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Innovation in Compliance

The Six Elements of an Effective Compliance Program: Part 4 – Training and Education: Effectively Getting your Compliance Messaging Out


Welcome to a special five-part podcast series, The Six Elements of an Effective Compliance Program. This podcast series is sponsored by StoneTurn. To celebrate Corporate Compliance and Ethics Week, we will consider each of the six elements required for an effective compliance program. They include: Risk Assessment, Governance and Structure, Policies Procedures and Controls, Training and Education, Oversight and Reporting, and Response and Enhancements. Over this five-part podcast series, I will be joined by Stephen Martin and Valerie Charles, Partners at StoneTurn and Toby Ralston and Jamen Tyler, Managing Directors at StoneTurn. In this fourth episode, I visit with Jamen Tyler on effectively getting your compliance messaging out. Highlights include:

  • In the Work From Home era how can you determine the effectiveness of your compliance training and communications?
  • In the 2020 Update, the DOJ for the first time discussed short training and communications, focusing on one issue messaging. What are some of the trends you are seeing in such micro-learning? What about other types of training?
  • In terms of compliance training frequency and cadence, what are you seeing as current best practices?
  • What are the advantages of compliance ambassadors across a multi-national organization? Can they be outside the compliance dept?

Resources
For more information on StoneTurn, click here.

Categories
Daily Compliance News

November 5, 2020-Election Blues edition

In today’s edition of Daily Compliance News:

  • Son of Brazilian President to face graft charges. (WSJ)
  • Top tech trends for business. (com)
  • Trump ends where he began: corruption. (WaPo)
  • Saudi Arabi pledges to reform Kafala system. (com)
Categories
12 O’Clock High-a podcast on business leadership

Margaret Johnson on moving your leadership to WOW

In this episode, I visit with Margaret Johnson, the author of the book from From SOS to WOW. This book can help you to move your leadership skills to a new level through by helping you bust through assumptions, unleash your creative ideas and take courageous action to finally make the move to where you really want to be personally or professionally. Johnson is a long-time business leadership coach who shares some of the techniques she uses to help folks achieve greater results in business and in life.

We discuss her growing up and college years in Michigan why she got to Texas as quickly as you could. She details her professional career in the energy and power industries and how that work prepare you for your current career. She then talks about what led her to write her book and how it can be used by a person to help achieve personal and professional goals.
You can find the book on Amazon.com by clicking here.
You can find out more about Margaret Johnson by checking out her website, ideasandbeyond.com.

Categories
Compliance Into the Weeds

Turbulence in the Compliance Profession


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. In this episode Matt and Tom go into the weeds to look at the turbulence brought to the compliance profession and compliance job market. Some of the issues we consider are:

  • How Working From Home has brought a material change to the practice of compliance.
  • How to follow the money in the age of Coronavirus?
  • Has the pandemic made compliance more relevant?
  • Why is there such turbulence in the compliance job market?
  • How has the pandemic transformed one traditional risk into something that manifests quite differently.?
  • How is the compliance profession evolving? 

Resources
See Matt’s blog posts on Radical Compliance– Compliance and Career Turbulence

Categories
Innovation in Compliance

The Six Elements of an Effective Compliance Program: Part 3 – Policies, Procedures and Controls: the Backbone of Your Compliance Program


Welcome to a special five-part podcast series, The Six Elements of an Effective Compliance Program. This podcast series is sponsored by StoneTurn. To celebrate Corporate Compliance and Ethics Week, we will consider each of the six elements required for an effective compliance program. They include: Risk Assessment, Governance and Structure, Policies Procedures and Controls, Training and Education, Oversight and Reporting, and Response and Enhancements. Over this five-part podcast series, I will be joined by Stephen Martin and Valerie Charles, Partners at StoneTurn and Toby Ralston and Jamen Tyler, Managing Directors at StoneTurn. In this third episode, I visit with Toby Ralston on why policies, procedures and internal controls are the backbone of your compliance program. Highlights include:

  • Why is the Code of Conduct foundational?
  • Is one of the key functions of compliance policies to provide a deeper level of guidance?
  • What audience should a Code of Conduct, policies and procedures be written towards? Should they be translated into local languages? Should you have employees attest to reading them or use some other model to demonstrate effectiveness?
  • Why should Internal Controls for compliance be tied to your risk assessment? How do you do so?
  • Internal controls are often seen as financial controls. Can you discuss some instances of non-financial controls and their importance?

Resources
For more information on StoneTurn, click here.

