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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 23 – Investigative Protocols

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 Fox 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.

On Day 23, we delve into the essential steps for conducting a thorough and effective internal investigation following an internal report. The discussion is grounded in the ECCP’s guidelines, emphasizing the necessity of properly scoping investigations with competent personnel and adequate resources. A detailed written procedure is crucial for handling complaints or allegations of bribery and corruption, regardless of their origins. The episode outlines a five-component investigative protocol: opening and categorizing the case, planning the investigation, executing the investigative plan, determining appropriate follow-up, and closing the case. Emphasis is placed on maintaining transparency, consistency, and thorough documentation throughout the process. Three key takeaways are highlighted: the importance of a written protocol, the need for transparency and documentation, and the critical role of consistency across the organization.

Key highlights:

  • Key Questions for Internal Investigations
  • Detailed Procedures for Handling Complaints
  • Steps in the Investigative Process
  • Importance of Consistency in Investigations

Resources:

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

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Business Integrity Innovations

Business Integrity Innovations: Empowering SME’s Through Business Ethics with Fatma Elmaawy

Business Integrity Innovations is brought to you by the Center for International Private Enterprise (CIPE) and the Compliance Podcast Network (CPN). This podcast is inspired by Ethics 1st, a multi-stakeholder initiative led by CIPE that creates pathways for accountable and sustainable investment in Africa. Companies can use Ethics 1st to standardize their business practices, develop sound corporate governance systems, and demonstrate their commitment to compliance and business ethics.

In this episode of Business Integrity Innovations, host Tom Fox and co-host Lola Adekanye sit down with Fatma Elmaawy, founder of Milestones Resource Solutions, to explore her diverse professional background and journey into business ethics and compliance training. Fatma shares her experiences from working in various sectors, including airlines, to founding her own training company that initially focused on sales and customer service but eventually specialized in business ethics. She highlights the challenges SMEs face in environments where corruption is rampant and discusses practical solutions, such as mindset engineering and the three R’s approach (Response, Report, Review), to help businesses operate with integrity.

Fatma also touches on the importance of training the trainers to create a ripple effect of ethical practices within organizations and explains how pivotal leadership is in setting the tone for business integrity. The conversation further delves into the success stories of companies that have transformed their compliance cultures and shares strategies for leaders to embed ethical practices effectively.

Key highlights:

  • Fatma Elmaawy’s Professional Journey
  • Challenges and Realities of Business Ethics
  • Success Stories and Impact
  • Training the Trainers and Leadership
  • Practical Solutions and Collective Action

Resources:

Milestones Resources Solution

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Daily Compliance News

Daily Compliance News: January 23, 2025, The Can’t Sue the Zoo 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:

  • Elephants can’t sue to get out of the Zoo. (Reuters)
  • CEOs need a mindset shift re: growth. (FT)
  • Ukraine chief psychiatrist arrested on corruption charges. (BBC)
  • An ex-Everton player and China coach was jailed for bribery. (ESPN)

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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Into the Darkness

Into the Darkness: Ending the Journey – A Concluding Interview with CJ Goodwyn

Into the Darkness: CJ Goodwyn’s Vision of Sherlock Holmes: Mare of the Night is a deep dive into the creative journey behind an ambitious reimagining of the Sherlock Holmes legacy. This 10-part podcast series will unravel the entire movie production process, offering listeners an insider’s look into the making of Sherlock Holmes Mare of the Night, a film that blends the mystique of classic Sherlock Holmes with a dark, supernatural twist. In episode 10 and the concluding episode of ‘Into the Darkness’, host Tom Fox welcomes back filmmaker CJ Goodwyn.

We discuss the post-production process, including work with the composer on the score and challenges faced with completing the project under tight deadlines. CJ discusses the marketing strategies, including successful ticket sales and navigating the complexities of getting the film distributed in theaters. He shares his insights on the Digital Cinema Package (DCP) and offers advice for aspiring filmmakers. He emphasizes the importance of patience, discipline, and solid pre-production planning. The episode concludes with details on the film’s premiere and CJ’s plans.

Highlights include:

  • Post-Production Journey
  • Understanding Digital Cinema Package (DCP)
  • Publicizing the Film
  • Mentorship and Team Building
  • Premiere Night Excitement
  • Advice for Aspiring Filmmakers

Resources:

Sherlock Holmes-Mare of the Night

On Facebook

TriGoodwyn Productions

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Blog

AI, Process Management, and Compliance

Integrating artificial intelligence (AI) and advanced analytics with robust process management principles can unlock new levels of efficiency and innovation. Mars Wrigley, the global confectionery leader, offers an instructive case study. In an article in the Harvard Business Review entitled, How to Marry Process Management and AI Thomas H. Davenport and Thomas C. Redman wrote that through its strategic deployment of AI to digitize its supply chain and manage operations, Mars Wrigley demonstrates how a systematic approach to process management can achieve significant improvements in operational performance, customer satisfaction, and sustainability.

Mars Wrigley’s success story holds valuable lessons for compliance professionals about aligning technology, data, and governance to enhance compliance frameworks and drive value across organizations.

Digitization and AI: The New Frontier for Process Management

Mars Wrigley began its journey by building a digital twin of its production line and feeding real-time operational data into machine-learning models. The results were striking. The company received predictive insights that reduced overfilling, minimized waste, and optimized supply chain processes. They partnered with vendors like Aera Technology for data visualization and preventive maintenance and with Kinaxis to balance supply and demand, automate invoices, and increase truck utilization by 15%.

