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Advanced Compliance and Ethics Workshop 2017 San Francisco

Speaker(s): Alan W. Gibson, Andrew McBride, Brian J. Bartow, Dan Seltzer, Darek Kochman, CPA, CFE, David Wong, Erin Schneider, Heather Axe, Jay C. Mumford, Kathleen Collins, Laura Fragomeni, Lewis Zirogiannis, Melissa Allain, Monica Lopez Reinmiller, Pamela R. Davis, Paul E. McGreal, Ravi Inthiran, Sam Pailca, Sean R. Coutain
Recorded on: Nov. 6, 2017
PLI Program #: 186318

Brian J. Bartow is General Counsel and Chief Compliance Officer of the California State Teachers Retirement System (CalSTRS), the largest educator-only pension fund in the world.  As of July 31, 2017, CalSTRS had assets of approximately $213.5 billion and a membership of over 900,000.  As General Counsel, Mr. Bartow is legal counsel to the Teachers’ Retirement Board and heads CalSTRS’ Legal Services Division, as well as its Office of Ethics and Compliance, Information Security Office, Enterprise Information Management Program and Enterprise Compliance Program. Mr. Bartow also serves as CalSTRS’ Chief Compliance Officer.

Mr. Bartow is a member of the California State Bar, the American Bar Association, the National Society of Compliance Professionals and the National Association of Public Pension Attorneys where he chairs the Cyber Security Committee.  Mr. Bartow serves on the Advisory Board for Institutional Investors Forums, is a member of the Society of Corporate Compliance and Ethics and is a Certified Compliance and Ethics Professional (CCEP).  Mr. Bartow has served as an Adjunct Professor for Cyber Security Law at Elon University School of Law.

Mr. Bartow received his Juris Doctorate from Martin Luther King, Jr. Hall School of Law, University of California at Davis and holds a bachelor’s degree in history from the University of California at Riverside and an associate’s degree in nursing from Queensborough Community College, City University of New York. He is a veteran of the United States Army Military Police Corps.

Dan Seltzer is the Senior Director of Anticorruption and Government Compliance at Accenture, where he is responsible for ensuring the company’s compliance in all interactions with the government by its 400,000+ employees working more than 120 countries. Dan oversees a team of more than 40 attorneys working around the globe in developing company policy relating to anticorruption or government compliance, designing and delivering training, conducting legal monitoring, vetting the company’s external contractors and business partners, and serving as the subject matter expert on anticorruption and government compliance for his colleagues in legal, as well as the business.  In 2017, the Association of Corporate Counsel recognized Dan as one of the world’s Top 10 attorneys in their 30s.

Prior to joining Accenture, Dan was Senior Compliance Counsel to Agilent Technologies (formerly Hewlett-Packard); a senior associate in the Los Angeles office of Latham & Watkins, where he specialized in white collar criminal investigations and defense; and a law clerk to a federal judge in Los Angeles. During Dan’s career, he has conducted investigations and spearheaded compliance initiatives on every continent other than Antarctica, and has personally delivered training on compliance issues in more than twenty countries around the world.

Dave Wong is a Vice President at FireEye Mandiant. Mr. Wong manages the FireEye Mandiant cybersecurity consulting practice in North America. In this capacity, he leads a team of cybersecurity experts to help organizations respond to cybersecurity attacks and make them more resilient to future cybersecurity attacks.

Mr. Wong has extensive experience in cybersecurity and investigating cybercrime. Over the past 10 years, he has investigated some of the largest cybersecurity incidents, including ransomware attacks and intellectual property theft from nation states. Dave brings true front-line experience of real world cyberattacks. Through the investigations, Mandiant learns how attackers circumvent security controls. He uses this experience to help guide companies to secure their networks, data, and intellectual property.

Prior to joining FireEye, Mr. Wong was the Chief Operating Officer of the Intrepidus Group, a boutique cybersecurity firm that focused on mobile application and device security. Dave also has experience working in the financial industry at hedge funds and investment firms.

Mr. Wong is a Certified Information Systems Security Professional (CISSP) and holds a degree in Engineering from the Cooper Union for the Advancement of Science and Art.

Heather Axe is Vice President, Associate General Counsel and Deputy Compliance Officer for Korn Ferry, a New York Stock Exchange listed global provider of talent management solutions with locations in over 53 countries. In this role, she is responsible for implementation and management of the company’s global Ethics and Compliance Program. Other areas of focus include corporate governance, corporate responsibility, client and vendor transactions, and litigation management. 

