In this episode, host Cindy Moehring sits down with Global Co-Chair of Investigations and White Collar Defense Practice Charles “Chuck” Duross to discuss his lengthy career in the law deaing with white collar crime, business ethics and compliance. They discuss topics such as fundamental shifts that businesses have taken to recognize the importance of ethics and compliance, how these changes have impacted frontline managers, and common mistakes new managers make that land them in trouble.
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Episode Transcript:
0:00:00.1 Cindy Moehring: We have with us today Chuck Duross, who's a partner at the law firm, Morrison Foerster. And Chuck, we are so excited to have you here, thanks.
0:00:10.0 Charles Duross: Thank you.
0:00:10.8 Cindy Moehring: You bet. You have a very interesting background, and I wanna take just a few minutes to tell the audience about you and some of the work that you've done, and then let you tell us how you landed in that spot. So Chuck, he serves as Morrison Foerster's Global Co-Chair of their investigations and white collar defense practice. He is also the co-leader of the firm's Foreign Corrupt Practices Act, FCPA, for those of you, for shorthand, who don't know that, and global anti-corruption practice. Interestingly, he's been dubbed Mr. FCPA in the Washington Post. So he spends a lot of his time working on corruption matters. He focuses on that, internal corporate investigations, compliance counseling and many other things. He previously served as the Deputy Chief in the Fraud Section of the Criminal Division of the Department of Justice, and that's where he led the Foreign Corrupt Practices Act FCPA unit, and he was also in charge of all of the FCPA investigations, prosecutions and resolutions in the US.
0:01:15.2 Cindy Moehring: He's recognized internationally for a leading role that he played in developing and implementing the government's FCPA enforcement strategy, and he's widely credited with developing the current enforcement regime, where they've come out, the DOJ has, with an updated resource guide now, but you really were the principal of drafting the first one which the second one was based on, so we'll talk a little bit more about that. It's a very, very important resource guide for the industry. And he's also served as the DOJ's principal representative to the Organization for Economic Cooperation and Development, the OECD working group on bribery, for many years and helped develop their good practice guidance on internal controls, ethics, and compliance. Interestingly, you started his career as a litigation associate at an international law firm, and then you joined the US Attorney's office in Southern District of Florida, and there you prosecuted a lot of white collar cases, bank frauds, embezzlements, mail and wire fraud, money laundering, securities fraud and trademark violations. So I have to start by asking you: What haven't you done? [chuckle] You've done a lot.
0:02:34.3 Charles Duross: It's funny, how I got to the current position is in large part just a willingness to follow opportunities. So I always talk to students that I teach about just being open to other options or always having a plan B, because I knew that I wanted to go and be a prosecutor at some point, but I really was sort of open to where that would be and what it would be about and what I would work on, and so I first went to Miami 'cause it seemed like a great opportunity, and it really was a fantastic place to be a prosecutor. It's, as we used to refer to it, a target-rich environment. There was a lot going on in Miami. There's guns and drugs and bank robberies and homicides, and then there are all kinds of white collar cases and fraud. There's bank or mail fraud, wire fraud, and there's all kinds of people involved in Ponzi schemes and Medicare fraud, and the list kinda goes on and on. And so it was a very interesting place to be a prosecutor. I learned a great deal. And then after five years there, I moved up to DC, and I'd never even heard of the FCPA, which is kind of incredible if you think about it now...
0:03:48.3 Cindy Moehring: Yeah, for Mr. FCPA, who had never heard of it when he started. [chuckle]
0:03:52.4 Charles Duross: Right. Humble beginnings, and so I...
0:03:54.7 Cindy Moehring: Everybody has to start somewhere. [chuckle]
0:03:58.3 Charles Duross: Yes, and I had come up to DC from Miami with the idea that I was gonna be doing a public corruption case, and ultimately by the time I got there, the case that I was coming up to work on, for reasons I don't wanna bother people getting into, sort of went away and was gonna be handled by different folks within the department, and I got handed a new case and they said, "Are you interested in handling a case involving a Congressman from New Orleans who had gotten caught with $90,000 in cash in his freezer?" And I was like, "Of course, yes, I'm very interested. It sounds interesting." And what I didn't realize at the time, but found out quickly thereafter, was it was actually both a domestic corruption case and a foreign bribery case, so the cash in the freezer was actually supposed to be delivered by the Congressman to the then Vice President of Nigeria to secure a business deal, and thus became this case that was the first case in history in which... And the only case in history... In which a member of Congress has been charged with an FCPA violation. And so I got on that case and for the next couple of years worked on this both domestic and foreign bribery case. And then ultimately, when I was done with that, I took over the unit and then led it, as you indicated before.
