In this week’s #jammingwithjason episode I speak with Sohail Saleem about lessons he learned from being a CAE. We discuss various topics including: investing time and money into your career development (and yes that even means out of your own pocket), having a vision, determining what you need to get to the next level, seeing the big picture, developing your soft-skills, and thinking outside of the box.
Take a listen to the episode to learn Sohail’s career path and advise on becoming a CAE at: http://www.jasonmefford.com/jammingwithjason/
So much wisdom from Sohail in this episode.
Sohail Saleem is the Executive Director of Internal Audit (CAE) at Mount Royal University
Calgary, Alberta, Canada.
#internalaudit #chiefauditexecutive #internalauditpodcast
Day: July 28, 2020
On the latest episode of EMBARGOED!, Brian and Tim dissect the continued downward spiral of U.S.-China relations, including the sweeping new Executive Order aimed at “normalizing” U.S. relations with Hong Kong and the latest tit-for-tat sanctions imposed by the U.S. and China, respectively. Next, we cover two notable recent enforcement actions: OFAC’s settlement with Amazon and a joint DOJ/OFAC resolution with Essentra FZE relating to North Korea sanctions violations. Finally, in the Lightning Round, we share quick thoughts on recent OFAC designations targeting Nicaragua and some personal reflections on the United States’ reliance on human rights as a basis for economic sanctions policies.
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Questions? Contact us at podcasts@milchev.com.
EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
EMBARGOED! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike, hosted by Miller & Chevalier Members Brian Fleming and Tim O’Toole. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe for new bi-weekly episodes so you don’t miss out!
Timestamps:
0:10 Introduction and Roadmap
The Rundown
4:21 China Round-up
22:30 Amazon OFAC Enforcement Action
30:51 North Korea Enforcement Action by DOJ/OFAC
39:39 Lightning Round:
40:00 Ortega’s Inner Circle Targeted by OFAC
43:59 A Few Words on Human Rights and the Death Penalty
55:45 Final Thoughts
***Stay sanctions free.***
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Scott Sullivan, the Chief Integrity and Compliance Officer at Newmont Mining.
Scott Sullivan is a versatile and innovative governance, risk, compliance, ethics and legal executive with significant experience advising C-suite leaders and Boards of Directors in a global enterprise in a wide array of sensitive, high profile subject matter areas. He has extensive leadership in designing, implementing and enhancing world-class programs and favorably resolving regulatory crises for multinationals. He has managed ethics and compliance for a $5B global Fortune 500 corporation, directing a Business Integrity & Compliance function impacting 20,000 employees in over 55 countries with over 100 legal entities.
In this final episode, Sullivan discusses how the role of a CCO has evolved from a legal response to government enforcement under the FCPA; driven by lawyers to something else. We consider some of some of the biggest changes for Sullivan has observed. We conclude by looking down the road, as we move into the 2020s where Sullivan sees compliance moving to? It includes data, data, data – continuous monitoring, automation, finely tuned machine and how some of the changes wrought by Covid-19 accelerate these trends and perhaps others; including remote options, less travel and opportunities outside traditional comfort zone for compliance professionals.
One of the areas many companies do not focus on enough is possible corruption in their supply chain for goods and services provided on a company’s behalf. The FCPA risks can be just as great through those entry points as it can be through the sales side of an organization. You need to know who your company is doing business with through this channel as much as you need to know your agents seeking business opportunities on your behalf. Most companies have exponentially more vendors than sales agents, so this task may seem daunting. However, a well thought out plan to risk rank your company’s third-parties on the supply chain side can go a long way towards ameliorating this issue. The key is to set reasonable parameters and then management those third-parties which present true corruption risk to your organization.
This determination of the level of due diligence and categorization of a supplier should depend on a variety of factors, including, such factors as whether the supplier is (1) located, or will operate, in a high risk country; (2) associated, or recommended or required by, a government official; (3) currently under corruption investigation, or has been recently convicted of any form of corruption; (4) a multinational publicly traded corporation with a recognized exemplary system of compliance and internal controls; or (5) a provider of widely available services and products that are not industry specific. You should note that any supplier, which has foreign government touch points, should move up into a higher level of scrutiny.
My suggestion is that you create a three-tiered risk matrix consisting of (1) high-risk suppliers, (2) low-risk suppliers, and (3) minimal-risk suppliers. Below this final category is another category for providers of goods which are commonly available and pose almost no corruption risk.
