Categories
The Compliance Life

Ellen Smith – College & Early Career

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 Ellen Smith, who has sat in the chair of a Director of Trade Compliance.

Ellen graduated from Dickinson College in central Pennsylvania in 1989 with a double major in Political Science and International Policy & Management Studies, spending her junior year abroad in Bologna, Italy.  Her first job was  at a family-owned freight forwarding company. After a couple of years, she started night law school in NYC, eventually graduating from John Marshall Law School. Ellen started her family and then moved into the law firm world, starting at a plaintiff’s med mal firm where she learned how to strategically work through a case in a team. Eventually, Ellen switched practice focus back to her trade roots and went to a boutique International Trade firm in Chicago, where she got her feet wet in the International Trade legal space working on many different customs and export issues.

Favorite Adopted Saying “In all due respect…”

Categories
Compliance Kitchen

FinCEN Solicits Comments


The Kitchen discusses the opening of FinCEN Public Comment window on sharing of SARs.

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EMBARGOED!

EMBARGOED! Episode 43: Russia and Iran and China, Oh My!

This week on EMBARGOED!, Brian and Tim cover three of their favorite topics: Russia, Iran, and China. First, they discuss the latest U.S. threat to deploy Huawei-style foreign direct product rule restrictions on exports to Russia. Next, they consider whether it is truly now or never for JCPOA 2.0 and, then, contemplate the future of DOJ’s China Initiative in the wake of a high-profile dismissal. Finally, in the Lightning Round, Brian and Tim go below deck to provide some perspective on recent developments in a Helms-Burton lawsuit targeting major players in the cruise industry and share some quick thoughts on the new U.S. government advisory regarding Burma (Myanmar).

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***

Categories
Innovation in Compliance

A Behavioral Approach to Risk Management with Vera Cherepanova


 
Tom Fox welcomes back Vera Cherepanova on this episode of the Innovation in Compliance Podcast. Vera is an ethics advocate, consultant, author and speaker. She joins Tom to talk about behavioral risks, the steps behavioral scientists take to analyze risk, and strategies from financial institutions that other industries can use.
 

 
Behavioral Risk in The Banking Sector
Behavioral risk is more or less the same across every industry. What is specific to the financial industry however, and banking in particular, is that the individuals work with money. This creates higher risk as the outcomes can be more immediately seen and felt by the customers. 
 
The Regulator’s Role
“The regulator has a very limited role in mandating culture because no regulator can mandate what kind of a culture and organization needs to have,” Vera begins. The compliance regulator can mandate what the culture is, but how that corporate culture is going to be in reality will not be up to them. Speaking specifically of the UK and the Netherlands, Vera expresses that the regulators in these regions have played a largely educational role in the business industries. She gives Tom a few examples of the events the regulators have done in these regions.
 
Assessing Behavioural Risk
Tom asks Vera to talk about some of the practical steps behavioral scientists take when analyzing behavioral risk. Vera cautions that the first thing to understand when applying behavioral science is that interventions don’t always work. The first thing that scientists do is assess risk using a method called ethnography. They want to understand what is really happening inside organizational teams. They focus on subcultures, and then compare that against what is written in policies and regulations. Holistic cultural assessments aren’t done as behavioral scientists concentrate on specific teams. Surveys are also only used to categorize the data the scientists have collected, and to generalize some of their observations. 
 
Strategies To Emulate
The methods financial institutions use to conduct audits are accessible for any industry. Looking into behavioral risk on top of a risk management framework is one concept that can be emulated across industries, as well as using subculture audits. These skills will be modified for each industry but Vera remarks that the basic concepts will be the same across the board.
 
Resources
Vera Cherepanova | LinkedIn 
Studio Etica
European Banks Are Behavioral Risk Pioneers. No, Really
 
 

Categories
Daily Compliance News

February 1, 2022 the Not Fit For Purpose Edition


In today’s edition of Daily Compliance News:

  • Cardinal Health to pay $13MM for FCA claim. (Reuters)
  • Junior auditor liability in UK.  (WSJ)
  • Corruption in Latin America growing. (Miami Herald)
  • Mike Lynch attacks extradition treaty. (DailyMail)