0:05:21.0 Cindy Moehring: Wow, very interesting. So during that time from when you started, and now you've become Mr. FCPA according to the Washington Post, tell us about the changes that you've seen in the environment in corporate America around ethics and compliance, and risk management and governance, 'cause my sense is it's really changed over the years. I'd like your views on that.
0:05:43.7 Charles Duross: I agree with you. And it's interesting, so I had a pretty significant background in investigations and criminal reporting, and I'll be honest, I didn't know that much about compliance when I first got to Washington DC and I moved to the fraud section. In many ways, I was being educated by the companies that were coming in to talk to us about their own compliance programs, and so you learn by osmosis and you start to realize who's got a really good program and who doesn't. And then over time, during that seven years that I was working, doing almost exclusively FCPA cases, I really saw a dramatic change, a fundamental change in both the importance of compliance, the exposure of compliance within organizations, and I think the...
0:06:35.2 Charles Duross: Through the community of compliance professionals, developing in their own way in terms of the expertise and expectations, and really coming into their own. And just to give you some examples. Early days when we were speaking to companies, and when we were speaking to companies, we were talking about things that happened years before. So things that are mid-2000s, we're having conversations with companies about it, and they wouldn't have hotlines, they wouldn't follow up on investigations. I remember there was a letter to a CEO about some very serious allegations of misconduct within the company, and the awkward exchange we had with the company when I was at DOJ when we were asking them, "Well, what happened? What was the outcome? Were the allegation substantiated? What did you do?" And they said, "We need to look into that. We're not sure." Okay. And then once passed by, we kept coming and we're like, "What's going on?" Turns out nothing was ever done, ever, and there's both process issues as well as judgment issues.
0:07:47.0 Charles Duross: They're short of focus and bandwidth, there's experience and expertise. And what I saw was whether it was hot lines or third party due diligence or internal accounting controls or training, all the tone from the top. These things which were previously not a big focus in many companies, some, but not many, really changed dramatically and you suddenly got exposure of compliance issues and the importance of compliance at the board level. The board started to recognize that this was not just something that they had oversight over, but that they needed to actually be educated about, have input into, they started to learn the kinds of information that they should be asking the C-suite for, there were expectations that were starting to be delivered from the top.
0:08:36.4 Charles Duross: And once that happened, you certainly got the most senior managers in the company involved and engaged, and I really saw a dramatic shift in terms of the way that companies were addressing it. And part of that also then what I at least started to see from my vantage point was that there weren't a lot of compliance professionals at that time with that level of experience and expertise, and it started to develop and people started to compare notes and they were benchmarking against each other, and compliance professionals were picking up the phone and calling others at other peer companies or maybe companies in the same geography, and they started to share experiences and the like, and the enforcement started to drive the compliance.
0:09:24.9 Charles Duross: It was interesting when we met with some compliance officers later on as we were working on the FCPA Resource Guide, and I remember we set some series of meetings, and I thought that we were gonna get a lot of criticism from the compliance officers. I thought that they would come in and they'd say, "Oh, you guys are beating us up too much, and you're being unfair, too tough on companies." And I got the opposite reaction which is, keep going. Each case you bring highlights the importance of compliance within our own organization, the individual accountability, because it is a criminal law people went to prison and still do for violating it, gets everybody's attention in a way that other kinds of enforcement don't. And so it highlights and makes relevant for us the compliance programs within our own organizations, and it helps us get resources and exposure, it changes the way we engage with the business, they wanna actually be educated on some of these issues as opposed to seeing us as the department of business avoidance.
0:10:25.4 Charles Duross: And so there were some fundamental shifts. It doesn't mean that it's even throughout industries or across companies. There's still a number of companies and you see big enforcement actions even in the past year. So not every organization is the same, it has embraced it. But I will say that it went from zero to 60 in a very significant way. We can talk a little bit more about it. But I then think the US in particular started to export this approach to compliance, the professionalism of it, the importance of it, the systemic approach to it, to many companies across the world, and this made a profound change, not just in the corporate space, I should think it's made a profound change, and continues to, in communities around the globe. And you see that in Brazil and other places.
0:11:22.7 Cindy Moehring: How do you think the dramatic changes that we've just talked about here have affected maybe the front line business managers?
