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31 Days to More Effective Compliance Programs

Strategies For and With AI in Compliance


Today, I want to consider the article Strategy For and With AI by David Kiron and Michael Schrage. The authors premise is, “A company’s strategy is defined by its key performance indicators. Artificial intelligence can help determine which outcomes to measure, how to measure them, and how to prioritize them.”
Their article had several insights for the Chief Compliance Officer (CCO) or compliance practitioner who is looking to employ Artificial intelligence (AI) to help move their compliance program up a level. One of the first key insights is that it is not enough to simply have a strategy for AI. The authors stated, “Creating strategy with AI matters as much — or even more — in terms of exploring and exploiting strategic opportunity. This distinction is not semantic gamesmanship; it’s at the core of how algorithmic innovation truly works in organizations. Real-world success requires making these strategies both complementary and interdependent. Strategies for novel capabilities demand different managerial skills and emphases than strategies with them.”
This makes clear that AI does not supplant the compliance function or the compliance professional, AI complements what the compliance professional can do with the information available to them. Yet the authors believe that when it comes to machine learning, an appropriate compliance strategy is defined by the key performance indicators (KPIs) leaders choose to optimize. This means that a CCO who cannot clearly identify and justify their strategic KPI portfolios has no strategy.
The bottom line? AI plays a critical role in determining what and how compliance KPIs are measured and how best to optimize them. Optimizing carefully selected compliance KPIs becomes AI’s strategic purpose in the compliance function. Understanding the value of optimization is key to aligning and integrating strategies forand with AI and machine learning. KPIs create accountability for optimizing strategic aspirations, including compliance.
Three key takeaways:

  1. Use KPIs to define and measure your innovation strategy.
  2. AI should only supplement, not supplant a compliance professional.
  3. What are your compliance KPIs?

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit this month’s sponsor Affiliated Monitors at www.affiliatedmonitors.com.

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This Week in FCPA

Episode 195 – the Where are you going for Spring Break edition


With travel bans coming to the fore, Jay worries about Spring Break while Tom heads to DisneyWorld. They take a break to consider some of the top compliance articles and stories which caught their eye this week.

  1. The Cardinal Health FCPA enforcement action. Harry Cassin breaks the story on the FCPA Blog. Tom looks at business relationships in the FCPA Compliance and Ethics Blog. Matt Kelly considers management’s role in Radical Compliance. Mike Volkov considers on Corruption Crime and Compliance. Jaclyn Jaeger considers on Compliance Week. (sub req’d)
  2. Is your compliance program effective? Mike Volkov explores on Corruption Crime and Compliance.
  3. The Astros sign stealing scandal and breach of fiduciary duty. Mike Peregrine in the Harvard Law School Forum on Corporate Governance.
  4. CRO fined $450,000 individually for failures in compilance. Kristin Broughton in the WSJ Risk and Compliance Journal.
  5. Does conflict rob you of success? Linda Henman in CCI.
  6. Wow moments in compliance, Part 3. Geert Vermeulen continues his 5-part series in Risk and Compliance Platform Europe.
  7. Are you under pressure as a compliance professional. We suggest you read Julie DiMauro in the FCPA Blog (and then listen to both David Bowie and Queen)
  8. How can you manage digital disruption? Jim DeLoach considers in Part 1 of a two-part series on CCI.
  9. On the Compliance Podcast Network, Tom opens a new month by looking at the role of innovation in compliance on 31 Days to a More Effective Compliance Program.This week saw the following offerings: Monday-What is Innovation in Compliance; Tuesday-Welcome to ComTech; Wednesday-skills needed for innovation; Thursday-the advantage of data in compliance; Friday-strategies for and with AI in compliance. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. This month’s sponsor is Affiliated Monitors, Inc.
  10. Join Tom in Houston on March 10 as Convercent is hosting a Roundtable, from 12-2 at Steak 48. Our featured speaker will be Philip Winterburn and featured guest is Terri Springer from HP. We will focus on key KPIs for compliance. Information and Registration here.
  11. Join Tom in NYC on Thursday, March 12 as Convercent is hosting an Innovation Forum from 3:30-7 PM at Santina. This event will allow you to network with like-minded individuals within the ethics and compliance space and hear from Thomas Fox and Philip Winterburn as well. For more information and registration click here.
  12. If not Houston or NYC, how about joining Tom in Philly? Join Baker Tilly and the Philadelphia Chapter of the Institute of Internal Auditors for the 2020 Fraud and Ethics Symposium. Information here and registration here

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

Categories
Daily Compliance News

March 6, 2020-the Remember the Alamo edition


In today’s edition of Daily Compliance News:

  • Even domestic bribery is illegal (sometimes). (WSJ)
  • Will SCt. reward fraudsters? (Radical Compliance)
  • Will US take over UAW like it did the Teamsters. (New York Times)
  • Maxine Waters calls on Wells Fargo board members to resign and considers referral of former CEO Tim Sloan. (Washington Post)