Day: June 7, 2023

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Trekking Through Compliance

Trekking Through Compliance-Episode 6-Mudd’s Women

In this episode of Trekking Through Compliance, we consider the episode Mudd’s Women, which aired on October 13, 1966, Star Date 1329.1.

Harry Mudd attempts to evade the Enterprise with his small class J cargo ship and leads it into an asteroid field. The Enterprise extends its shields over Harvey’s ship, burning out three of its four lithium crystals. The crew of the Enterprise becomes fascinated with the three beautiful women Mudd has been transporting.
As a result of the destruction of three of its lithium crystals, the Enterprise is forced to divert to Rigel 12 to obtain new crystals. Mudd makes his bargain with the lithium miners on the planet. At Mudd’s prompting, the miners offer to provide Kirk with lithium only in exchange for Mudd’s freedom and the three women. Kirk learns the women’s beauty secret: Mudd has been providing them with the Venus drug. Kirk beams down to collect the lithium from Childress while providing Evie with red gelatin she believes to be the Venus drug. Evie believes herself again to be beautiful and unintentionally reveals her natural inner beauty. In the end, Kirk gets his lithium, Evie remains with Childress, and Mudd is taken into custody.
Compliance Takeaways:
  1. How can your risks change, and are you prepared?
  2. A CCO needs to understand you may not be telling the truth to them.
  3. Have you added the Modern Slavery requirements to your compliance regime?
Resources
The story synopsis comes from the Excruciatingly Detailed Plot Summary by Eric W. Weisstein for Mudd’s Women.
Additional insights from the MissionLogPodcast.com episode Mudd’s Women
Categories
Great Women in Compliance

Great Women in Compliance – Carolyn Renzin on Compliance at FanDuel

Welcome to the Great Women in Compliance Podcast, hosted by Mary Shirley and Lisa Fine.

Over the past few years, it seems like fantasy sports and online gaming have a higher profile than ever, and they are part of a rapidly growing industry. Today’s guest, Carolyn Renzin, is the Chief Legal and Compliance Officer at FanDuel, which is one of the leaders in that space. In a wide-ranging discussion, Carolyn and Lisa discuss building a compliance function at the same time an industry framework is being built, and how she has grown her team. She also talks about FanDuel’s commitment to integrity – both as an organization and for professional sports in general.

Her analogy between sports and her role is one we can all keep in mind – “you play offense, we play defense, and we need each other.”

You can find the Great Women in Compliance Podcast on the Compliance Podcast Network where you can find several other resources and podcasts to keep you up to date in the Ethics and Compliance world. You can also find the GWIC podcast on Corporate Compliance Insights where you can learn more about the podcast, stream prior episodes and catch up on Mary’s monthly column “Living Your Best Compliance Life.”

Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program with Boards – The Board Compliance Committee

Under the U.S. Sentencing Guidelines, the Board must exercise reasonable oversight on the effectiveness of a company’s compliance program. The DOJ Prosecution Standards posed the following queries: 1) Do the directors exercise independent review of a company’s compliance program? and 2) Are directors provided information sufficient to enable the exercise of independent judgment? Moreover, the  FCPA Resource Guide, 2nd edition required a CCO to have direct access to the Board or an appropriate sub-committee and requires a tangible commitment from the top levels of an organization, starting with the Board of Directors, that the company creates an ethical culture.

This requirement was brought forward in 2017 in the FCPA Corporate Enforcement Policy. Finally, nn the 2020 Update to the Evaluation of Corporate Compliance Programs, under the section entitled Oversight, it posed the following questions What compliance expertise has been available on the board of directors? Have the board of directors and/or external auditors held executive or private sessions with the compliance and control functions?
Today’s regulatory climate and hyper-transparency in social media make a Board Compliance Committee’s task seem Herculean. But more than simply the regulatory climate, shareholders are taking a much more active role in asserting their rights against Boards of Directors. It is incumbent that Boards seek out and obtain sufficient information to fulfill their legal obligations and keep their company off the front page of the New York Times, Wall Street Journal or Financial Times, just to name a few, to prevent serious reputational damage. A Board Compliance Committee is a good place to start.
Three key takeaways:

  1. The Board Compliance Committee exists to provide oversight and assist the CCO, not to substitute its judgment for that of the CCO.
  2. The Board Compliance Committee should work to hold the CCO accountable to hit appropriate metrics.
  3. The Board Compliance Committee is ideal for leading the efforts around strategic planning.

For more information check out The Compliance Handbook, 3rd edition, available from LexisNexis here.

Categories
Daily Compliance News

Daily Compliance News: June 7, 2023 – The Built on Non-Compliance 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.

  • SEC brings an action against Coinbase for allowing trading of unregistered securities. (NYT)
  • SEC brings an action against Binance for commingling of funds. (NPR)
  • Argentina corruption case against Cristina Fernandez is dismissed. (AP)
  • Gensler says crypto built on ‘non-compliance’. (FT)
Categories
Compliance Into the Weeds

Compliance into the Weeds: Compliance and Middle Managers

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Join Tom and Matt as they delve into middle managers’ crucial role in fostering a culture of ethics and compliance within organizations. In this episode, the hosts discuss compliance officers’ challenges in working with middle managers and share some practical tips on building alliances, teaching soft skills, and developing personal relationships. They also examine the use of incentives and consequence management in promoting compliance and highlight the need for positive incentives for middle managers. Take advantage of this insightful and thought-provoking discussion on enforcing internal controls in a compliance program and learn more about the different ways to ensure compliance in gift travel and entertainment expenses. Tune in now to stay ahead in the world of compliance!

Key Highlights:

  • The Role of Middle Managers in Compliance
  • Training Middle Managers on Ethical Leadership
  • Investing in middle managers for ethical conduct
  • Compliance: Incentives and Consequence Management

 Notable Quotes:

“Compliance officers need to think about because you live and die in the success of your corporate culture, and the middle managers are the custodians of that culture.”

“Compliance officers should think about how do I help middle managers. How do I coach them on how to be good leaders?”

“Nothing is as significant as that personal touch point.”

“If the middle manager either turned a blind eye to the unethical practice or should have known about it but was just so aimless about it and didn’t care, should that middle manager suffer consequences along with the frontline employees who committed the offense? And the answer was generally yes.”

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn