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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 1 – Introduction

In her October 2021 speech, presaging the Monaco Memo, Deputy Attorney General Lisa Monaco talked at length about the importance of corporate culture. She noted, “Corporate culture matters. A corporate culture that fails to hold individuals accountable or fails to invest in compliance — or worse that thumbs its nose at compliance — leads to bad results. Let me also be clear: a company can fulfill its fiduciary duty to shareholders and maintain a commitment to compliance and lawfulness. Companies serve their shareholders when they proactively place compliance functions and spend resources anticipating problems. They do so both by avoiding regulatory actions in the first place and receiving credit from the government. Conversely, we will ensure the absence of such programs inevitably proves a costly omission for companies who end up the focus of department investigations.” These thoughts were formalized in the Monaco Memo.

What does all this mean for compliance professionals going forward? DOJ officials have emphasized that the changes laid out in the Monaco Memo and the requirements around CCO Certification are to empower compliance professionals. In the Monaco Speech, DAG Monaco stated, “Companies should feel empowered to do the right thing—to invest in compliance and culture and to step up and own up when misconduct occurs. Companies that do so will welcome the announcements today. For those who don’t, however, our Department prosecutors will be empowered, too—to hold accountable those who don’t follow the law.” However you may characterize it, I will channel my inner Glenn Fry (with a nod to Miami Vice) and simply say to CCOs and compliance professionals, “The Heat is On.”

Three Key Takeaway:

  1. The DOJ will now evaluate corporate culture in an enforcement action.
  2. You must assess, manage, monitor, and improve your culture.
  3. Corporate culture is now a key metric for regulators.
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Career Can D0

The Podcast Success Blueprint with Megan Dougherty

Megan Dougherty is the co-founder of One Stone Creative, a multimedia content agency specializing in podcasts and online courses. With over a decade of experience in digital marketing and online business development, Megan has collaborated with hundreds of business owners across various industries. Notably, Megan is the driving force behind the success of this very podcast, contributing her expertise to elevate Career Can Do’s quality. She joins Mary Ann Faremouth to delve into the world of podcasting, exploring its significance for businesses, the key elements that make a podcast successful, and the upcoming Podcasting for Business conference. 

Megan emphasizes the importance of strategic planning for a podcast: your podcast goals should align with your overall business objectives so you can measure the show’s impact. She tells Mary Ann, “If you don’t know the impact that the show is making on your business, and you have no way of measuring what that impact is, then you’re going to not be able to attribute any new relationships, new revenue, new traffic to it.” A well-organized workflow is a critical success factor. A poorly organized process, with information scattered and a lack of communication among team members, can lead to unnecessary confusion and hassle. Also, clearly defines success metrics from the outset. “It comes down to figuring out at the start what’s the most important thing my podcast has to do for the business and then optimizing all of the areas of the podcast to achieve that goal,” she says. 

The Podcasting for Business conference takes place on November 13-15. Megan expresses excitement about Mary Ann Faremouth’s presentation on the guest selection. The conference, designed for business owners, offers a platform to learn about podcasting as a marketing channel. Megan outlines various events, including networking opportunities, expert presentations, and new “Ask the Expert” sessions focused on generative AI, SEO for podcasting, and video podcasts. The comprehensive lineup ensures attendees gain practical insights to enhance their podcasting endeavors.

Resources

Megan Dougherty on LinkedIn | X (Twitter) | One Stone Creative | Podcasting for Business Conference

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Compliance Into the Weeds

Compliance into the Weeds: SEC Sues Solar Winds and CISO

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 explore a subject more thoroughly, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC Civil Complaint against Solar Winds and its CISO, Timothy Brown, for undisclosed failures in the company’s cybersecurity compliance program disclosures prior to, during, and after the infamous Solar Winds data hack.

The recent SEC lawsuit against SolarWinds Corp and its CISO, Tim Brown, following the 2020 data breach has sparked a critical conversation about executive liability in cybersecurity disclosures. Matt views this lawsuit as a significant development that raises essential questions about the personal liability of senior executives for inaccurate or misleading disclosures about cybersecurity risks. He emphasizes the potential implications this case could have for other executives in charge of trouble, such as compliance officers.

