All Things Investigations

Tom Fox
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Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations practice group’s podcast All Things Investigations. Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group represents many of the premier companies around the world, providing advice on issues spanning the full anti-corruption and compliance spectrum. In this podcast host Tom Fox and members of the Hughes Hubbard Anti-Corruption & Internal Investigations practice group will highlight some of the key legal issues involved in white collar and other investigations, both domestically and internationally. We will tackle topical issues involved in investigations as well as explore how companies can help prevent and detect issues that arise in conducting business on a worldwide basis.

  1. ATI In-House Insights: Cultivating a Speak Up Culture: Whistleblower Management Insights with Maria Buccieri and Ashley Smith

    6D AGO

    ATI In-House Insights: Cultivating a Speak Up Culture: Whistleblower Management Insights with Maria Buccieri and Ashley Smith

    Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. This is a special series featuring sights from in-house practitioners, hosted by Mike DeBernardis. In this podcast, Mike visits with Maria Buccieri and Ashley Smith, Deputy General Counsel at Amtrak, about Encouraging and Managing Whistleblowers. Ashley and Maria, both compliance and legal leaders from Amtrak, discuss how to encourage and manage whistleblowers as a core element of an effective compliance program, emphasizing that a lack of reports does not indicate a healthy organization. They describe a “speak-up” culture as one where employees feel heard, senior leaders model speaking up, and reporting is accessible across a diverse workforce through multiple channels (phone, email, QR codes, mobile tools, in-person availability) and languages. Key barriers include fear of retaliation (often through subtle workplace ostracism), disappointment when nothing happens, and loss of anonymity. They outline best practices for handling reports consistently with other serious complaints, preserving confidentiality “as much as possible,” training mid-level managers and investigators, and maintaining communication with reporters during lengthy investigations. They also caution against dismissing “serial reporters,” recommending contextual analysis and internal process checks. Key highlights: Healthy Speak Up Culture Why Employees Stay Silent Handling Reports Fairly Protecting Confidentiality Keeping Reporters Updated Serial Reporters and Sparse Tips Resources: Hughes Hubbard & Reed Website Mike DeBernardis Maria Buccieri on LinkedIn Ashley Smith on LinkedIn

    34 min
  2. ATI In-House Insights: Navigating Internal Investigations: A Conversation with Mike Gill

    APR 2

    ATI In-House Insights: Navigating Internal Investigations: A Conversation with Mike Gill

    Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. This is a special series featuring sights from in-house practitioners, hosted by Mike DeBernardis. In this podcast, Mike D visits with Mike Gill, Assistant GC and Director of Investigations at HII, on conducting internal investigations from an in-house perspective in a defense shipbuilding environment. Gill says the first concern when allegations arise is immediate safety risk to employees and the integrity of work affecting Navy and other military customers, followed by designing an investigation that will be viewed as timely, accurate, and credible. He emphasizes scoping, planning, selecting the right team (including technical experts and, sometimes, outside counsel), and establishing disciplined communication and reporting lines to management and customers while protecting privilege. Gill highlights building employee trust through fair processes, enforcement of anti-retaliation policies, and appropriate follow-up, and notes common mistakes: jumping to conclusions, failing to bound scope, and inadequate planning. Key highlights: Safety First Priorities Architecting the Investigation Scope Planning and Team Protecting Privilege Culture and Fairness Anti-Retaliation Trust Top Mistakes to Avoid Resources: Hughes Hubbard & Reed website Mike DeBernardis Mike Gill on LinkedIn

    33 min
  3. ATI In-House Insights: Challenges and Tips for Navigating a Changing Risk Landscape with Sarah Iles

    MAR 18

    ATI In-House Insights: Challenges and Tips for Navigating a Changing Risk Landscape with Sarah Iles

