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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 15 – Monitoring and Improving Internal Controls

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In this episode, we look at the ongoing process of monitoring and improving company internal controls. Christina Ravelo starts by posing fundamental questions about the frequency of manual approvals and control overrides, emphasizing the importance of continuous evaluation and recalibration. This episode highlights the misperception among many compliance professionals and lawyers that controls are static and unchanging once implemented. Instead, internal controls should be dynamic, requiring regular reviews and updates based on collected data, such as the frequency of overrides. Proper documentation is crucial, and companies should engage in periodic self-reviews as part of their continuous monitoring efforts. Ravello also stresses the necessity of identifying issues and remedying them to prevent further complications. Today’s key takeaways include the idea that control overrides are not inherently problematic if appropriately managed, the dynamic nature of internal controls, and the importance of a comprehensive monitoring process incorporating feedback from every line of defense.

Key highlights:

  • Understanding Control Overrides
  • Continuous Monitoring and Improvement
  • Assessing and Updating Controls

Resources:

Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast.

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Career Can D0

Mrs. Kelly’s Journey Home: Learn to Trust Your Instincts with Breeda Miller

What if you tried something new, and it turned out great? Breeda Miller joins Mary Ann Faremouth on this episode of Career Can Do to share her journey of creating and performing a one-woman show that captivates audiences and brings meaningful stories to life. Breeda is an accomplished speaker, storyteller, and performer who uses humor and heartfelt narratives to connect with people on a deeper level. In this episode, Breeda takes us behind the scenes of her creative process and how she transformed her love for storytelling into a theatrical production.

The idea for her one-woman show, Mrs. Kelly’s Journey Home, was born from her desire to preserve her mother’s legacy while exploring themes of identity, resilience, and belonging. Through her personal journey, Breeda reflects on how we all carry stories within us that shape who we are. She found that by sharing these stories, she could help others see the humor and humanity in their lives, creating a bridge between her personal experiences and the universal emotions that connect us all.

Crafting a one-woman show isn’t just about writing a script — it’s about delivering an authentic performance that resonates with audiences deeply emotionally. Breeda’s show isn’t just about sharing her mother’s story; it’s about inviting the audience into a shared experience, where they laugh, cry, and walk away feeling like they’ve been on a journey with her.

She emphasizes the importance of taking creative risks, even when stepping into the unknown feels daunting. Breeda encourages listeners to trust their instincts, push past their fears, and embrace vulnerability because that’s where the magic happens. Through her performance, Breeda shows that it’s never too late to step into the spotlight, create something meaningful, and share your voice with the world.

Her journey reminds us that sometimes the most rewarding and transformative experiences come from taking the leap into new creative endeavors, even when it seems scary or uncertain.

Resources:

Breeda Miller on the Web I LinkedIn

Mrs’s Kelly’s Journey Home – upcoming performances

Mary Ann Faremouth on the Web I X (Twitter)

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Compliance Into the Weeds

Compliance into the Weeds: Navigating Return to Office Policies and Corporate Speak Up Culture

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 fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly delve into JP Morgan Chase’s treatment of employees who commented on the bank’s Return to the Office policy.

JP Morgan’s recent decision to require employees to be back in the office five days a week caused the bank to disable employee comments on the internal announcement, citing backlash. Tom and Matt explore the implications this has on workplace respect, speak-up culture, and employee morale, juxtaposed with the compliance officer’s role in measuring and maintaining corporate culture. They also detail how these corporate policies might reflect broader trust issues and potential fallout from a discontented workforce.

Additionally, the episode revisits Meta’s (formerly Facebook) recent rollback on DEI initiatives and its promotion of a more ‘freewheeling’ speech environment, considering the ethical and compliance ramifications of such a culture shift. The hosts compare these actions to other reported corporate behaviors that may undermine workplace respect and discuss the fragile balance a Chief Compliance Officer must maintain in fostering a fair and open workplace compliant with evolving societal norms and internal policies.