From 2005 to 2015, Heather worked in the corporate headquarters legal group of Occidental Petroleum Corporation, acting most recently as Assistant General Counsel.  At Occidental, Heather focused on global compliance and anti-corruption issues, litigation management, government investigations, and general corporate matters.   

Prior to joining Occidental, Heather was an associate in the Litigation Department of Sidley Austin.

Heather graduated summa cum laude and Phi Beta Kappa from UCLA with a Bachelor of Arts in English. She has a Juris Doctorate from UC Berkeley Law School, where she served as Senior Executive Editor of the California Law Review. 

Jay has an extensive track record of innovation in developing and managing international corporate compliance and ethics programs which encourage ethical conduct as well as technical compliance.  Jay has designed and run a wide variety of compliance domains, including an innovative interactive code of conduct, cyclical ethics and compliance training systems, ethics and compliance risk assessment processes, internal anti-corruption management systems, third party channel partner anticorruption management, the data privacy office, records and information management process oversight, life sciences transparency functions, audit support, and policy oversight management. Jay has also taught Code of Ethics training around the world.

In addition, Jay is a process efficiency expert and software developer.  Jay has written many thousands of lines of code that are used daily in the Bio-Rad Corporate Compliance Department program to support sophisticated compliance data analysis and reporting.

Jay’s programs have received multiple external and internal recognitions of effectiveness. In addition, Jay has been an active contributor to multiple compliance and ethics organizations, including the Ethics and Compliance Officer Association board of directors, the one-time chair of the Bay Area Ethics and Compliance Association, the Conference Board Council on Global Business Conduct, and a speaker at multiple Practicing Law Institute and other compliance training events.

Katy Collins serves as a Chief Compliance and Regulatory Counsel at ServiceLink, a division of Fidelity National Financial, Inc.  As Chief Compliance and Regulatory Counsel, Katy is responsible for managing the compliance program for the ServiceLink businesses.  Her responsibilities include developing, implementing and monitoring compliance initiatives to ensure adherence to regulatory, legal and operational requirements for the title and escrow services, default services, appraisal, flood and subservicing operations.

Katy joined ServiceLink, formerly known as LPS, in January 2013.  Prior to joining, Katy spent three years as the Associate General Counsel for Control Components Inc., a severe service valve manufacturer. While at CCI, Katy was responsible for the successful completion of a three- year Department of Justice ordered monitorship.  Before joining CCI, Katy was with The First American Corporation for 11 years where she held several corporate legal positions including Senior Vice President, Director of Corporate Compliance and Special Counsel.  In this position Katy was responsible to developing and establishing an enterprise compliance program.

Katy received her law degree from Loyola Law School, Los Angeles, CA.

Melissa Allain has advised and represented organizations in governance, risk and compliance as legal counsel, ethics officer, board member and consultant. She is currently an associate general counsel and director of ethics and compliance at Avnet, Inc., a global technology distributor and services provider headquartered in Phoenix, Arizona. There Melissa is responsible for managing and implementing Avnet’s global ethics and compliance program in the Americas and Caribbean, ensuring that the program is both relevant and effective for the region.  She also leads cross-functional endeavors on global compliance initiatives, and advises her internal clients on various supply chain management issues.

Melissa previously served in a variety of legal and compliance leadership roles with non-profit organizations and public companies, including general counsel to King Abdullah Petroleum Studies & Research Center in Riyadh and Lawrence Livermore National Laboratory in California, and chief compliance counsel to Tyco Fire & Security. She conducted environmental due diligence in mergers and acquisitions at AutoNation where she also expanded environmental, health and safety compliance into a comprehensive ethics and compliance program.

Before moving in-house, Melissa engaged in private practice, culminating as a principal at one of the oldest law firms in Los Angeles. She represented clients in a wide variety of environmental, health and safety regulatory proceedings, and resolved toxic torts and natural resources litigation in federal and state courts. She also conducted compliance audits and training to improve workplace safety and environmental protection.

Melissa is a graduate of Loyola Marymount University and Harvard Law School, where she served as managing editor of the Harvard Environmental Law Review and published an article on the environmental implications of synthetic fuels. She shares her family’s enthusiasm for travel and learning about other cultures.

Monica Reinmiller is a legal compliance and risk professional. With fifteen years of professional experience in financial compliance, risk management and corporate ethics and compliance, Ms. Reinmiller has built expertise managing global compliance programs for multinational companies across multiple industry sectors: automotive, telecommunications, chemical, technology and business outsource services. She also provides legal advisement as an in-house attorney.

