Categories
Compliance Into the Weeds

Algorithm Failures in Ethics and Equity at Stanford


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 how badly Stanford University Health Systems botched it decision on whom in the organization would receive its allotted Covid-19 vaccinations. Stanford used a faulty algorithm which mandated that only seven of the Health Systems 1300 medical residents would receive the vaccine. As you might guess these front-line health workers were up in arms over Stanford’s incompetence on this issue.
Some of the issues we consider are:

  • The plan had been for the algorithm to assign vaccination slots for the first 5,000 employees, who would begin receiving the Covid vaccine on Dec. 18.
  • What were the parameters of the algorithm?
  • Why was there so little ethics in the process?
  • Why was there so little equity in the result?
  • What are the implications for the compliance professional of the use of the algorithm to make such a critical decision?
  • What does the EEOC decision allowing companies to mandate vaccines for employees mean for compliance?

Resources
For more information see Matt’s blog post in Radical Compliance:
Lessons on Algorithms, Ethics and Equity

Categories
Daily Compliance News

December 23, 2020-the Break Up BAFin edition


In today’s edition of Daily Compliance News:

  • DOJ sues Walmart for its role in opioid crisis. (NYT)
  • Trump banker at Deutsche departs. (NYT)
  • Rabbit bailing DOJ. (WSJ)
  • FT calls for folding up BaFin. (NFT)
Categories
The Affiliated Monitors Expert Podcast

Cost Issues Around Monitorships


In this episode, I am joined by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. In this episode, we look at cost issues when hiring a monitor and how a company can work to ameliorate them. Some of the highlights from this podcast include:

  1. What will be the overall scope of the monitorship?
  2. What will be the frequency of engagement by the monitor?
  3. What will be the duration of the monitorship?
  4. What is the experience of the monitor and how does that play into overall costs?
  5. How you can work through cost control issues by using a robust monitor’s Workplan?
  6. How selective sampling is a powerful tool and why it can be a cost-saving measure.

For additional reading see Jay Rosen’s article How Much Will a Corporate Monitorship Cost? on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. visit their website here.

Categories
The Compliance Life

The Compliance Life-Kim Yapchai, Make Tomorrow Better (and have some fun)


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 Kim Yapchai, the Chief Counsel – Environmental, Social & Governance at Tenneco Inc.  This encompasses both compliance and sustainability.
Kim calls herself a “businessperson with a law degree” and she has had a distinguished career in the in-house world. She held in-house positions at Ford Motor Credit Company and Masco before moving to Whirlpool to become the company’s first Chief Compliance Officer. From there she moved to Tenneco to the CCO chair and then into her current role. Further, she is the company’s first Chief Sustainability Officer. In this role, she is working to improve transparency of information shared with stakeholders, set goals, and promote the use of that information by investors, customers, and others. Kim has received numerous awards include the prestigious Top Minds in Compliance Award from Compliance Week.
In this fourth and final episode, Kim discusses receiving the designation of Chief Sustainability Officer and how that intersects with her role as CCO. We conclude with a look at where the risk management professional and risk management profession might be in 2030 and beyond. Finally, in her role as Chief Sustainability Officer, Kim wants to work to “Make Tomorrow Better”.

Categories
12 O’Clock High-a podcast on business leadership

Crucibles of Leadership


In this episode of 12 O’Clock High, a podcast on business leadership, Richard Lummis and myself consider how leaders grew and evolved during crucible crisis in their professional careers. This podcast is based on the Harvard Business Review article, Crucibles of Leadership by Warren Bennis and Robert J. Thomas, where the authors posited that “a crucible is, by definition, a transformative experience through which an individual comes to a new or an altered sense of identity. It can often involve the experience of prejudice, as “it forces an individual to confront a distorted picture of him- or herself, and it often unleashes profound feelings of anger, bewilderment, and even withdrawal. For all its trauma, however, the experience of prejudice is for some a clarifying event. Through it, they gain a clearer vision of who they are, the role they play, and their place in the world.”
The key is how individuals deal with such or even any similar adversity. You can and indeed must learn from negative events. This is not simply learning from your mistakes but forces you into a deep self-reflection where you examine a wide set of core beliefs, including your own judgment. A successful leader will emerge from such a personal trauma stronger, more confident, with more purpose and indeed more committed to your values and work.
Some of the highlights include:

  1. What a “Crucible of Leadership”?
  2. Some examples of crucibles of leadership.
  3. Sidney Harman-Richard
  4. Vernon Jordan-Tom
  5. Four Essential Leadership Skills
  6. Engage Others in Shared Meaning
  7. Distinctive, Compelling Voice
  8. Integrity
  9. Adaptive Capacity
Categories
Daily Compliance News

December 22, 2020-the J’accuse edition


In today’s edition of Daily Compliance News:

  • Charles Schwab fined in UK. (WSJ)
  • Google denies US anti-trust claims. (NYT)
  • How did Congress actually fight corruption. (com)
  • Microsoft accuses Trump Administration of corruption. (NPR)
Categories
FCPA Compliance Report

James Koukios on the MoFo Top 10 International Anti-Corruption Developments for September 2020


In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for September 2020.
Some of the highlights include:

  1. Brazil developments. Car wash to be extended?
  2. SEC Amends Rules Governing Whistleblower Awards. Why were they amended?
  3. Why has it become so important/powerful?
  4. Any chance new Administration or Congress would fix Supreme Court decisions in Kokesh and Digital Realty Trust?
  5. Sargent Marine FCPA enforcement action-a rare criminal prosecution against a company. Why are such cases so rare?
  6. The discount: what was the basis; what is the process for seeking such a discount? What types of evidence is required?
  7. Oil Trader Charged with Bribing Ecuadorian Officials. 

Resources
To a copy of the Top 10 International Anti-Corruption Developments for September 2020 Newsletter click here.

Categories
Daily Compliance News

December 21, 2020-the Exiles edition


In today’s edition of Daily Compliance News:

  • Wasted work, wasted time, wasted space. (WSJ)
  • Can we save the country from monopolization? (WaPo)
  • Of exiles and anti-trust. (NYT)
  • 5 retail marketing trends COs need to consider. (AdAge)
Categories
Sunday Book Review

December 20, 2020, the John le Carré edition


In today’s edition of Sunday Book Review:

  • The Spy Who Came in from the Cold
  • Tinker, Tailor, Solider, Spy
  • The Little Drummer Girl
  • A Prefect Spy
Categories
Daily Compliance News

December 19, 2020-the Trojan Horse edition

In today’s edition of Daily Compliance News:

  • The Trojan Horse attacks start against the AML whistleblower law. (WSJ)
  • GOP tries to rein in Fed before Biden becomes President. (NYT)
  • Oil companies and (even worse) reputational damage. (HoustonChronicle)
  • Google AI Team Demands Ousted Black Researcher Be Rehired And Promoted. (NPR)