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31 Days to More Effective Compliance Programs

Originating and Managing a Compliance Ecosystem


Have you ever thought of compliance as an ecosystem? When you consider the concept, it becomes clear that this is one thing every company should strive towards. Obviously, every multi-national company must have a compliance program. But to have true effectiveness, your compliance program must be operationalized throughout the organization. One way to facilitate this is through the ecosystem concept.
There is another way that this ecosystem approach can make your compliance program more effective. Think about the third parties your company has both on the sales and the supply chain side. If you could work to create a closer ecosystem with those stakeholders from the compliance perspective, it would not only make the business relationship stronger but also make the entire business process more efficient.
2020 has brought a paradigm shift to corporate compliance as a result of technological and digital innovation. CCOs who cannot interpret the data from their own systems will likely find themselves consigned to the dustbin of corporate luddites. Compliance will be moving into a new era of collaboration and connection to more fully operationalize compliance to make all business stakeholders more efficient and at the end of the day more profitable.
Three key takeaways:

  1. A compliance function’s customers are a variety of stakeholders.
  2. Compliance can improve business processes.
  3. A compliance ecosystem can help to operationalize compliance.
Categories
Innovation in Compliance

The Six Elements of an Effective Compliance Program: Part 1 – Risk Assessments: Understanding and Managing Key Compliance Risks


Welcome to a special five-part podcast series, The Six Elements of an Effective Compliance Program. This podcast series is sponsored by StoneTurn. To celebrate Corporate Compliance and Ethics Week, we will consider each of the six elements required for an effective compliance program. They include: Risk Assessment, Governance and Structure, Policies Procedures and Controls, Training and Education, Oversight and Reporting, and Response and Enhancements. Over this five-part podcast series, I will be joined by Stephen Martin and Valerie Charles, Partners and StoneTurn and Toby Ralston and Jamen Tyler, Managing Directors at StoneTurn.
In this first episode, I visit with Stephen Martin on Risk Assessments. Highlights include:

  • Properly seen, an effective compliance program is an ongoing ecosystem. Why is an effective compliance program dynamic, requiring an ongoing, multi-disciplinary approach?
  • Businesses have traditionally had an historical bias toward financial and operational risk. Why have about legal and regulatory and reputational risks become so much more important in the era of Covid-19 and social justice movements around Black Lives Matter and Diversity and Inclusion? Why must these risks be assessed?
  • The Department of Justice mandated in its 2020 Update to the Evaluation of Corporate Compliance Programs that risk assessments be performed on a much more ongoing basis, such as when risks change. What does this mean in practice?
  • The Department of Justice said in its 2020 Update that compliance must break down silos and functional impediments to an effective compliance program. Why do you see this as so critical?
  • The 2020 Update mandated greater information from a compliance program be used to improve it. How do you leverage code and policy questions received into enhancements to an overall Enterprise Risk Management process? 

Resources
For more information on StoneTurn, click here.

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The Ethics Experts

Episode 035–Ricardo Pellafone


On this episode of The Ethics Experts, Nick welcomes Ricardo Pellefone to chat about the shift from litigation to compliance training.

Check out more episodes, and don’t forget to subscribe on your favorite podcast platform!

Categories
FCPA Compliance Report

James Koukios on the MoFo Top 10 International Anti-Corruption Developments for April 2020


In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for April 2020.
Some of the highlights include:

  1. DOJ Announces Repatriation of $300 Million to Malaysia in Connection With 1MDB.
  1. Colombia Officially Enters the OECD. What was the process and what does this mean for Colombia?
  2. What is the DOJ saying around FCPA enforcement in the Covid-19 era?
  3. London court discharges 3rd ever unexplained wealth order?
  4. ENI resolves Algeria FCPA allegations.

 Resources
To a copy of the Top 10 International Anti-Corruption Developments for April 2020 Newsletter click here.

Categories
Daily Compliance News

November 2, 2020-Zombie Directors edition


In today’s edition of Daily Compliance News:

  • Once a cheat, always a cheat? (NYT)
  • EY getting more DAX audits after Wirecard. (FT)
  • Diversity in corporate leadership. (WSJ)
  • Zombie directors. (NYT)