In house ethics and compliance practice includes:

  • Internal Investigations & Audits
  • Ethical and Legal Compliance Policies & Training
  • Enforcement matters and inquiries
  • Legal Compliance Risk Assessments and Audits
  • Ethical Leadership

Legal advisory services to internal clients focus on:

  • Anti-corruption and FCPA
  • Privileged internal audit engagements
  • OFAC and Export/Trade Compliance
  • Cross Border Enforcement and Criminal Matters
  • Ethics & Compliance Program Standards

She is an active member of the Association of Corporate Counsel Washington Chapter as a Board Director, Treasurer and previous Co-Chair of the Pro Bono Committee. She is a Faculty Board member for the Journal of Business Law and Ethics, Board member of Geek Girl Con in Seattle, and a guest speaker at industry conferences, trade groups, and university program events.

An active pro bono volunteer, Monica supports Wayfind Microenterprise and Non- Profit Legal Clinics, Eastside Legal Assistance Program Wills Clinics, and is a planning committee member of the annual Washington State Bar Association’s Non-Profit Law Institute. She also continues to lead pro bono coordination and fundraising with the Association of Corporate Counsel’s Washington Chapter.

Monica Reinmiller graduated with a J.D. from California Western School of Law, and M.B.A. from Xavier University. She is a licensed attorney in California, a certified compliance and ethics professional, and certified in risk and information systems control.

Pamela R. Davis is a partner in Orrick’s White Collar, Investigations, Securities Litigation & Compliance group.  Pam focuses her practice on defending companies and individuals in government investigations involving white collar and regulatory matters.  She has extensive experience in all facets of the FCPA and global investigations.

Pam has conducted numerous investigations for multinational organizations throughout the world. She is currently leading investigative teams throughout Asia, South America, South Africa and North America that require the use of Orrick's global resources in China, Hong Kong, the United Kingdom and the United States. Pam has been selected two times by the SEC and DOJ as an FCPA Monitor in matters involving a medical device company and a banking technology company.  She recently gained the unique distinction of being selected three times by the U.S. government to serve as an independent FCPA monitor when she was recently selected by the SEC as the Independent Compliance Consultant for a separate medical device company. 

In addition to her investigative practice, Pam conducts global reviews of existing compliance plans, FCPA Policies and Global Codes of Ethics, as well as due diligence associated with M&A work. She assists clients in revising existing FCPA and Global Codes of Ethics to fit today's heightened focus on anticorruption legislation. In addition to her significant work on FCPA related and global investigation matters, she also continues to represent companies and individuals in connection with a variety of other matters, including, health care fraud, antitrust offenses, securities fraud, trade secrets theft allegations, securities and export violations, mail and wire fraud, and environmental cases. Additionally, when a matter cannot, or should not be settled, she has substantial trial and courtroom experience in broad-based U.S. state and federal criminal matters, and related civil litigation, including more than 50 jury and court trials.

Paul E. McGreal is a Professor of Law at the Creighton University School of Law. He came to Creighton in July 2015, as dean of the School of Law, and he served in that position through July 2017. He is Compliance Adviser to the Omaha Business Ethics Alliance, and he teaches a course on leadership and conflict engagement in Creighton’s Master’s program in Negotiation and Conflict Resolution.

Professor McGreal also teaches in the Texas A&M University Executive and Professional MBA Programs.  His courses there have included modules on corporate vicarious liability, domestic and foreign anti-corruption laws (including the Foreign Corrupt Practices Act), corporate compliance and ethics programs, business ethics, and corporate governance.

Professor McGreal was previously dean of the University of Dayton School of Law from 2011 to 2014.  Before that, he was associate dean and professor of law at Southern Illinois University School of Law, where the graduating class voted him the Senior Class Award in 2008, 2009, and 2010.

Prior to joining SIU, Professor McGreal established the Corporate Compliance Center at the South Texas College of Law, where he taught for 10 years.  While at South Texas, he created and taught the first course on corporate compliance and ethics programs offered at a United States law school. 

Professor McGreal is a frequent speaker and commentator on corporate compliance and ethics programs, and he authors an annual survey of legal developments on the subject for The Business Lawyer, published by the Business Law Section of the American Bar Association. He has also published over 40 articles and essays in law journals at schools including University of Notre Dame, Northwestern University, and the University of Pennsylvania.