You need to risk rank the third-parties which your supply chain might engage with for FCPA exposure. It should be based on your company’s experience and risk going forward. As with all other third-party risk management issues, you must “Document, Document, and Document”.
Three key takeaways:
- Risk rank your supply chain based on well-conceived strata.
- Consider not only the compliance risk but also your business risk.
- Only manage those suppliers which present a corruption risk.
Categories
Episode 020–Rob Chesnut
On this episode of The Ethics Experts, Gio speaks with Rob Chesnut about his amazing book on Integrity, and how he became a household name in Ethics and Compliance.
Check out more episodes, and don’t forget to subscribe on your favorite podcast platform!
Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. In this episode, I visit with Jerry Coyne who is Managing Director of State Monitoring Services at Affiliated Monitors, Inc. At Affiliated Monitors, Mr. Coyne oversees monitoring agreements with corporations, healthcare entities and individuals. We discuss the rise of telemedicine during the Covid-19 health crisis and what it may mean for compliance.
Some of the highlights include:
- What is telemedicine?
- Why has it risen so quickly during the Coronavirus health crisis?
- What are some of the compliance, data privacy and other challenges arising from the rise of telemedicine?
For me information check out the Affiliated Monitors website here.
Gene Geiger of A-LIGN joins Tom Fox on this week’s show to discuss his company’s innovative compliance management platform, A-SCEND. Gene remarks that there was a market need to drive technology in the professional services space. “What we’ve been missing is driving automation and driving workflow and driving efficiency through technology, and that’s really what A-SCEND is meant to do. It’s meant to complement the people in the audit workflow to make the job as efficient and as automated as possible,” he says.
Built For Users
“The need for technology crosses multiple compliance standards,” Gene remarks. A-SCEND is built to comply with eight compliance standards in the cybersecurity industry. In addition, Gene says, users can input their own internal standards using the custom object module. He describes various features of the platform that helps clients automate their compliance workflow, and manage compliance tasks throughout the year, rather than just for the annual audit. A unique feature of A-SCEND is its ability to de-duplicate requests across multiple compliance standards, resulting in up to a 50% decrease in workload when preparing for audits. Gene points out how these innovative features allow their clients to do anytime, anywhere audits, and how both they and their clients were able to pivot easily to remote work as a result of the COVID-19 pandemic. Tom asks how feedback is built into the platform. Gene outlines several mechanisms, including their advisory board, surveys, and their customer support system. “We are able to build an application for compliance management that really meets the needs of the users,” he says.
The Future of Strategic Compliance
Tom and Gene discuss the future of strategic compliance. Gene predicts that there will be movement towards benchmarking, AI-based review and evidence collection, and data-driven metrics.
Resources
A-lign.com
In today’s edition of Daily Compliance News:
- Wirecard in the Philippines. (KYC360)
- Obese politicians signal corruption. (Eurasianet)
- Fraud reimbursement in Congo. (WSJ)
- Things not looking too good at Under Armour. (WSJ)
Gene Geiger of A-LIGN joins Tom Fox on this week’s show to discuss his company’s innovative compliance management platform, A-SCEND. Gene remarks that there was a market need to drive technology in the professional services space. “What we’ve been missing is driving automation and driving workflow and driving efficiency through technology, and that’s really what A-SCEND is meant to do. It’s meant to complement the people in the audit workflow to make the job as efficient and as automated as possible,” he says.
Built For Users
“The need for technology crosses multiple compliance standards,” Gene remarks. A-SCEND is built to comply with eight compliance standards in the cybersecurity industry. In addition, Gene says, users can input their own internal standards using the custom object module. He describes various features of the platform that helps clients automate their compliance workflow, and manage compliance tasks throughout the year, rather than just for the annual audit. A unique feature of A-SCEND is its ability to de-duplicate requests across multiple compliance standards, resulting in up to a 50% decrease in workload when preparing for audits. Gene points out how these innovative features allow their clients to do anytime, anywhere audits, and how both they and their clients were able to pivot easily to remote work as a result of the COVID-19 pandemic. Tom asks how feedback is built into the platform. Gene outlines several mechanisms, including their advisory board, surveys, and their customer support system. “We are able to build an application for compliance management that really meets the needs of the users,” he says.
The Future of Strategic Compliance
Tom and Gene discuss the future of strategic compliance. Gene predicts that there will be movement towards benchmarking, AI-based review and evidence collection, and data-driven metrics.
Resources
A-lign.com