Tom underscores the concerns regarding the accuracy and transparency of SolarWinds’ cybersecurity disclosures. He highlights the evidence of a culture of deception within the company and the need to hold executives accountable for inaccurate disclosures. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.

 Key Highlights:

  • Liability of Senior Executives in Cybersecurity
  • SolarWinds’ Orion Software: Russian Government Cyberattack
  • Personal Liability for Misleading Cybersecurity Disclosures
  • Implementing Relevant Controls for Cybersecurity

 Resources:

Tom 

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Into the Chair - Tales from Chief Compliance Officers

Into the Chair – Tales from Chief Compliance Officers: Kevin Cremi: From Finance to CCO Success

Welcome to the latest edition of the Compliance Podcast Network: Into the Chair: Tales from Chief Compliance Officers, which details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to navigate the compliance waters in any company successfully? What are some of the top challenges CCOs have faced, and how did they meet them? These questions and many others will be explored in this new podcast series. Into the Chair: Tales from Chief Compliance Officers is a Comply podcast hosted by Tom Fox and is a production of the Compliance Podcast Network. In this episode, I visit with Kevin Cremi, Chief Compliance Officer/Operations Analyst at RTD Financial.

Kevin Cremi is a seasoned professional with a robust background in finance and management information systems, currently serving as the chief compliance officer at RTD Financial. Kevin’s perspective on the importance of compliance, continuous learning, and technology in business is shaped by his diverse experiences, including his role as a CCO and deep understanding of cybersecurity. He views compliance as a critical aspect of business that should not be overlooked and believes in the power of continuous learning and adaptation in the ever-evolving landscape of compliance and technology. Kevin also sees a strong connection between compliance and cybersecurity, envisioning a future where compliance continues to play a significant role as rules and regulations change. Join Tom Fox and Kevin Cremi on this episode of the Into the Chair podcast to delve deeper into these insights.

Key Highlights:

  • Kevin Cremi’s Journey to CCO Success
  • The Evolving Role of CCO in Compliance
  • The Future of Compliance: AI and Cybersecurity

Resources

Kevin Cremi on LinkedIn

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Great Women in Compliance

Great Women in Compliance – Renee Rajkumar – The Heart of Compliance

Today’s episode features Renee Rajkumar, a Risk and Compliance Manager at the University of Arts, London. Hemma was very excited to host her long-time friend and compliance mentor to talk about how compliance is the conscience of the organization. Renee shares tips on how to overcome negative perceptions of the compliance function, how to build trust, motivate risk awareness and compliance, and how to leverage the strengths of your business partners while doing so. Learn about a new form of AI in compliance called “Added Intelligence” – first coined here. Grab a blanket and a cup of tea and tune in to hear how, with a little love and care, compliance can be the heart and pulse of an organization – and create the conditions where our internal business partners are the best source of compliance intelligence and risk management.

Hailing from the warm island of Trinidad and Tobago, Renee is enthusiastic about life and the happiness of people. She believes in the value of genuinely caring for others. This is the basis of Renee’s career background. Indecisive in the earlier days of her career, Renee worked in process operations, quality, marketing, and advertising health and fire safety and has now ended up in risk and compliance. Renee’s unique skill set and approach bring fresh and easy energy to risk and compliance.

Renee is also the founder of Portal Coaching Limited, which she launched at the start of the COVID lockdown. She is trained in NLP, solution-based coaching, business coaching, and hypnotherapy. Renee started Portal Coaching Limited to work with companies and individuals to help them gain clarity on who they are, their purpose, work situations, and relationship issues. She calls herself a Liberator and has set many people free of their worries and negative thought patterns. Renee draws on these principles in her various training with a seamless cross-application into coaching and Compliance.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance-related offerings. GWIC is also sponsored by Corporate Compliance Insights, where we have a page where you can hear every episode. If you are enjoying this episode, please rate it and/or provide a review.