Key highlights:

  • JP Morgan’s Return to Office Policy
  • Employee Reactions and Speak Up Culture
  • Ethics and Compliance Implications
  • Workplace Respect and Culture
  • Meta’s Policy Changes and Corporate Culture

Resources:

Matt in Radical Compliance

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Daily Compliance News

Daily Compliance News: January 15, 2025 – The Corruption is Back 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 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.

Top stories include:

  • The UK Minister resigned over the corruption investigation in Bangladesh. (Reuters)
  • US Rep introduces domestic ABC bill. (Des Moines Register)
  • Menendez’s wife loses bid to delay trial. (NY Post)
  • Pope Francis on Vatican bribery and corruption. (CNN)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

Check out The FCPA Survival Guide on Amazon.com.

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Great Women in Compliance

Great Women in Compliance – Catherine Razzano on Leading with Passion

In this week’s episode, Hemma visits Catherine Razzano, a veteran legal and compliance expert and Head of Global Legal Compliance at social media giant TikTok.

Learn about Catherine’s transition from private practice to in-house compliance work as she shares her journey from a prestigious clerkship and partnership track in Big Law with an FCPA and white-collar practice to leading in-house compliance teams at General Dynamics, Panasonic, and TikTok. Hemma asked Catherine about the challenges and benefits of working under a monitorship, with Catherine emphasizing the importance of relationship building and trust. Catherine also shared her experiences leading teams under scrutiny and pressure, including during the pandemic and at TikTok.

Catherine discusses the source of her firm commitment to mentoring and sponsoring the next generation of ethics and compliance leaders. Tune in to hear inspiring insights on the importance of intentionality and finding your passion when navigating transitions as we enter the second quarter of the century in 2025.

Highlights include:

  • Managing compliance teams under scrutiny and pressure
  • Culture-building in global organizations
  • Navigating different industries as a compliance professional
  • Following your passion for career growth and transitions
  • The importance of mentoring and sponsorship

Biography:

Catherine Razzano is the Head of Legal Compliance at TikTok, the social media giant where she leads a global team of compliance professionals. She joined TikTok from Panasonic Avionics Corp., where she was hired in 2018 to help the company strengthen its compliance systems while under independent oversight following an investigation into violations of U.S. antibribery law. Before Panasonic, Catherine was an Associate General Counsel and Director of International Law & Compliance at General Dynamics after leaving her white-collar criminal practice at prestigious law firms, Cadwalader Wickersham and Taft and Clifford Chance, LLP, and serving as Judicial Law Clerk to the Honorable John M. Facciola in the United States District Court for the District of Columbia

Thanks, as always, to our sponsor, Corporate Compliance Insights, and our wonderful #GWIC community. You can join the Great Women in Compliance community on LinkedIn here.

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Blog

Climbing the Jungle Gym: Embracing Lateral Career Moves

In compliance, we often view career advancement as a ladder, a relentless climb toward greater authority, higher compensation, and more significant responsibilities. But what if the path to long-term success is not a straight ascent? Instead, what if it is more like a jungle gym, offering opportunities to move sideways or even down temporarily to reach greater heights in the future?

The phrase “careers are a jungle gym, not a ladder,” attributed to journalist Pattie Sellers and popularized by Sheryl Sandberg, offers a refreshing perspective. Adopting this mindset can be transformative for compliance professionals, as well as for both individual growth and organizational resilience. Interestingly, the Department of Justice evaluates the mobility of compliance professionals within an organization. Brian Elliott looked at this phenomenon in a recent MIT Sloan Management Review article entitled When Moving Sideways Makes Sense.

Why Compliance Professionals Feel Stuck 

In today’s job market, many professionals find themselves in a rut. The slowdown in promotions and a stabilizing economy have left employees feeling stagnant. While layoffs have not accelerated, promotions have plateaued, and opportunities for upward mobility seem limited. Rising burnout rates compound this reality. For compliance professionals managing the “do more with less” mantra, the grind of repeating the same tasks without growth opportunities can lead to disengagement.

