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The Compliance Life

Audrey Harris-Academic Career and Early Professional Background in FCPA Investigations

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 navigate the compliance waters in any company successfully? 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 Audrey Harris, who handled FCPA cases before the explosion of FCPA enforcement actions in the early 2000s, sat in the CCO Chair, led compliance program work back in private practice, and now as Managing Director for Global Anti-corruption, Compliance, Ethics & Non-Financial Risk at Affiliated Monitors Inc.

Audrey graduated from Central Florida with a BA, got a MA at the University of Miami, and her law degree from Georgetown. A question about whether she wanted to go to South Beach when she was a summer clerk at Kirkland & Ellis led to FCPA work and eventual partnership at Kirkland. When she began, it was a different time in FCPA enforcement, pre-2004, and the explosion in FCPA growth. In this role, she loved problem-solving and seeing patterns, and asking why (and why and why).

Resources

 Audrey Harris on LinkedIn

Audrey Harris on Affiliated Monitors, Inc.

Categories
Compliance Kitchen

UK Sanctions on Russia


This week the Compliance Kitchen is looking at sanctions levied on Russia because of its invasion of Ukraine. Today, the UK’s first wave of sanctions on Russia in regards to Ukraine.

Categories
The ESG Compliance Podcast

Optimizing ESG Opportunity in the Pandemic with Laura Tulchin


Consulting expert Laura Tulchin passionately advocates the implementation of ESG, working in the mantra of “minimizing risk today means optimizing opportunity.”
In this episode, she dives deep into the growing significance of ESG in the pandemic, the social and monetary advantages, the cruciality of regulation, and how ESG is looking into the future.
▶️ Optimizing ESG Opportunity in the Pandemic with Laura Tulchin
Key points discussed in the episode:
✔️ Laura Tulchin summarizes her professional and educational background.
✔️ Laura Tulchin explains the increasing relevance of ESG in the past two years. Companies with perceived good ESG performance are financially outperforming their competitors.
✔️ESG gains steam in today’s fractured social and capitalist system. Consumers are seeking purpose, even in the way they spend their money. Transparency in ESG is enough incentive for companies to step up.
✔️ The formation of the International Sustainability Standards Board in the 2021 UN Climate Change Conference was a step forward for ESG standardization. Laura Tulchin believes that we still have a long way to go. A hodge-podge of voluntary standards still remains in the ISSB, along with jurisdictional regulations in the EU.
✔️ Interpretation and analysis – or looking under the hood – are still challenging in ESG reporting. The necessary tools needed to achieve a higher level of transparency aren’t readily available. Some businesses resort to presenting a positive but generalized report to gain mass favor.
✔️ ESG isn’t a one-size-fits-all program. It’s bound to be managed in different ways across industries.
✔️Compliance lays a strong foundation for a good ESG program.
✔️ ESG should be an accurate portrayal of an organization’s social and environmental impact.
✔️ ESG isn’t just about saving the elephants. It’s also about saving your dollars. Running an ESG program brings long-term profit. Nowadays, consumers are more conscious of who they’re buying from and whether products are ethically sourced and manufactured.
✔️ ESG would soon become a natural business practice.
Laura Tulchin is an MBA with expertise in ESG risk, compliance, and governance. She has extensive experience with investment professionals, large multinationals, and financial institutions in managing risk and bringing the right frameworks, processes, and tools for risk management. She is hands-on with big-data and technology implementation experience to help clients determine strategic vulnerabilities and use data effectively to understand, measure and mitigate risk.
Connect: https://www.linkedin.com/in/laura-tulchin-b5577611/

Categories
Innovation in Compliance

The Data Confident Internal Auditor with Yusuf Moolla


 
Tom Fox welcomes Yusuf Moolla on this episode of the Innovation in Compliance Podcast. Yusuf is a Director at Risk Insights, co-cost of The Assurance Show Podcast, and co-author of The Data Confident Internal Auditor. He joins Tom to talk about how compliance professionals can utilize data analytics, data governance, and internal auditing.
 

 
Best Approaches To Data
The easiest way to approach data, Yusuf suggests, is to think about it as another form of evidence. “Over the years we’ve collected lots of manual documents as evidence…Data is just another piece of evidence,” he tells Tom. Data can be used by anybody, and it is very simple to do so. Currently, there has been an emergence of open-source tools to process data which has made it easier and cheaper for individuals. These open source tools have made it safer as well, as there are options to look into the source code for digital traps. Visualization is another approach to data that individuals can utilize. While relatively new, being able to visualize techniques both in terms of exploring and explaining data is becoming something that is gaining traction in the data analytics world. 
 
Internal Auditing Approaches
Yusuf explains to Tom that there are four main data approaches to consider when doing internal audits:

  • Data being used purely for reporting
  • The data-driven approach where the data does the talking
  • The process-focused approach
  • The hypothesis-focused approach

There are similarities between the process and hypothesis approaches. The process-focused approach has been the traditional way of doing audits. Over the years, however, it’s become less about how the process is done to achieve the intended result; it’s now about what the auditing result is. “So it’s not about looking at whether a process actually works the way that it’s been designed, it’s about looking at whether the process is working in the way in which it’s intended to be able to achieve its outcome,” Yusuf adds. 
 
Data Governance in Auditing
Making sure that data doesn’t fall into the wrong hands as an auditor is one of the main facets of data governance. It is a very basic and traditional approach, but over the years professionals have been implementing it in an overzealous way. This can hinder the ability to create value through data. Yusuf suggests a slight reverse approach where everyone has access to data unless there is a specific reason for them not to. “We want to keep a range of data elements secure, but others we want to open up,” Yusuf tells Tom. 
 
A Look Ahead
Tom asks Yusuf what the future of data analytics, data governance, and internal auditing will look like in the coming years. Yusuf explains that there will be a greater use of data science, and a greater use of data within internal audit without the need for data scientists and specialists. More practitioners will be getting into, and understanding IT, and more people will be using data for themselves. This will free the data scientists from the more mundane tasks, so they will have time to dedicate to the more advanced techniques. The same would apply for compliance as well. 
 
Resources
Yusuf Moolla | LinkedIn
Risk Insights
The Assurance Show
The Data Confident Internal Auditor
 

Categories
Daily Compliance News

March 1, 2022 the We’ re No. 2 Edition


In today’s edition of Daily Compliance News:

    • According to TI-CPI, Nigeria second most corrupt country in West Africa. (Business Insider Africa)
    • How allowing corruption corrupts those who allow it.  (The Guardian)
    • Gertler offers deal to end corruption investigations. (Haaretz)
    • Leak broke Ericsson corrupt payments to ISIS. (ICIJ)