Richard Lummis and Tom Fox begin a two-part series on leadership lessons from Woodrow Wilson. In this Part 1, we look at lessons from Wilson’s formative years in growing up in the South, his educational career, his academic profession and thought leadership; his Presidency of Princeton, his governorship of New Jersey and the Presidential election of 1912. In Part 2 we will take up his Presidential years.
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The Family Tree
Welcome to the latest edition to the Compliance Podcast Network, The Wirecard Saga. In this series, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors. In this episode, we take a deep dive into the government officials ensnared in the Wirecard scandal, Wirecard nexus to the MNC scandal and more dodgy deals. All this and much more in the Family Tree edition.
Some of the highlights include:
- Short Sellers Strike Again
- Wirecard Nexus to MNC Scandal
- BR Shetty’s Empire Falls
- Finablr Enables Dirty Deals
- Muddy Waters Alleges EY Too Cozy
- India & UAE Wirecard Execs Like Unimoni
- Knoechelmann and Partners Share Everything
- DPO, Acona, Wirecard and Apis Co-Mingle
- DPO Goes Shopping
- Network International Buys Into the Action
- More Dodgy Deals In India
- All Roads Lead to Singapore
There is nothing like an internal whistleblower report about a compliance violation, the finding of such an issue, or (even worse) a subpoena from the DOJ or notice letter from the SEC to trigger the Board of Directors and senior management attention to the compliance function and the company’s compliance program. Such an event can trigger much gnashing of teeth and expressions of outrage followed immediately by proclamations “We are an ethical company.” However, it may well be the time for a very serious reality check.
You may find yourself in the position that you will have to have some very frank discussions about what to expect in terms of costs and time outlays. While much of these discussions will focus on the investigative process and those costs, these discussions will allow you to initiate the talk about remediation going forward and begin to explain why money must be budgeted for the remediation process.
One of the things rarely considered is how the investigation triggers the remediation process and what the relationship is between the two. When issues arise warranting an investigation that would rise to the Board of Directors level and potentially require disclosure to the government, there is usually a flurry of attention and activity. Everyone wants to know what is going on. In an interview with Russ Berland, CCO at Aventiv Technologies, he noted, “for that short moment in time, you have everyone’s full attention.” Yet it can still be “a tricky place, because you get your fifteen minutes to really get everyone’s full attention, and from then on, you’re fighting with everybody else for their attention, like the normal things in business life.”
Three key takeaways:
- A serious FCPA allegation gets the attention of the Board and senior management. Use this time to move the compliance program forward.
- Be aware of how your investigation can impact and even inform your remediation efforts.
- Be prepared to deal with the dreaded “where else” question.
In this episode, I am joined by Jay Rosen, VP of Business Development for Affiliated Monitors, Inc.. Corporate culture exists in the space between what an organization professes and what it does. today, we examine any key aspect of corporate culture, including why it matters, what influences culture, the CCOs role in culture, assessing corporate culture and how to use that information to improve culture. We consider how to assess your corporate culture.
Highlights include:
- Who should perform the assessment of corporate culture?
- An in-house resource may be seen as more ongoing monitoring than culture assessment.
- Conversely an independent outside expert may be able to garner more fulsome information of the true state of your corporate culture.
- Tools to assess the culture of an organization include employee surveys, conversations, visits to field operations.
- What are the differences, if any, which must be considered when assessing a global company?
- Why do you need to “fine-tune” a cultural survey to get a good understanding of the company’s culture and obtain meaningful metrics?
- The bottom line is you should take the temperature of your employees internally by doing regular monitoring of your company to understand its culture and what needs to be done.
For more information on Affiliated Monitors, Inc. check out their website here.
For more information see Jay’s blog post How does a company assess its culture? on Corporate Compliance Insights.
Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
When we think about lawyers in the Compliance context, a number come to mind. Those who represent us in the event of government action taking place, those who help us with investigations, those who help us objectively evaluate our Compliance program, those who give us advice on a point of law when we need it, those who are appointed to us as monitors and so on. One area that doesn’t get a lot of attention is the role of the lawyer as whistleblower representative. This Great Women in Compliance Podcast sheds some light on this advocate role by way of our interview with Mary Inman who heads up the International Whistleblower Practice at Constantine Cannon.
In her legal practice, Inman represented the high profile Theranos whistleblower Tyler Schulz, among others. We draw on this fascinating experience to bring you Part 1 of a two-part series on whistleblowing starting with Inman’s perspective as an advocate for whistleblowers and ending with the view from the other side of the fence as the whistleblower with Erika Cheung, another of the Theranos whistleblowers.
Inman, who is the epitome of effervescence, does some level setting for us by explaining the role of a whistleblower lawyer and why a whistleblower might want one. She gives her view on whether there are any differences between male and female whistleblowers based on her extensive experience and as someone who has spent her entire career in private practice, shares a tip on avoiding burnout.
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 which is hosted on the Compliance Podcast Network.
Lisa and Mary have extended the Great Women in Compliance brand to the booking “Sending the Elevator Back Down: What We’ve Learned from Great Women in Compliance” (CCI Press, 2020) which can be found on Amazonand features valuable wisdom and advice from Great Women in Compliance across the world.
If you’ve already read the booked and liked it, will you help out other women to make the decision to leverage off the tips and advice given by rating the book and giving it a glowing review on Amazon?
As always we’re so grateful for all of your support and if you have any feedback or suggestions for our 2021 line up, or would just like to reach out and say hello, we always welcome hearing from our listeners.
Join the Great Women in Compliance community on LinkedIn here.
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the Capital One resolution of the FinCEN enforcement action. We look at the compliance program; red flags missed, and how the bank was faulted as its compliance program was found to be not effective.
Resources:
See Matt’s blog post Capital One Whacked on AML Failures
See Tom’s blog post the Capital One FinCEN Enforcement
The Compliance Life 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 success navigate the compliance waters in any company? 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. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Gwen Hassan, Managing Counsel and Director of Compliance at CNH Industrial.
In this third episode, Gwen shares the advice would you give to someone who may be interested in pursuing a career in compliance. She details the most challenging thing about being a compliance professional and what is the most rewarding. She looks into the future and explores where she sees the profession headed over the next decade and what new skill sets will be needed/required to be successful in 2025 and beyond.
Robert Meyers is the Channel Solutions Architect for One Identity, a software company that helps organizations establish an identity-centric security strategy. Tom Fox welcomes him to this week’s show to talk about compliance, data privacy, and employee data issues.
The Role of One Identity
“Most companies forget about employees, and this gets impacted by GDPR,” Robert says. His role at One Identity allows him to explain to companies where they can fit identity protections for employees. He also helps companies with their logging systems to prevent them from sending out sensitive information into their log store. Robert adds that he also works as a consultant for partners and helps with privileged access management.
Data Has a Life Cycle
“Data itself should have a life cycle,” Robert emphasizes. The concept of never deleting anything and keeping copies of everything is a bad idea. Data discipline and data management governance expects that you remove data at an appropriate time. Robert iterates that data privacy and data protection have to be integrated with operations because if it isn’t, it won’t be dealt with at all. In response to Tom’s question on who owns Compliance, Robert says that it has to be the Chief Operating Officer.
What’s Next
Tom asks Robert what businesses should expect to happen around data privacy between now and 2023. Robert says that there will be more risk assessment. Most breaches conducted within organizations are internal. He advocates for greater enforcement of laws and regulations as well as more legislation.
Resources
OneIdentity.com
Robert Meyers | Twitter, LinkedIn