The Compliance Kitchen returns with a wrap-up of the week’s top trade and economic sanction issues. In today’s episode, Silvia Surman visits the DOJ revised its Corporate Enforcement Policy and the Kitchen looks at the highlights.
Day: February 10, 2023
How do small towns and rural counties invest in their future? Tom Fox and Andrew Gay explore this topic in their new podcast series Investing in the Future – Developing Leadership in Kerr County. Leadership Kerr County is the premier leadership program in the Hill Country which enables men and women to learn more about the issues and topics that face Kerrville, Kerr County, and the Hill Country on a daily basis; everything from education and social services to economic development and health care. Kerr County has decided to invest in its citizens to create future leaders and lay a foundation for their future involvement in the leadership of Kerrville and Kerr County. This podcast is produced and hosted by the Texas Hill Country Podcast Network.
In our inaugural episode, we visit with Tabor McMillan, current chairman of the Leadership Kerr County Steering Committee. We discuss how his involvement in LKC and his passion for local leadership. He takes pride in living and raising his family here in the Texas Hill Country. Tabor is a local banker here in Kerr County.
Highlights include:
-How did he find out or hear about LKC?
-What was his experience when he was a class participant?
-What was involved with being a class participant?
-How does he feel about our ability in our community to make a difference locally?
Resources
Tabor McMillan on LinkedIn
Andrew Gay on LinkedIn
Tom Fox on LinkedIn
For more information on Leadership Kerr County, click here.
The SEC has continued to emphasize the accounting provisions of the FCPA, specifically the internal controls provisions. The reason is straightforward; a company with rigorous internal compliance controls is better able to prevent, detect and remedy any FCPA violations that may occur. What can you do around the FCPA’s requirements for internal controls and continued SEC enforcement emphasis? You should begin with an exercise where you map the internal controls your company has in place to the indicia of the Hallmarks of an Effective Compliance Program, as set out in the 2020 FCPA Resource Guide. While most compliance practitioners are familiar with the Hallmarks, you may not be as familiar with standards for internal controls. Here, begin with the COSO 2013 Internal Controls Framework as your starting point.
As a CCO or compliance practitioner, this is an exercise that you can engage in at no cost. You simply investigate and note what internal controls you have in place and how they may be a part of your anti-corruption efforts going forward. Compliance is a straightforward exercise; this does not mean that it is easy, you do have to work at it so that you will simply not have a paper, “check the box” program. But using the excuse that you have limited resources is simply an excuse and a rather poor one at that. While the clear lesson from the BHP enforcement action is that you are required to have effective internal controls in place, by engaging in this mapping exercise you can then figure out what you have and, more importantly, what internal compliance controls that you do not have and need to institute.
Three key takeaways:
1. Learn the internal controls your company currently has in place.
2. Map your compliance internal controls to the COSO 2013 Internal Controls Framework.
3. Use your gap analysis as a basis for remediation.
Categories
The Halo Effect
Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network.
Ronnie’s company, Learnings and Entertainment, utilizes the entertainment devices that people use to consume information in their everyday, non-work lives, and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies and resources more accessible.
In this episode, Tom and Ronnie discuss the Halo Effect and its role in compliance communications.
Highlights include:
- What is the importance of making training and comms shorter? What makes it more entertaining, stickier, and helps compliance professionals get increased airtime and exposure, with their messages carried forward.
- The Halo Effect, which is that people are left with a positive impression.
- The Halo Effect is not a residual benefit…it is the benefit!
- The opposite of the Halo Effect is called the Horn Effect…which is that people are left with a negative impression. Hello Compliance!
- Your compliance reputation doe matter.
- In every interaction compliance professionals have with employees and leaders, think about Halo’s and not Horns!
- Maya Angelo once said, people won’t remember what you say, but they’ll remember how you made them feel.
Resources:
- Ronnie Feldman (LinkedIn)
- Learnings & Entertainments (LinkedIn)
- Ronnie Feldman (Twitter)
- Learnings & Entertainments (Website)
- Compliance Confessions – inspired by “Mean Tweets” these 90-second commercials address misconceptions and excuses to promote speak up culture and the E&C team as positive and helpful.
- E&C Training Jams – a soulful singer banters with ethics & compliance explaining policies, sharing examples and debunking excuses.
- Tales from the Hotline – Real speak up-themed stories about workplace behavior gone wrong.
- Workplace Tonight Show! – E&C meets SNL Weekend Update explaining corporate risk topics and why employees should care.
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.
Stories we are following in today’s edition of Daily Compliance News:
- SW blames the weather, and its pilots blame outdated tech. (Reuters)
- 5th circuit says foreigners can be charged under FCPA for work outside the US. (Law360)
- Starting the fight against corruption in schools. (Miami Herald)
- Merck insurers deny payment for cyber-attack based on war exclusion. (WSJ)