0:11:32.8 Charles Duross: Well, I think... So the answer is, it depends. And so I think some business managers who've embraced compliance can use it to their advantage. They use it if they have KPIs or other metrics by which they judge their own people that report to them, it can incentivize people to engage in compliance, reward good behavior, potentially discipline bad behavior. It gives people an ability, often, if you're a sales person, also to differentiate your company from others, that you wear the kind of company you wanna work with, we're not gonna be the company's gonna wind up in a newspaper article that's gonna embarrass you or your organization for being a partner with us. And then it can also be used as both a sword and a shield. In terms of a shield, many companies, large multinationals have come to us and told us that they are... Both I was at DOJ and in private practice that they can... They'll wear a company logo-ed shirt when they go to certain government offices, because they have developed a reputation as companies that don't engage in certain misconduct that maybe sought out, and they are able to use it.
0:12:46.5 Charles Duross: I remember where I was at DOJ, a very well-known company. To everybody who's gonna hear this podcast, they will have heard of this company, that they say that they were able to go in and avoid solicitations or bribes, by having a reputation as a company that just simply wouldn't do it, and it protected their employees in many ways by saying, "Look, I can't do it. If I do do it, these guys at the DOJ are gonna put people in prison, and the company will be hurt. Even if I wanted to, I can't." And once they established that reputation, I think it was pretty key.
0:13:24.0 Charles Duross: And so those are among the kinds of things that middle managers I think can do and can embrace. The challenge, at least the way I see it, both when I was at DOJ and since leaving, is that a lot of times people talk about the tone at the top, and how important that is, and I don't disagree with that. The problem I see is oftentimes, who's at the top depends on where you sit, and while many people may think of the CEO as the top, or the board as the top or the C-suite as the top, the truth is, if you happen to work in a particular country, your country manager or the local, the President, or whoever it may be, or your direct boss, that's the tone at the top for the person that's in that position, and so it's not enough to have somebody at headquarters issuing certain messaging. It's gotta be something that's echoed by and amplified by local leaders and middle managers, and that's a critical role, which is why many of the companies that we work with will actually provide messaging that can be used at meetings.
0:14:34.3 Charles Duross: Just like many of the folks in the energy industry, safety is just a key function, and I know that we have meetings, and I've been in them with some of our clients in the energy industry, where we start off the meeting talking about where the exits are and other safety protocols, that people actually have compliance moments that get brought up, and it allows the middle managers to deliver a message so that it's the tone at the top, but from whoever your boss is, and that can have a huge impact. And the flip side, by the way, is equally important or potentially devastating, which is if you have all the right messaging from headquarters, but you have local managers or middle managers who are saying, "They don't really mean that," or "That's not how we do business here," or "They don't understand this region," or this business or this city, or whatever it may mean, and suddenly that messaging that has been worked on and considered in great detail at headquarters is now muddled in a way that really can be debilitating to the effectiveness of a compliance program throughout the organization.
0:15:44.8 Charles Duross: And I think people often think, and this is... And I've met really smart people who think this, and it's just that if they do it, they don't need to be lawyers, they're just wrong... Which is if they think, "Well, as long as I don't do it myself, or if I just get someone else, I just don't ask the questions and I don't get any bad answers, it'll all be okay." And unfortunately, for people who learn the hard way and they go to prison for that, which is actually, no, it does matter that you're involved and you choose to be willfully blind or deliberately ignorant as the law describes. And so middle managers who either get the messaging wrong and/or think that they're not personally involved in some of these things, people unfortunately will find out pretty quickly that it can be pretty bad. So those are the kinds of things that I see in terms of the importance of middle managers.
0:16:35.4 Cindy Moehring: So with that in mind, tell me what are some of the most common mistakes that you think young managers, young business managers make when they get out in the business world that lands them in trouble?
0:16:48.8 Charles Duross: Well, so I think the first thing is that... And I've been through counseling, for about seven years, I've been going to a business school talking to people about what to do and what to think about when you're in these positions, 'cause people graduate from business school and they think "Well, this is fantastic," and they're gonna go have this challenging job, they may travel internationally and do this work, and that's great, and people are excited about it. And then at some point somebody will say, "We need to do X," and it's at that moment that people need to think to themselves about what they're gonna do and what the risks are, because as a prosecutor, I used to stand up in front of a jury, and in white collar cases, I would say, "Life is about choices and living with the consequences," and then I would talk about whatever the conduct was. And so I think the challenge, I think for particularly young business people is they wanna make sure they're pleasing their bosses, they wanna be... They think it's all sort of teamwork, we're all in it together, and I think sometimes that plus the immediacy of the issue, people have a short-term approach to what could be a long-term problem, and those tend to be the moments when younger business folk need to have access to good guidance.
