Categories
Adventures in Compliance

Adventures in Compliance: The Abbey Grange

Today, I consider The Adventure of the Abbey Grange.

In the story The Adventure of the Abbey Grange, Holmes feels something is just not right about the story told by Lady Mary Brackenstall regarding the death of her step-father Sir Eustace Brackenstall. Holmes’ largest concern turns on the contents of three wine glasses, one of which contains beeswing and the other two do not. It turns out that Sir Eustace was killed by a companion of Lady Mary, which Holmes uncovers. However, Holmes has an adaptability for justice when the situation demands it, stating, “Once or twice in my career I feel that I have done more harm by my discovery of the criminal than ever he had done by his crime.” Satisfied the actions of the criminal and his accomplice (Lady Mary) were both warranted and just; Holmes does not report his findings to the local police. Klinger dryly noted, “his sympathies may have overridden his judgement: Many scholars believe that Holmes lets himself be fooled by a villainess clever than he credited.”
This story provide two key points for any best practices compliance program.

  1. Institutional Fairness through the Fair Process Doctrine, which mandates that the process itself is fair and impartial.
  2. Institutional Justice which means more than simply fair and equitable treatment; it requires employees concerns, once raised, be listened to and addressed, all without the fear of retaliation. Moreover there will be a consistency of both discipline and incentives.
Categories
Daily Compliance News

Daily Compliance News: March 12, 2019-the loonshot edition

MARCH 12, 2019 BY TOM FOX


In today’s edition of Daily Compliance News:

Categories
Innovation in Compliance

Innovation in Compliance: Using AI to Detect Bad Actors with Brandon Carl


Can you pick up misconduct signals from a conversation? Joining us today is Brandon Carl, the Vice President of Product Management at Digital Reasoning. He oversees their product portfolio and brings together research, machine learning, and development for their audio analytics and conduct surveillance, and he’s here to share how artificial intelligence can change the way we do compliance.

Digital Reasoning Solutions
Digital Reasoning got its start working with government institutions on identifying bad actors. When they shifted over into conduct surveillance, it was a very natural foray into looking for misconduct or bad actors within financial markets. The key behind all these regulations is to instill confidence in people participating in markets and make sure that the market is protected and liquid and that they’re getting fair prices.
Finding signals
When you take a look at bad actors in general, you tend to find two buckets of people:
1) Negligent bad actors who don’t have bad intentions, but are probably just unaware of the laws, and 2) Nefarious bad actors who are working to skirt the system and are intentionally engaging in misconduct.
When you take a look at them, you will see signals around how people communicate: someone may ask people to “keep things confidential” after engaging in some form of misconduct; if someone is narcissistic, you may hear them boasting after the fact. So the technology not only looks for the act of misconduct itself, but these behavioral signals as well.
Passing on the information
There are two views of the world that their customers traditionally think of:
First, the Alert-Based View, which you can think of as a single communication travelling through time that the algorithm will scan. Second is the Investigations View, where teams will review and investigate the alerts.
Now you want to amalgamate the various alerts that have happened over time, and think of those as either weak indicators of misconduct (like boasting), or strong indicators of misconduct (that point to a very specific form of activity). The world has evolved, and we’re realizing our communications say a lot about who we are and what we do.
Ongoing Education Credits
If you’re a compliance professional looking for a convenient and effective way to fulfill your continuing education requirements, check out our 4 hour-long training packages that will keep you up to date with the latest developments in the compliance field.
Resources
Brandon Carl (LinkedIn)
Resources for Digital Reasoning
Website
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Financial Conduct Surveillance
AI is Starting to Change Compliance Practices. Here’s how