    In this episode of the ATI: InHouse Insights Podcast, Mike DeBernardis speaks with seasoned in-house compliance leader Sarah Isles about navigating an ever-changing risk landscape shaped by political, geopolitical, regulatory, and technological shifts.  Sarah shares her background across manufacturing sectors and discusses how multinational compliance risks evolve as jurisdictional priorities shift, including sanctions, export controls, tariffs, sustainability, labor rights, data protection, and AI. They identify internal challenges, including a lack of infrastructure to address new risks, siloed ownership, and weak change management, and emphasize clear governance and accountability. Sarah advises “back to basics,” using DOJ’s Evaluation of Corporate Compliance Programs, focusing on real risk mitigation over form-heavy questionnaires, keeping communication channels open through formal committees and informal connections, scaling risk assessments appropriately, targeting communications to relevant audiences, escalating thoughtfully, and building resilient programs by expecting and embracing constant change. Key highlights: Geopolitics Drives Risk Internal Adaptation Hurdles Silos and Ownership Culture and Change Proactive Compliance Basics Partnering With Business Right-Sized Risk Assessments Communicating Emerging Risks Resources: Sarah Iles LinkedIn Mike DeBernardis LinkedIn ATI: In-House Insights Podcast Hughes Hubbard & Reed Website

    27 min
  4. Navigating Compliance Challenges in Venezuela’s Energy Sector

    JAN 12

    Navigating Compliance Challenges in Venezuela’s Energy Sector

    Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Mike DeBernardis to discuss the implications of entering Venezuela for energy companies and the historical precedents. They explore the return of US energy companies to the Venezuelan market and historical precedents, such as the Iraq Oil-for-Food Program, post-2003 Iraq, and the 1990s Russian market opening, to identify the risks and the necessary compliance measures. Key insights include the importance of stringent third-party controls, understanding the nuances of dealing with state-owned entities such as PdVSA, and having a robust risk management strategy. The conversation underscores the critical need for compliance professionals to thoroughly understand business operations to build effective compliance programs in high-risk environments. Key highlights: Challenges and Opportunities in Venezuela Historical Parallels: Iraq Oil for Food Program Lessons from Post-2003 Iraq Comparing Venezuela to 1990s Russia Counseling Clients on High-Risk Opportunities Resources: Hughes Hubbard & Reed website Mike DeBernardis

    21 min
  5. Building and Benefiting from a Culture of Compliance

    10/27/2025

    Building and Benefiting from a Culture of Compliance

    Welcome to the inaugural episode of the newly rebranded ATI Podcast: Inhouse Insights—formerly known as All Things Investigations. Presented by the Hughes Hubbard & Reed LLP Anti-Corruption & Internal Investigations Practice Group, this premiere episode sets the tone for a bold new chapter—bringing practical, in-house perspectives to today’s most pressing compliance challenges. Host Michael DeBernardis welcomes Darryl Cyphers Jr., Senior Director of Legal Compliance at Klaviyo, for a candid and forward-looking conversation on how organizations can build—and sustain—a culture of compliance that actually works. Together, they explore how compliance leaders can move beyond policies on paper to create real organizational impact—through measurable culture metrics, smarter use of AI to drive policy engagement, authentic tone at the top, and meaningful collaboration with HR and business partners. Darryl also shares practical guidance for navigating compliance gray areas and strengthening trust through continuous employee engagement and feedback. Highlights include: Defining a modern culture of compliance Metrics and tools for measuring cultural effectiveness Employee engagement and feedback that drive results Building partnerships across HR and business teams Innovative and engaging compliance training approaches Navigating gray areas with confidence and credibility Resources: Hughes Hubbard & Reed Website Klaviyo Darryl Cyphers Jr. on LinkedIn

