In today’s edition of Daily Compliance News:
Day: January 21, 2021
The 2020 Update was very clear about the need for continuous improvement in any compliance program. It stated quite succinctly, “One hallmark of an effective compliance program is its capacity to improve and evolve. The actual implementation of controls in practice will necessarily reveal areas of risk and potential adjustment. A company’s business changes over time, as do the environments in which it operates, the nature of its customers, the laws that govern its actions, and the applicable industry standards. Accordingly, prosecutors should consider whether the company has engaged in meaningful efforts to review its compliance program and ensure that it is not stale.”
Continuous improvement through continuous monitoring or other similar techniques will help keep your compliance program abreast of any changes in your business model’s compliance risks and allow growth based upon new and updated best practices specified by regulators. A compliance program is in many ways a continuously evolving organism, just as your company is. You need to build in a way to keep pace with both market and regulatory changes to have a truly effective anti-corruption compliance program.
Three key takeaways:
- Your compliance program should be continually evolving.
- Monitoring and auditing are different, yet complimentary tools for continuous improvement.
- Culture assessment and monitoring are also now required as well.
When it comes to scams and frauds, it’s not just individuals at risk, but also companies. In Episode 2 of Digging Deeper, Chris Morgan Jones interviews Jordan Arnold about corporate scams, and they even discuss cracking the case of a stolen Dali.
How can individuals and organizations recognize scams before they fall victim to them? K2 Integrity offers the following guidance to individuals and entities alike.
Top Tips to Avoid the Scammers:
- Before it happens – online sharing. In today’s world, a digital footprint can be invaluable for criminals. From social media to publicly available information, criminals are able to make scams increasingly personalized. By practicing safe online sharing practices, organizations and individuals can have a first line of defense against scammers.
- Keep your information close. Scammers often aren’t who they say they are – they can call, text or email as a friend or family member. If you’re not expecting a request, don’t share personal information or financial information, no matter how real it may feel.
- Don’t pay for anything upfront. Whether it is debt relief or the trip of a lifetime, scammers will explain away why you need to put a down an initial payment. Even if it sounds amazing, do not wire, pay cash, write a check or pay via peer to peer services
- If it seems too good to be true, it probably is. When you’re approached by a dream offer, make sure you do your homework and don’t let your guard down. For example:
- When was the email domain created? If it was recently – even three months ago – it’s probably a hoax.
- Did you reach out to the verified company, not just the individual? To check whether a call or an email is real, contact the company the person is with – even considering reaching out to their PR firm or external representation.
Digging Deeper, an investigative podcast series by K2 Integrity, helps shine a light on the investigations industry as few can: via the real-world, exceptional practitioners who, day in and day out, conduct this work across sectors and around the globe. Listen in to each episode where guests explore unique cases and share what they uncovered along the way to crack the code for clients. Learn more by clicking here, or subscribe on Apple Podcasts, SoundCloud, Spotify or Stitcher.
Richard Lummis and Tom Fox begin a two-part series on leadership lessons from Woodrow Wilson. In this Part 1, we look at lessons from Wilson’s formative years in growing up in the South, his educational career, his academic profession and thought leadership; his Presidency of Princeton, his governorship of New Jersey and the Presidential election of 1912. In Part 2 we will take up his Presidential years.
