, legal scholar, professor and advocate, joins the podcast to talk about her latest book, Big Dirty Money: The Shocking Injustice and Unseen Cost of White Collar Crime. Jennifer focuses, in particular, on how much more gently we treat corporate financial crime than we do very petty financial crime, in spite of the fact that the former costs taxpayers far more money.

Robert Clark, Manager of Legal Research at TRACE, discusses the TRACE Matrix, a data-driven tool that assesses the likelihood—by country—of a company being asked to pay a bribe. This podcast is technical and may be of particular interest to academics and those in civil society seeking new ways to measure risk.

Paul Massaro of the U.S. Helsinki Commission discusses the scope of doping in international sport, the foreign policy implications and the Rodchenkov Anti-Doping Act (RADA) offered in response. This episode was originally published in March 2019.

New York Times reporter Ian Urbina discusses his excellent but grim series about crime and impunity on the high seas.

Sarah Chayes joins the podcast to talk about her latest book: On Corruption in America and What is at Stake. She takes us from the myth of King Midas through to the present in a lively history of corruption and then leaves listeners with a detailed call to action.

Bradley Hope discusses his excellent book about the rise of Crown Prince Mohammed bin Salman and key milestones like the “Ritz Carlton Prison”, the kidnapping of Prime Minister Hariri of Lebanon and the murder of Jamal Khashoggi. He also discusses some of MBS’s modernization efforts and what the Kingdom might look like if he hadn’t risen to a position of power.

James Wright of the Organized Crime and Corruption Reporting Project (OCCRP) discusses the FinCEN files. He describes the coalition of investigative reporters who dug into the leaked documents and what they found as they reviewed over 2,000 Suspicious Activity Reports (SARs) spanning more than five years.

Harvard law professor Matthew Stephenson provides some context for understanding Trump's new executive order and then lists the three primary threats it poses for corruption. A more detailed discussion can be found on his Global Anticorruption Blog.

Alex Crutcher with the Al Jazeera Investigative Unit discusses the sale of “golden passports” to wealthy criminals and high-risk individuals. The team pursued the story in the wake of a major data leak, and their reporting has resulted in the cancellation of the program and several high-level resignations in the Cypriot government.

Dan Alexander, author and senior editor at Forbes, discusses his book about Trump’s business deals with foreign entities, including one very strange deal with the sovereign wealth fund of Qatar.

Randall Eliason talks about extortion, conspiracy, cover-up crimes and plea bargains – topics covered in his excellent new 24-lecture course available through Great Courses. He also takes us through some examples from recent headlines.

David Shimer discusses his fascinating and timely new book, which includes a sweeping review of covert interference with elections by both Russia and the U.S. over the last century. He discusses what we know about Russian interference in the 2016 election and what we need to know about their much greater capacity to interfere this November.

Pedro Pizano and Jeffrey Smith, with the McCain Institute and Vanguard Africa respectively, discuss the reputation laundering that musicians, actors and athletes facilitate when they agree to perform for dictators and kleptocrats. They also describe how these same artists can use their platforms for good instead and show support for the citizens living under brutal regimes.

Amee Sandhu, founder and CEO of Lex Integra in Toronto, discusses Canada’s history with anti-bribery efforts, some recent developments and where things stand today.

Hilary Mossberg, Director of Illicit Finance Policy at The Sentry, discusses the relatively new trend of African kleptocrats and war criminals laundering money through real estate in African cities, rather than some of the more traditional choices like London, Miami and New York.

A note to our listeners: The audio quality of this recording may be slightly lower than usual, but we hope you'll stay with it for the interesting and important content.

Ian Urbina joins us to talk about his latest project on the lawless seas. Ian has uncovered and documented a stunning story of criminality: illegal shipping, sanctions violations, devastated squid stocks and the 500 “ghost boats” that have washed up on Japanese shores with the crew dead or missing. Visit Outlaw Ocean for more details and to follow Ian’s ongoing reporting.

Sandy Garossino of the National Observer discusses the Canadian government’s latest misstep with the award of a massive pandemic-related contract to an ill-equipped charity with ties to key decision-makers.

Lisa Rice, president and CEO of the National Fair Housing Alliance, provides some historical context for discriminatory housing practices, describes how uneven progress has been and, most importantly, the extraordinary and lasting impact it has. Where we live shapes almost every aspect of our lives: education, wealth accumulation – even life expectancy.

