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31 Days to More Effective Compliance Programs

One Month to More Effective Reporting and Investigations – Answering DOJ Questions on Confidential Reporting

What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation.”

This was expanded in the DOJ’s 2020 Guidance, in the section entitled “D. Confidential Reporting Structure and Investigation Process,” with the following language, “Another hallmark of a well-designed compliance program is the existence of an efficient and trusted mechanism by which employees can anonymously or confidentially report allegations of a breach of the company’s code of conduct, company policies, or suspected or actual misconduct. Prosecutors should assess whether the company’s complaint-handling process includes proactive measures to create a workplace atmosphere without fear of retaliation, appropriate processes for submitting complaints, and processes to protect whistleblowers.”

Three Key Takeaways:

  1. Internal reporting systems indicate a working, operationalized compliance program.
  2. There must be a solid communication line between the people doing the investigation and those leading the remediation.
  3. Your internal reporting mechanism must be trusted.
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Compliance and AI

Mastering ChatGPT: Part 2 – ChatGPT and Ethical AI

Welcome to a special five-part podcast series on mastering ChatGPT. My special guest throughout this journey is Larry Roberts, an accomplished professional with over 25 years of multifaceted experience. Having initiated his career in the corporate training sphere, he exhibited a remarkable shift to IT, contributing greatly as a Business Intelligence Analyst. His proficiency lies in harnessing predictive analytics for inventory and sales projections, which led him to tap into the realm of AI. In 2021, Larry chose to cozy up with podcasting and content creation. His tryst with ChatGPT began in November of the same year, and he has been fully engrossed with it since then. His insights into data models, large language models, and his overall passion for AI are certain to illuminate any forum.

In this Episode 2, we look at the ethical considerations of AI models such as ChatGPT.

In the age of AI, the ethical consequences of this transformative technology present pressing concerns for developers and industry professionals alike. In this episode 2, Tom and Larry shed light on the myriad ethical issues surrounding AI, from securing data privacy and GDPR compliance to mitigating the misuse of AI tools and addressing job displacement. There is a wealth of information and best practices to guide your ethical approach to AI, ensuring transparency, user control, and adaptability in a rapidly evolving landscape. Embark on this journey with us to ensure that the power of AI is harnessed responsibly, respecting every stakeholder’s rights and privacy.

In this episode, you will be able to:

  • Discover the crucial ethical questions surrounding AI and ChatGPT.
  • Uncover hidden truths about data privacy concerns and your control options.
  • Explore the significant role of GDPR and the collective effort required for privacy.
  • Understand how to combat the misuse of AI instruments through user collaboration.
  • Learn about AI ethics and why transparency, bias evaluation, and human supervision are paramount.

Key Highlights:    

  • Data Privacy
  • AI and Disinformation
  • Human in the Loop

Resources:

Larry Roberts

Larry Roberts on LinkedIn

Red Hat Media

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Daily Compliance News

Daily Compliance News: July 11, 2023 – The A Nap a Day 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:

  • ECB governor goes on trial for corruption. (Bloomberg)
  • Napping at work is good for you. (FT)
  • Clarence Thomas accepted more gifts. (The Guardian)
  • More senior employees are mentoring younger employees. (WaPo)
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Data Driven Compliance

Data Driven Compliance: Christian Perez-Font on Law, Compliance & Data

Are you struggling to keep up with the ever-changing compliance programs in your business? Look no further than the award-winning Data Driven Compliance podcast, hosted by Tom Fox, which is a podcast featuring an in-depth conversation around the uses of data and data analytics in compliance programs. Data Driven Compliance is back with another exciting episode. The intersection of law, compliance, and data is becoming increasingly important in cross-border transactions, mergers, and acquisitions.

In this episode, Tom welcomes Christian Perez-Font for the first of two parts on using performance bonds and data analytics to guarantee these transactions and the legal requirements and nuances of different jurisdictions when conducting due diligence. They also discussed how technology changes how companies manage Latin American operations, how practitioners need to understand Excel spreadsheets, and how to share data to benchmark and extract the correct information. Christian’s background in engineering and economics has helped him incorporate data analytics, compliance, and law into a unique package. Tune in to Data Driven Compliance and stay ahead of the curve in the compliance world!

