Dheeraj Thimmaiah is Global Director of Ethics and Compliance, heading Compliance Analytics at AB InBev. He is data-driven and passionate about innovation. Dheeraj is dedicated to spending close time with AB InBev’s users and customers because even if you have the best tools, your organization will not get far without an audience. He joins Vince Walden to share insights about his role and work at AB InBev.
BrewRIGHT is AB InBev’s advanced data analytics program, which has 15 different apps and compliance workflows in 60 different countries. BrewRIGHT continuously monitors compliance (which has been especially useful during the pandemic), assists in managing investigations, and allocates resources effectively.
Dheeraj shares tips on how to get started on the analytics journey for compliance: ask yourself how you can control the uncertainties, identify the problems, and find a way to use technology as an enabler in building impact.
Resources
Dheeraj Thimmaiah on LinkedIn
AB-InBev.com
Podcast
In this episode, Vince Walden goes one-on-one with Sergio Moro, former Minister of Justice of Brazil and Managing Director of Disputes & Investigations at Alvarez & Marsal. With over two decades of legal and investigative experience, Sergio specializes in leading high-profile and complex anti-corruption, white-collar crime, money laundering, and organized crime investigations. They talk about his fascinating career journey from a federal judge to Minister of Justice, as well as some of the landmark cases he presided over, such as Operation Car Wash, which greatly impacted the corporate culture of Brazil. This was not the case only five or six years ago.
The normal behavior of corporate culture in the past was to deny everything and refuse to cooperate whenever issues arose, but various operations led by Sergio caused Brazilian companies to drastically change the way they did compliance. Many compliance systems were previously used by third parties to channel bribes to public officials. It’s not enough just to have policies and procedures written down; they must be implemented and operationalized.
Resources
Sergio Moro on LinkedIn
Ernest Brod is Managing Director with Disputes and Investigations services and head of the Global Investigations and Intelligence practice at Alvarez & Marsal. For 30 years, Ernest has worked with top law firms, corporations, and financial institutions to reduce clients’ risk of fraud, corruption, Foreign Corrupt Practices Act issues, and anti-money laundering and terrorism concerns. He joins Vince Walden to discuss new technologies that are redefining how due diligence is done.
The traditional practices of third-party due diligence involve public record searches supplemented by dumpster diving and surveillance. However, advancements in technology have allowed Alvarez and Marsal to do deeper, more advanced and efficient due diligence. Alvarez and Marsal provide intelligence services such as web, bank, contact, and location intelligence which have incredibly dynamic applications and reduce the risk of fraud and corruption.
Some of the providers of these types of intelligence are shady and often push the envelope where legality is concerned. Acquiring these services through recognized firms like Alvarez & Marsal is the safest way to conduct the advanced due diligence that they provide as their practices are filtered through ethical concerns.
Resources
Ernest Brod on LinkedIn | Twitter
AlvarezandMarsal.com
Shub Nandi is the co-founder and CEO of PiChain Innovations Pvt Limited, a RegTech company that researches and develops DeepTech systems to proactively learn, solve, and automate complex problems. Shub joins Vince Walden to discuss PiChain’s use of AI and blockchain to help with the automation of customer onboarding.
Roughly 1 trillion USD is laundered yearly in the US, yet only 1% of those illicit transactions are uncovered, Shub cites. This occurs despite the existence of regulations and compliance, suggesting that the implementation of these measures is lacking. Shub comments that many financial institutions view compliance as a “black box that is yet to be solved.”
PiChain is bridging the gap between the unbanked population and financial institutions via easy, simple, and convenient interfaces that are easily accessible through smartphones. Onboarding the 400+ personas in this population requires enhanced KYC and advanced programming like artificial intelligence to create ideal financial products for their needs. In addition, PiChain uses blockchain in conjunction with AI technology to ensure that their processes are compliant, and their models are fair and explainable.
Shub advises financial service companies to focus on understanding their customers rather than just their financial details.
Resources
Shub Nandi on LinkedIn
PiChainLabs.com
Sam Eastwood is a litigation partner at Mayer Brown’s Litigation Practice in London and a member of the firm’s White Collar Defense & Compliance practice. He joins Vince Walden on this week’s episode to discuss the risks and trends related to global compliance and data analytics.
Sam expresses that companies need to disclose more about their compliance programs operations. Transparency into the data analytics itself is a good way to conduct audits, he adds. Data protection and the way data is collected, processed, and transferred is getting more challenging. As such, Sam stresses that the fraud detection process is in need of an upgrade.
Corruption is a human rights issue. It is important for clients within the compliance field to have an effective human rights compliance program. As things progress, Sam states that human rights due diligence laws are soon to be passed. When these laws are eventually introduced, companies will be expected to conduct human rights due diligence on the impact of their business activities. Monitoring legislative developments and carrying out human rights assessments are two of the ways Sam says that companies can do this.