Learn more and watch the Seven Days documentary mentioned in the podcast at nationalfairhousing.org.

Danielle Brian, Executive Director of the Project on Government Oversight—POGO—provides a brief and lively description of the history of U.S. Inspectors General (IGs), their importance in ensuring government accountability and the recent worrying spate of terminations.

Paul Radu, co-founder and executive director of the Organized Crime and Corruption Reporting Project (OCCRP), describes his team’s work in uncovering an international team of cash machine skimmers that ultimately skimmed hundreds of millions of dollars, largely from tourist hot spots.

TRACE’s Director of Compliance Resources, Illya Antonenko, looks back at the CCI case from 2009. Although a relatively small FCPA resolution financially, there are a number of interesting issues, including a corrupt corporate culture and reaching commercial bribery via the Travel Act.

Tess Davis, Executive Director of the Antiquities Coalition, describes how criminals use art and antiquities for corruption, to launder money and to fund terrorism. She also discusses the current legal state of play and how the public can be part of the solution.

Abigail Bellows with the Carnegie Endowment for International Peace describes how a $5 million surcharge could be levied on FCPA enforcement actions and then deployed quickly to support incipient anti-corruption efforts worldwide. This would address, in part, concerns that the victims of corruption rarely benefit from the substantial sums involved in settlements.

Omar Zúñiga of Mexico City’s Creel law firm discusses the tax provisions there that are making companies nervous and prompting a scramble to vet vendors against blacklists.

Mike Ward, partner at Vinson & Elkins in San Francisco and former chief compliance officer with Juniper Networks, discusses the overstated role attributed to business partners as the sole conduit of corruption. Mike also addresses the widely misunderstood role that agents, distributors and channel partners play, and why companies often need to work through these sales and marketing networks to go to market worldwide.

Barnard College professor Alex Cooley and Wiley partner Kevin Muhlendorf discuss telecommunications scandals and the risk of corruption in 5G telecom implementation. They are the authors of chapters on these two subjects in TRACE’s new book, Corrosive: Corruption and its Consequences.

Kara Brockmeyer, a partner in Debevoise & Plimpton’s Washington, D.C. office and former Chief of the SEC’s FCPA Unit, discusses some changes she’s observed in the implementation of compliance programs with much of the world in lockdown. She also describes the pace of investigations now that DOJ and SEC lawyers are working remotely, and she wraps up with a few predictions about what we might see in this field post-pandemic.

Darshak Dholakia, a partner in Dechert’s Washington, D.C. office, provides a timely overview of the current Committee on Foreign Investment in the United States (CFIUS) approach to foreign investment in the U.S., comparable laws of other countries, and how scrutiny of health care and biotechnology sectors may increase in light of the COVID-19 pandemic.

Bill Steinman—of Steinman & Rodgers—takes us back to 2014 and the Eleventh Circuit’s very fact-specific analysis of what constitutes a “foreign official” under the FCPA.

Melissa Duffy, a partner at Dechert LLP focused on international trade matters, provides an excellent review of the current status of the movement of goods into and out of the United States by air, land and sea. Melissa also addresses relevant tariffs, including recent exemptions, and restrictions by other countries on the export of their own critical medical supplies and equipment. Melissa wraps up with some very practical strategies for companies on managing the movement of goods in these uncertain times.

Jeff Clark—a partner with Willkie, Farr & Gallagher—discusses the novel aspects of the 2016 Och-Ziff bribery case, including the claim for restitution under the Mandatory Victims Restitution Act.

Jessica Tillipman of George Washington Law School covers the highlights and key points from the Siemens bribery case of 2008.  It was a startling case at the time and divided the international enforcement landscape into the world before and after Siemens.

 

Former Crown Prosecutor and current investigative journalist, Sandy Garossino, walks us back through the early days of Vancouver’s money-laundering scandal: how the problem was uncovered, the violence associated with infiltration by organized crime, what has been done to remedy the problem to date and what still remains to be done.

Randall Eliason, law professor and former Assistant U.S. Attorney provides an excellent account of the days leading up to the recent sentencing of political operative Roger Stone. The Department of Justice’s unprecedented interference in--and reversal of--its prosecutorial team’s recommendation led to the resignation from the case of all four prosecutors. Over 2000 former DOJ officials have called on Attorney General Barr to resign in the wake of his interference in the case.  