    29 min
  6. Sean Reilly on Tariffs

    09/29/2025

    Sean Reilly on Tariffs

    Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast All Things Investigation. In this podcast, host Tom Fox welcomes back Sean Riley to discuss the complexities of tariffs under the current administration.   Their conversation highlights the dynamic nature of tariff regimes, the importance of maintaining compliance, and the risks of tariff evasion. Sean provides insights into creating effective tariff compliance programs, the potential for False Claims Act liabilities, and the critical role of commercial sense in assessing tariff changes. The episode also touches on enforcement priorities and the strategic importance for boards of directors to remain vigilant about tariff-related risks. As the discussion moves towards the evolving landscape leading into 2026, Sean emphasizes the importance of staying informed and prepared for ongoing tariff regulations.  Highlights Include  ·      Compliance and Enforcement in Tariff Management ·      Commercial Sense in Tariff Decisions ·      Board Oversight and Tariff Compliance ·      Future of Tariffs and Compliance Going Forward  Resources: Hughes Hubbard & Reed website  Sean Reilly

    23 min
  7. FinCEN’s Recent Actions: Existential Threat for Financial Institutions in Mexico

    09/11/2025

    FinCEN’s Recent Actions: Existential Threat for Financial Institutions in Mexico

    Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Jeremy Paner and Diego Durán de la Vega to discuss recent FinCEN enforcement actions targeting three Mexican financial institutions. The conversation explores the implications of these actions under the Fend Off Fentanyl Act, the evolving regulatory landscape, and the existential risks facing financial institutions operating in Mexico. The guests provide practical compliance guidance, lessons learned, and a forward-looking perspective on U.S. enforcement trends. Highlights include: Why These Enforcement Actions Matter The Fend Off Fentanyl Act: A New Legal Tool U.S. Government Focus on Mexico Lessons from OFAC Enforcement Compliance Implications for Financial Institutions Responding to Enforcement: Practical Steps Global Jurisdiction and the U.S. Financial System Key Lessons for Compliance Officers Looking Ahead: Future Enforcement Trends Key Takeaways for Compliance Professionals: The Fend Off Fentanyl Act introduces new, immediate risks for financial institutions, especially those with ties to Mexico. U.S. enforcement actions can have global reach, severing access to the U.S. financial system. Compliance programs must be robust, proactive, and responsive to regulatory advisories and negative media. Effective communication between compliance and legal functions is crucial for mitigating risk. Resources: Hughes Hubbard & Reed website Jeremy Paner Diego Durán de la Vega

    31 min
  8. DOJ’s Evolving Guidelines: Implications from Liberty Mutual’s FCPA Case

    08/25/2025

    DOJ’s Evolving Guidelines: Implications from Liberty Mutual’s FCPA Case

    Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Mike DeBernardis to discuss the recently released first Foreign Corrupt Practices Act (FCPA) enforcement action, a Declination involving Liberty Mutual Insurance Company. Mike DeBernardis, partner at Hughes Hubbard & Reed, and Tom delve into the first FCPA enforcement action of 2025 involving Liberty Mutual. They discuss the nuances of self-disclosure during ongoing investigations, the challenges facing defense attorneys, and the expectations set by the new corporate enforcement policy. Key topics include proactive cooperation, dealing with deconfliction, and the importance of root cause analysis. The conversation provides valuable insights into how the Department of Justice communicates its expectations through enforcement actions and the evolving landscape of corporate compliance. Key highlights: Exploring the Liberty Mutual Case Challenges of Early Self-Disclosure Corporate Enforcement Policy Changes Full and Proactive Cooperation De-confliction in DOJ Investigations Root Cause Analysis Importance Social Media and Ephemeral Messaging  Resources: Hughes Hubbard & Reed website Mike DeBernardis

    24 min
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Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations practice group’s podcast All Things Investigations. Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group represents many of the premier companies around the world, providing advice on issues spanning the full anti-corruption and compliance spectrum. In this podcast host Tom Fox and members of the Hughes Hubbard Anti-Corruption & Internal Investigations practice group will highlight some of the key legal issues involved in white collar and other investigations, both domestically and internationally. We will tackle topical issues involved in investigations as well as explore how companies can help prevent and detect issues that arise in conducting business on a worldwide basis.

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