Day: January 13, 2021

The Missing Private Banker: When Bank Fraud Takes a Dark Turn

Post author By FTI Consulting
Post date January 13, 2021
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The Carrasco case is a cross-border financial crime that is worth revisiting. Its lessons remain as relevant today as they were in 1998 when the fraud first erupted.

Join us each week as we take a deep dive into the various forms of fraud across the world and discuss crime families, penny stock boiler rooms, international money launderers, narco-traffickers, oligarchs, dictators, warlords, kleptocrats and more.

Scott Moritz is a leading authority on white-collar crime, anti-corruption, and in the evaluation, design, remediation, implementation, and administration of corporate compliance programs, codes of conduct. He is also considered an authority in the establishment, training, and oversight of the investigative protocols carried out by financial intelligence, corporate security, and internal audit units.

Tags Carrasco

31 Days to More Effective Compliance Programs

Day 13 | Institutional Justice and Fairness

Post author By admin
Post date January 13, 2021
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Companies have finally come to realize that institutional justice and fairness are perhaps the most basic tenet of any successful workplace. If employees believe they will be treated fairly, it will engender a level of trust that can work to not simply motivate employees but lead to a more successful workplace and, at the end of the day, a more profitable company. This encompasses the entire lifecycle of the employment relationship, from hiring through separation. It works in areas as seeming disparate as compensation and incentives, discipline, promotion and internal reporting.
On this final point, Kyle Welch and Stephen Stubben, in their 2019 paper entitled “Evidence on the Use and Efficacy of Internal Whistleblowing Systems”, noted that a robust whistleblower reporting system speaks to a functioning and ethical corporate culture. Employees who can report issues, in a fair manner, without fear of retaliation are more empowered to make the company run more efficiently and more profitably. Yet an equally interesting finding was where there was robust internal reporting, employees were more likely to speak up to improve overall business processes, thereby making the company more profitable.
An often-overlooked role of any CCO or compliance professional is to help provide employees with institutional justice. If your compliance function is seen to be fair in the way it treats employees, in areas as varied as financial incentives, to promotions, to appropriate and consistent discipline meted out across the globe; employees are more likely to inform the compliance department when something goes array. If employees believe they will be treated fairly, it will go a long way to more fully operationalizing your compliance program.
Three key takeaways:

The DOJ and SEC have long called for appropriate and consistent application of both incentives and discipline.
The Fair Process Doctrine will help set institutional justice as the norm in your organization.
Inconsistent application of discipline will destroy your compliance program credibility.

Tags institutional justice

The Ethics Experts

TEE Open To Work Bonus Episode 002: Wendy Badger

Post author By ComplianceLIVE
Post date January 13, 2021
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Great Women in Compliance

Tiffany Archer on Mastering the Art of Compliance with 3 Non-Negotiables

Post author By admin
Post date January 13, 2021
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Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley. In this episode of Great Women in Compliance, Lisa speaks with Tiffany Archer, Regional Ethics & Compliance Officer and Corporate Counsel for Europe and the Americas at Panasonic Aviation Corporation. Tiffany talks about the guideposts that have defined her life and her ethics and compliance career. These pillars are Excellence, Discipline and Integrity, and have led her to undertake challenges and accomplish goals, both personal and professional.
Tiffany provides insight on how these pillars helped her from her time in law firm life to today at Panasonic Aviation. In particular, she keeps these values in mind while recognizing the importance on building relationships and knowing that there is no “one size fits all” approach to building an ethics and compliance program. Tiffany also talks about how these pillars impacted how she has addressed COVID-19 as a leader and compliance officer, as well as how she thinks about Black Lives Matter and today’s social justice movement.
Lastly, for all of us who consider ethics and compliance a passion as much as a career, she talks about how her work in the E&C community compliments her full-time job, and her tips as to how she does all of these things she does.
Have you heard that the Great Women in Compliance Book, Sending the Elevator down is now available in an electronic version? Head to Amazon to get your copy today!
If you’ve already read the booked and liked it, will you help out other women to make the decision to leverage off the tips and advice given by rating the book and giving it a glowing review on Amazon?
As always we’re so grateful for all of your support and if you have any feedback or suggestions for our 2021 line up, or would just like to reach out and say hello, we always welcome hearing from our listeners.
Join the Great Women in Compliance community on LinkedIn here.

Tags Tiffany Archer

Innovation in Compliance

The 100 Book Challenge: The Culture Map by Erin Meyer

Post author By admin
Post date January 13, 2021
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In this episode of the 100 Book Challenge series, Tom Fox and Nick Gallo are talking about Erin Meyer’s book, The Culture Map. They discuss the dynamic of culture. Tom asks how a Chief Compliance Officer can communicate effectively within a multinational organization. Nick shares the eight axes that make up a culture from the book. He adds that understanding differing cultural norms and dynamics, and being able to communicate within that realm, is important for compliance practitioners.

Erin Meyer is a professor at INSEAD Business, based in Paris. Her work focuses on how the world’s most successful leaders navigate cultural differences in a multicultural environment.
Listeners can read Nick’s notes on this book at his LinkedIn page.

Resources
Tom Fox on LinkedIn | Twitter
CompliancePodcastNetwork.net

Nick Gallo on LinkedIn
ComplianceLine.com
The Culture Map by Erin Meyer

Tags The Culture Map by Erin Meyer

Compliance Into the Weeds

Deutsche Bank FCPA Enforcement Action

Post author By admin
Post date January 13, 2021
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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. Today we consider the Deutsche Bank Foreign Corrupt Practices Act resolution. We look at the compliance program; red flags missed, overlooked or avoided and internal control failures.
Some of the issues we consider are:

The Bank’s compliance program was a paper program only.
Where was compliance?
What Red Flags were missed?
Internal Audit did its job but was ignored.
Actual Knowledge of corruption?
What about the DFS?

Resources
Tom is running a 5-part blog post series on the FCPA Compliance and Ethics Blog:
Part 1–Introduction
Part 2– The Bribery Schemes
Part 3- Overlooked Red Flags and Internal Control Failures
Part 4-Recivist Penalty
Part 5-Final Thoughts
Matt’s blog post in Radical Compliance:
Deutsche Bank Control Failures Cost $130 million