 

Aisling O’Shea of Sullivan & Cromwell describes the Airbus settlement that resulted in penalties totaling almost $4 billion and involved resolutions with U.S., UK and French authorities.

Investigative reporter Scilla Alecci of the ICIJ describes the excellent work that team did, using more than 715,000 leaked documents, to untangle the vast and often opaque business empire of Isabel dos Santos, Africa’s richest woman and daughter of the former president of Angola.

Dr. Frank Badua, Associate Professor of Accounting and Business Law at Lamar University College of Business, describes the misconduct from the 1950s through the 1970s by a group of companies that led to widespread support for passage of the US Foreign Corrupt Practices Act.

Jeff Clark, a partner with Willkie Farr & Gallagher and well-known to TRACE members, provides an excellent summary of U.S. foreign anti-bribery activity in 2019. 

Emmanuel Farhat of the AFA discusses Sapin II and his organization’s role in vetting the implementation of the corporate compliance programs that the law mandates. 

C4ADS Senior Analysts Stella Cooper and Cecile Neumeister discuss their fantastic report on the little known problem of illegal logging in South Sudan and the environmental, social, financial and security implications. The report is available here

With compliance professionals showing increased interest in behavioral ethics and asking not just how employees and others engage in misconduct, but also why, we’re re-posting this podcast with Shaul Shalvi on his research into what motivates criminals.

Bill Steinman, senior partner at boutique compliance firm Steinman & Rodgers, walks us through some continuning trends—and surprises--from 2019.

 

Olivier Catherine, Group General Counsel of Sonepar in Paris, describes in detail the company’s experience as the first to complete an audit by the French Anticorruption Agency (AFA), from the initial letter launching the review through the Sanctions Committee’s dismissal of all claims.

Kevin Chapla, a Civil Affairs Officer with the US Army, discusses the work his team has done with foreign governments and civilian populations to reduce the poaching and trafficking of wildlife in Central Africa.

 

Paul Lavery of McCann FitzGerald in Dublin discusses the conflict between the GDPR’s emphasis on privacy and the requirement under anti-bribery laws that companies undertake reputational due diligence on their business partners. There is a direct and as yet unreconciled conflict between privacy and transparency.

Nicola Bonucci, Director of Legal Affairs at the OECD, describes successes and failures of the anti-bribery convention as well as some of the challenges still ahead.

Priyanka Goswami of Quad Law, TRACE’s partner firm in New Delhi, provides a great overview of the compliance landscape in India, together with a lot of very practical advice for companies operating there.

Sam Eversman with KsaUsaLegal in Riyadh talks about current anti-bribery efforts in Saudi Arabia, recently relaxed restrictions for women travelers and what, if anything, we can take away from the 2017 incarceration of the Saudi elite at the Ritz-Carlton Hotel.

Danielle Cannata, Senior Counsel, International Trade at SABIC, talks about some of the challenges, surprises and successes arising out of doing business in Saudi Arabia.

Jonathan Turner, Vice President, Ethics & Compliance, at Smith & Nephew in Memphis, discusses the admissions scandal that has rattled several top-tier U.S. universities and ties some of the lessons learned back to the work of compliance professionals.

On today’s podcast, we speak with Merritt Smith of TRACE. Merritt has expertise in data science and public policy and the intersection of the two fields. We talk about how AI can support anti-bribery compliance and risk assessments, but also whether the advantages of AI have been overstated and underdelivered.

Peter Humphrey and his wife were well-respected compliance professionals active in China when they were arrested, tried and imprisoned for two years.

 

A 22-year veteran of Treasury and consultant to the Dept. of Justice, John Madinger sheds light on some of the money laundering schemes he has uncovered and why the Breaking Bad car wash scheme probably wouldn’t have worked.

Bob Mackin, a multimedia journalist based in Vancouver, discusses the extradition case involving Meng Wanzhou of Huawei, the proposed new beneficial ownership registry for real estate in British Columbia and the occasionally shady influence of Chinese money in Canada.

Diana Henriques describes Madoff’s Ponzi scheme, discusses how difficult it is to uncover fraud by those who prey on the trust of others and addresses the simple, consistent controls that saved some investors from losses.

A brief and lively description by Pascale Dubois of the work of INT, including investigations, prevention and the group’s work with the private sector.

