Day: May 15, 2023

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Multiplying the Influence of Compliance

What if you could multiply the impact and effectiveness of your compliance program throughout your company? That would be a great boon to any compliance practitioner and compliance program. It is also possible by considering a 360-degree view of communications in compliance using multipliers.

Liz Wiseman is the co-author with Greg McKeown of “Multipliers: How the Best Leaders Make Everyone Smarter,” a book about the various types of leaders. They focus on two different types of leaders, Diminishers and Multipliers. Multipliers are leaders who encourage their workers’ growth and creativity, while Diminishers hinder and otherwise keep their employees’ productivity at a minimum.

Now imagine applying this leadership technique as you are trying to operationalize your compliance program fully. If you take this approach of leading by asking questions, you not only guide the functional unit but you get greater buy-in to the entire concept and process as it becomes their process. The non-compliance team may design it and have ownership over it.
Wiseman concluded by challenging each of us to multiply our influence to make those we work with work even better. You can use these skills to operationalize your compliance program more fully. If you do so, you will not only fulfill the requirements of the DOJ, as laid out in the Evaluation, but you will integrate compliance into the DNA of your company by making it a part of how you conduct your business.

Three key takeaways:

  1. Multipliers are leaders who encourage growth and creativity from their workers.
  2. Diminishers hinder and otherwise keep their employees’ productivity at a minimum.
  3. Multiply the influence of the compliance function inside and outside the company in this manner.
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Career Can D0

Mastering Sales With Optimism with James Rankin

Sales is not about being pushy or manipulative; it’s about building trust and relationships. In this episode of Career Can Do, Mary Ann Faremouth interviews sales expert James Rankin about the art of selling and the key skills required to be successful in this field. James is the Chief Marketing Officer for Moody Insurance Group, and the author of over 14 books on sales, training, philosophy, and literature. He has extensive experience in sales and sales management. In this episode, James shares his insights on the power of persuasion, the importance of product knowledge, and the changing landscape of sales in the post-COVID world. He also emphasizes the crucial role of trust in the sales process and highlights the need for salespeople to be ethical and passionate about what they do.

According to James, sales professionals are drawn to the economic opportunities that come with the profession. In sales, a person’s value is directly related to their efforts: this means that they maximize their time. He believes that a salesperson’s optimism and hope are what keep them productive and balanced. On the other hand, many people are afraid to go into sales because of low self-esteem, James tells Mary Ann. He introduces his Diamond Program, which assesses the four areas everyone needs to succeed. These include self-image, self-esteem, meaning, and philosophy. Your self-image is what you see so you’ll never rise above your self-assessment. Your self-esteem is how you feel about what you see, and it’s important to understand your strengths and weaknesses to build your self-esteem. He believes that meaning and purpose are necessary to find satisfaction in your work, and your philosophy is essential in determining your life’s direction.

For corporations to attract and retain salespeople, James believes they must follow Doss’ Theory P formula, which emphasizes preparation, performance, and potential. He also stresses the importance of attitude, skill set, and the ability to present a persuasive presentation. Additionally, corporations should focus on creating a positive company culture, providing opportunities for growth and development, and rewarding their employees for their efforts. By doing so, companies can reduce turnover, which can directly impact revenues.

James emphasizes that salespeople should not only focus on selling, but they should also become experts in marketing. James emphasizes the need for ethics and long-term relationships with clients, and Marianne agrees that trust is the common denominator in any relationship. A solid relationship can turn a client into an advocate and influencer. Social media has become a significant marketing tool, and salespeople must do their due diligence and understand their clients’ needs to build trust.

Resources:

James Rankin Email | LinkedIn | (800) 252-4002, Ext. 114

Faremouth.com

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Corruption, Crime and Compliance

Cryptocurrency and Sanctions Compliance with Matt Stankiewicz

Cryptocurrency has become a popular way to invest and transact, but with that comes the need for sanctions compliance. In this episode, Michael Volkov and Matt Stankiewicz discuss the recent enforcement actions against Poloniex, Bittrex, and Kraken for violating US sanctions regulations with cryptocurrency transactions. Matt is a Partner at Volkov Law and a leading cryptocurrency expert. He and Michael dive into the common themes and basic failures that led to these enforcement actions, including IP blocking, transaction monitoring, and the use of screening tools. They also explore the challenges of compliance when dealing with regions like Crimea and Ukraine, as well as the importance of voluntary disclosure.

