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31 Days to More Effective Compliance Programs

Finding compliance patterns in raked leaves


We previously considered how AI can be used as a business advantage for compliance. The power of AI can extend the more traditional functions of prevention, detection and remediation. The first way is in simply the mass amount of data which could inundate a compliance practitioner. Many compliance practitioners are overwhelmed about the amount of data available to them and do not know how or even where to begin.
Patrick Taylor has said that AI allows the compliance practitioner to understand the “subtle clues in that pattern of activity that will clue me in to take a different look.” He likened it to seeing “patterns in raked leaves” which allows you to then step in and take a deeper and broader look at an issue, either through an audit or investigation. This is where compliance practitioner can step back and literally keep an eye on the big picture and longer term as opposed to just the immediate numbers and information in front of them. It may also be the best hope for finding that kind of systemic fraudulent behavior
Three key takeaways:

  1. Do you know what your information means?
  2. AI can help both the detect and prevent prongs in a best practices compliance program.
  3. AI can help you to see the patterns in raked leaves.

 

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Great Women in Compliance

Breaking the Glass Ceiling for Muslim Women in Private Practice


Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.In this episode of GWIC, Lisa speaks with Fatema Merchant, who is an  International Trade and White Collar Defense partner at Sheppard Mullin.  She is also the first hijab-wearing woman to make partner at a Washington, D.C., Am Law 100 firm.
Fatema talks about wearing the hijab in the context of how each of us expresses our identities and some common misconceptions.  Many of us, women and men, may feel like our identities impact how others view our roles  in meetings and investigations and Fatema speaks about her own experiences.  When Fatema made partner, many South Asian, Muslim and women attorneys reached out to her and she talks about the role of mentorship in creating diverse leaders in the compliance and legal professions.
Fatema is also a member of the steering committee for Sheppard Mullin’s Organizational Integrity Group.  OIG helps clients avoid potential crises by identifying and addressing threats to companies’ integrity through proactive solutions.  As Lisa works in-house, Fatema turns the tables on Lisa and asks her some questions about working with outside counsel.
Join the Great Women in Compliance community on LinkedIn here.

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Compliance Into the Weeds

OCC Guidance on 3rd Party Risk Management


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 we take a deep dive into recent OCC Guidance on managing 3rd party risk. Some of the highlights include:

  • What was the Office of the Comptroller of the Currency, guidance published the on March 5?
  • Why is 3rd party risk still a chronic issue?
  • What is the role of due diligence?
  • What are sustainable business models for 3rd party risk management?
  • What are 4th party risks?
  • What is Kelly’s Law of 3rd Party Risk Management?
  • A short discussion of FINRA’s new bulletin on pandemic risk?

Resources
Matt Kelly blog post, Some Good Guidance on 3rd Party Risk

Categories
31 Days to More Effective Compliance Programs

March 11, 2020-the I Promise to do Better edition


In today’s edition of Daily Compliance News:

  • Is working from home over-rated? (NYT)
  • Wells Fargo CEO promises to do better. (NYT)
  • John Wood reserves $46MM for FCPA settlement. (WSJ)
  • Surge in sanctions lift need for compliance. (WSJ)