Alberto Ayala, Executive Director/Air Pollution Control Officer at Sacramento Metropolitan Air Quality Management District, speaks to Vasu Muthyala of Kobre & Kim about the tenacious work Alberto did to get to the bottom of the Volkswagen Emissions scandal and cover-up.

Doyle Hodges, Commander, USN (Ret.), and Stephen Wrage, Professor, U.S. Naval Academy, describe how Leonard Frances of Glenn Defense Marine Asia (“Fat Leonard”) organized and executed a scheme that corrupted at least 30 officers and compromised over 400 others.

Martina Vandenberg, Founder and President of the Human Trafficking Legal Center, describes patterns of trafficked labor in supply chains, recent cases and how her organization is holding traffickers accountable through civil litigation and criminal restitution. HT Legal leverages pro bono support from law firms to gain compensation for survivors.

In this TRACE Compliance Minute, Karen Benson of Royal Caribbean Cruises provides three tips to avoid compliance training fatigue.

Bestselling author Rich Cohen describes the “missing link” between American pirates and gangsters: underworld legend and notorious criminal Albert Hicks. Rich also makes clear how far law enforcement has come since the days of Hicks’ many gruesome crimes.

Pulitzer Prize winning author Jesse Eisinger joins the podcast to talk about his colorfully named and provocative book “The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives.” We chat about political will, revolving doors and what Jesse calls “compliance theater."

Brad Bailey, a criminal defense lawyer and former federal prosecutor, discusses the Insys Therapeutics case and the expanded use of RICO in white collar criminal cases.

Drago Kos, Chair of the OECD Working Group on Bribery, discusses the working group’s successes as well as some challenges. He addresses the current shift away from international cooperation and how a more insular political climate is threatening anti-corruption efforts.

Misti Mukherjee of Extensio Law describes the impact of #MeToo, the seismic shift in our debate and the compliance initiatives and employment best practices that continue to evolve.

Karen Benson, Associate VP and Assistant Chief Compliance Officer with Royal Caribbean Cruises, shares a broad range of tips on how to build a targeted, innovative training program that keeps employees interested and engaged.

Jonathan Drimmer, currently the Chief Compliance Officer of Barrick Gold Corporation, describes practical, effective steps toward building and sustaining a culture of compliance.

In this TRACE Compliance Minute, Jonathan Drimmer of Paul Hastings describes how to create and sustain a culture of compliance.

Thad McBride, an international trade partner with Bass, Berry & Sims, describes corruption and sanctions challenges associated with doing business in Russia and how to enter and exit this challenging market prudently.

Lauren Camilli, VP and Chief Ethics and Compliance Officer at Blumont, talks about some of the challenges that are specific to the global aid and development world, as well as some that are universal.

In this Compliance Minute, Pia Vining of TRACE describes non-negotiable components of any due diligence exercise.

 

In this Compliance Minute, Richard Grime of Gibson Dunn discusses risks associated with the FCPA books and records provision.

In this Compliance Minute, Illya Antonenko of TRACE hits the highlights of the GDPR.

 

In this Compliance Minute, Bill Steinman of Steinman & Rodgers discusses challenges associated with sub-agents and sub-distributors.

 

In this TRACE Compliance Minute, Nathaniel Edmonds of Paul Hastings discusses the biggest mistakes companies make after discovering a bribe has been paid.

 

Richard Grime of Gibson, Dunn & Crutcher, and formerly with the SEC, provides an overview of the internal controls provision, recent enforcement actions and tips on tailoring controls to your risk environment.

A panel of former prosecutors discusses trends and make predictions about FCPA compliance and prosecutions over the next few years.

On today’s podcast, we have what might be Rod Rosenstein’s last speech while in office—given at the TRACE Forum last week—ranging broadly across his career, the work of the Department of Justice and the FCPA.

Nathaniel Edmonds of Paul Hastings describes the key steps to take in the first 48 hours after you learn a bribe may have been paid.

Barbara Tsai, APAC Head--and Deputy Global Head--of Anti-bribery for UBS, talks us through three compliance challenges associated with her region: weddings, funerals and hong bao envelopes for the Lunar New Year.

Stephanie Davis, Chief Ethics & Compliance Officer for Volkswagen Group of America, discusses how to uncover and address conflicts of interest in the workplace.

Jeff Cottle of Norton Rose Fulbright discusses how to secure and maintain board support, what ideal communications patterns look like and when and how to leave if the board refuses to hear bad news. (This episode was originally published in 2019.)

