Day: April 17, 2020

31 Days to More Effective Compliance Programs

Monitoring for continuous improvement

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Post date April 17, 2020
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Another mechanism for continuous improvement of your compliance program is through risk-based monitoring. Under the topic of Control Testing DOJ’s 2019 Guidance posed the following questions, Has the company reviewed and audited its compliance program in the area relating to the misconduct? More generally, what testing of controls, collection and analysis of compliance data, and interviews of employees and third-parties does the company undertake? How are the results reported and action items tracked?
Finally, the beauty of all these techniques articulated by Locwin is that they are tools that can make companies more efficient and, at the end of the day, more profitable. They also move compliance into the fabric and DNA of an organization or operationalize compliance. Her intonation to operationalize compliance speaks to the use of a wide variety of tools to input information, so you can continuously improve your compliance program. Risk-based monitoring is certainly one mechanism to obtain information and feed back into your compliance program in both the prevent and detect prongs.
Three key takeaways:

How do you monitor manifested risks?
A risk-based monitoring approach allows you to see things in almost real-time.
Management of risk can serve your compliance program in a variety of ways.

Tags continuous improvement

FCPA Compliance Report

Join Me at ECI’s IMPACT 2020 Benchmarking Conference

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Post date April 17, 2020
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The IMPACT 2020 Annual Benchmarking Conference was originally scheduled to take place in Boston, Massachusetts from April 21-23, 2020. In light of the unfolding situation involving the coronavirus (COVID-19), and in an effort to protect the health and safety of all the attendees, IMPACT 2020 will now be a virtual, online-only event. The conference will take place during the same timeframe as previously April 21-23, 2020.
ECI has worked diligently to make sure that you can extract all or more of the same value you would receive from attending this event in Boston in a high-quality, online format.
There is still time to register for this great event now!
We hope that you are looking forward to our IMPACT conference and we are excited to be able to present this information to you in an exciting, new way.
As a teaser for the event, please check out this podcast I did with David Rocks, CEO and Co-Founder of the Neuroleadership Institute about his keynote talk.

Tags David Rock, ECI Impact 2020

Creativity and Compliance

Using Fictional Characters to Promote Compliance Engagement

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Post date April 17, 2020
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Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the Compliance Podcast Network to explore these issues. In today’s episode we are joined by Joel Katz the CCO at Booz Allen Hamilton. Katz was previously CCO at CA Technologies where he gained notoriety for the use of fictional characters in creative programming to promote employee engagement around compliance.
Some of the highlights include:

The professional journey of Joel Katz.
What was the Griffin Peabody character you created at CA Technologies?
How fiction-based characters in compliance training drove the highest employee satisfaction reported in the CA Technologies employee survey.
Although the characters were fictional, the stories were based on employees’ personal experiences. This helped drive engagement.
All this became a part of a branded communication campaign for CA Technologies.
What were some of the key lessons learned by Katz and his compliance team?

Ronnie Feldman
Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)
Learnings & Entertainments (Website)
60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.
Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.
Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.

Tags employee engagement

This Week in FCPA

Episode 201– the Farewell to Brian Dennehy edition

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Post date April 17, 2020
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As Emperor Trump says that only he can decide when the country will re-open for business and Congress can adjourn and the lads note the passing of Brian Dennehy, self-distancing Tom and Jay are back to consider some of the top compliance articles and stories which caught their eye this week.

Former Goldman exec charged with FCPA violations. Harry Cassin breaks the story in the FCPA Blog. Matt Kelly says Goldman Sachs got a great outcome, in Radical Compliance.
How beliefs impact mindset. Jaclyn Jaeger reviews both angles in Compliance Week.
What will happen to ‘Made in China”? Dick Cassin explores in the FCPA Blog.
What steps can be taken to fight corruption in the response to Coronavirus. Sarah Steingrüber in theGlobal Anti-Corruption Blog.
What FCPA landmines are lurking beneath COVID-19? Scott Roybal in National Law Review.
Does the Coronavirus health crisis hobble monitors? Mengqi Sun in the WSJ Risk and Compliance Journal.
BAT under investigation for export control violation. Mengqi Sun in the WSJ Risk and Compliance Journal.
What might a national US privacy law look like? Logan Finucan in CCI.
What do scam PACs and Coronavirus have in common? Sara Kropf explores on Grand Jury Target.
On Compliance and Coronavirus this week: Abikoff and Huneke on why neither enforcement nor compliance ever sleep; Ryan Wilkins on corp governance issues during COVID-19; Tricia Cornell on why new and different time horizons during the coronavirus crisis.
The Everything Compliance gang is back with a look at compliance and coronavirus. Check it out on iTunes
On the Compliance Podcast Network, Tom concludes a month of looking at the role of innovation in compliance And opens a month of exploring continuous improvement, all on 31 Days to a More Effective Compliance Program. This week saw the following offerings: Monday-the Culture Audit; Tuesday-the Fraud Audit; Wednesday-the Integrity Audit; Thursday-the Mock Audit; Friday-Monitoring for continuous improvement. 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.