Day: August 19, 2020

Categories
FCPA Compliance Report Wirecard

Wirecard and Fraud


In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors.  Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and international law.  She is accustomed to working on extremely sensitive and high-profile matters, both nationally and internationally. In this episode, we continue our multipart series on the Wirecard accounting fraud. Today, we take up the issue of fraud in the Wirecard saga.
Some of the highlights include:

  • Did Wirecard ever make money?
  • Was Wirecard even designed to make money?
  • Was it simply a Ponzi scheme??
  • Why BCCI and not Enron was Wirecard’s role model?
  • How could BaFin employees oversee Wirecard while investing in it? (Ans: they couldn’t)
  • What is Round-Tripping fraud and how did Wirecard master it?
Categories
The Affiliated Monitors Expert Podcast

The Early Days of AMI


In this episode, I welcome back Vin DiCianni, Chief Executive Officer (CEO) and founder of AMI. We discuss the early days of AMI. DiCianni drew as inspiration for AMI, a number of special Commissions that were created by New York City to address improprieties by construction contractors in building public schools in New York City. Out of those Commissions arose the concept of Independent Private Sector Inspector General (IPSIG) and the model was to bring accounting, legal, and engineering skills into the oversight of construction contractors who were about to lose a contract because of some type of violation of the terms of the contract. This IPSIG model was used to provide oversight for these contractors so that the buildings needed could get built. However, this IPSIG model was very intrusive, with the monitor literally in the back pocket of the contractor reviewing accounting records, engineering drawing and contracts on an almost continuous basis. DiCianni envisioned a less intrusive, more collaborative model. Yet he noted it took time to convince all the relevant parties, the regulators, defense counsel and companies of the effectiveness of this approach. He said there were three key factors in this process.
They were (1) to convince the regulators that a truly independent monitor not only had advantages but would work; (2) many government agencies and state oversight boards did not want to put the licensed companies and persons out of business because the government and people in a state needed the services; and (3) economic pressures which caused cut-backs to funding and the regulators simply did not have the head count to fulfill the oversight role that an independent monitor can perform. DiCianni was able to answer these questions and others; all of which helped in the formation and growth of AMI.
For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit Affiliated Monitors at www.affiliatedmonitors.com.

Categories
Daily Compliance News

August 19, 2020-the Just Kidding edition


In today’s edition of Daily Compliance News:

  • Former NRA insider pens tell-all book. (NYT)
  • Banks set up partnerships to combat crime. (WSJ)
  • After trying to destroy Postal Service, Trump Administration says ‘just kidding’. (WSJ)
  • Average CEO salary now $21.3MM. (WaPo)
Categories
Innovation in Compliance

A Conversation with Skillsoft and StoneTurn: Part 3 – Jamen Tyler on Conducting Effective Risk Assessments


Welcome to a special five-part podcast series, A Conversation with Skillsoft and StoneTurn: From the Code of Conduct to Risk Assessment to Continuous Improvement. This week’s podcast series is jointly sponsored by Skillsoft and StoneTurn Group, LLP. In this podcast series we will explore the recently released 2020 Update to the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (2020 Update). We focus on your Code of Conduct and how it is informed by your Risk Assessment, training on your Code of Conduct, performing a Risk Assessment and conclude with how all this ties to continuous monitoring and continuous improvement. Participants in this podcast series include: from Skillsoft, Charlie Voelker, Director, Compliance Products; John Arendes, Vice President and GM of Global Compliance Solutions; from StoneTurn, Toby Ralston, Managing Director, Jamen Tyler, Managing Director and Stephen Martin, Partner. In this third episode, I visit with Jamen Tyler on conducting an effective risk assessment.
We began with some of Tyler’s top tips for conducting a risk assessment. She began that everyone needs to understand that risk assessments are about putting together and thinking about all of your risks. This means typically thinking about risks falling into kind of four buckets. They are (1) financial, (2) operational (3) legal/regulatory and (4) reputational. While most companies are pretty well versed in conducting risk assessments for financial and operational risks; legal regulatory and reputational can be just as harmful. This means a company needs to think critically about those final two buckets of risk, in addition to the more traditional financial operational risks. This means targeting specific risk areas by subject matter and even breaking it down to specific geographies or business units, can be both more efficient. It can also help to insure you are conducting risk assessments on a timely basis.
Join us tomorrow where I visit with John Arendes, Vice President and GM of Global Compliance Solutions at Skillsoft, who helps us take a deep dive into assessing your risks and using that process to then manage those risks.
Webinar
If you enjoyed today’s podcast, I want to let you know about an upcoming webinar Skillsoft and StoneTurn are hosting. The webinar “Evolving Your Compliance Program” will be held on Wednesday Sept 23 and will explore how companies are leveraging data and information to improve and evolve their compliance programs. Information and Registration click here.
Resources
For more information on Skillsoft’s compliance offerings, click here.
For more information on the Skillsoft/StoneTurn partnership, click here.
For more information on StoneTurn, click here.

Categories
Compliance and Coronavirus

Vin DiCianni on Challenges in WFM and Ambassadors for Remote Operations


Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. As the Voice of Compliance, I wanted to start a podcast which will help to bring both clarity and sanity to the compliance practitioner and compliance profession during this worldwide health and healthcare crisis. In this episode, I am joined by Vin DiCianni, founder and CEO at Affiliated Monitors, Inc. We discuss challenges from isolation in this work from home environment and how compliance Ambassadors can facilitate and more fully operationalize compliance.
For more information on Affiliated Monitors, Inc. check out their website here.

Categories
Great Women in Compliance

Sonia Zeledon, Part 1-Doing Well by Doing Good


Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
The Great Women in Compliance Podcast introduces another two-part series this week, featuring Sonia Zeledon of The Hershey Company.  Sonia shares the philosophy of the Company: “Doing well by doing good” which seems like a dream environment for a Compliance Officer to walk into and Sonia shares how to not let such a front foot position lead to complacency.
Sonia discusses the company’s supplier code of conduct and how it’s at the heart of the company’s supply chain Compliance program.  She also canvasses the intersection between privacy and compliance in her role and how the show had to go on during COVID-19.  She also draws on her previous experience specializing in national security and shares with us some of the considerations when working in a Compliance function which must prioritize national security risk.
Lisa and Mary are currently busy working on the Great Women in Compliance book with Corporate Compliance Insights.  One of the most enjoyable aspects of publishing the book is planning the launch party.  The team is looking forward to sharing the details with their audience shortly and hopes that you all will be able to attend and raise a glass to toast all of the wonderful Great Women in Compliance that you know, starting with yourselves.  Watch this space for further details!
Join the Great Women in Compliance community on LinkedIn here.

Categories
Compliance Into the Weeds

Governance Lessons from the Post Office

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 Matt comes in smoking hot over the Trump Administration’s attempted evisceration of the US Postal Service. He cools down to present multiple lessons for the compliance professional.
Some of the highlights include:

  • What is the controversy?
  • What happens when the CEO has a conflict of interest with his own organization?
  • What happens when business objectives conflict with business priorities?
  • How the amplification of social media can create undue pressures.

 Resources
See Matt’s blog post, Governance Lessons from the Postal Service on Radical Compliance.