The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Gabe Hidalgo, Managing Director at K2 Integrity and former CCO.
Hidalgo moved into CCO chairs at Community Federal Savings Bank and at Noble Bank International. His role in both of these financial institutions was primarily AML compliance but it included broader compliance roles as well. The biggest lesson was that the ‘buck stops with the CCO’. Ultimately it is your responsibility and you must have accountability of all areas of compliance. As a CCO a key trait is empathy which you must employ in your dealings with other executives and employees. He believes you must connect with your employees.
Resources
Gabe Hidalgo LinkedIn Profile
Gabe Hidalgo K2 Integrity Profile
K2 Integrity
Day: June 15, 2021
Categories
OFAC and Burma
In this episode, the Kitchen checks into the ingredients of OFAC’s new general license for Burma and how did the UK amend its defense and military items open general export licenses.
Are you up and ready to return to the workplace?
Scenario: The CDC has dropped its mask mandate and social distancing guidelines. Your CEO says he wants plans for returning to the workplace (RTW) from each department head in one week. You are in the middle of evaluating your compliance training program, which for the past year has been virtual and remote, and you push to the back burner to get ready to return to the office. One day into that project, you get an email from the CEO who says he wants compliance training to be updated for RTW and, by the way, make it more exciting and relevant.
You call HR and ask if there have been any training evaluation surveys, and it turns out there have not been any, so you don’t know where the CEO’s comment came from.
What are some of the key steps you think about to improve the quality of your compliance training, make it applicable to RTW, make it effective, and most importantly, avoid compliance training fatigue?
Key takeaways in the episode:
✔️ Measures relating to RTW issues. Returning to work presents the perfect opportunity to train (or retrain) everyone on basic COVID practices and compliance responsibilities. Many states and jurisdictions require COVID-specific training before reopening offices.
✔️ Risk ranking employees for compliance training. Determine who needs what training through risk ranking by job duties. Train people on what they need to know and don’t throw extra training at anyone “just to be safe.”
✔️ The benefits of live training. Human interaction is essential. Think about how much richer the context is if you do compliance training at the yearly sales kickoff event, this shows your people the personal element to compliance.
✔️Which is better, a one-hour online course v. monthly 5-minute training videos? Either way works. Adults need to hear information approximately seven times before they remember it. Short, monthly videos would help with that retention. On the other hand, a more extended module would allow for more context and real-world scenarios in training. Both have benefits and takeaways.
✔️ Measure effectiveness with what happens AFTER training — are your people making good choices? Are issues being caught and reported? Do people come to HR/Compliance/Legal with questions/issues/red flags?
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Welcome to SURVIVE AND THRIVE, the newest addition to the Compliance Podcast Network. This is a podcast where we unpack compliance, crisis disasters and walk you through all the red flags which appear, and give you some lessons learned going forward. This show is hosted by Compliance Evangelist Thomas Fox and Kortney Nordrum, Regulatory Counsel & Chief Compliance Officer, Deluxe Corporation.
Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com.
Jedidiah Yueh is Tom Fox’s guest this week on the Innovation in Compliance Podcast. Jedidiah is a data innovator, a best-selling author, and the founder and CEO of Delphix. He has spent the last two decades decoding innovation and collecting and testing frameworks that motivate many successful entrepreneurs in technology. Jedidiah has invented software products worth more than $4 billion in sales. He joins Tom Fox to discuss digital transformation and digital disruption, and what companies need to know and do about both.
Technology, Creativity & Evolution
“What’s interesting about technology today is it’s an incredibly broad white canvas,” Jed begins. Creativity is applied to the development of technology as much as it is to the liberal arts, he tells Tom. “If you think about some of the things that you do as an English major where you’re really looking for these themes and these tropes within works of literature… You have to do that for the world of technology as well.” Tech evolves on so many levels that you have to see and analyze, similar to what’s done in literary analysis.
Digital Disruption
When Jed first ventured into tech, his main objective was finding a concept or product that would give him a competitive advantage. He had the idea of taking the backup data from MP3 players and transitioning that into the technology enterprise. Jed says that he knew that the concept would be disruptive and that it would change the industry. “That’s exactly what happened over the course of a decade,” he tells Tom.