Johan H. Andresen chairs the Council on Ethics for the largest sovereign wealth fund on earth. With over US$1 trillion in assets, Norway’s Government Pension Fund Global holds 1.3% of the world’s stocks, including investments in over 9,000 companies across 70 countries. Andresen explains how the Council works to ensure that this vast array of investments reflects the values of the people of Norway.

On today's podcast, David Montero discusses his new book "Kickback" and tells the story of how Saddam Hussein found collaborators willing to help him thwart the purpose of the Oil-for-food program and prop up his thuggish regime.

Michelle de Kluyver of Addleshaw Goddard provides an overview of Brexit and then drills down on its potential impact on specific compliance issues, including anti-bribery, AML and sanctions.

Pia Vining of TRACE discusses the five most common due diligence challenges her team sees and the growing sophistication of the international community of third party intermediaries.

Kara Brockmeyer, former Chief of the SEC’s FCPA Unit and now with Debevoise & Plimpton, discusses key enforcement actions, the shifting legal landscape and compliance trends from 2018, together with a few predictions for 2019.

Lisa Miller, Integrity Compliance Officer with the World Bank Group, describes the work her team does to help bring small-to-medium sized enterprises back into the fold after sanctions.

Tax evasion, money-laundering and fraud: Jeff Kelly Lowenstein describes his research--and that of colleagues--into the surprising forms of financial crime associated with lotteries. (Their research was supported by the Fund for Investigative Journalism)

Bruce Horowitz of TRACE Partner Firm Paz Horowitz Abogados in Quito talks about current anti-bribery challenges and enforcement trends in Ecuador.

Robert Clark, Manager of Legal Research at TRACE, discusses the challenges associated with measuring something as widespread and varied as corruption and refinements to the 2018 TRACE Bribery Risk Matrix after another year of research.

Speaking at the TRACE European Forum, Michelle de Kluyver of Addleshaw Goddard provides a comprehensive and insightful update on the UKBA and recent enforcement trends in the UK.

Alexander Cooley, political science professor at Columbia University and author of Dictators Without Borders, describes the corruption climate across Central Asia.

Finnish journalist Jessikka Aro has investigated pro-Russia Internet trolls, their disinformation efforts and related financial crimes since 2014.  She has continued in spite of the barrage of death and rape threats designed to silence her.  Now, a recent verdict has brought some relief and vindication with sentences for three of the worst offenders for aggravated defamation and stalking.

In her first podcast, Lisa Osofsky discusses her goals for the Serious Fraud Office and how her professional background will make her a “different kind of Director”.

Judge Mark Wolf of Integrity Initiatives International and Matthew Stephenson of Harvard Law School debate the pros and cons of an International Anti-Corruption Court

Gary Hughes of Ākarana Chambers in Auckland discusses corruption and other financial crimes in New Zealand and whether the country deserves its rankings on the various bribery indices.

Carrie Cohen of Morrison & Foerster explains the regulatory and compliance implications of blockchain-enabled technology, including cryptocurrency.

Nat Edmonds of Paul Hastings describes his work as a prosecutor on the Jack Abramoff corruption cases and then provides broader insight into the compliance risks and schemes he sees worldwide.

Rafael Gomes with Petrobras discusses all that has been going on in Brazil recently on the anticorruption front, the current outlook there and the upcoming run-off election.

Jonathan Walton, Harvard professor and ethicist, discusses prosperity theology and the role it plays in both power and poverty.

Anders Worsøe of the Magnusson firm in Copenhagen discusses Danish attitudes toward corruption and then looks at compliance and enforcement in Denmark

Charles Laubach of Afridi & Angell’s Dubai office discusses the compliance and enforcement landscape there, as well as some common misperceptions and his advice for companies operating in the UAE.

Charles Laubach of Afridi & Angell’s Dubai office discusses the compliance and enforcement landscape there, as well as some common misperceptions and his advice for companies operating in the UAE.

John Langdale, a professor at Macquarie University in Sydney, discusses his research into Chinese criminal gangs, their method of attaching to legitimate business and trade routes, and some implications for Belt and Road projects.

Roomy Khan, “Tipper A” in the Galleon Group insider trading case, discusses the many small decisions that lead to catastrophic consequences in the world of financial crime.

