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Anthony Lee
Anthony Lee

[S2E3] Beyond Our Control !!LINK!!

While Lexi strives to take control, her sister Cassie spends several hours a day squeezing, stretching and mostuzing her skin, to the point of oil overdose, making sure her hair, makeup and outfit are perfectly composed, all in the hope of securing a single admiring glance from Nate, who refuses to acknowledge her existence while at school.

[S2E3] Beyond Our Control

After being unable to control or ease the splitting headaches, Clark soon found himself losing control entirely. Lashing out at both Jonathan and Jordan, he came dangerously close to injuring his sons as he almost activated his heat vision in a rage.

Season two begins right after the events of the season finale of season one. Pete and Myka find that Artie has survived the explosion thanks to the Phoenix artifact, which was slipped into his pocket by MacPherson during their struggle. Though the Phoenix saves Artie from the explosion, in exchange, it causes Mrs. Frederic's driver to die and then explode, with Mrs. Frederic barely surviving by jumping out of the car before the explosion. While still under MacPherson's control, Leena locates another past Warehouse agent named H.G. Wells. She reverses the bronzing process, freeing her to assist MacPherson in penetrating the Escher Vault inside the Warehouse. Wells eventually turns on MacPherson and kills him after taking an artifact from the Vault. Mrs. Frederic realizes that Leena was the one stealing Artifacts from the Warehouse for MacPherson while under the Pearl of Wisdom's control and helps remove the artifact from Leena's brain. Later, when Artie starts seeing MacPherson over the Warehouse, Leena explains that the visions may indicate that he has some unfinished business with MacPherson. Meanwhile, Leena keeps having vertigo, and it is revealed that her condition is due to residual energy from MacPherson trapped in her brain, which Mrs. Frederic and The Regents removed.

MacPherson frees H.G. Wells (Jaime Murray) and escapes the Warehouse with the aid of Leena (using mind control). The agents track MacPherson and Wells back to the warehouse, where Wells turns on MacPherson.

And I like to say that I'm a practitioner who happens to direct the center and teach a little bit. So, when I come at these topics, I really look at them for a practitioner side and that's one of the main objectives for the Rowling Center generally, but also for me in the way that I structure my classes to teach students. So how did I get here? Well, I'm actually from a ranch out in the west and we didn't have a whole lot of international business going on there, so probably part of it was just my desire to, I loved it there, but it was the desire to explore the world beyond my part of the United States. And so, very early on I decided I wanted to do something global and probably within the law. I studied political science and international relations, and then had a wonderful opportunity kind of at the last minute to study European integration at the University of Limerick in Ireland. And I received a fellowship from the European Commission to do that. And I think that piqued my interest in international affairs generally and gave me some background in international law and business.

Eric Hinton: Well, it was funny you asked that because I remember when I was early in the practice of law, there was an article, that posited the following: it said, did compliance kill ethics? And I think the concern there and maybe this shows that ethics as a discipline and compliance as a discipline were quite different and really hadn't come together yet. But the idea was that by focusing on compliance, which is often the case with lawyers and compliance including trade professionals, you somehow get away from what the ethics of an organization is. And in some ways ethics might be a proxy for culture. But if you only focus on compliance, you might get away from that. I think the opposite could be true too, which would be that if you focus only on ethics, nobody knows what the roles are, nobody knows what the controls are and what things you actually do to comply with the law.

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

Now, the various guidances that I mentioned, in particular, the DOJ guidance have added some additional elements that I would also recommend any organization implement. One is, what is your approach around the use of third parties? So, in the export area, what is it when it comes to your freight forwarders or your customs brokers? What are these other parties that could provide a risk of transshipment to an embargo destination? Or maybe transship some sort of controlled item that shouldn't be exported in the way that it's being exported? So, what's your third-party due diligence and oversight process? Also related in some ways to that would be what is your strategy around mergers and acquisitions? So, when you bring on a target company, if you're the buyer and you're buying assets or certainly entities, that you understand, number one, what it is you're buying, and that's priced into the nature of your deal. But also, that once that entity's been acquired and is being integrated into the compliance system of the company, that you address any challenges or problems that might have arisen or become clear through the due diligence or the acquisition process.

Eric Hinton: Yeah. I talked a lot about the building blocks of an effective program. And when I talk about that what I'm saying is what does the global program look like? But what you need to remember, and this is regardless of the size of your organization, is that while you might have the building blocks in place, you need to have parallel structures or at least a program for every single substantive compliance and legal area that comes within your company. So, trade compliance is an important area and as we know, that can be pretty complex, even in and of itself. That can include products that are controlled by BIS, dual use items. It could cover items that are defense articles. And then you have the sanctions that come into play, right? And all of those are really different and discrete areas, even though we kind of lump them together. And then abstract out onto that international sanctions or international controls, and you have a pretty complex regulatory scheme, and you need to have those structures in place in order to have an effective program. So, for instance, you need to have responsible parties within the organization who understand and have expertise and are overseeing the trade controls program. You need to do training. You have to do a risk assessment. You need to have policies and procedures. At some level, you need to have oversight, fundamentally, by your board of directors to make sure that it is effective.

Derrick Kyle: Yes, for sure. So, this next question, I find to be an interesting one, and this is goes back to what we may be seeing in the news or legal publications. Are you seeing any recent trends in enforcement cases or trade controls or global trade practices that you think companies should particularly be monitoring or be made aware of, if they're not already?

From a global perspective, there are a few things that I think are emerging and I mentioned this recent Monaco memo and as I said, it's new, but it still remains to be seen how that plays out. But there's some important elements that relate to that, a couple things I'll throw out. One was the compensation issue. But there's also some other questions that relate to what extent individuals versus entities are going to be prosecuted and held responsible for compliance failures. I think the trend over time has been to go after more individuals and that certainly could be the case within the international trade sector. And also, certainly it would be the case potentially with sanctions and with export control violations. The other thing that's come out of that memo is, once you settle a case, what does that look like? And to what extent will prior misconduct factor into how the department decides the resolution of your case? And also, whether or not they would appoint a monitor to oversee compliance with any sort of agreements that you would have with the Department of Justice. So I think it's important to remember that, even though trade is a specific regulatory scheme, it ultimately could be subject to enforcement and resolution under the rules that you see that apply through the DOJ. Absolutely. 041b061a72


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