Categories
Innovation in Compliance

Defining and Building Effective Compliance Programs – What’s on the Horizon?


In this five-part podcast series, sponsored by K2 Intelligence FIN, we have considered defining and building effective compliance programs. I have been joined in this series by Michelle Goodsir, a Managing Director at K2 Intelligence, and Gail Fuller, Financial Integrity Network (FIN) Vice President. Michelle has 25 years of financial crime compliance experience which includes fraud risk management, anti-bribery and corruption, corporate security and investigations, sanctions, and Anti-Money Laundering (AML) program experience working within the financial services industry and the US government. Gail focuses on developing, refining, and implementing FIN’s quantitative and qualitative risk rating tools. She leads engagements focused on helping FIN’s jurisdictional and private sector clients understand their exposure to financial crime risk and develop and implement strategies to mitigate their risks.
Over this series we have considered key challenges in compliance, why compliance needs a seat at the table, how to do compliance on a budget; training and culture and what is on the horizon. In our conclusion, Part 5, I visit with Gail Fuller as we look into that veiled land of the future and view what’s on the horizon for compliance. Highlights include:

  • What are regulators looking for when it comes to compliance? Regulators are looking for professionals to be proactive and creative problems solvers. 
  • If compliance was an area that was previously not sufficiently funded, what are three things people need to do now if things are cut even further? Reinforce your commitment to compliance; rethink geographic distribution of your compliance team; and think through technology investments.
  • Thinking about this whole series, we talked about a lot of tips… what are the areas you’d suggest our listeners focus on as they look to rebuild or enhance their programs? Be sure to communication your compliance priorities clearly, leverage personnel to more fully operationalize compliance and then harness and pursue technologies.

Resources
K2 Intelligence financial crimes risk & compliance page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance 
K2 Intelligence AML page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-money-laundering-compliance
K2 Intelligence Anti-corruption page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-corruption
K2 Intelligence DOLFIN: https://www.finintegrity.com/dolfin.html

Categories
Creativity and Compliance

Ricardo Pellafone-Your Compliance Training Sucks


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 Ricardo Pellafone, founder and CEO of Broadcat. We visit with Ricardo about his journey into compliance and why he thinks most compliance training sucks, why it should be ditched and how we all need start over. Some of the highlights include:

  • Ricardo’s journey into compliance and what led him to found Broadcat.
  • Why is compliance training the worst?
  • Why is using the using the right tool for the job critical in compliance training?
  • How can compliance training educate?
  • Why is it important to target specific behaviors in compliance training?
  • Why is awareness and communications so critical when thinking about compliance training?

Resources
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.
Ricardo Pellafone and Broadcat
For more information on Broadcat, click here.
For Ricardo’s LinkedIn profile, click here.

Categories
This Week in FCPA

Episode 206 – the Start of Summer edition


The Memorial Day weekend traditionally signifies the start of summer. What does it mean this year? Self-distancing Tom and Jay are back to consider some of the top compliance articles and stories which caught their collective eye this week.

  1. How can you assess a conflict of interest risk? Jeff Kaplan in the Conflict of Interest blog.
  2. Deemed exports rears its ugly head in Higher Ed. Matt Kellyexplains in Radical Compliance.
  3. Mike Volkov takes a deep dive into beneficial ownership in a four-part series on Corruption Crime and Compliance.
  4. What were the top anti-compliance enforcement developments from this decade. James Koukios and Amanda Aikman in CCI.
  5. What steps can you take to refresh your whistleblower system? Lawyers from Wachtell Lipton opine in NYU’s Compliance and Enforcement Blog.
  6. What does a modern bank heist look like? Jon Rusch explores in Dipping Through Geometries.
  7. What are some old school fraud schemes? Francine McKenna discusses in The Dig.
  8. How can company’s win the trust of whistleblowers back? Jonathan Marks in Board and Fraud.
  9. Three more (former) KPMG partners go down in the firm’s test cheating scandall. Aaron Nicodemus in Compliance Week. (sub req’d)
  10. Interested in moving to the CCO chair? Check in on this month’s edition of The Compliance Life where Tom visits with Ellen Hunt, CCO at AARP. In this Part 3, Hunt discusses what happens when you finally sit in CCO chair. New episodes appear each Tuesday in May at 1 PM CST. The Compliance Life is now available on iTunes.
  11. On Compliance and Coronavirus this week: John Shegerian explains why data is the new oil in the time of Covid-19; Matt Whitteker on supply chain risks in this health crisis; Matt Kelly joins me to discuss the requirement for Covid-19 health attestation by Massachusetts businesses reopening in Phase 1 of the state’s reopening. Compliance and Coronavirus is available on iTunes here.
  12. On the Compliance Podcast Network, this month topic: written standards; all on 31 Days to a More Effective Compliance Program. This week’s offerings: Monday-Charitable donation enforcement actions; Tuesday-Opinion Release guidance on charitable donations; Wednesday-Policies and procedures on charitable donations; Thursday– Policies on political contributions; Friday– the problems with Facilitation Payments. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel.

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

May 22, 2020-the Horrified and Ashamed edition


In today’s edition of Daily Compliance News:

  • VW ‘horrified and ashamed’ by its racist ad. (NYT)
  • Of course he does. (NYT)
  • Loughlin to plead guilty. (WSJ)
  • S&P fires employee who spoke to Senate staffers. (WSJ)