Before teaching, he worked in the Dallas office of Baker Botts LLP. After graduating from law school, he served as law clerk for Justice Warren Matthews of the Alaska Supreme Court.


Professor McGreal earned an LL.M. from Yale Law School, a J.D. from the Dedman School of Law at Southern Methodist University, and a B.A. in economics from Williams College.

Andrew is an international compliance attorney, admitted to practice law in California, England and Australia. He is also a Certified Compliance & Ethics Professional (CCEP), Certified Information Privacy Professional (CIPP/US) and Certified Fraud Examiner (CFE).

Andrew has over 15 years of compliance experience, both in private practice and in-house. Andrew’s last position was as Associate General Counsel Compliance at BHP Billiton, the world’s largest diversified natural resources company, based in Melbourne. In that role Andrew was responsible for representing BHP Billiton before global regulators, managing internal compliance investigations and a global team of anti-corruption, antitrust and trade attorneys. Andrew’s first role at BHP Billiton, based in the Netherlands and then the UK, was as its senior antitrust lawyer, responsible for the design and implementation of the company’s antitrust compliance program and securing regulatory clearance for M&A involving BHP Billiton.

Prior to BHP Billiton Andrew was senior antitrust counsel at BP, based in London and then Chicago. Prior to BP Andrew spent 7 years as managing counsel at Linklaters, in their EU/Competition team in London and Brussels.

Andrew has recently moved to the US and, pending receipt of his green card, expects to assume a senior in-house compliance position at a US multinational. In the meantime, he is improving his surfing skills in San Diego.

Darek is a Manager in the Lighthouse, KPMG’s Data & Analytics Center of Excellence. Darek works with his clients to create business strategies which leverage data & analytics (D&A) technology to address rapidly changing business models, seize market opportunities, and to run their businesses more effectively. Darek's primary focus is on helping Chief Compliance Officers embed analytics into their compliance & ethics programs. He has served clients in the healthcare, technology, media, and telecommunications industries. Darek is also responsible for developing and managing D&A operations related to KPMG’s global alliance with Microsoft.

Darek has a technical background as a Certified Public Accountant (CPA) and a Certified Fraud Examiner (CFE), which includes experience in controls & compliance evaluation (SOX), compliance risk assessment, financial statement analysis, and technical accounting application. Early in his career, Darek served on active duty as a non-commissioned officer (NCO) in the US Army. He is a leader in the KPMG Veterans Network and is passionate about engaging on, and proactively addressing, military related issues such as veteran employment.

In her current role as Assistant General Counsel and Senior Director of the Office of Legal Compliance, Investigations for Microsoft Corporation, Ms. Pailca manages the global business conduct compliance investigation program. Prior to joining Microsoft in 2007, she served two three-year terms as the Director of the Office of Professional Accountability for the City of Seattle, an appointed role overseeing internal investigations of the Seattle Police Department. Before that, Ms. Pailca was a Senior Deputy Prosecutor in the Office of the King County Prosecuting Attorney leading the Labor and Employment Division, where she advised and defended three branches of county government.

Ms. Pailca has over 20 years of hands-on experience advising, creating and directing internal investigations programs in both large government agencies and a multi-national corporation.

She has written, consulted and lectured extensively on:

•           Internal investigation program design and management

•           Conducting internal and administrative investigations

•           Police accountability program design and function

•           Effective corporate compliance program design and management

•           How to learn from investigations data

•           Feedback loops: Detection + Remediation = Prevention

•           Building a culture of accountability

Ms. Pailca received her law degree from the University of Washington in 1989, cum laude, and a B.A. in Political Science and Public Policy in 1986 from Washington State University, Phi Beta Kappa.

She also serves as Chair, King County Civil Service Commission Board, and Commissioner, Public Safety Civil Service Commission, City of Seattle. Sam is on the Board of Trustees, Seattle Children’s Theatre and is a past Board Member, NACOLE (National Association of Civilian Oversight of Law Enforcement).

Sean Coutain is Deputy Chief Compliance Officer at Snap Inc., the maker of the Snapchat app and Spectacles camera glasses. His role encompasses development and enforcement of policies and processes, training, internal investigations, risk assessments, and compliance related due diligence of counterparties and acquisition targets.

Prior to his in-house roles, Mr. Coutain spent two years as an Assistant Federal Public Defender at the United States District Court for the District of Hawaii and eight years in the white-collar and internal investigation practices of the Proskauer Rose and Skadden Arps law firms. He is an experienced trial attorney, having served as first-chair trial counsel in several criminal jury trials. He earned a B.A. from McGill University in Montreal Canada and a J.D. from Harvard Law School. He is a member of the bars of California, Colorado and Hawaii and resides in Los Angeles with his wife and two children.

