In today’s edition of Daily Compliance News:
In the Episode, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and international law. She is accustomed to working on extremely sensitive and high-profile matters, both nationally and internationally. In this episode, we continue our multipart series on the Wirecard accounting fraud. Today, we begin a two-part exploration of the role of money-laundering in the Wirecard saga.
Some of the highlights include:
· How money laundering works?
· What is threat finance?
· Other examples of German corporate fraud?
· Why 2006 was such an important year in anti-money laundering?
· How Wirecard made money through money laundering.
· The risk related business model used by Wirecard.
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 Kelly and Tom Fox consider the $20+ billion spend by Wells Fargo for its various regulatory fines and penalties, investigative and remediation costs since the initial announcement of its fraudulent accounts scandal back in 2016.
Some of the highlights include:
Resources
See Matt’s blog post, Wells Fargo’s Staggering Compliance Costs on Radical Compliance.
In this episode, I visit with Vin DiCianni, CEO and founder of Affiliated Monitors, Inc. (AMI) about his idea which led to the founding of AMI. DiCianni discusses how he developed the idea which led to the founding AMI. DiCianni began formulating the idea of an independent monitor when he observed a series of corporate punishments which he believed did not fit the crime. As a white-collar defense lawyer in the 1990s, DiCianni saw that there was only two ways a state regulator could go if someone was convicted of a transgression such as billing mistakes or similar regulatory violations. The licensed professional would either be convicted and have their state license suspended or revoked or there would be no prosecution. DiCianni viewed this as “a death sentence” for a licensed professional. He added, “It just seemed wrong to me, but there was nothing that was out there. For about seven, eight years, this idea just percolated in my head about doing something to create these alternative sanctions, if you will, on the probationary side of things. So that a doctor or the practitioner could get better.”
From this point, DiCianni was able to convince some state regulators in Massachusetts to try this third way of having an independent monitor step in and assess whether a professional, who had run afoul of a regulatory scheme, could be rehabilitated via a probationary structure. He then I reached out to a number of folks in the Boston area. Some of them were regulators, some were attorneys who represented folks before the state boards, some were acting state attorneys general and some were in business. With this idea coming to fruition, the next step for DiCianni was to create a business organization to fill this niche.
For more information on Affiliated Monitors, check out their website at www.affiliatedmonitors.com.
Welcome to a special five-part podcast series, A Conversation with Convercent and StoneTurn: From the Code of Conduct to Risk Assessment to Continuous Improvement. This week’s podcast series is jointly sponsored by Convercent and StoneTurn. In this podcast series we will explore the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (2020 Update). We focus on investigations, data analytics, evaluating compliance programs, internal reporting and corporate culture. Participants in this podcast series include: from Asha Palmer, Chief Compliance Officer and EVP from Convercent; Rex Homme, Michele Edwards, and Stephen Martin, all Partners at StoneTurn. In this third episode, Michele Edwards and I discuss how a compliance professional can create an inventory of metrics by which to monitor and then improve a compliance program.
Join us tomorrow, as Asha Palmer, EVP at Convercent, discusses corporate culture itself to better monitor and improve your compliance program.
Resources
For more information on StoneTurn, check out their website, here.
For more information on Convercent, check out their website, here.
To download a copy of the Convercent Interactive Self-Assessment based on the 2020 Update to the Evaluation of Corporate Compliance Programs, click here.
Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. In this episode, I visit with Jed Gardner, Senior Vice President at Linedata Technology. We discuss moving from disaster recovery to business continuity to business as usual during the time of Coronavirus.
Some of the highlights include:
For more information on Linedata Technology click here.
Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
In today’s episode, Lisa speaks with Neta Meidav, who founded Vault Platform. It is a reporting and resolution platform which is intended to be a safe space to report any form of misconduct and for follow up.
Neta’s idea for Vault came out of personal experience as she was harassed at a job earlier in her career. She left that role, and months later she learned of another victim. This stayed in her mind until #metoo, and then started developing this reporting system using her experience and her technology and business acumen.
We talk about allegation reporting generally, and how it is important to provide a safe space for victims of harassment, and to make it easier to save information. This is a very important topic in order to improve our ability in the ethics and compliance world to effectively address the issues brought to light in the Black Lives Matter movement, as well as COVID and #metoo.
Neta also provides insight into what trends she is seeing now, and what advice she has to encourage reporting and effective resolution of allegations.
Join the Great Women in Compliance community on LinkedIn here.
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 Louis Sapirman, Vice President, Chief Ethics & Compliance Officer and Chief Compliance Counsel for Panasonic Corporation of North America, the principal North American subsidiary of Panasonic Corporation. He oversees the company’s regulatory and compliance function, maintaining a culture of ethics, and ensuring all employees are upholding Panasonic’s longstanding values in their work.
Louis previously served as Associate General Counsel & Chief Compliance Officer for the Dun & Bradstreet Corporation. During his tenure as CCO, the company was recognized as one of the World’s Most Ethical Companies by the Ethisphere Institute. Prior to moving in-house, Louis worked in private practice with several law firms including Wilmer Cutler Pickering Hale & Dorr and Buchanan Ingersoll. Throughout his career, Louis has been recognized for his work. In both 2015 and 2016, the Ethisphere Institute named him to their list of Attorneys Who Matter in Compliance and Ethics, and in 2010 he was named International Employment Lawyer of the Year by the Association of Corporate Counsel.
In this Episode 2, we explore the qualities of the Successful CECO. Some of the key leadership attributes Sapirman sees as critical are Great Communication, a skill that should be practiced constantly, to ensure you remain successful. You should engage in Servant Leadership and your success lies solely in the success of others. Why you need to be flexible and even be a Chameleon. You must be innovative because if you keep doing the same thing over and over, eventually it becomes stale and is destined to fail. Success in E&C requires the ability to be creative and see the novel solutions and change necessary to keep your program successful.
The basic framework for internal controls is derived from the COSO Model developed by the Committee of Sponsoring Organizations of the Treadway Commission in 1992 (COSO). This model has become the standard for an internal control framework and provides a structure to ensure companies address the key elements that should result in an effective system of internal controls. Using the COSO Model, as modified in 2013, provides a very supportable approach when regulators challenge whether a company has effective internal controls. The COSO Model defines internal controls in a pyramid, from bottom to top, as follows: (a) Control environment, (b) Risk assessment, (c) Control activities, (d) Information and communication, and (e) Monitoring.
Internal controls for a Board or Board Compliance Committee should be broken down into five concepts:
Three Key Takeaways