David Mizrachi of Panamanian law firm MDU Legal discusses recent AML enforcement in Panama and living under the cloud of the “Panama Papers”.

Jim Quiggle, of the Coalition Against Insurance Fraud, joins us to discuss the many grisly shapes that insurance fraud takes including, astonishingly, parachute sabotage.

Simona Weinglass, a reporter with the Times of Israel, describes the US$10 billion global binary options scam that she and her colleagues exposed. Far from being a sophisticated scheme, it was simply unchecked fraud on a massive scale.

Lisa Phelan, who until very recently was responsible for criminal enforcement of US antitrust laws and is now a partner with Morrison & Foerster, explains the world of antitrust violations.

Lacie Pierson of the Charleston Gazette-Mail discusses the startling and controversial removal of all sitting justices in West Virginia.

Kelly Carr discusses her research, with Jaimi Dowdell, that uncovered the gaps in US oversight of private planes that make the country more vulnerable to terrorists and drug lords.

Anders Worsøe of the Magnusson firm in Copenhagen discusses Danish attitudes toward corruption and then looks at compliance and enforcement in Denmark.

Peter German, author of the comprehensive German Report, discusses the unique and unsettling “Vancouver Model” of financial crime, which includes both money-laundering and drug trafficking using casinos as the way station.

Tina Søreide discusses her work, through the IBA, to bring consistency and predictability to bribery settlements worldwide.

Dominique Mondoloni with TRACE’s partner firm in France, Willkie Farr & Gallagher, discusses the new Sapin II law and its implications for both compliance and enforcement there.

Neil Walsh, Chief of Cybercrime, AML and Counter-Financing of Terrorism at the UNODC in Vienna, discusses the work that his department does to coordinate and advance international initiatives.

Two-time Pulitzer Prize winner John Carreyrou discusses his excellent book about the Theranos scandal, “Bad Blood”, and how Elizabeth Holmes conned everyone.

James Klotz with TRACE’s partner firm, Miller Thomson, discusses anti-bribery efforts in Canada, the patchy enforcement of the CFPOA and last year’s repeal of the facilitation payment exception.

Valerie Salembier, former publisher of Harper’s Bazaar and founder of The Authentics Foundation, discusses the true cost of counterfeit luxury items:  child labor, trafficked labor and organized crime.

Ken Bensinger discuss his fascinating book, Red Card, and the decades of misconduct by FIFA eventually uncovered by the FBI. We play “violation bingo” as Ken describes the bribery, self-dealing, conflicts of interest and money-laundering that were business as usual at FIFA.

Marike Bakker, with TRACE partner firm NautaDutilh in Amsterdam, discusses recent Dutch anti-bribery enforcement efforts.

Judd Hesselroth and Alexandra debate the merits of the ISO anti-bribery standard and the associated accreditation process.

Illya Antonenko, privacy counsel with TRACE, discusses the direct conflict between the GDPR and robust anti-bribery due diligence and TRACE’s efforts to press for revisions to laws for a carve-out for due diligence.

Christian Schefold, with TRACE partner firm Dentons in Berlin, discusses anti-bribery enforcement and compliance developments in Germany.

James Klotz with TRACE’s partner firm, Miller Thomson, discusses anti-bribery efforts in Canada, the patchy enforcement of the CFPOA and last year’s repeal of the facilitation payment exception.

Senator Russ Feingold discusses McCain-Feingold, Citizens United and the vast, opaque sums involved in US politics today.

Sebastian Abbot, author of “The Away Game;  The Epic Search for Soccer’s Next Superstars,” talks about Qatar and the biggest soccer talent search in history, as well as the darker side of recruiting for the sport.

Amanda DeBusk, sanctions expert with Dechert LLP, provides an update on Iran, China’s ZTE and North Korea.

 

Jim Trusty, previously responsible for the RICO review unit at the US Department of Justice, talks about the US racketeering law and how it has been used against the Mafia, MS13 and, more recently, FIFA.

Carolyn Lindsey and Alexandra discuss a series of “red flags” relating to a problematic fictional agent, Tan, and the relevance of each.

 

Daniel Bühr, with TRACE’s Swiss partner firm LALIVE, discusses recent cases in Switzerland and the country’s uneasy relationship to transparency and financial crime.

Aaron O’Connell, a Marine colonel, author and history professor discusses his research of, and personal experience in, Afghanistan and his excellent book: "Our Latest Longest War: Losing Hearts and Minds In Afghanistan."