Alan Gibson is an Assistance General Counsel in Microsoft’s Office of Legal Compliance.  Currently serving as a thought leader and change agent in applying digital solutions to modernize how companies manage compliance risks and measure program effectiveness (e.g., data analytics, machine learning, artificial intelligence, robotic process automation, and blockchain). Striving to become a "digital compliance officer."  During his 16 years at Microsoft, he has served in a variety of legal, compliance, and business roles including providing legal advice to sales, marketing, and product teams; while also working in business development, product development, and commercial operations teams.  Before joining Microsoft, Alan was an associate at Orrick, Herrington & Sutcliffe where he focused on corporate finance, securities, and M&A.  Before law school, he worked in a variety of sales and marketing roles for public and private companies--including a sales company that he founded before selling it to attend law school.  Alan received his B.A. from Whitman College, and J.D. and M.B.A. from Seattle University.

Laura Fragomeni is the VP US Regulatory Compliance for, where she oversees multiple eCommerce Compliance Program in 13 Subject matters. Prior to this role, Laura was the Vice President General Counsel  for Walmart eCommerce Latin America. She holds a Master degree from Harvard Law School (LL.M) and a postgraduate degree in Corporate and Economics Law at FGV – RJ. She graduated at the Pontificia Universidade Catolica School of Law. She is the author professor at the Media Law course at FGV – RJ. She taught Civil Law and coordinated the Intellectual Property at Fundação Getulio Vargas – RJ. She is the author of several books and legal publications, among them the “International Libel and Privacy” – published by Bloomberg and co-author of Carter – Ruck on Libel and Privacy – Brazil Chapter, 6th edition.

Ravi Inthiran leads the implementation and management of Zenefits’ compliance & ethics program, product (HR saas platform, benefits, payroll and other financial products) compliance, regulatory change management, and internal audit programs. This includes enterprise policy governance, compliance training and communications, investigations, board reporting and enterprise risk management. As Zenefits’ Chief Compliance Officer, Ravi reports to the General Counsel and the Zenefits’ Board of Directors. Prior to Zenefits, Ravi was Senior Director in the Global Compliance & Ethics department at McKesson (a Fortune-8 healthcare company), responsible for a wide swathe of McKesson’s U.S. compliance program, and spent 13 years at Deloitte, working with numerous clients to assess and create compliance programs centered on privacy, data security, and overall control environments.

Erin E. Schneider is the Associate Regional Director for enforcement in the U.S. Securities and Exchange Commission’s San Francisco office.  Ms. Schneider began working in the San Francisco office in 2005 as a staff attorney and became an Assistant Regional Director in 2012.  She served as a member of the Division of Enforcement’s Asset Management Unit since its inception in 2010 until January 2015.  In her role as Associate Regional Director, Ms. Schneider oversees the San Francisco office’s enforcement efforts for northern California and the Pacific Northwest.  Prior to joining the SEC staff, Ms. Schneider worked as a litigation associate in the Washington D.C. and San Francisco offices of Gibson, Dunn & Crutcher LLP, and as an auditor at PricewaterhouseCoopers LLP.  Ms. Schneider earned her bachelor’s degree in business administration from the University of California at Berkeley in 1995, and her law degree cum laude from the University of California’s Hastings College of the Law in 2001.

Lewis is currently the Chief Compliance Officer and Executive Counsel for GE Digital based in San Ramon, CA.  Lewis joined GE in 2012 as Managing Director, Compliance and Supervisory Affairs for GE Energy Financial Services, a GE Capital Business Unit based in Stamford CT.  Prior to joining GE, Lewis spent four years as Associate General Counsel, Global Head of Anti-Corruption and Antitrust at American International Group, Inc. (“AIG”) during the height of the financial crisis and AIG’s government bailout.  Earlier in his career, Lewis was a litigation lawyer at Hughes Hubbard & Reed and Wilson Sonsini in New York.  In private practice, Lewis has appeared in the United States Supreme Court, the United States Court of Appeals for the Second Circuit, the Southern District of New York, the Eastern District of New York, the New York Court of Appeals and various state courts and administrative agencies.  Before private practice, Lewis served as a judicial law clerk to the Honorable Richard M. Berman, United States District Judge for the Southern District of New York.