0:18:13.9 Charles Duross: Because I think if someone asks you to smooth over losses, or stuff a channel, or hire a consultant that was recommended by a government official so you'll win some business, or speak to somebody about pricing at another company, these are all the kinds of things that may not sound like a terrible, awful thing to do in just the immediate moment, maybe that's the way business is done in a certain place is the way it's described to you, and the like, but there's gotta be some sort of a spidey sense that goes off. It says, "This doesn't sound exactly right to me." And most good organizations have channels or platforms by which young folk can reach out and get advice from Compliance, from Legal, through a hotline, going to a different manager or supervisor, or going to the supervisor if it's a colleague that's doing something as well because the truth is that the company doesn't want individuals to engage in criminal conduct. You're not actually part of a team. You may think in that moment you are, but you're not, and so when the music stops, you don't wanna be the person who's made some bad choices.
0:19:24.8 Charles Duross: And by the way, typically... I'll just say this... Typically the first thing that people do in any kind of criminal activity, any kind of unethical conduct, is not generally some huge leap over, past some bright line rule. It tends to be incremental. Someone does something once and then they do it again, and then it gets a little bit bigger, and before you know it, now it's a big problem. It tends to be like that, sort of like the water boiling slowly. And so people need to realize, it's that first decision that they need to make, that first dilemma that they need to focus on. And those can be recommendations from a boss or a colleague, someone that you think you trust, but if you think that there's something about it that makes you a little uncomfortable, those are the kinds of mistakes.
0:20:13.3 Charles Duross: And I tell people, you don't need to be a lawyer to think about The Wall Street Journal test, which is if this wound up on the front page of The Wall Street Journal, would this be something you'd be proud about or embarrassed by? Would it hurt the company? Because if the answer is, "Yeah, it might actually embarrass me or hurt the company," then you probably shouldn't be doing it, and you should be speaking to somebody in Legal and Compliance to figure that out. And so these are the kinds of mistakes or errors, trying to please bosses, not thinking long-term. And by the way, just thinking following orders is an excuse, it's not, and it's not a criminal offense either.
0:20:47.7 Cindy Moehring: So we've seen so many changes. What do you think the future holds for the field of ethics and compliance and governance and risk management on the business side? What should business students today be prepared for in the future when they get out?
0:21:06.8 Charles Duross: Well, so I think there's some good things and some challenging things. So on the one hand, I think the goal posts are moving in terms of compliance. What met expectations from the government enforcement agencies before, the SEC, DOJ, etcetera, they are much higher today than they were five years ago, and certainly 10 and 15 years ago. And that means companies are expected to do more, whether it's do more with less, but at least be smarter about it. And so the government definitely has higher expectations in terms of compliance, whether that's effectiveness of training, effectiveness of internal accounting controls, the use of technology, the appropriate resources, whether that's technology or people to achieve an effective compliance program. It's not about just having the programs, it's having it be effective, and I really do think that those goal posts are moving.
0:22:02.3 Charles Duross: And so, for example, I do think that the government expects people to use artificial intelligence and big data to look at and sift through various transactions in an automated fashion, to see whether or not they're red flags. Those are gonna be expectations, not for every company, but certainly for major multinationals, for publicly traded companies, these are the companies that will come under scrutiny and they will be held to account to a pretty high standard. So that's both good and bad, in some ways. I think generally good because it's moving the industry in the right direction. The challenge I think that people are facing, is that matters that would have been resolved through civil or administrative or regulatory action, 10 years ago or 20 years ago certainly, they're investigated criminally now.
0:22:58.5 Charles Duross: And when people think back to some of the biggest white collar enforcement cases in the 1980s, Ivan Boesky or Michael Milken, names that probably don't even make sense to anybody any more, for insider trading and the like. I always refer my students to Wall Street, and the Ivan Boesky example. But those people received like a five year sentence for it, which sounds like maybe a lot. The sentences that people are getting today are 12, 15, 20 years in prison. Obviously, some of those sentences have been trimmed for certain people, but for insider trading in Manhattan, people are getting very serious sentences. The highest sentence in the FCPA context is 15 years. The former CEO of a telecom company in Miami received a 15 year prison sentence. And where I think the problem is with that is that prosecutors, including myself, went after various companies and business executives, and at some point, the line goes from being a prosecutor to being a regulator, and there needs to be decisions made about, "Is this really the appropriate application of criminal enforcement with potential prison attached to it?"
