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Compliance Tip of the Day

Compliance Tip of the Day – A Personal Operating System for Compliance Professionals

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 importance of a personal operating model for compliance officers.

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The Ethics Experts

Episode 206 – Scott Sullivan

In this episode of The Ethics Experts, Nick welcomes Scott Sullivan.

Scott E. Sullivan was most recently the former Chief Integrity & Compliance Officer of Newmont Corporation, the world’s leading gold company. Newmont has approximately 20,000 employees and 25,000 contractors with 12 operating mines and 2 non-operated JVs in 9 countries. Mr. Sullivan oversaw, developed, implemented, and managed Newmont’s integrity and compliance program, including ethics, anti-bribery, corporate investigations, conflicts of interest, and global trade compliance. Previously, Mr. Sullivan was the Chief Ethics & Compliance Officer of Flowserve Corporation, a global manufacturer of fluid motion and control products with approximately 17,000 employees operating in 55 countries.

Linkedin.com/in/scottesullivancco

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Corruption, Crime and Compliance

[Replay] The Boeing Plea Agreement

This week, we are pleased to bring you one of our most popular episodes of 2024. Please enjoy, and we will be back next week with more insights from the Corruption, Crime, and Compliance podcast.

Have you heard of the recent controversies around the Boeing 737 MAX and its safety? Have you wondered what is being done about its concerns? In this episode of Corruption, Crime, and Compliance, Michael Volkov delves into the latest developments in the Boeing 737 MAX case, highlighting the recent plea agreement proposed by the Department of Justice (DOJ). The Boeing 737 MAX case took another dramatic turn. On July 24, 2024, the Department of Justice filed a proposed plea agreement with Boeing with the United States District Court for the Northern District of Texas. Under the Plea Agreement, Boeing will plead guilty to the original information filed in 2021 with the Deferred Prosecution Agreement (“DPA”). The discussion focuses on Boeing’s alleged failure to implement adequate compliance measures, leading to significant risks and violations and the case’s ongoing legal and ethical implications. Tune in to hear a detailed analysis of the complexities and legal ramifications of Boeing’s recent plea agreement and what it means for corporate compliance and accountability.

You’ll hear him talk about:

  • Certification Issues: Boeing failed to ensure the accuracy of its 737 MAX certifications, risking false certifications to the FAA.
  • DOJ Plea Deal: Boeing agreed to plead guilty to conspiracy to defraud the U.S., facing opposition from victims’ families who find the resolution insufficient. The plea agreement, which has been filed under Federal Rule Criminal Procedure 11(c)(1)(C), requires the Court to approve and accept the deal. The Court can reject the plea deal and require the parties to renegotiate the terms.
  • Victims’ Rights: The proposed resolution has been controversial because of the opposition of the families of the victims, who have opposed the plea agreement and general disposition of DOJ’s investigation and prior resolutions as insufficient to vindicate the public interest and their rights as victims of Boeing’s malfeasance
  • Compliance Failures: Boeing breached its DPA by not implementing effective compliance controls, particularly in safety and quality processes.
  • Independent Monitor: Boeing will be monitored for three years and must invest $455 million in compliance and safety improvements.
  • Ongoing Challenges: Boeing’s anti-fraud measures still have gaps, with broader implications for industries where safety is critical.

Resources:

Michael Volkov on LinkedInTwitter

The Volkov Law Group

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Daily Compliance News

Daily Compliance News: March 24, 2025, The ABC Task Force 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.

Top stories include:

  • UK, France, and Switzerland launch the ABC task force. (WSJ)
  • How resilient is your power supply? (BBC)
  • China targets ‘petty’ corruption. (WSJ)
  • Is the Former Argentinian President banned from the US for corruption? (Buenos Aires Times)
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FCPA Compliance Report

FCPA Compliance Report – Navigating the Complexities of FTO Designations and Compliance in Mexico and Latin America

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Tim O’Toole and Matt Ellis from Miller & Chevalier Chartered to discuss the significant implications of President Trump’s executive order designating Mexican drug cartels as foreign terrorist organizations (FTOs).

Tim and Matt elaborate on the heightened compliance risks and operational challenges now faced by companies operating in these regions. The conversation delves into the legal distinctions between Specially Designated Nationals (SDNs) and FTOs, the broad-ranging impact on industries such as agriculture and logistics, and the urgent need for robust risk assessment strategies to mitigate civil and criminal liabilities under U.S. law. They also explore the broader Latin American context and potential collateral consequences for U.S. and Latin American companies amid anticipations of increased regulatory scrutiny and enforcement actions. The discussion concludes with timely observations on recent U.S. Treasury directives aimed at curbing cartel money laundering activities, showcasing the lengths the administration is willing to go to combat these criminal enterprises.