You’ll hear Michael and Matt talk about:

  • Cryptocurrency companies are struggling to implement KYC and geo-blocking controls, which is leading to violations involving sanctioned jurisdictions.
  • OFAC is taking an aggressive stance against cryptocurrency companies. Companies in the cryptocurrency industry need to implement effective sanctions compliance programs to avoid hefty fines and enforcement actions from regulatory authorities.
  • There is no materiality requirement for sanctions violations, and even small transactions can result in multimillion-dollar fines.
  • Retroactively applying controls to existing customers is important, and failing to do so can lead to violations.
  • Companies need to have a comprehensive and automated system in place to detect and prevent violations.
  • Companies need to be vigilant about screening individuals and transactions against the relevant sanctions lists, including screening field text, addresses, and ID cards.
  • Geo-blocking for IP addresses is a crucial compliance control, but it is not perfect and can be circumvented by VPNs.
  • Voluntary disclosure of violations can lead to more favorable outcomes and lower fines from regulatory authorities.
  • OFAC and other regulatory authorities are using analytical tools to monitor transactions and flag potential violations, so cryptocurrency companies should not assume they can go under the radar.
  • Companies can use the public blockchain to monitor transactions and identify potential sanctions risks.
  • Sanctions compliance programs should be regularly reviewed and updated to address new risks and changes in regulations.

 

KEY QUOTES
“There are a lot of tools available to these companies to monitor transactions, maybe better than in the traditional finance world, just because everything on the blockchain is public record essentially.” – Matt Stankiewicz

 

“It’s just interesting to see OFAC go so aggressively against these companies. Not too surprising considering the extreme sanctions risk that cryptocurrency poses. Very importantly, there’s still a lot of takeaways that really any industry can take away from these enforcement actions.” – Matt Stankiewicz

 

“If you find problems, obviously you want to remediate them, but figure out what you need to do in terms of voluntary disclosures, because typically you’ll be much better off than if OFAC figures it out on their own, which they usually do.” – Matt Stankiewicz

 

Resources:

Matt Stankiewicz on LinkedIn | Twitter 

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
Daily Compliance News

Daily Compliance News: May 15, 2023 – The Like a Cancer 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:

  • PwC is facing potential criminal actions in Australia. (The Guardian)
  • Binance to UK-regulate us.  (FT)
  • FIFA corruption witness gets no jail time. (Reuters)
  • Who wants to be a CEO. (NYT)
Categories
FCPA Compliance Report

FCPA Compliance Report – Virginia Newman on Enhancing UFLPA Compliance: Solutions for Forced Labor Prevention

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In the latest episode of FCPA Compliance Report, Tom Fox visits Virginia Newman from Miller & Chevalier, an expert on the Uyghur Forced Labor Prevention Act (UFLPA) and supply chain ESG work. Together, they discuss the UFLPA, its affirmative obligation on companies to comply with US import laws, and the burden of proof on businesses to prove their goods were not made using forced labor. Virginia shares valuable insight into the CBP’s enforcement efforts and how companies can exercise reasonable care to avoid having their goods detained. They also delve into trade compliance and third-party screening, predictive mapping, and the long-term changes companies must make to their compliance and sourcing programs. Thomas recommends Virginia as a source of knowledge on the subject because of her passion. Listen to this engaging and informative podcast to better understand the UFLPA and its impact on businesses.

Key Highlights:

  • Virginia’s background and UFLPA
  • US Law Prohibiting Import of Xinjiang-made Goods
  • US Customs’ Role in Enforcing UFLPA
  • CBP’s Forced Labor Technical Expo Solutions
  • Types of Companies for Supply Chain Mapping
  • Impact of a trade war on supply chain compliance

Notable Quotes:

“The US government had an import prohibition for any goods made in whole or in part with forced labor.

“The US import prohibition is one of the longstanding ones that has had the most effect on companies, but it wasn’t enforced too much until about 3 years ago.”

“If your goods are coming from Xinjiang, and you accept that they’re coming from Xinjiang, Then, really, the burden is on you to prove that they’re not made with any forced labor, which is an incredibly high burden and to our knowledge importers have not been trying meet it.”

“Customs put together this enforcement dashboard that contains all of these statistics on how they’ve been enforcing the UFLPA.”

Resources

Virginia Newman on LinkedIn

Miller & Chevalier

Tom Fox

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