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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The Hill Country Podcast

Hill Country Podcast – Educational Leadership in Kerrville and Kerr County, Part 1

Welcome to the award-winning The Hill Country Podcast. The Texas Hill Country is one of the most beautiful places on earth. In this podcast, Hill Country resident Tom Fox visits with the people and organizations that make this the most unique area of Texas. Join Tom as he explores the people, places, and activities of the Texas Hill Country. In this episode, I begin a special two-part episode on primary and secondary education in Kerrville, Kerr County, and the Hill Country. In this exploration, I am joined by Dr. Robert Templeton, Superintendent of the Independent Ingram School District, Dr. Brent Ringo, Superintendent of the Kerrville Independent School District, and Dr. Charlie McCormick, President of Schreiner University in Kerrville.

Dr. Templeton, Dr. Ringo, and Dr. McCormick are all leaders in rural school districts, each with a unique perspective on leadership and educational challenges in these areas. Dr. Templeton, having grown up in a small town in West Texas, believes in providing equal opportunities and high standards for all students, regardless of their background or socioeconomic status. Dr. Ringo, a product of a humble upbringing in Amarillo, Texas, emphasizes the importance of collaboration, vision, and prioritizing students’ success in overcoming the challenges faced by rural school districts. Dr. McCormick, a seasoned higher education professional, focuses on cultivating capacity and competency in students who may not meet traditional academic metrics, highlighting the importance of inclusivity and collaboration and recognizing the value of all individuals in the education system. Join Tom Fox, Dr. Robert Templeton, Dr. Brent Ringo, and Dr. Charlie McCormick on this episode of the Hill Country Podcast to delve deeper into their experiences and perspectives on leadership and educational challenges in rural school districts. 

Key Highlights:

  • Influential Past Relationships Shaping Leadership Styles
  • Building Capacity through Collaborative Education
  • Supporting Essential Staff and Student Well-being
  • Transparent Communication for Strong Leadership
  • The Regional Influence of Schreiner University
  • Opportunity for Associate’s Degree from High School

 Resources:

Dr. Robert Templeton

Dr. Brent Ringo

Dr. Charlie McCormick

Tom Fox:

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Daily Compliance News

Daily Compliance News: November 1, 2023 – The Communications 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 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:

  • France wants an anti-corruption commission with teeth.  (Politico)
  • Companies are still struggling with communications compliance. (WSJ)
  • Exonerated Deutsche Bank traders can go after the bank for scapegoating claims. (Reuters)
  • Brokers fees anti-trust violation. (FT)
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Blog

Leadership Lessons from the Presidents of the Republic of Texas-Mirabeau B. Lamar: Impact and Controversies

The Republic of Texas holds a unique place in American history as a short-lived independent nation. In this special four-part blog post series, I will be diving into the intriguing world of the presidents of the Republic of Texas, shedding light on their leadership styles, political tensions, and the challenges they faced. This blog post focuses on Mirabeau B. Lamar, the third president of the Republic of Texas.

Lamar left a lasting impact on the state’s history. Known for his bravery in battle and his poetic nature, Lamar made significant contributions to education and played a key role in establishing the city of Austin as the capital. However, his presidency was not without controversy, particularly regarding his Indian Removal Policy and his failed expedition to Santa Fe.

Lamar’s military prowess was evident during the Battle of San Jacinto, where he earned a battlefield promotion from private to colonel. His fearlessness and tender heart were on display as he fought alongside his comrades. After the battle, Lamar transitioned into the civilian realm and was appointed Secretary of War by provisional president Burnett. This appointment showcased Lamar’s diverse interests and his belief in his own abilities as a polymath.

One of Lamar’s most significant contributions was his dedication to education. He is often referred to as the father of education in Texas, as he implemented policies to establish a primary and secondary educational system. Recognizing the importance of education in building a nation, Lamar set aside acreage from every survey to support a public education fund. However, the implementation of these policies varied across different communities and counties, with some embracing the idea while others ignored it. It would take several decades for Lamar’s vision to fully materialize.