Key Highlights:

  • Law Compliance & Data
  • Data as Fuel
  • Data Analytics in M&A
  • Data Analytics in Compliance

Resources:

Christian Perez-Font on LinkedIn 

Thinkeen Legal

 Tom Fox 

Connect with me on the following sites:

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Blog

Mastering ChatGPT: Ethical Challenges of ChatGPT

In this Part 2 of a five-part blog post series, I am considering the revolution wrought by ChatGPT. Today we consider how and, more importantly, why AI developers and industry professionals need to garner insights into the ethical considerations surrounding AI and ChatGPT. With the guidance of AI expert and founder of Red Hat Media, Larry Roberts, we will delve into the complexities of AI ethics, including data privacy, misinformation, bias, and job displacement. Roberts’s extensive field knowledge and experience make him a relatable source for understanding the challenges and best practices in implementing ethical AI solutions. By addressing these ethical concerns head-on, this article will equip you with the necessary tools and knowledge to navigate the ethical landscape of AI development, ensuring responsible and informed decision-making. Say goodbye to uncertainties and us as we demystify AI ethics, paving the way for a more ethically sound AI industry.

Human in the Loop

Human in the Loop (HITL) is an interaction model involving a human operator in AI decision-making. Due to their unpredictability, HITL scenarios often occur when definitive responses are difficult for AI systems to generate without human intervention. HITL emphasizes that human input and collaboration are critical in AI development, as an AI alone may only partially account for unforeseen situations.  Larry Roberts discusses the ‘Human in the Loop’ approach extensively. He highlights examples where human intervention was necessary to prevent unforeseen outcomes, implying the indispensability of human involvement in AI usage and development. Larry reiterates that even with advances in AI technology, human input remains vital to ensure quality results and prevent unexpected consequences.

AI Ethics and Best Practices

AI ethics is the study of the ethical issues related to the development and application of AI. It includes accountability, privacy, intellectual property, discrimination, bias, and job displacement. Fostering a deeper understanding and implementation of AI ethics ensures that advancements in AI technology are a force for good, benefiting humanity as a whole.  Referencing the episode, Larry Roberts provides an in-depth discussion on AI ethics. He emphasizes that understanding the perspectives of AI developers is paramount to accurate assessment and mitigation of bias. Recognizing the issues surrounding job displacement due to AI implementation, Larry suggests the potential of AI to create new opportunities, underlining the necessity of monitoring and adapting to the evolving AI landscape.

Securing Data Privacy and GDPR Compliance

The digital revolution has brought to the fore the importance of securing data privacy and tick-marking all requirements of the General Data Protection Regulation (GDPR) across industries. The speed and sky-rocketing impact of artificial intelligence (AI) technologies necessitate special attention to these aspects. As data forms the lifeblood of AI systems, ensuring the secure handling of this data keeps prominence. Equally significant is the adherence to GDPR policies, which is a step beyond data privacy, focusing on EU citizens’ fundamental rights. Non-compliance can lead to severe penalties. Addressing these requirements is more than just about legal and ethical obligations; it’s about building trust with the end users, enhancing business reputation, and ensuring that privacy concerns or non-compliance issues do not hold back AI’s fantastic potential.

Mitigating the Misuse of AI Tools

As we consider the suitability of AI technologies for various tasks, it’s crucial to discuss the potential for misuse. With the pervasiveness of AI in our digital landscape, there’s an increasing risk of these technologies being exploited. One of the leading concerns revolves around ethical use, mainly because AI technologies like chatbots can process vast amounts of data, some of which can be sensitive or private. Consequently, the misuse of AI tools could result in a breach of privacy and security, making it significantly vital to establish preventative measures.

As we strive to achieve an increased understanding of AI ethics and best practices for implementation, let us remember that great power comes with great responsibility. By staying informed, remaining vigilant, and consistently reassessing our practices, we can pave the way for a future where AI serves as a force for good. Join us tomorrow when we consider how ChatGPT will transform compliance training.

For more information on Larry Roberts, check out Red Hat Media.