Categories
Great Women in Compliance

Kirsten Liston on Training that Resonates

Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley. In this week’s episode of Great Women in Compliance, Mary Shirley sits down with Kirsten Liston to talk about some of the old school ways of Compliance training and more modern approaches that will help better get your message across. Kirsten’s a pretty darn good authority on effective Compliance training – she’s just released a book on the very subject called “Creating Great Compliance Training in a Digital World”. Some of the highlights include:
Compliance programs used to be evaluated simply by having certain fundamentals in place.  Policies? Check. Training? Check.  Hotline for reporting? Check.   Compliance has now evolved to where regulators are asking questions about whether the aforementioned cornerstones of your compliance program are any good. Are they effective?  Do they help employees do their jobs in a more ethical way? Do employees understand what is required of them?  Do they retain education and messaging?  Are they receiving it often enough?  The considerations nowadays go far beyond the mere existence of controls.
We bust the following myths:
Legalese driven language is the only way to go.  Let’s make materials that appear to have been written by lawyers, for lawyers.  After all, Compliance is a serious topic.
In order to be sufficiently comprehensive and really teach the learner everything they need to know; Compliance training should be at least an hour long to view or read.
Annual training needs to cover every single risk area under the sun, every year, otherwise we’re leaving ourselves open to scrutiny from regulators.
We round out the episode to consider whether being “too nice” is an impediment to successKirsten Liston
Categories
Compliance Into the Weeds

Juniper Networks FCPA Enforcement Action

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recently released FCPA enforcement action by the SEC involving Juniper Networks.
Some of the highlights include:
Ø Who is responsible for the continued violations after initial discovery, the subsidiaries or the parent?
Ø What happens when a grandparent ‘speaks sternly’ to a grandchild?
Ø Why does a decentralized compliance structure allow for internal abuse?
Ø Do your policies and procedures actually support your compliance efforts?
Ø As CCO do you have visibility into where customer discounts are going?
Ø Should lawyers ever review expense reports from foreign business units?
For additional reading see the following:
Tom’s blog post, Juniper Network FCPA Enforcement Action, on the FCPA Compliance & Ethics Blog.
Matt’s blog post, Juniper Networks Hit on FCPA Charge, on Radical Compliance.
Jonathan Marks considers these points as well as the Board of Directors role in his blog post, Slush Funds and the Juniper Networks FCPA Settlement, on his always great Board and Fraud blog.