Delphix
Tom asks Jed why he founded Delphix. In Jed’s previous company, a lot of customers had issues where they had to be restoring data to other locations to be able to use it. The demands for data efficiency had risen. Jed created Delphix to answer this market need. “The idea was we wanted to build a new architecture that was focused on enabling the multi-use of data for all of these strategic and valuable use cases that drive innovation and differentiation for companies,” he remarks.
COVID-19 & Beyond
The pandemic and the relocation to remote work was a profitable opportunity for Jed’s company. There was an acceleration of digital transformation. Tom asks Jed what companies need to focus on in the coming years. “I think companies really need to focus on what is real digital transformation and what is not,” Jed remarks. Real digital transformation changes the way your business operates. The overall ecosystem of the business has to be transformative. “If a company doesn’t engage in a digital transformation and make its own data available to itself to make their business processes more efficient, frankly they’re going to be left in the dust by their competitors who do so.”
Resources
Jedidiah Yueh | LinkedIn | Twitter
Delphix
Introducing The ESG Report with Tom Fox
ESG has exploded into compliance and business consciousness in 2021, so as a compliance industry professional, you need to be up to date. To open up the show, Tom Fox is speaking with Trysha Daskam, the Head of ESG Strategy at Silver, a premier provider of regulatory compliance, ESG and due diligence advisory services to the investment management industry. She and Tom are talking about regulatory shifts, the G7, trends in reporting and key risk areas.
Trends and Shifts at Home and Abroad
Trysha talks about how ESG stakeholders in the states have been paying close attention to what is happening in the EU, and specifically regulations that are coming out of the European Commission. She talks about what they mean for American companies and other entities. Investors are very interested in the indirect impacts from what is happening across the pond. She goes on to talk about the first ESG alert that is identifying the riskiest practices in the space.
The G7 Summit
The early focus of ESG was on the link between environmental and investment risk, but it is much broader now. Tom and Trysha discuss the climate conversation, the focus of the Biden administration, and the different governmental and other bodies involved in it. Of particular interest is the strong stance the G7 leaders took on the Task Force on Climate Related Financial Disclosure.
The Business Case for ESG Analysis
Tom and Trysha talk about the portfolio of ESG risks, and how there was a shift from looking at it as primarily environmental to a much broader spectrum of risk. There are hundreds of factors that fall under the ESG profile, and investment managers are looking at them to fully understand the benefits and risks of different opportunities. A strong focus on governance has been a hallmark of being a manager to other people’s assets. Trysha shares an example about Exxon Mobile, and their lack of transparency about risk in the Gulf Coast.
Resources:
Silver Regulatory Associates
How EU Climate Regulations May Affect US Private Fund Managers
In this edition of Cordery Head to Head @ Home Cordery’s Jonathan Armstrong talks to Don Smith.
They talk about how Don first became involved in looking at cyber threats and information security. They talk about current threats including ransomware and the distributed nature of ransomware gangs.
Don is the Director of SecureWorks’ Director Counter Threat Unit-Cyber Intelligence Cell (CTU-CIC) where more than 70 researchers constantly monitor more than 135 threat actors involved in cybercrime.
There are some thoughts from Cordery on ransomware and the legal and regulatory aspects at https://www.corderycompliance.com/client-alert-ransomware-covid19-and-upgrading-defences/.
Don’s contact details are here https://www.ncsc.gov.uk/organisations/dell-secureworks and you can keep up-to-date with current events with the SecureWorks blog here https://www.secureworks.com/blog.
You can find out more about Cordery and its work here https://www.corderycompliance.com/. You can also read about current issues in dealing with the pandemic here https://www.corderycompliance.com/category/covid19/including our thoughts on data security issues during the pandemic here https://www.corderycompliance.com/coronavirus-covid19-and-dp/ You can also find out more about Cordery’s experience of cybersecurity issues here https://www.corderycompliance.com/cyber-security/
You can view more Cordery Head to Head interviews here http://bit.ly/corderytv and you can listen to audio feeds from our favourite films as a podcast here https://bit.ly/ch2hpodcast.
Jonathan mentions the BBC’s Lazarus Heist podcast which is here https://www.bbc.co.uk/programmes/w13xtvg9
