Day: February 24, 2023

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Compliance Kitchen

Compliance Kitchen – Navigating OFAC’s Latest Guidance on Russia’s Metals and Mining Sector

The Compliance Kitchen, hosted by Silvia Surman, is a podcast that examines and evaluates the changing legal framework of international compliance. In this episode, Silvia examines OFAC’s brand new determination concerning the metals and mining sector of the Russian Khanate. She provides listeners with an FAQ about the determination and explains that it authorizes certain energy-related transactions or if General Licensed 6C only authorizes those activities. Silvia further elaborates that the license authorizes transactions related to the production, manufacturing, sale, transport, or provision of medicine and medical devices. Tune into Compliance Kitchen to stay updated with the evolving legal framework of international compliance.

Notable Quotes

1. “This February 24 determination authorizes sanctions on any person that the government determines to operate or have operated in the metals and mining sector of the Russian economy.”

2. “OFAC does not intend to target persons for operating in this metals and mining sectors where the provision of their goods and services is solely for safety and care of personnel protection of human life, prevention of accidents or injuries, maintenance, necessary repairs, to avoid significant or environmental damage or activities that are related to environmental mitigation or remediation.”

3. “Non-US persons generally do not risk exposure to US blocking sanctions. Under executive order 14024 for engaging in transactions with black persons, including in the metals and mining sector where those transactions would not require a license if a US person were engaging in the transactions.”

4. “Non-US persons generally do not risk exposure to US blocking sanctions if they engage in transactions in the mining and metals sector. If General License 8F would normally authorize such transactions as in Frank. That 1 authorizes certain energy-related transactions or if General would only authorize those activities Licensed 6C. That license authorizes certain transactions related to the production, manufacturing, sale, transport, or provision of medicine, medical devices, including certain industrial isotopes used in nuclear medicine.”

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Investing in the Future

Investing in the Future – Episode 3 – Wynita Yancy

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 daily; 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 3rd episode, we chat with Wynita Yancy, a current class participant in Leadership Kerr County. Wynita is currently the Director of Marketing and Community Relations at The Hill Country Youth Ranch just outside Kerrville, Texas. Wynita is originally from Chicago and has been here in the Texas Hill Country just over a year now and takes great pride in the impactful work she is doing here for The Hill Country Youth Ranch, the kids’ lives they serve, and in our local community.

Highlights include:

-What led Wynita to find and apply to Leadership Kerr County?

-As a current class participant, what has been a standout experience thus far?

-What impact has the class had on her so far?

-In her perspective, what’s the difference between being involved in a community like Kerr County versus a larger community where she was involved previously (Chicago)?

Resources

Wynita Yancy on LinkedIn

Andrew Gay on LinkedIn

Tom Fox on LinkedIn

For information on The Hill Country Youth Ranch, go here

Categories
31 Days to More Effective Compliance Programs

One Month to More Effective Internal Controls – COSO Objective V: Monitoring Activities

The fifth and final Objective is Monitoring Activities. As with all other components of the COSO Cube, Monitoring Activities are part of an interrelated whole and cannot be taken singularly. Monitoring Activities have grown in importance for the CCO or compliance practitioner over the past few years. They will continue to do so in the future, as is reinforced in the COSO 2013 Internal Controls Framework.

The Monitoring Activities objective consists of two principles: 1) The organization selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning, and 2) the organization evaluates and communicates internal control deficiencies timely to those parties responsible for taking corrective action, including senior management and the Board of Directors, as appropriate.

Principle 16: Ongoing evaluation.
Principle 17: Evaluation and communication of deficiencies.

