Categories
The Ethics Experts

Episode 202 – Avril Ussery Sisk

In this episode of The Ethics Experts, Nick welcomes Avril Ussery Sisk.

Avril Ussery Sisk, serves as Chair of the National Association of Corporate Directors (NACD) Capital Area Chapter Advisory Board and is on the Advisory Boards of MABLE Software and Athena Alliance. She recently served on the board of a privately held information technology company, where she supported strategic public-private partnerships and the government relations strategy to drive significant revenue and, ultimately, a transaction.

An attorney with more than 30 years of professional and community leadership, Avril has a strong record of innovation in large and midsize government, business, and nonprofit organizations and consulting experience in Japan and the United States.

https://www.linkedin.com/in/avril-ussery-sisk/

Categories
Corruption, Crime and Compliance

[Replay] Review of the EU Whistleblowing Directive with Alex Cotoia and Daniela Melendez

This week, we bring you a replay of one of our most impactful podcasts from last year, featuring Alex Cotoia and Daniela Melendez. Listen in as we discuss the EU Whistleblower Directive of October 2019. We’ll return next week with one of our regular updates.

Directive 2019/1937 of the European Parliament and Council dated 23 October 2019 on the “protection of persons who report breaches of Union law” (the “Directive”) is currently being implemented by EU Member States. The directive has broad applicability to organizations operating in the EU internal market and applies to both public and private sector organizations alike. Whistleblowers are guaranteed legal protection to the extent: (1) they have reasonable grounds to believe that the information reported was true at the time of the report; and (2) the whistleblower reported either internally to the organization, externally to a competent authority, or publicly. Private sector organizations with 50 or more workers are legally required to establish channels and procedures for internal reporting of EU law breaches and conduct appropriate follow-up. 

In this episode, Mike Volkov is joined by Daniela Melendez and Alex Cotoia from the Volkov Law Group, who bring their expertise to the table as they delve into the EU Directive and its implementation by several member states. Listen to this discussion to understand and navigate the complexities of the EU Whistleblowing Directive.

  • The EU Whistleblower Directive shifts the burden of proof on retaliatory actions to the person taking the detrimental action, requiring them to demonstrate it was not linked to reporting concerns.
  • Global companies are taking a proactive stance by increasingly focusing on robust ethics and compliance programs. This strategic move is aimed at mitigating risks and promoting positive corporate citizenship in today’s economy, where adherence to legal and ethical standards is paramount.
  • France signed the EU Directive into law on March 21, 2022, outlining protocols for gathering and handling whistleblower reports, including a two-month deadline for imposing disciplinary sanctions.
  • Germany enacted the EU Directive on May 12, 2023, allowing anonymous reports and setting a three-month investigation deadline after receiving the report.
  • Spain addressed the EU Directive on February 2023 by covering additional topics like occupational health and safety breaches. The directive established a three-month deadline for investigations and allowed anonymous reports.
  • Italy transposed the EU Directive on August 4, 2022, including administrative, financial, civil, and criminal offenses not covered by the Directive, with a 30-day deadline to conduct investigations upon receipt of reports.
  • Companies are advised to make resources available to conduct investigations quickly due to the short timeframes set by various countries’ whistleblower protection laws.

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Alex Cotoia on LinkedIn 

Email: acotoia@volkovlaw.com

Daniela Melendez on LinkedIn

Email: dmelendez@volkovlaw.com

Categories
FCPA Compliance Report

FCPA Compliance Report – Eric Morehead on Understanding the Role and Function of the U.S. Sentencing Commission

Welcome to the award-winning FCPA Compliance Report, the longest-running compliance podcast. In this episode, Tom welcomes Eric Morehead to discuss the role and function of the U.S. Sentencing Commission.

Eric is the Director of Advisory Services Solutions at LRN and former Assistant General Counsel at the U.S. Sentencing Commission. He and Tom review the intricacies of the U.S. Sentencing Commission’s role, structure, and impact. Eric walks through his professional journey and explains the Sentencing Commission’s function in standardizing federal criminal sentences and promoting organizational compliance programs. He emphasizes the importance of the Sentencing Guidelines, the process for their amendment, and the challenges faced by the Commission, such as quorum issues. The discussion also touches on current topics, including the potential impact of executive orders on DEI policies and the FCPA pause, stressing the continued relevance of the Sentencing Guidelines in compliance program development.