Kara Brockmeyer, former Chief of the SEC Enforcement Division’s FCPA Unit, describes the Unit’s role in the joint enforcement of the US anti-bribery law

Gary Kalman of the FACT Coalition argues for transparency in corporate ownership and an end to the use of anonymous shell companies in this timely discussion about offshore accounts.

Michelle de Kluyver of Addleshaw Goddard discusses the UK Bribery Act in a lively, informative interview.

Jeff Clark of Willkie Farr & Gallagher provides comprehensive guidance for planning and executing internal investigations and leveraging resources.

Michela Wrong discusses her excellent book about Kenyan whistleblower John Githongo, the corruption he uncovered and what has--and hasn’t--changed.

 

Alexander Kupatadze discusses corruption and smuggling in his native Georgia and neighboring post-Soviet states.

Anita Raghavan discusses Raj Rajaratnam and her book, “The Billionaire’s Apprentice, The Rise of the Indian-American Elite and Fall of the Galleon Hedge Fund.”

Guillermo Jorge, a partner at Governance Latam in Buenos Aires, discusses the new Argentinian law that creates corporate liability for bribery that came into effect on March 1.

 

Prof. Jason Sharman at King's College, Cambridge, discusses his book about how kleptocrats operate and advocates for a controversial "bounty hunter" model for asset recovery.

Investigative journalist Dorothee Myriam Kellou tells the story of the Lafarge plant in Syria that was ultimately taken over by ISIS.

Michael Johnston talks about the research for his book “Transitions to Good Governance: Creating Virtuous Circles of Anticorruption”.  He provides some cause for optimism as he describes lessons we can learn from modest success stories like Botswana and Georgia. 

Chuck Duross, partner with Morrison Foerster and former head of the DOJ’s FCPA unit, discusses lures, stings, wiretaps and INTERPOL Red Notices.

Norm Eisen, former White House Ethics Czar and then Ambassador to Prague and current Chairman of CREW, talks about his work at the White House and the importance of setting the right tone.  Norm also previews his new book:  “The Last Palace.”

Colonel Bashar Khatib, head of Lebanon’s financial crimes and money-laundering division, discusses his organization and mandate and some successes and ongoing challenges.

Moisés Naím, author, public intellectual at Carnegie Endowment and former Minister of Trade and Industry for Venezuela discusses his book, Illicit:  How Smugglers, Traffickers, and Copycats are Hijacking the Global Economy.

Vasu Muthyala of Kobre & Kim discusses some of the challenges facing companies doing business in India, and some recent improvements there. View the TRACE Bribery Risk Matrix country report for India here.

Roman Borisovich of ClampK discusses going undercover to film his documentary, “From Russia with Cash”, which exposes exploitation of the London real estate market by kleptocrats and money-launderers. He is also the architect of London’s “Kleptocracy Tours”.

Richard Conway of BBC Sports describes the vast state-sponsored Russian doping scandal and how the credibility of global sports is being undermined.

Commissioner Simon Peh of Hong Kong’s Independent Commission Against Corruption discusses its mandate, tools, successes and future challenges.

Wendy Wysong of Clifford Chance describes the aspects of Hong Kong's anti-bribery law and enforcement regime that set it apart from most others.

Jessica Tillipman provides a comprehensive and fast-paced explanation of how the government and others use suspension, debarment and blacklisting for punishment or deterrence.

Daniel Maldonado discusses Mexico’s ramped-up anti-bribery enforcement efforts, where problems still linger and how the WalMart case is perceived there.

Louise Shelley, founder of the Terrorism, Transnational Crime and Corruption Center, discusses her book about the links between the three international scourges.

Grant Wahl of Sports Illustrated discusses power, governance and the upcoming election at US Soccer as Sunil Gulati steps down.

Billy Jacobson describes the key FCPA enforcement actions of 2017, what surprised him last year and his assessment of enforcement under Trump.

Olukayode Dada of Udo Udoma & Belo-Osagie in Lagos discusses the compliance climate and corruption in Nigeria.

International sports expert, Declan Hill, returns to the podcast to discuss the FIFA trial that concluded in late December and the outlook for meaningful reform.

A 22-year veteran of Treasury and consultant to the Dept of Justice, John Madinger sheds light on some of the money-laundering schemes he has uncovered and why the Breaking Bad car wash scheme probably wouldn’t have worked.