Key highlights:

  • Executive Order and FTO Designation
  • Heightened Risks for Companies in Mexico
  • Complexities of Cartel Influence in Mexico
  • Risk Management Strategies for Companies
  • Broader Implications for Latin America
  • Potential Weaponization of FTO Designation
  • Corporate Compliance and Human Rights

Resources:

Designation of Cartels as FTOs Creates Heightened Risks for Companies Operating in Latin America

Miller & Chevalier

Tim O’Toole

Matt Ellis

Tom Fox

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Blog

Compliance Leadership Week: A Personal Operating System for Compliance Professionals

This week, we begin a five-part exploration of leadership for compliance professionals. All of this week’s blog posts will be based on articles from McKinsey & Company, and all authors are with McKinsey. I will look at individual leadership issues, compliance team leadership issues, and issues for a Chief Compliance Officer (CCO) or compliance professional for greater corporate matters. We begin our exploration by considering individual leadership issues for compliance professionals. Today’s (and tomorrow’s) blog posts are based on the article Warning: Upgrade your personal operating model by McKinsey authors Arne Gast and Suchita Prasad.

Compliance professionals are used to alerts and notifications reminding us to keep our organizational technology and systems up-to-date. Messages like “Update now or risk losing access” flash across our screens regularly, prompting immediate action to secure organizational infrastructure. But how often do we take such vigilant measures to update our personal operating systems and the personal models that guide our professional effectiveness and impact?

In today’s rapidly evolving corporate landscape, compliance officers face unprecedented challenges. Regulatory shifts, technological advancements, new business risks, and societal expectations are constantly in flux. To navigate these waves successfully, we must regularly revisit and recalibrate our personal operating models. Like any critical business system, your personal operating model comprises the choices you make regarding your priorities, the roles you fulfill, the allocation of your time, and the management of your energy.

The Importance of a Personal Operating Model for Compliance Officers

Just as outdated technology poses security risks to an organization, an outdated personal operating model can compromise your effectiveness as a compliance officer. Regularly updating your approach helps ensure alignment with organizational goals, regulatory demands, and professional growth opportunities. Yet, unlike device upgrades, no automatic alerts prompt these updates; compliance officers must generate internal notifications for reflection and action.

The Four Drivers of Your Personal Operating Model

To effectively refresh your compliance operating system, consider four critical drivers: priorities, roles, time, and energy. Each element is essential to your professional impact and resilience.

1. Priorities

Compliance leadership starts with setting clear, strategic priorities. Have you identified your compliance mandates? Do you understand the expectations and potential areas of overshooting or underperformance? Compliance mandates come from various stakeholders, including senior executives, board members, regulatory bodies, and external auditors. Clarifying these mandates and transparently communicating them is vital. Leaders must boldly determine which mandates to fulfill, manage stakeholder expectations, and consciously decide where strategic disappointments might be necessary, always within manageable bounds.

Consider a compliance officer entering a new organization. Initially hesitant to make sweeping changes to established protocols, a careful stakeholder review might reveal a clear mandate for significant compliance transformation. Recognizing and embracing these mandates positions you to effectively lead impactful change.

2. Roles

Effective compliance officers clearly define roles, prioritizing tasks uniquely suited to their capabilities and delegating responsibilities to leverage organizational strength effectively. Are you focusing only on critical compliance tasks that you can manage effectively? Are you building positive leverage by engaging competent team members?

For instance, overseeing critical internal investigations might require direct involvement, while day-to-day compliance monitoring could be delegated to well-trained compliance staff. Choosing where to apply your expertise maximizes your overall impact and builds robust organizational compliance capabilities.

3. Time

Managing time is a fundamental skill for compliance leaders. How effectively are you scheduling and structuring your time to handle critical compliance issues proactively rather than reactively? Establishing boundaries, creating productive rhythms, and thoughtfully redesigning meetings can dramatically increase compliance effectiveness.

For example, compliance executives often experience calendar overload with meetings, training sessions, and urgent crisis interventions. Reflecting on your meeting structure can streamline effectiveness, eliminate unnecessary gatherings, and improve the productivity and clarity of compliance communications. Clearer schedules allow space to manage emerging compliance risks and regulatory changes proactively.

4. Energy

Finally, maintaining and protecting your energy is crucial for sustained effectiveness and resilience. Compliance roles are demanding and often filled with high-pressure situations and complex problem-solving. Do you actively manage your health, nurture supportive relationships, and connect deeply with the purpose behind your compliance work?

A compliance leader in a multinational firm found himself stretched thin by constant international travel and demanding audits. Realizing his health was compromised, he committed to regular exercise, improved nutrition, and better sleep habits. Coupled with meaningful social connections and reflection on his professional purpose, these actions revitalized his energy, enhanced productivity, and deepened his commitment to his compliance leadership role.

Implementing Your Personal Operating System Upgrade

To systematically update your personal compliance operating model, consider enlisting accountability partners, colleagues, mentors, or trusted personal contacts—to ensure consistent reflection and action. Regularly scheduled reviews, akin to software updates, help maintain your personal operating system’s integrity and effectiveness.

As compliance officers, our effectiveness hinges significantly on our ability to adapt and respond proactively to evolving regulatory and business landscapes. While technology alerts remind us to upgrade our devices, we must generate our notifications, prompting essential personal model upgrades. Continually recalibrating priorities, clearly defining roles, efficiently managing time, and actively preserving our energy empower us to deliver impactful compliance leadership.

Maintaining an up-to-date personal operating model positions compliance professionals to proactively anticipate risks, effectively drive organizational compliance initiatives, and sustain long-term professional resilience. Regular updates to your personal compliance operating system are not merely beneficial; they are essential to your continued success and the broader success of your organization.