Key highlights:

  • Eric Morehead’s Background and Role at the U.S. Sentencing Commission
  • Understanding the U.S. Sentencing Commission
  • Process of Creating and Amending Sentencing Guidelines
  • Impact of Sentencing Guidelines on Compliance Programs
  • Current Issues in Compliance: DEI and FCPA Enforcement

Resources:

Eric Morehead on LinkedIn

LRN

US Sentencing Guidelines for Organizations

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Compliance Tip of the Day

Compliance Tip of the Day – Chatbots in Compliance

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned compliance professional or just starting your journey, we aim to provide bite-sized, actionable tips to help you stay on top of your compliance game. Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

Today, we look at the use of chatbots in a best practices compliance program.

Categories
Blog

AI Chatbots in Compliance

AI-powered compliance chatbots are not just an incremental improvement; they represent a transformative shift, turning static codes of conduct into dynamic, interactive assistants. Employees no longer must flip through pages of policy manuals or wait days for an answer from compliance staff. Instead, these digital advisors immediately deliver instant, consistent, and accurate guidance, facilitating proactive decision-making and significantly reducing compliance risks.

How AI Chatbots Revolutionize Compliance

AI-driven compliance chatbots represent a major advancement in corporate compliance. They function as intelligent conversational agents designed to assist employees in navigating company policies, ethical dilemmas, and regulatory requirements. Powered by Natural Language Processing (NLP), these chatbots interpret employee inquiries accurately and deliver prompt, tailored responses. By integrating seamlessly into everyday tools such as Microsoft Teams, Slack, or corporate intranets, these chatbots become an intuitive part of employees’ existing workflows.

Consider an employee facing a potential conflict of interest scenario, unsure about the acceptability of receiving a gift from a vendor. Rather than delaying action, seeking colleague advice, or bypassing compliance protocols, the employee can privately consult the chatbot and instantly receive precise, policy-specific guidance. This immediate support increases compliance adherence and encourages a proactive, transparent approach to compliance matters.

Beyond quick access, AI compliance chatbots offer a critical advantage in consistency. Every employee receives uniform, accurate guidance, eliminating the risks of varying human interpretations or misunderstandings. These chatbots continually evolve, improving their responses by learning from past interactions and incorporating new regulatory updates and policy changes. This continuous learning capability ensures that the chatbot’s guidance remains relevant, accurate, and aligned with the latest compliance standards, ultimately promoting a robust and dynamic organizational compliance culture.

Strategic Insights for Maximizing AI Chatbot Value

Compliance professionals looking to leverage AI chatbots should consider the following strategic insights:

Define Clear Boundaries and Use Cases. Identify specific compliance areas where chatbots can add the most significant value, such as answering common HR policy questions, managing conflict of interest disclosures, or providing guidance on regulatory requirements. Establish precise limits to the chatbot’s scope to avoid ambiguity or misuse. Ensuring clarity in these boundaries helps employees understand when and how the chatbot should be used. This approach promotes efficient use and maximizes the chatbot’s effectiveness.

Prioritize Data Quality and Currency. Maintain high-quality, current information within chatbot databases by regularly updating them with the latest policy documents, regulatory updates, and procedural adjustments. Frequent reviews ensure that chatbot responses remain accurate and relevant. Outdated information can lead to compliance risks and erode employee trust in the chatbot. Consistent data updates reinforce chatbot reliability, ensuring employees receive correct and timely guidance.

Ensure Data Privacy and Security. Protect sensitive compliance inquiries by implementing robust data privacy and security measures. Employ stringent access controls, encryption standards, and secure storage solutions to safeguard employee interactions. Communicate these protections to employees to build trust and encourage open, honest dialogue with the chatbot. Data privacy and security are vital to maintaining employee confidence and regulatory compliance.

Manage Bias and Ensure Fairness. Regularly audit chatbot interactions to detect and address biases, ensuring fair responses for all employees. Biases in AI systems can unintentionally arise from underlying training data or model design. Conducting regular reviews helps identify and correct such biases, promoting fair and unbiased compliance guidance. A fair and impartial chatbot strengthens employee trust and ensures compliance advice remains universally applicable.

Establish Clear Human Escalation Points. Clearly outline scenarios where chatbot queries must escalate to human compliance officers. Define specific criteria, such as the complexity or sensitivity of the query, to determine when human intervention is required. Ensuring a smooth transition between chatbot and human guidance maintains a balance between automated support and expert oversight. This strategy helps prevent critical compliance issues from going unaddressed or mishandled.

Rigorous Testing. Conduct extensive pilot tests of chatbots using real-world compliance scenarios to identify and address potential knowledge or conversational gaps. Involve diverse employee groups in testing to capture varied interactions and unexpected questions. Thorough testing helps refine chatbot accuracy and responsiveness before broader deployment. This rigorous approach ensures reliability and user satisfaction upon full implementation.