0:24:20.3 Charles Duross: And there's a balancing that has to happen, but I think the risk for business students today is that the '80s seemed quaint back then. DOJ and FBI and the Internal Revenue Service, which by the way, we always use 'cause IRS, they can dig around and they can find all kinds of stuff. People are surprised like postal, we use the postal service. People, for example... When you're doing white collar cases, the FBI is great, but they wanna put the habeus grabus on people. They got guns, they wanna run around. The IRS guys know how to follow the money. They got like the...
0:24:58.8 Cindy Moehring: That's right.
0:25:00.2 Charles Duross: Green visor. They're scarier in some ways than the FBI. So, as a young business person moving off into the world, it's complicated, there's a lot going on, things are international in a way that they used to be, things move at a much quicker pace. Sometimes the train can shift underneath you and so you really need to have your wits about you, because if you are engaged in something that seems like maybe it's bad, but you're not really sure, but your boss told you to do it, it's not gonna get you out of it. And there's a lot of regulators, there are a lot of criminal guys running around, and there can be some very serious consequences for actions that a decade or more ago would not have resulted in a criminal prosecution. And that's why I think the future of compliance is so important, because it helps keep people from getting in trouble, it creates that sort of buffer and if people follow the guidance that the company has in terms of policies, procedures, using hotlines or access to Legal and Compliance, if they have questions, is their best guarantee to avoid finding themselves in front of a jury when someone's talking about choices and consequences.
0:26:12.2 Cindy Moehring: Yeah, so the stakes are just so much higher today.
0:26:16.6 Charles Duross: You just said it in one sentence. [chuckle] It took me five minutes to say. Yes, that's exactly right. The stakes are much higher.
0:26:24.9 Cindy Moehring: But so, but what we haven't talked about is, why do you think we've seen the stakes go up for the same type of offense? Why is that occurring?
0:26:38.2 Charles Duross: It's a good question. I'm not entirely sure. So, I think part of it is that there's been a focus that's been increasing on corporate malfeasance through very big events. So, Enron comes to mind in the early 2000s time frame. You had sort of the 2008 financial crisis. Frankly, in which there was a lot of criticism of DOJ in particular for not putting the heads of banks in prison, the CEOs in prison. All kinds of criticism for that. And frankly, I was at DOJ at the time, not particularly involved in those kinds of matters, but what I think people sometimes push for and clamor for, whether it's on Capitol Hill or on Main Street, is they assume because bad things happen, it must have been criminal. And there's a very important distinction between negligence on the one hand, and intentional misconduct on the other. And one is a civil liability, and the other has criminal liability attached to it. If it's sort of wilful and knowingly intent to defraud, those kinds of things, well that puts it into the criminal bucket, but just being wrong, even sort of being negligently wrong, shouldn't.
0:28:00.0 Charles Duross: But I think that's a difficult component to see. And so, as prosecutors look at, whether it's big banks, or big multinational corporations, or others, there is this external pressure that they see from the public sort of demanding that they go after people. And on the one hand, you do wanna hold people accountable. There is an important deterrent message, but you also need to pull the reins back and make sure that you're doing it for the right reasons and they're pursuing justice. Because sometimes when we used to hire young prosecutors, we would say, "It's easy to always ask for the maximum. It's easy to always sort of throw on all these charges". Sometimes it takes greater discretion, and frankly hutzpah and bravery to say, "You know what, I actually don't think that this is the right case to do that. And here's why." And so there's a tension there, on the one hand trying to do the right thing and be appropriately aggressive to both protect and defend the citizens and the community and the financial network in the US, and on the other hand being so aggressive that you're actually going after individuals for things that maybe you shouldn't be. And there are alternative ways to do it.
0:29:08.1 Charles Duross: And so I think that's a tension. The last thing I'll say is the... What used to sort of happen internationally, in particular, used to stay there. And people didn't know about it, right? So, years ago, kind of what happened in China, stayed in China. Well, that's not true anymore. And with email, and text messages, and WeChat, and all these different Telegram and WhatsApp, there's a lot of communications. And a part of the way if you're a prosecutor, because so much business is international, a lot of times people don't talk on the phone because of time zone differences.
0:29:45.3 Cindy Moehring: Right.
0:29:45.6 Charles Duross: So, they will say things in an email that they otherwise would have said on the phone call or walking down the hallway. And so, the evidence is sort of, you can actually gather it. And so, it's created sort of a very complex environment, but also sometimes it's rich with evidence and leaves some sort of a paper trail that you might not otherwise have had 10 years ago.
