Day: March 13, 2020

Episode 196 – the We Won’t Screw You (Again) edition

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Post date March 13, 2020
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As the new Wells Fargo CEO tells Congress that things are really different this time, Tom and Jay reflect on the corporate scandal that may well never end and consider some of the other top compliance articles and stories which caught their eye this week.

Compliance Week has a plethora of articles relating to Wells Fargo. Aaron Nicodemus considers the testimony of Charlie Scharf; Jaclyn Jaeger on Lessons Learned and Board resignations. (Even though a subscription is required for these articles, if you go to Compliance Week site and register for a free account to view four articles at no charge.)
John Wood Group reserves $46MM for anti-corruption settlement. Dylan Tokar in the WSJ Risk and Compliance Journal.
Is unified transaction monitoring a paneca? Sujata Dasgupta explains in CCI.
Is every email a FCPA violation? Bill Steinman asks in the FCPA Blog.
OCC issues some excellent guidance around 3^rd Matt Kelly considers in Radical Compliance.
Wow moments in compliance, Part 4. Geert Vermeulen continues his 5-part series in Risk and Compliance Platform Europe.
What are the dangers of a hyper-focused sales culture? Mike Volkov explores in Corruption, Crime & Compliance.
Supply Chain and coronavirus. Global Supply Chain Blog.
Economic crime levy in UK. Jonathan Rausch considers in Dipping Through Geometries.
Banks behaving badly, parts 3088 and 3089. SwedBank and Fifth Third.
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-Compliance capabilities needed to use AI programs; Tuesday-4 practices for delivering an AI solution; Wednesday-Finding compliance patterns in raked leaves; Thursday-Using AI in compliance contracting; Friday-taming complexity 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.

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.

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31 Days to More Effective Compliance Programs

Taming Complexity in Compliance

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Post date March 13, 2020
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One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. Whether a corrupt employee is working to actively hide a pot of money, which can or will be used to pay a bribe, or an improper payment slips through the cracks; complexity can work to defeat a best practices compliance program. If a compliance function does not have visibility into a business unit, how it does business and where its payments are going; it may be due to design or inadvertent complexity.
Compliance is now in an era of brisk innovation and evolution. It is prone to technological change and rapid obsolescence of the lawyer-driven, spreadsheet and word document based compliance programs. Going forward the compliance professional needs to understand that a “package of resilience, adaptability, coordination, and inimitability becomes more attractive than the package of efficiency, understandability, manageability, and predictability.” The key is to learn how to harness complexity on a sustainable basis.
Three Key Takeaways:

If a business is too complex for the compliance function to understand; it is in greater danger of illegal or unethical activity.
Taming complexity starts with simple operating principles.
Always remember to fix, repair and prune.

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STAKE: The Leadership Podcast

Lay Down the Law with Employees

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Post date March 13, 2020
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Today’s employees are much more likely to engage better, stay longer, and perform better for leaders who are invested in their personal and professional goals.
How do you do that?
In today’s episode I’m sharing with you my simple and very effective goal setting process: Lay Down the Law. This process can be used, with a few tweaks, for yourself, even your kids…but today’s focus is your employees.
As you work through this process with your employees, they will see and feel your investment in them and more of than not, they’re going to give that investment back to you tenfold.
Take your leadership results to the next level by laying down the law with your people today!
———-
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If you want to reach out to me directly, email alyson@vanhooser.com.
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