So, what’s the solution? It may not be looking outside your organization but exploring new opportunities within. Lateral moves, whether to a different team, project, or function, can offer a much-needed change of pace, a chance to build new skills, and a renewed sense of purpose.

Recognizing When It’s Time to Move Laterally

Knowing when to consider a lateral move is critical. Here are some signals:

  1. Lack of Learning Opportunities. If you have mastered your current role and no longer feel challenged, it is time to look for something new.
  2. Misalignment with Leadership or Team. A poor fit with your manager or team can make work a struggle. Moving to a different group can offer a fresh start.
  3. Desire for Skill Development. If your long-term career goals require expertise, you can’t gain it in your current role, so a lateral move could help you bridge the gap.
  4. Burnout or Low Engagement. When work feels monotonous, a change of scenery, even within the same company, can re-energize you.

For compliance professionals, these factors often align with organizational needs. Expanding your skill set or shifting to a new area within compliance—such as data privacy, ESG reporting, or third-party risk management—can position you as a more valuable asset and expand your personal brand while keeping you engaged.

The Challenges of Lateral Moves

Despite their benefits, lateral moves come with risks. They may involve stepping down in authority, accepting stagnant compensation, or facing initial performance challenges in an unfamiliar area. These risks can be daunting in compliance, where professionals are often judged by their titles, responsibilities, and influence.

However, the rewards often outweigh the risks. Moving laterally can expand your network, broaden your expertise, and prepare you for leadership roles that demand cross-functional knowledge. These moves can be especially valuable in compliance, where adaptability and breadth of expertise are prized.

Building a Culture of Internal Mobility

For organizations, encouraging lateral mobility is not just an employee retention strategy but a business imperative. Companies like Google and Synchrony have recognized the value of internal mobility, implementing programs that make it easier for employees to explore new opportunities within the company. These initiatives reduce burnout, foster innovation, and build a pipeline of well-rounded leaders.

Yet many organizations lack the infrastructure to support lateral moves. Performance metrics and compensation structures often reward upward mobility, while managers may resist losing top talent to other teams. To overcome these barriers, compliance leaders can champion internal mobility by creating formal programs to develop frameworks for lateral moves, including short-term assignments or rotations, to encourage cross-functional collaboration. Another tactic might be to recognize lateral successes within your organization. Finally, train your middle managers on the benefits of internal mobility and encourage them to support their team members’ growth.

How Compliance Professionals Can Navigate Lateral Moves

If you are a compliance professional considering a lateral move, here are some strategies to ensure success:

  1. Identify Allies and Sponsors. Building relationships with leaders who can advocate for you is critical. Sponsors can provide guidance, open doors, and reduce the risks of making a significant change.
  2. Communicate Your Goals. Be transparent about your desire to grow and learn. This helps managers and mentors understand how they can support your development.
  3. Invest in Learning. Pair a lateral move with external learning opportunities, such as certifications or professional development courses, to enhance your value.
  4. Stay Open to Short-Term Setbacks. Accept that a lateral move might not yield immediate rewards. Focus on the long-term benefits, such as skill acquisition and expanded career options.

Why Lateral Moves Matter for Compliance 

Compliance professionals operate in a dynamic environment where regulations, risks, and business priorities constantly evolve. Lateral moves can equip you with the diverse experiences needed to navigate this complexity. Consider that a move from investigations to training can deepen your understanding of preventative measures; shifting from a regional role to a global one can enhance your perspective on cultural and regulatory nuances; or transitioning from compliance to a related function, like internal audit or legal, can broaden your strategic insights. These experiences make you a more effective compliance professional and prepare you for leadership roles where cross-functional expertise is essential. Never forget the Brand of You.

Final Thoughts: The Jungle Gym Advantage 

In the compliance field, careers are not linear. Embracing the jungle gym approach can help you stay engaged, continuously learn, and build the skills needed for long-term success. For organizations, fostering a culture of internal mobility is a strategic advantage, enabling you to retain talent, drive innovation, and develop future leaders.

So, the next time you feel stuck, consider a lateral move. It might just be the step you need, not up but across, to achieve your goals and elevate your career in compliance.