Educate and Set Expectations. Launch chatbots alongside comprehensive communication plans clearly outlining chatbot capabilities, limitations, and confidentiality practices. Provide examples and demonstrations to help employees understand proper usage. Transparency about chatbot functionalities fosters realistic expectations and promotes trust in the technology. Effective education encourages regular and informed chatbot use.

Integrate Seamlessly into Workflows. Position chatbots within common communication tools and operational platforms that employees use daily. Ensuring easy, intuitive access encourages regular interaction with the chatbot. A seamless integration into familiar workflows significantly boosts employee adoption and compliance engagement. Such integration makes compliance advice readily accessible at critical decision-making moments.

Leverage Analytics. Use data generated from chatbot interactions to identify compliance “hot spots,” frequent misunderstandings, or unclear policy areas. Analytics provide valuable insights into employee behavior and compliance knowledge gaps. By acting on these insights, compliance teams can proactively refine policies, training, and communication strategies. Continuous analysis enhances overall compliance effectiveness and responsiveness.

Start Small, Scale Wisely. Begin chatbot deployment with targeted use cases or specific employee groups to validate effectiveness and build internal trust. Demonstrate initial successes to garner broader organizational support for expansion. Gradually scaling chatbot capabilities and reach ensures continuous improvement based on feedback and real-world experience. This cautious yet strategic approach maximizes chatbot utility and organizational impact.

The Future is Now: Chatbots in Action

After implementing their AI-driven compliance chatbot, Kimberly-Clark experienced a significant uptick in employee compliance inquiries. This surge highlighted a previously unmet demand among staff for immediate and easily accessible compliance guidance. Before the chatbot’s introduction, many employees hesitated to seek clarification on compliance issues because of uncertainty about whom to contact, embarrassment over basic questions, or the time-consuming nature of traditional communication channels. With the chatbot readily available, these barriers effectively vanished, creating an environment where employees felt empowered to address compliance concerns proactively.

This proactive engagement brought multiple benefits to Kimberly-Clark’s compliance program. First, the increased inquiry rate showed that the organization’s compliance awareness had improved dramatically. Employees who previously might have operated under assumptions or incomplete information were now seeking and receiving definitive guidance directly aligned with corporate policies and regulatory expectations. Second, it allowed compliance officers to identify areas of confusion or knowledge gaps, enabling more targeted and effective training programs and policy updates.

The chatbot’s data analytics provided Kimberly-Clark’s compliance team with valuable insights into employee behavior and compliance hotspots. Trends identified through chatbot interactions helped pinpoint frequently misunderstood policies or areas where additional clarity was needed. This intelligence empowered the compliance team to refine and streamline communications, enhancing overall compliance effectiveness proactively.

Ultimately, Kimberly-Clark’s experience underscored how integrating AI chatbots into compliance operations not only facilitates real-time, consistent guidance but also significantly strengthens the compliance culture within an organization. Employees transitioned from passively absorbing compliance information to actively engaging with it, reinforcing a shared responsibility for ethical and compliant behavior company-wide.

Navigating Challenges Thoughtfully

However, incorporating AI into compliance isn’t without challenges. Accuracy remains paramount; organizations must vigilantly guard against chatbot “hallucinations” or inaccurate guidance by implementing rigorous training, testing, and continuous oversight. Employee trust also must be nurtured, ensuring transparency about how chatbot interactions are logged and managed.

Data privacy, integration complexity, and regulatory compliance regarding AI use require careful planning. Compliance professionals must continuously assess and refine chatbot implementations to ensure these digital tools serve as trustworthy, valuable assistants rather than new sources of risk.

AI-driven compliance chatbots represent more than mere technological innovation; they symbolize corporate compliance’s proactive, integrated future. By embedding real-time, personalized compliance guidance into everyday business operations, companies can dramatically strengthen their compliance posture, mitigate risks effectively, and cultivate a robust culture of integrity.

Embracing these Chatbot tools thoughtfully, with a strategic approach to implementation and oversight, allows compliance professionals to move from reactive problem-solving to proactive risk prevention, ensuring ethical decision-making becomes a seamless, instinctive aspect of everyday corporate life.

Categories
Daily Compliance News

Daily Compliance News: March 10, 2025, The Measles at Dulles 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:

  • Conspiracy to gouge on egg prices? (NYT)
  • Boeing will face shareholder claims for the MAX 9 blowout. (Reuters)
  • Clement says all charges against Adams should be dismissed. (NYT)
  • Measles cases in MD. Possible exposure at Dulles. (Forbes)

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.