Peter Hellman, Wine Spectator regular and author of In Vino Duplicitas, tells the almost unbelievable story of wine fraudster, Rudy Kurniawan.

Bill Browder discusses Canada’s new Justice for Victims of Corrupt Foreign Officials Act and which country he hopes will be the 6th to adopt a similar law.

Nima Elbagir and Raja Razek of CNN go undercover in Libya to expose a hellish, thriving slave trade.

Chaim Gelfand of Israeli law firm Shibolet & Co talks us through the corruption scandals involving two Israeli Prime Ministers and discusses the current compliance environment in Israel.

Randall Eliason discusses the recent Menendez trial, the impact of the Supreme Court’s McDonnell decision and the current state of domestic anti-bribery enforcement in the U.S.

Andrea Lo Gaglio, a Partner at Studio Legale Biamonti in Rome, describes corruption, compliance and the role of the mafia in Italy.

David Green, the Director of the SFO, talks about the SFO’s priorities, changes he has made as Director and what’s next for him.

Our “spotlight” series takes a closer look at one country.  Today, Paul Holden of Corruption Watch talks about Zuma’s corruption scandal, the Gupta family and the nature of commercial bribery in South Africa.

Will Fitzgibbon, an ICIJ reporter on the Paradise Papers team, describes this latest tranche of documents.  He discusses the corrosive nature of offshore accounts, even in those cases where they are technically legal.

Journalist Daphne Caruana Galizia was killed by a car bomb in October 2017 while reporting on corruption in Malta. Roberto Montalto, her lawyer, describes her courage, her work and the loss of a Maltese institution.

Walt Pavlo describes how his organization helps offenders prepare for their incarceration and discusses challenges—and a few surprises--within the prison system.

Bradley Hope of the Wall Street Journal describes his team’s in-depth and ongoing research into Malaysia’s 1MDB scandal--and where Leonardo DiCaprio fits in.

Martina Vandenberg, Founder and President of the Human Trafficking Legal Center, describes patterns of trafficked labor in supply chains, recent cases and how her organization is holding traffickers accountable through civil litigation and criminal restitution. HT Legal leverages pro bono support from law firms to gain compensation for survivors.

Peter Humphrey and his wife were well-respected compliance professionals active in China when they were arrested, tried and imprisoned for two years.

Before becoming chairman of Transparency International, Jose Ugaz was the “ad hoc state attorney” (special prosecutor) who brought down Peruvian President Fujimori and his head of intelligence, Vladimiro Montesinos.

Hui Chen describes her role as the DOJ’s Compliance Consultant, what companies should focus on and why she resigned.

Rob Leventhal of the US State Department discusses the tools available to the US Government to make the lives of kleptocrats more difficult.

Eugene Soltes describes his fascinating research into what motivates white collar criminals and how distance from their victims makes it easier.

Join two legal experts for a conversation about compliance challenges in China.

Declan Hill discusses the pervasive and sinister nature of match-fixing and how we can prevent sport from being turned into theater.

Amanda DeBusk walks us through the goal and nature of US sanctions, and the penalties for getting this important issue wrong.

Bloomberg’s Michael Kavanagh describes his research into the extensive holdings of the Kabila family in the DRC.

Nick McKenzie tells the exciting story of his role in the investigation into Unaoil.

Michelle Gavin, former ambassador to Botswana, discusses corruption on the continent and how the west is perceived.

Shaul Shalvi, a professor of behavioral ethics, describes how people convince themselves that their misconduct is OK.

Adam Davidson of the New Yorker joins the podcast to talk about his research into the baffling Trump Hotel deal in Baku.

Bill Browder discusses Canada’s new Justice for Victims of Corrupt Foreign Officials Act and which country he hopes will be the 6th to adopt a similar law.

Grant Wahl of Sports Illustrated discusses how decades of FIFA corruption and self-dealing have undermined the world's favorite sport. 

Peter Solmssen, former GC of Siemens, tells their story.  “They didn’t need to pay bribes.   We were perplexed.”

Brian Klaas, Associate Professor at University College London and host of the award-winning podcast “Power Corrupts,” joins us to discuss his book “Corruptible: Who Gets Power and How It Changes Us”. Brian describes research on who is drawn to positions of power and how power impacts us, including potentially re-wiring our brains.