Lamar’s vision for Texas extended beyond education. He played a pivotal role in the establishment of Austin as the capital, strategically positioning it as the crossroads of empire. By moving the capital from Houston to Austin, Lamar was playing the long game, anticipating the eventual annexation of Texas by the United States. His foresight and belief in the potential of Austin as a hub of commerce and influence laid the foundation for the city’s growth and development.

Despite his accomplishments, Lamar’s presidency was not without controversy. His Indian Removal Policy led to the forced removal of indigenous tribes from Texas. This policy, driven by Lamar’s belief in the superiority of Anglo-American civilization, resulted in the displacement and suffering of Native American communities. Additionally, Lamar’s ambitious expedition to Santa Fe proved to be a financial disaster, significantly increasing the national debt of the Republic of Texas.

As we have noted, Lamar’s presidency was marked by controversy and division, there are still some leadership lessons that can be gleaned from his time in office. While there are leadership lessons that can be derived from his time in office, there are also important lessons about the consequences of certain leadership decisions and the need to balance ambition with ethical considerations.

  1. Vision and Ambition: Lamar had a grand vision for the Republic of Texas, which included expanding its territory and building a strong, independent nation. His ambition and willingness to think big can be seen as a positive leadership trait, as it inspired others to work towards a common goal. CCOs can help lead an organization through vision for a compliance program and ambition to see it through.
  2. Determination: Lamar was determined to achieve his vision for Texas, even in the face of challenges and criticism. This determination can be seen as a key leadership quality, as compliance leaders often need to persevere through difficult times to achieve their objectives.
  3. Strong Communication: Lamar was an eloquent speaker and writer, and he used these skills to communicate his vision and ideas to the people of Texas. Effective communication is a crucial leadership skill, as it helps to inspire and motivate others. It still is today.
  4. Decision-Making: Lamar made some controversial decisions during his presidency, including his policy towards Native American populations. While not all of his decisions were popular, he demonstrated a willingness to make tough choices and take responsibility for them. Compliance leaders often need to make difficult decisions, and the ability to do so is an important leadership trait.
  5. Nationalism: Lamar was a strong advocate for Texas independence and nationalism. He believed in the importance of a distinct Texan identity and worked to promote it. This shows that effective compliance leaders can inspire a sense of identity and pride in their followers, which can be a powerful motivator.
  6. Long-Term Planning: Lamar’s vision for Texas extended beyond his presidency, as he worked to lay the groundwork for future growth and development. Effective compliance leaders often think beyond their immediate term in office and plan for the long-term success of their organizations or nations.
  7. Handling Criticism: Lamar faced criticism and opposition during his presidency, but he remained steadfast in his convictions. Compliance leaders should be prepared to face criticism and push back. The key is to learn how to respond to it constructively while staying true to their principles.

The political landscape during Lamar’s presidency was marked by personal animosity and rivalries. His predecessor, Sam Houston, and Lamar were on opposite sides of the political spectrum and had a contentious relationship. Lamar undid many of Houston’s policies, further highlighting the divide between the two leaders. However, despite their differences, both Houston and Lamar left lasting impacts on Texas, navigating their presidencies with resilience and determination.

It is important to consider the tradeoffs and challenges associated with Lamar’s impact and controversies as Texas president. While his contributions to education and the establishment of Austin as the capital were significant, his Indian Removal Policy and failed expedition to Santa Fe highlight the complexities of leadership and decision-making. Balancing different factors and considering the impact on various communities is crucial when evaluating the legacy of leaders like Mirabeau B. Lamar.

In conclusion, Mirabeau B. Lamar’s presidency had a profound impact on Texas. His bravery in battle, dedication to education, and strategic vision for the state left a lasting legacy. However, his controversial policies and ambitious endeavors also sparked debate and criticism. Lamar’s presidency serves as a reminder of the complexities and challenges faced by leaders in shaping the course of a nation’s history.