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Great Women in Compliance

Great Women in Compliance – GWIC 2.0- Introducing Lisa’s New Co-Host Lloydette Bai-Marrow

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

As part of the countdown to 200, Lisa and Mary have their last two episodes before the GWICies and the summer hiatus before GWIC 2.0.  Today, we get to announce our new co-host, Lloydette Bai-Marrow, who was featured in Episode 110.  She is the founding partner of Parametric Global Consulting ,a former prosecutor at the UK’s Serious Fraud Office, is a member of the Board of Spotlight on Corruption, a UK-based anti-corruption charity that tracks how the UK implements its anti-corruption laws and has a commitment to anti-corruption in Africa and particularly Sierra Leone.

She is also committed to sending the elevator back down and our community.  In the episode, she discusses how she decided to make time to add co-hosting this podcast to her full plate, and some of her ideas for GWIC 2.0.  Lloydette also talks about the impact that Mary has had in the E&C world, and how that inspired her to join Lisa on the journey.

We are very excited about this next phase for all of us, including Mary’s upcoming book and her ongoing column at Corporate Compliance Insights!

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.

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Blog

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 3-Defining the Effectiveness of Compliance Training

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer Success at Diligent; Kevin McCoy, Customer Success Manager at Diligent; Jessica Czeczuga, a Principal Instructional Designer; Andrew Rincon, Global Accounts Management Advisor at Diligent; and David Greenberg, former CEO and Special Advisor at LRN and Director at International Seaways. Over this series, we will consider the importance of ongoing communications, the value of targeted training, training third-parties, and the role of the Board of Directors. In this Part 3, we consider the always challenging topic of defining the effectiveness of training with Jessica Czeczuga.

The Department of Justice (DOJ) requirement for ‘effective’ training is one of the most challenging areas for compliance professionals. Fortunately, Jessica Czeczuga is a highly respected Principal Instructional Designer with a remarkable 25-year career in the learning and development field and as a seasoned content creator, Jessica has collaborated with numerous experts to create effective training programs that resonate with different learning styles. I was able to visit with her on some of the key steps to get Improved training effectiveness through micro-learning and metrics.:

1. Adopt micro-learning techniques for content delivery
2. Utilize interruptive training methods for behavior disruption
3. Tailor targeted training for at-risk employees

1. Adopt micro-learning techniques for content delivery. Adopting micro-learning techniques is an essential approach for effectively delivering content to learners, particularly in the realm of compliance training. Micro-learning encompasses the practice of focusing on quick, digestible, and repetitious bursts of learning that serve to reinforce essential concepts while being easily accessible to learners. This method deviates from traditional lecture-style training, power point induced traing and allows for an interruptive and integrative learning experience that caters to the needs of varying learners. Leveraging micro-learning as a tool for training purposes allows for a higher likelihood of information retention and eventual behavior modification, as it allows individuals to reflect on their own learning patterns and apply the concepts in a more seamless way.

Czeczuga believes that by utilizing metrics such as pre and post-test scores and survey feedback to determine the effectiveness of training and cater the approach accordingly, highlighting the importance of collaboration between the compliance and training departments in this process. The adoption of micro-learning for compliance training holds significant importance as it ensures that all employees have a comprehensive understanding of relevant concepts and principles. Given that this understanding forms the basis of an organization’s culture of compliance and ethics, it is crucial to ensure that the training methods employed are effective in communicating this information.

2. Utilize interruptive training methods for behavior disruption. One essential approach to keep in mind when implementing compliance training is the use of interruptive training methods for behavior disruption. Interruptive training takes the form of quick, simple, and repetitious bursts of learning that are easily accessible and cater to different styles of learning. This approach allows for content delivery that is geared towards disrupting employees’ routine and thought patterns to promote engagement, behavior change, and a deeper understanding of the material.

Czeczuga noted this approach can be especially beneficial for sending general compliance messages like anti-bribery or corruption communications to a broad audience. Additionally, she related that pre and post-tests can provide useful metrics to determine the effectiveness of the training, while surveys can offer additional insights into how well the content is resonating with employees. In this way, interruptive training methods not only serve to catch employees’ attention and disrupt thought patterns but also allow for a more objective assessment of training success.

3. Tailor targeted training for at-risk employees. In recent years, there has been a significant shift towards more targeted and efficient training methods, particularly for at-risk employees. As a result, targeted training for at-risk employees ensures that they receive the specialized instruction they need, while also making it more likely that they will retain the information and apply it in their daily work activities. Czeczuga explained that even though there may be a need for longer, more focused training for certain employees who are considered more at risk, micro-learning can still be a highly effective tool for delivering general messages, like those related to anti-bribery. The interruptive nature of micro-learning allows it to be delivered in various modes, catering to the needs of different types of learners.

