Day: June 13, 2019

Categories
Trekking Through Compliance

Trekking Through Compliance-Episode 12-The Menagerie (Part Two)

In this episode of Trekking Through Compliance, we consider the episode The Menagerie (Part Two) which aired on November 24, 1966, Star Date 3012.4.
Compliance Takeaways:

  1. What happens with your counter party refuses to comply with FCPA requirements?
  2. When the time comes will you as a CCO speak truth to power?
  3. Sometimes failure and being left behind are options.

Resources
Excruciatingly Detailed Plot Summary by Eric W. Weisstein for The Menagerie (Part Two)
MissionLogPodcast.com-The Menagerie (Parts 1 & 2)

Categories
Everything Compliance

Daily Compliance News: June 13, 2019, the 6 months at home edition

In today’s edition of Daily Compliance News:

  • Are high numbers of athletes at a university indicia of bribery? (Washington Post)
  • Tesla shareholders fail to pass corporate governance improvements. (WSJ)
  • Will Switzerland become a global courthouse? (FT)
  • No water time for ex-Stanford sailing coach, at least for 6 months. (Reuters.com)
Categories
Everything Compliance

Episode 48-Trump Administration and Compliance, Half-Year Report, Part 1

Welcome to the only roundtable podcast in compliance. In this episode, we begin a two-part episode where we consider the Trump Administration and Compliance, Part 1. This episode includes Sarah Hadden, Mike Volkov and Matt Kelly. Our next episode will feature Jay Rosen, Jonathan Armstrong and your host, Tom Fox.

  1. Sarah Hadden bemoans the death of privacy and explains how the Number 7 has come to haunt her in the modern world of advertising algorithms. Sarah shouts out to the resistance to the Surveillance State and Surveillance Capitalism.
  2. Matt Kelly considers both where the SEC has been and is headed in its rollback of SEC 404 protections and the SEC changes to its whistleblower provisions under Dodd-Frank. Matt treats us to a double shot of rants today as he cannot control himself on the subject of the Trump Administration calling sub-regulatory guidance from the DOJ worthless “paper” while continuing to issue Guidance such as the 2019 Guidance for Compliance Programs. He also rants about the Dutch Data Protection Authority who violated GDPR in a recent release of data and then failed to timely report said breach (to themselves).
  3. Mike Volkov goes hyperbolic in his discusses of the new OFAC compliance program and the current state of OFAC sanctions. Mike rants about the petty criticism of the DOJ’s Evaluation of Corporate Compliance Programs.

The members of the Everything Compliance are:

The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network.

Categories
Excellence in Training

Envision Your Compliance Training Program

In this episode of Excellence in Training, Shawn Rogers and I consider how you should envision your training.
Shawn begins his journey with the famous book, The Seven Habits of Highly Effective People, where Stephen R. Covey said, “All things are created twice. There’s a mental or first creation, and a physical or second creation to all things. Take the construction of a home, for example. You create it in every detail before you ever hammer the first nail into place. . . Then you reduce it to blueprint and develop construction plans. . . Begin with the end in mind. ”

This principle applies to creating a compliance training program. A common mistake is jumping right to the question if which courses you want and how to deploy them. However, there are several things you need to think about before you start building the program.
Here are the steps we followed at GM as we envisioned what our compliance training should look like:
  1. Decide on the program’s guiding principles
  2. Establish program design objectives
  3. Develop a style guide or set of course standards
  4. Determine the exact risks that will be addressed by the training program
  5. Set up a governance process to ensure stakeholder alignment, approve the program design, approve the budget, and monitor effectiveness.In Covey’s terms, these activities resulted in the blueprint — or the  “first creation” —  of our compliance training program. We did all of these before we selected our vendor and started building our training courses.