Categories
Innovation in Compliance

The Six Elements of an Effective Compliance Program: Part 2 – Governance and Structure: Ensuring a Strong and Functional Compliance Program

Welcome to a special five-part podcast series, The Six Elements of an Effective Compliance Program. This podcast series is sponsored by StoneTurn. To celebrate Corporate Compliance and Ethics Week, we will consider each of the six elements required for an effective compliance program. They include: Risk Assessment, Governance and Structure, Policies Procedures and Controls, Training and Education, Oversight and Reporting, and Response and Enhancements. Over this five-part podcast series, I will be joined by Stephen Martin and Valerie Charles, Partners at StoneTurn and Toby Ralston and Jamen Tyler, Managing Directors at StoneTurn. In this second episode, I visit with Stephen Martin on compliance program governance and structure. Highlights include:

·      A CCO must have access and expertise. Who should a CCO have access to and what should be a CCO’s level of expertise?

·      A compliance function must be adequately resourced programs – what does this mean in practice? How much budget should your compliance program have? What should be your compliance function head count? What about those outside the compliance function that assist compliance?

·      Why should a Board have compliance expertise? What does the Department of Justice’s 2020 Update to the Evaluation of Corporate Compliance say about compliance expertise on the Board?

·      Why should there be a Compliance Committee, separate and apart from the Audit Committee?

·      Why should the Compliance Committee on the Board have a Charter?

Resources

For more information on StoneTurn, click here.

Categories
Compliance and Coronavirus

Ray Dookhie on Unemployment Fraud During the Era of Covid-19


Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. In this episode, I am joined by Ray Dookhie, Managing Director at K2 Intelligence FIN. Ray returns to discuss the recent FinCEN alert on unemployment fraud and the evolving fraud risks brought on by Covid-19.
Some of the highlights include:

  • We are now some 8 months into the pandemic and the challenges financial institutions face have morphed. What are some examples?
  • Recently Treasury Department’s Financial Crimes Enforcement Network issued an advisory on unemployment fraud. What is the significance of this release?
  • What is this type of fraud?
  • Why is Unemployment insurance a prime target for fraudsters?
  • What are some of the red flags?
  • Why are Financial institutions effectively at the front lines against the fight against fraud?
  • If a financial institution detects suspicious payments or other evidence, what should they do?

Resources
For more on current fraud risk, see Fraud’s Perfect Storm: Mitigating Risk in a Global Pandemic by JoAnne Taylor
For more on fraud issues around PPP, see PPP Lending—A Unique Compliance Challenge for Banks
For information and resources on Covid-19, see the K2 Intelligence FIN COVID-19: Resources and Insights
Read the full FinCEN Alert

Categories
Great Women in Compliance

Andrea Falcione, Part 2-Policies


Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
We invite back Andrea Falcione to round off this series on documentation by exploring best practices in Compliance policies. Before we do however, we hear about Rethink Compliance’s approach to maximizing the resource of women returning to the workforce or looking for flexible hours. It sounds win-win to us!
In this episode we discuss the difference in focus between your code and policies, frequency of revisions to policies, desired tone and message, making the most of learning aids and other hot topics for assembling a collection of best in class Compliance policies.
Have you heard that Lisa and Mary have published a book? Yes, you can get your very own copy of “Sending the Elevator Back Down: What We’ve Learned From Great Women in Compliance” (CCI Press, 2020) on Amazon right now! Enjoyed your copy? Don’t forget to leave a review!
Join the Great Women in Compliance community on LinkedIn here.

Categories
Daily Compliance News

November 4, 2020-Election edition II


In today’s edition of Daily Compliance News:

  • JPMorgan facing additional regulatory scrutiny? (WSJ)
  • Ant faces regulatory backlash (In China). (WSJ)
  • US District Judge excoriates Trump Administation illegal attempt to block voting by mail. (WaPo)
  • Deutsche Bank looking to dump Trump. (com)
Categories
The Affiliated Monitors Expert Podcast

Case Studies of Working with 3rd Party Independents


In this podcast, I am joined by AMI Managing Director Donald K. Stern. In this episode, we look at some case studies. Case studies are something every lawyer and compliance practitioner responds to because it presents real facts and events that the corporate compliance discipline can learn from and, hopefully, incorporate these lessons learned into their organizations.
Stern believes, “it does lend some support. The organization under investigation not only has the right instincts, motivations and goals but it intends to fix the problem.” He believes they do “not expect you to assess every conceivable possibility and turn over every possible rock to interview every employee that might be involved. They want you to take a more risk based focused view on where you see the problems. The best way to do that is not by looking to people internally whose livelihood depends upon getting a paycheck every other week or every month from the company, but the people who were outside the company and who have some measure of independence.”
It is about the data and the metrics you use to reach your conclusions. This is because prosecutors are becoming much more sophisticated in their understanding of what constitutes a best practices compliance program. Stern noted that in areas as diverse as the FCPA or health care fraud not just the federal government, but state governments and now increasingly local governments, are really asking the right questions. They want to know, “what makes a good compliance program and what assurances do we have that if we give you a break in this case that you’re actually going to end up at the end?” The government wants corporations to be good corporate citizens and third-party independent monitors can help provide that assurance.