Categories
The Compliance Handbook

GWIC on Best Practices in Policies and Procedures

In this episode of The Compliance Handbook, I asked the Great Women in Compliance (#GWIC) co-hosts Mary Shirley and Lisa Fine to talk about some of their best practices around written standards for a compliance program.
The definition of a successful compliance program is not foreign for many compliance specialists. However, the challenge is to understand what it truly means for a compliance program to be effective.

Most organizations claim that the central meaning of compliance is to define and enforce guidelines and standards that can minimize the possibility of a violation of compliance. Though, the truth remains that if misconduct exists, your attempt to highlight that your compliance policy conforms with regulatory requirements will increment your culpability score and contribute to a noticeable difference in fines and jail time.
To help you paddle through your compliance programs, I recently met two influential women in compliance, Lisa Fines and Mary Shirley. These phenomenal women will add transparency to these ethics and compliance concerns. We will dive into written compliance and touch base on #GWIC (Great Women In Compliance) and how it has become a powerful platform that supports compliance practitioners.
Key takeaways discussed in the episode:

  • Know what is written compliance inside out. Understand that everybody needs to know what the rules are. But, it should not be lawyer-written, 20 pages long. Use the simplest terms possible, break things down to the absolute essential thinking.
  • Call to mind that the code is our ethos, and the policies are the regulations to explain them. If possible, get your message across in the shortest possible time using the least words possible.
  • Hark back to the truth that there is no one size fits all compliance program. Thus, make learning come to life and apply it to people’s job roles. As much as possible, tell people what the expectations are and help facilitate their decision-making.
  • Factor into that it’s natural to maintain your relationships with former colleagues, but It’s not okay and could be risky if you talk shop with them.
  • Support Women Empowerment and appreciate their contributions, especially in compliance. Learn how #GWIC grew into a community of great women who share valuable resources and support compliance practitioners.

The Compliance Handbook, 2nd Edition incorporates the most current government pronouncements governing best practices compliance programs, including the 2019 Evaluation of Corporate Compliance Programs released by the Fraud Section of the Department of Justice, and its 2020 Update; the updated FCPA Resource Guide 2nd edition; the Framework for OFAC Compliance Commitments; and the 2019 DOJ Antitrust Division’s Evaluation of Corporate Compliance Programs in Criminal Antitrust.
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Categories
MoForecast

MoForecast: Predictions on the FCA


In this episode of MoForecast, Morrison & Foerster partner James Koukios speaks with fellow partners Brian Kidd and Alex Ward about what to expect in the False Claims Act (FCA) space under the new Biden Administration.

The MoForecast podcast series, produced by global law firm Morrison & Foerster, looks into what we saw in the legal landscape under the Trump administration and how policies might change under President Biden by leveraging the firm’s decades of private practice experience and insight from former government roles. Discover more MoForecast episodes.
About the Speakers
James Koukios is co-chair of Morrison & Foerster’s Securities Litigation, Enforcement, and White Collar Defense Group and serves as co-head of the FCPA + Global Anti-Corruption Practice. James represents companies and individuals in high‑stakes government enforcement actions and complex internal investigations. He previously served as a federal prosecutor at the U.S. Department of Justice (DOJ), where he was the lead prosecutor in two landmark FCPA related trials: United States v. Esquenazi and United States v. Duperval. While at DOJ, James also served as lead prosecutor in United States v. AEY Inc., a defense procurement fraud and export licensing case that served as the basis for the 2016 film War Dogs. He also previously served as Special Counsel to then-FBI Director Robert S. Mueller, III.
James is joined in this episode by:

  • Alex Ward, partner in Morrison & Foerster’s Washington, D.C. office and co-chair of the firm’s Government Contracts and Public Procurement practice
  • Brian Kidd, partner in Morrison & Foerster’s Washington, D.C. office and former Chief of DOJ’s Market Integrity and Major Frauds Unit

The Morrison & Foerster team is made up of talented defense lawyers, including many who once served as prosecutors and regulators. The team helps firm clients resolve their legal issues by immersing themselves in how their clients think and operate. Learn more about the firm’s Investigations + White Collar Defense, False Claims Act, and Government Contracts + Public Procurement groups.
 

Categories
Innovation in Compliance

Business and Financial Fraud: Yesterday, Today, and Tomorrow: Part 3 – Best Practices in Fraud Prevention


Welcome to a special five-part K2 Integrity sponsored podcast, series Business and Financial Fraud: Yesterday, Today, and Tomorrow. In this series I am joined by Joanne Taylor, a Managing Director at K2 Integrity. She has 20 years of legal, investigations and financial crime compliance experience, working within the financial and legal services industries. I am also joined by Ray Dookhie, a Managing Director in K2 Integrity’s Investigations and Risk Advisory practice, with more than 25 years of experience in compliance, integrity risk monitoring and management, and investigations. Over this series, we will consider the top fraud trends you might expect to see in 2021, what the regulatory landscape may well look like in 2021, best practices in fraud prevention, how to detect fraud and responding to fraud once it is uncovered. In Part 3, Ray Dookhie reviews best practices in fraud prevention.
Join us tomorrow in Part 4 where we look at strategies for detecting fraud.
For more information on K2 Integrity, check out their website here.

Categories
Great Women in Compliance

A Mary Soliloquy


Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
We love getting inspiration from great places and what a better a place to gain inspiration for an episode than one of our sister podcasts on the Compliance Podcast Network?!  In this week’s episode, Mary channels the Everything Compliance team and walks through her list of rants and raves for the moment.
We boo misogyny in the workplace (and well, everywhere if we’re frank), erosion of Chief Compliance Officer authority and treating job seekers with disrespect.
We celebrate male allies of feminism in Compliance, those volunteering for Compliance Career Connection and all of our listeners who keep an open mind as to different perspectives while investing in growth and professional development.
We like to share advice and tips on the podcast via our learned guests but some things don’t have immediate answers, including some aspects of what we’ve canvassed today.  If you’d like to share your thoughts on the issues raised, we invite you to connect with us at GWICpod@gmail.com.
The Great Women in Compliance Podcast is proudly featured on the Compliance Podcast Network and sponsored by Corporate Compliance Insights.  If you enjoyed this episode please subscribe to the podcast and rate it on your podcast player to help other compliance professionals find it.  Want to hear more from us?  We have a book, “Sending the Elevator Back Down: What We’ve Learned from Great Women in Compliance” (CCI Press, 2020) which is available on Amazon.com and Book Depository.
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 are 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.
You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.
Join the Great Women in Compliance community on LinkedIn here.

Categories
Compliance Into the Weeds

The SEC and Climate Disclosures


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. This week Matt and Tom take a deep dive into the recent announcement by the SEC that it would start paying more attention to companies’ climate change disclosures.  Some of the issues we consider are:

  • What did acting Chairman Allison Herren Lee announce?
  • A review of the 2010 Climate Guidance
  • What changes might be in the offing?
  • What will the SEC process be going forward?
  • What frameworks might the SEC use as a guide?
  • What does this mean for the compliance function?
  • What are the compliance lessons? 

Resources
Matt’s blog post on Radical Compliance:
SEC Fires Warning Shot on Climate Disclosure

Categories
Daily Compliance News

March 3, 2021, the Uncomfortable Truths edition


In today’s edition of Daily Compliance News:

  • Biden Administration sanctions Russia for poisoning of Navalny. (WSJ)
  • Gun industry lawsuit over false claims in advertising. (NYT)
  • Nike exec quits over COI. (BBC)
  • Gensler testifies. (WaPo)