This underscores a critical point from a compliance standpoint: Technology can only enhance compliance when processes are well-defined, integrated, and aligned with organizational goals. Compliance officers must recognize the potential of AI to streamline compliance monitoring, enhance risk detection, and reduce manual inefficiencies.

For example, consider AI tools that monitor high-risk transactions or flag anomalies in employee expense reports. When implemented in a robust compliance framework, these tools improve detection rates and allow compliance teams to focus on strategic initiatives rather than routine checks.

The Role of Process Management in Compliance

Process management is about understanding how tasks fit together to create a specific outcome and then optimizing those sequences. Put another way, it is about operationalizing compliance. Whether addressing department-level activities or end-to-end processes, process management principles can yield transformative results when applied to compliance. What are some of the ways process management can do so?

In areas as basic as error reduction, well-managed processes minimize compliance failures by reducing error rates and increasing consistency. A traditional compliance department area is cross-functional coordination with other corporate departments. Effective compliance requires breaking down silos, whether between legal, finance, HR, or operations, and aligning departments toward common objectives.

This approach can also positively impact corporate culture by increasing stakeholder buy-in and employee engagement. Process management often conflicts with hierarchical management structures. In compliance, this tension may manifest when reconciling DOJ mandates with operational priorities in your organization. Persuading stakeholders to prioritize compliance demands strong leadership and effective change management.

AI and Process Management: A Compliance Blueprint

AI supports specific subprocesses within larger workflows, but true transformation occurs when organizations integrate these capabilities across end-to-end processes. For compliance professionals, this is a roadmap for embedding AI into compliance programs.

Step 1: Establish Ownership

Every effective compliance initiative begins with clear accountability. A defined ownership structure underpinned Mars Wrigley’s digital twin success. Compliance programs require similar clarity. Appointing a “compliance process owner” ensures cross-functional alignment, while department-level compliance champions can coordinate implementation.

Step 2: Map and Redesign Processes

Mapping current compliance processes is essential for identifying inefficiencies. Process mining tools, which analyze enterprise system logs to identify bottlenecks, can uncover hidden risks. For instance, tracking the due diligence lifecycle in third-party onboarding can reveal inefficiencies, such as delays in background checks or missed follow-ups.

Redesign efforts should prioritize risk-prone areas, leveraging AI tools to streamline activities like transaction monitoring, policy distribution, and whistleblower case tracking.

Step 3: Define Metrics and Set Targets

Compliance performance must be measurable. Metrics such as incident resolution times, training completion rates, and risk assessment quality should guide process improvements. AI enables real-time metrics monitoring, providing insights that compliance officers can act on immediately. Mars Wrigley’s use of analytics to improve truck utilization offers a parallel for compliance: by tracking resource allocation, compliance teams can reduce unnecessary costs while ensuring optimal coverage of risk areas.

Step 4: Leverage Technology and Data

AI tools such as robotic process automation (RPA) and natural language processing (NLP) are increasingly used in compliance programs to automate routine tasks. RPA can streamline repetitive activities like generating regulatory reports. NLP can analyze large volumes of text, such as contracts or policies, to identify risks or inconsistencies.

Compliance professionals must also advocate for standardized data practices. As Mars Wrigley’s case illustrates, data silos impede process efficiency. In compliance, inconsistent data can obscure risks, making standardized data governance a cornerstone of effective compliance.

Step 5: Foster a Culture of Continuous Improvement

AI and process management are not “set it-and-forget it” solutions. As Mars Wrigley demonstrated, continuous monitoring and iterative improvements are critical for sustaining gains. This means regularly reviewing and updating AI tools for compliance professionals to address emerging risks and regulatory changes.

Lessons for Compliance Professionals

Mars Wrigley’s journey highlights several key takeaways for compliance leaders:

  1. Invest in AI Thoughtfully. Technology is not a silver bullet. Its effectiveness depends on how well it integrates with and supports compliance processes.
  2. Adopt a Holistic View of Compliance. Compliance risks rarely confine themselves to one department. Breaking down silos through cross-functional process management improves visibility and reduces risk.
  3. Prioritize Data Governance. High-quality, standardized data is essential for both AI and compliance. Without it, even the best tools cannot deliver meaningful insights.
  4. Embrace Change Management. As with Mars Wrigley’s digital transformation, compliance process improvements require buy-in from leadership and employees.

The Compliance Call to Action

Compliance has been reactive for too long, focusing on addressing failures rather than preventing them. Integrating AI into process management offers an opportunity to shift that paradigm. By combining the best of technology and process management, compliance programs can reduce risk and enhance business value.

Mars Wrigley’s success story reminds us that the tools and strategies to transform compliance are available—but the onus is on compliance professionals to lead the charge. Whether through smarter risk management, better stakeholder engagement, or innovative technology adoption, the path forward is clear: process management and AI are not just operational tools; they are the future of compliance.

Now is the time to act. By adopting process management principles and leveraging AI, compliance leaders can build programs that are not only effective but also resilient, sustainable, and aligned with organizational goals. The question is no longer whether compliance should embrace these tools but how quickly they can integrate them into their processes.

By learning from companies like Mars Wrigley, compliance professionals can reimagine their programs, aligning them with the business’s needs while staying ahead of regulatory requirements.