0:30:05.2 Cindy Moehring: Very interesting. Yeah, all true. So Chuck, let me ask you, what are three main things that you think universities should be doing to better prepare their students to enter the workforce with this evolving kind of risk profile, with the stakes being raised on compliance matters, and governance, and all of that. What are the three things that we can do to better prepare our students?
0:30:34.8 Charles Duross: Well, first, I think that to the extent that it is not already a part of the curriculum, it has to be. Ethics and integrity is absolutely key to any kind of a curriculum, but it needs to be practical. So when you're providing this advice, you need to be telling students what to expect, what to anticipate, and what to do. People are graduating from business school, they're not graduating from law school. They don't need to know all the detail about the elements of a bank fraud case, or a cartel investigation, or whatever. The importance is, make sure there's the curriculum, make sure that it's part of the curriculum, make sure that you are giving people practical advice about what to think about.
0:31:15.5 Charles Duross: And often what's so key I think about when it comes to compliances, it shouldn't necessarily be all rules-based. It can be about integrity, about messaging, about making sure that you have a true north compass to what you're doing. And giving people sort of the confidence really to be able to raise their hand as you say, and find a partner, or go and talk to somebody and actually push back, because you really need to have that, I think. Is be educated in the process. And then, have the confidence and feel, frankly, feel empowered to say, "You know what, ethics and integrity matter to me. This is a hard one. Reputation I have for it and I care deeply about it. I also care about my liberty, and I'm gonna raise my hand and raise issues if need be."
0:32:03.6 Charles Duross: Those folks are gonna become valuable assets in whatever organization they go and work with. And by the way, ultimately, hopefully lead. And so, I would say educate them right, empower them to make the right decisions. And then, by the way, we as a community, as a country, need to support people when they do come forward. Because honestly, it's not easy. Sometimes if you raise your hand, you may not make yourself popular in the short term, but in the long-term, people actually appreciate that you took the right approach.
0:32:31.8 Cindy Moehring: Yeah, it's not easy. That's true. That's a whole separate podcast. That's a whole different series of podcasts on how do that. [chuckle] So, we'll catch up on all of that. This has been a great conversation. I really wanna thank you for your time and end on some fun questions here. So tell us what you've been reading, watching, or listening to, if you listen to podcasts that have been fun, but also have an ethical dilemma attached to them in some way. So, we'll start with what have you been reading?
0:33:00.8 Charles Duross: Well, so I've been reading a book with my son. So, we read... We try to read a chapter a night called Boys in the Boat, which I don't know if you've read it, but an FBI agent friend of mine recommended it to me. And it's a... I think I I have it, I have it right here.
[chuckle]
0:33:22.3 Charles Duross: Boys in the Boat.
0:33:23.2 Cindy Moehring: Oh, cool.
0:33:24.6 Charles Duross: And it is a wonderful book about a group of people at the University of Washington in the 1930s that were part of a rowing crew. And ultimately ended up going to the Olympics in Germany in the '30s, and how sort of a hard scrabble group of boys kind of pulled together as a team to do something that nobody ever expected them to be able to do. So it's about leadership, and teamwork, and trusting each other. And anyway, it's about all those things, and the ability to dream big and then accomplish it. So it's a wonderful book. So that's what I've been reading. So in terms of podcasts, I think this may be my first podcast. I don't listen to podcasts. So, I'll have to listen to this one, it'll be my first podcast. Yeah.
0:34:21.5 Cindy Moehring: Absolutely.
0:34:21.9 Charles Duross: And then, in terms of what I'm watching... Well, I have just been going through all the Netflix. Perry Mason, I think is actually, I've been watching that just recently, just started, But Netflix, everything from Tiger King to Don't Mess with Cats. I won't get into the full name, but there's... Anyway, there lots of... Anything on Netflix I guess is what I watch.
0:34:47.4 Cindy Moehring: [chuckle] Very good. Alright, Chuck, this has been fabulous. Thank you very, very much for spending this time with us on the podcast. It's been great.
0:34:54.8 Charles Duross: Great. Well, thanks so much.
0:34:56.1 Cindy Moehring: Alright, see ya.
Cindy Moehring is the founder and executive chair of the Business Integrity Leadership Initiative
at the Sam M. Walton College of Business at the University of Arkansas. She recently
retired from Walmart after 20 years, where she served as senior vice president, Global
Chief Ethics Officer, and senior vice president, U.S. Chief Ethics and Compliance
Officer.