Monitoring Activities should bring together your entire compliance program and tell you whether it is running properly. The CCO and compliance practitioner should use both ongoing monitoring and auditing in support of this objective.
The most important item is that all the controls must be sustainable. You cannot just build one-off controls and not have a process to help you monitor all the controls you need to cover. Controls cannot just be a one-and-done. Many companies will find that their initial approach to this is one-and-done.
There must also be a mechanism to communicate controls that do not work or can readily be overridden. From there, you must be able to remediate your controls going forward. This will align with the compliance professional’s requirement to prevent, detect and remediate going forward.
Three key takeaways:

  1. Monitoring activities are interrelated with all other Principles and cannot be taken singularly.
  2. Monitoring activities helps to ensure that all controls are present and functioning.
  3. Monitoring Activities should bring together your entire compliance program and tell you whether it is running properly.
Categories
Creativity and Compliance

Do It Right Rick and Creating a Custom Character

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – 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 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 visit with Katherine Hill, Legal Compliance Manager at Ferguson Enterprises. We discussed the compliance program rebranding that Ronnie and his creative team at Learnings & Entertainment helped Katherine put together. They discuss the unique challenges for a blue-collar workforce and how Learnings & Entertainment was able to help Katherine and her team drive engagement through the creation of ‘Do It Right, Rick.’

Highlights include:

  • Why a Custom Character?
    • Improving the image
    • putting a friendly face on the program
    • highly customized messaging
  • What was involved?
    • Brainstorming and coming up with the ideas
  • How is it being deployed?
  • Lessons Learned.

Resources:

  • 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.
  • 60-Second Communication & Awareness Shorts – A variety of short, customizable, music and multimedia, quick-hitter “commercials” promoting integrity, compliance, speaking up, and the E&C team as helpful advisors and coaches.
  • Custom Live & Digital Programming – Custom creative programming that balances the seriousness of the subject matter with a more engaging delivery. After all, you can’t bore people into learning.
Categories
GalloCast

Gallocast – Episode 7

Welcome to the GalloCast. You have heard of the Manningcast in football. Now we have the GalloCast in compliance. The two top brothers in compliance, Nick and Gio Gallo, come together for a free-form exploration of compliance topics. It is a great insight on compliance brought to you by the co-CEOs of ComplianceLine. Fun, witty, and insightful with a dash of the two brothers throughout. It’s like listening to the Brothers Gallo talk compliance at the dinner table. Hosted by Tom Fox, the Voice of Compliance.

Tom Fox peppers questions to Nick Gallo and Gio Gallo from Ethico with topics like what companies should consider doing business in Ukraine and how to identify great business risks. They also provide an understanding of compliance, changing human behavior, and techniques to get around ethical controls. Topics are spiced up with references to the recent Pope’s speech and technological advancements. Be sure to tune in, and don’t miss out on the brothers’ educational insights and witty dialogue.

Key Highlights

·       Logistical Challenges of Working in Ukraine –[00:04:00]

·       Compliance as an Opportunity to Manage Business Risk – [00:07:20]

·       The Role of Persuasion in Ethics and Compliance -[00:10:40]

·        US Semiconductor Industry Moves Away from Supply Chains – [00:13:43]

·        Risk Assessment and Crowdsourcing -[00:17:00]

·       The Ineffectiveness of Risk Assessment Strategies – [00:20:30]

·       Behavioral Psychology in Compliance Programs and Compliance Discipline -[00:23:50]

·       CEO Understanding of Compliance and Its Impact on Budgeting -[00:27:00]

·       The Benefits of Exploring Different Perspectives Through Reading -[00:29:52]

·       The Ethical Implications of AI-Generated Content – [00:36:25]

·       The Impact of Technology on the Economy – [00:39:37]

·       The Power of Simplifying Your Policy with Technology –[00:42:40]

·       Pope’s Condemnation of Corruption – [00:46:02]

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Categories
Daily Compliance News

February 24, 2023 – The Just Say No—To Drag Shows Edition

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:

  • The State of Tennessee seeks to restrict drag shows. (Reuters)
  • After the assassination attempt, the Eskom chief fired. (FT)
  • Mom is always there when you need her. (FT)
  • Not a bribe, just an open-ended loan that was never repaid. (Ohio Capital Journal)