Resources
Sam Eastwood | LinkedIn
Andrew Levine is a partner at Debevoise & Plimpton LLP, who specializes in white-collar regulatory defense and internal investigations. He joins Vince Walden to discuss the compliance journey, what initiatives compliance professionals should take in 2021, and the recently updated DOJ compliance guidance.
The DOJ guidance that came out in June 2020 is a step in the right direction in terms of understanding how prosecutors incorporate compliance programs into their decision-making, Andrew says. It offers real, actionable advice for building a framework for analyzing a compliance program. The guidance is centered around three critical questions: Is the program well designed? Is it adequately resourced and empowered to function effectively? And, does it work in practice?
As prosecutors’ expectations for what makes up an effective compliance program continue to rise, leaders should think about enhancement opportunities. “Don’t let the perfect be the enemy of the good,” Andrew counsels. “Develop a reasonable plan, think about resourcing for implementation, think about a timetable that works, and then execute while understanding that the compliance journey is a never-ending one.”
Resources
Andrew Levine on LinkedIn
In this episode, Vincent Walden welcomes back Jason Lee, CEO of DailyPay to the Pond to discuss the earned-wage access business model and how major employers like Kroger, Target, Dollar Tree, and many others are rethinking how employees get paid in an efficient, compliant manner.
Covid has changed how we think about work and the people who do it, and Jason Lee believes that this new understanding of our reliance on the hourly workforce is going to create the impetus to serve and honor them more effectively. One of the ways this is going to be happening is through the earned-wage access. Rolling this out is a meaningful and valuable benefit for employees, but there are compliance issues that companies need to be aware of.
Jason says that it is incumbent upon employers to make sure that they are in compliance on three key issues: when taxes are owed and paid, wage and hour compliance and payroll deductions, and the issue of whether earned-wage access is being treated like a loan.
Resources:
Jason Lee at DailyPay / LinkedIn
Aaron Nicodemus is a staff writer and reporter at Compliance Week. He joins Vince Walden to discuss the recent report authored by COSO and to share new recommendations for managers and executives to manage compliance risks.
Internal audit professionals would be the compliance professionals most familiar with COSO, as they set the guidelines for Sarbanes-Oxley internal controls compliance. The report, titled “Compliance Risk Management: Applying the COSO ERM Framework,” was like a collaboration between accountants and attorneys, according to Vince.
Compliance should not be viewed as a low-level function, Aaron remarks. Rather, it should be viewed as a strategic partnership with a business to run their operations and initiatives according to the rulebook, in order to avoid missteps and minimize risk.
Resources
Aaron Nicodemus on LinkedIn | Twitter
ComplianceWeek.com
COSO report: Elevating compliance leads to more informed decision-making
Jennifer Saperstein is an Anti-Corruption and White Collar Partner and the Vice Chair of the Anti-Corruption Practice Group at Covington and Burling LLP. She joins Vince Walden to discuss why companies need to be smart about resourcing, compliance technology trends, and the compliance industry post-COVID.
Having a risk-based documented plan for effective compliance programs before consulting any external advisory service is beneficial for companies. Being able to demonstrate where they have focused their limited resources is always helpful. It is now even more important for companies to make smart, risk-based decisions about where to spend their time due to the current pandemic.
A recent survey of over 30 companies revealed that in the last 10 years, there has been a significant transformation in compliance technology trends. Almost 70% of respondents say they use technology for third-party due diligence and 100% saying they use an LMS system to train employees. However, many companies still rely on manual processes for certain parts of their compliance programs.
Resources
Jennifer Saperstein on LinkedIn
Cov.com
Steve Spiegelhalter is the North American Investigations Practice Leader and Managing Director at Alvarez & Marsal. As a former federal prosecutor with the US Department of Justice’s Criminal Division, Fraud Section, and the Foreign Corrupt Practices Act (FCPA) Unit, Steve has intimate experience in investigating complex criminal and civil affairs and implementing compliance programs. He joins Vince Walden to discuss the future of conducting internal investigations.
Steve talks about the improvements GCs and CCOs have made in internal investigations over the last five years. They have evolved their in-house skills and resources. Additionally, they have gotten better at interacting with external counsel to solve matters more efficiently.
COVID-19 has highlighted that foreign corrupt practices and corruption are long-term risks that are becoming more prominent. There has been a rise in fraud issues since the workplace has shifted to remote. Behaviors of malpractice that would have gone unnoticed are now being laid bare.
Resources
Steve Spiegelhalter on LinkedIn
AlvarezandMarsal.com