Czeczuga also emphasized the usefulness of pre- and post-tests as a means of assessing training effectiveness, as well as the value of surveys in gauging learner feedback. The importance of tailoring targeted training for at-risk employees cannot be overstated, as the consequences of compliance failures can be both costly and damaging to an organization’s reputation. Ensuring that these employees have the necessary information and tools to act ethically and responsibly is crucial in promoting a culture of compliance and minimizing risk. Collaborative efforts between compliance and training departments are essential for developing and implementing training strategies that strike the right balance between targeted, in-depth instruction for at-risk employees, and more generalized training for the broader staff. Ultimately, a well-executed and carefully tailored training program will lead to improved effectiveness and a more robust compliance culture throughout the organization.

The importance of effective compliance and training programs cannot be overstated for professionals in this field. The steps outlined above provide a comprehensive approach to building and sustaining a robust training strategy that not only engages your employees but also drives positive behavioral changes. From embracing micro-learning techniques and interruptive training methods to fostering collaboration between departments and reinforcing the message consistently over time, these steps can ultimately transform your organization’s culture into one that values and prioritizes compliance. Seize this opportunity to elevate your training efforts, and witness the remarkable impact on your organization as a whole.

Join us tomorrow for a review of training for 3rd parties.

For more information go to http://diligent.com/compliancetraining.

Categories
Uncovering Hidden Risks

Ep 9 – Don’t Get Caught Unprepared: Three Steps to Manage the Risks of Multicloud

This month’s episode of Uncovering Hidden Risks discusses the risks of running a multicloud strategy and how customers can think about this as they accelerate their digital transformation.

Ashish Kumar, Principal PM Manager at Microsoft, joins Erica Toelle and guest host Daniel Hidalgo on this week’s episode of Uncovering Hidden Risks. Ashish has over 25 years of experience in Engineering, Consulting, and Technology sales, helping businesses build products, increase revenue and market share, enhance branding, and lower operational costs. Ashish discusses the intersection between security and compliance, why knowing your posture is essential, and how we can have a safer digital world. You can also check out Ashish’s book, “Managing Risks in digital transformation.”

In This Episode You Will Learn:

  • The risks involved when you operate a multi-cloud environment
  • The importance of having real-time view of your cloud configuration and associated threats

Some Questions We Ask:

  • What is multi-cloud, and why is it important?
  • Can you share some takeaways for listeners looking to implement a multi-cloud strategy?
  • What is the main difference between hybrid and multi-cloud?

Resources:

View Ashish Kumar on LinkedIn

View Daniel Hidalgo on LinkedIn

View Erica Toelle on LinkedIn

Categories
Trekking Through Compliance

Trekking Through Compliance – Episode 20 – Court Martial

In this episode of Trekking Through Compliance, we consider the episode Court Martial which aired on February 2, 1967, Star Date 2947.3.

After sustaining severe damage in an ion storm, the Enterprise is forced to seek repairs at Starbase 11, where  Commodore Stone investigates the death of records officer Ben Finney, who died in the storm. Stone finds it was Kirk’s negligence that led to Finney’s death.  A trial ensues, and Kirk’s former flame Ariel Shaw is the prosecuting attorney, and Kirk seeks the services of attorney Samuel T. Cogley.

Spock discovers something amiss in the program bank of the Enterprise after he can beat the computer 5 times, even though its program should not be capable of losing. Recognizing the computer has been tampered with, they find Finney and  Kirk’s record is cleared, and Samuel Cogley takes on a new case: defending Finney.

Compliance Takeaways:

1. Have you tied down your documents before your investigation begins?
2. Your investigation can change based on facts on the ground.
3. Remember that each lawyer represents their client in an FCPA enforcement action.

Resources:

Excruciatingly Detailed Plot Summary by Eric W. Weisstein for Court Martial
MissionLogPodcast.com-Court Martial

Categories
Innovation in Compliance

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 3 – Defining the Effectiveness of Compliance Training

Welcome to a special 5 part podcast series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series, I will visit with Kunal Agrawal, Director of Customer Success at Diligent; Kevin McCoy, Customer Success Manager at Diligent; Jessica Czeczuga, Director, Compliance and Ethics at Diligent; Andrew Rincón, Client Director at Diligent; and David Greenberg, former CEO and Special Advisor at LRN and Director at International Seaways. Over this series, we will consider the importance of ongoing communications, the value of targeted training, training third parties, and the role of the Board of Directors. In this Part 3, we consider the always challenging topic of defining training effectiveness with Jessica Czeczuga.

Join Tom Fox and Jessica Czeczuga from Diligent in this episode as they discuss how to make compliance training effective. Jessica shares insights from years of creating targeted training materials, emphasizing the shift from traditional classrooms to microlearning. She explains how microlearning enhances comprehension, adaptability, and retention in learners. Tom and Jessica also explore the role of testing and assessments in compliance training and showcase the power of surveys in shaping the culture of compliance within organizations. Take advantage of this informative episode that will transform how you think about compliance, train, and communicate.

Highlights Include:

  • Effective Microlearning for DOJ Training
  • Benefits of Microlearning for Corporate Training
  • The Evolution of Compliance Training Testing
  • Building a Culture of Compliance and Ethics
Notable Quotes:

“Microlearning is probably one of the most effective ways to convey content to your donors.”

“One of the things that I love about microlearning beyond all those other benefits is the ability to put together what we call a multimodal communication campaign.”

“Even with all the benefits of microlearning, there are certain situations where longer and more targeted or focused training may be necessary.”

“But I think if you have a training function and a compliance function, they should always be in communication.”

For more information, go to Diligent.com

Join us tomorrow when we review a strategy for training third parties.

Categories
31 Days to More Effective Compliance Programs

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

Next, consider a couple of landmark failures at the Board level around bribery and corruption.

VimpelCom Ltd. In 2015 (now Veon Ltd.), the DOJ alleged that Dutch telecom VimpelCom sought to enter the telecom market through the acquisition of a local player, Unitel, as an entrée into the Uzbekistan market. Unitel made clear to VimpelCom that to have access to, obtain, and retain business in the Uzbeki telecom space, VimpelCom would have to, according to the DPA, “regularly pay Foreign Officials millions of dollars” to Gulnara Karimova, the daughter of the then President of the country. VimpelCom also acquired another entity Butzel, that was at least partially owned by an Uzbeki government official, who hid their interest through a shell company, which was known to VimpelCom. VimpelCom did not articulate a legitimate business reason for the deal and paid $60 million for Buztel.

Ultimately, VimpelCom agreed to pay approximately $800 million in fines for these activities in 2016. 

BizJet. Another FCPA enforcement action involved the Tulsa-based company BizJet International Sales and Support Inc. (BizJet), which had four senior executives convicted for their participation in a bribery scheme. But this case also involved the Board of Directions. In the Criminal Information, it stated that in November 2005:

…at a Board of Directors meeting of the BizJet Board, Executive A, and Executive B discussed with the Board that the decision of where an aircraft is sent for maintenance work is generally made by the potential customer’s director of maintenance or chief pilot, that these individuals are demanding $30,000 to $40,000 in commissions, and that BizJet would pay referral fees in order to gain market share.

In both cases, this is where the rubber hits the road. If a company is willing to commit bribery and engage in corruption to secure business, no amount of doing compliance is going to help. If senior management is ready, willing, and able to lie, cheat and steal, the Board is the final backstop to prevent such conduct. Both the VimpelCom and BizJet Boards sorely failed in their compliance duties.  

Three key takeaways:

  1. Board liability will be severe based upon similar conduct going forward.
  2. Board members must critically challenge management on its conduct.
  3. The Board is the ultimate backstop against bribery and corruption.

For more information, check out The Compliance Handbook, 4th edition, available here.

Categories
Daily Compliance News

Daily Compliance News: June 21, 2023 – The Paris 2024 Olympics

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in 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.

  • Paris 2024 Olympic offices raided in corruption probe. (ESPN)
  • It always starts at the top. (WSJ)
  • Jurisdictional issues around clawbacks. (JDSupra)
  • Palm oil industry corruption allegations. (Mongabay)
Categories
Compliance Into the Weeds

Compliance into the Weeds: A Material Weaknesses Catastrophe

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

In this episode, co-hosts Tom Fox and Matt Kelly dissect a disastrous 10k report filed by Ammo Incorporated, exposing the company’s shocking governance and compliance breakdown. The lack of personnel, internal control processes, and proper segregation of duties are just some of the material weaknesses that led to this corporate disaster. The hosts provide insightful lessons on what companies should avoid to maintain internal governance, share tips on approaching remediation, and emphasize the importance of self-awareness among senior management and the board. Tune in to hear how this niche investigative story was uncovered, and how Twitter played a crucial role in the investigation. Don’t miss Compliance into the Weeds – the podcast that will change the way you think about governance and compliance!

 Key Highlights 

·      Material weaknesses in internal governance practices

·      Material weaknesses in operations at Ammo

·      Challenges with Ammo Inc.’s strategic shift and internal controls

·      Remediating Company Failures: Story’s Disclosure

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn