Categories
Innovation in Compliance

Corporate Training Meets Artificial Intelligence with Neha Gupta


On today’s episode of the Innovation in Compliance Podcast with host Tom Fox, we get to meet Neha Gupta, chief executive officer at True Office Learning who shares the importance of effective training within an organization. Tom first met Neha at a presentation where she was speaking on innovative compliance techniques for training and what he got was a much broader appreciation of behavioral science around compliance programs. 

From Business to Compliance
Tom asks Neha how she worked her way up to the CEO chair. Neha explains how life is 50% serendipity and 50% plans that never quite turn out that way. She started her career in business, thinking of herself to be « not a lawyer by trade, a data science geek and engineer. For her, ethics and compliance are meaningful because she finds it amazing how infrequently business conversations are included in compliance. At Citygroup, she was in charge of their institutional technology and responsible for ethics and compliance along with employee engagement functions that she reported to the board. When she started work at True Office, she realized that it was possible to have a two-way-dialogue with people using technology and even predict how they will think and behave in certain situations. She took over the organization two years ago. 
Mapping Human Behavior 
Tom asks Neha how a training company is uniquely suited to map behavior, and why it can be a powerful tool that will allow an ethical organization to remain dedicated to integrity. Neha says our behavior is driven by the things we learn along the way. She adds that the reason why training is effective for mapping human behavior is that there are very few things in your organization that touch people at every level. It is a unique opportunity to have a captive audience, once a year where everybody interacts, but so many organizations approach training in an “empty-handed-one-way-I’m-just-gonna-push-out-information” manner instead of taking time to know how different teams within the organization would handle different situations. She says the best way to run a training is to use a simulation technique, to see how each person would act in different crisis situations. 
Utilizing Data Generated Through Training
Neha believes you have to have both the training experience (regular HR training) and the data training (artificial intelligence used after training) as a continuous cycle in your workplace, because humans often forget what they have learned, but with technology, one can easily be sent reminders or nudges about said training. That is when the power of technology comes in, by using artificial intelligence to find each employee’s weakness and send them nudges about actions to take to strengthen those weaknesses. She calls this ´Adaptive Compliance Training’, which you can learn more about here.
Tom has seen many examples of what Neha has shared, and believes that many of the strategies she talks about should be implemented by all HR departments to strengthen their training.
Resources 
Neha Gupta
True Office Learning

Categories
PHorensically Speaking

Corporate Governance, Part 2

In this episode two of a two-part podcast series on Phorensically Speaking, Jonathan Marks looks at corporate governance approaches to consider when evolving your leadership and creating or enhancing your Board. Corporate governance encompasses systems and processes that support sound decision making and prevent or dissuade potentially self-interested persons from engaging in activities detrimental to the welfare of stakeholders. Learn about the key elements and here commentary about why corporate governance helps in deterring fraud.
Categories
Daily Compliance News

Daily Compliance News: August 13, 2019-the confetti edition

In today’s edition of Daily Compliance News:

  • How much in jeopardy is CITGO? (Hint-a lot). (FT)
  • How relevant is the NCAA? It sanctions schools for using confetti. (SI)
  • Have a job at Anadarko? Be afraid, be very afraid. (Houston Matters)
  • Undocumented workers on Trump properties? What me worry? (Vox)
Categories
Trekking Through Compliance

Trekking Through Compliance-Episode 73-The Lights of Zetar

In this episode of Trekking Through Compliance, we consider the episode The Lights of Zetar which aired on January 31, 1969, Star Date 5725.3.
Compliance Takeaways:

  1. What is your internal reporting mechanism?
  2. Have you trained your managers to deal with complaints?
  3. What is your triage for complaints?
Categories
FCPA Compliance Report

Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part V-Cost Issues When Hiring a Monitor

This week, over a five-part podcast series, we have considered some of the basic questions around monitors and monitorships. I have been joined in this exploration by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduced the role of independent integrity monitors and corporate monitorships; discussed both pre-settlement and post-resolution monitorships and their different applications;  and listed out some of the considerations a company should take in hiring a monitor. Today, in our concluding Part 5, 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
FCPA Compliance Report

Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part IV-Considerations When Hiring a Monitor

In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of independent integrity monitors and corporate monitorships; discuss both pre-settlement and post-resolution monitorships and their different applications; considerations a company should take in hiring a monitor and cost reflections for monitorships. Today, in Part 4, we look at considerations when hiring a monitor.
Some of the highlights from this podcast include:

  1. Considering the type and style of the monitor in your selection process.
  2. What is the expertise of the monitor, not simply in the subject matter but concluding monitorships?
  3. Balancing the interests of the regulator, the company and other stakeholders.
  4. Making sure that the monitor is bringing value to the company.
  5. Why a Monitor must be independent and conflict-free.

I hope you will join us tomorrow for Part 5, where we discuss the issue of costs when retaining a monitor.
For additional reading see Jay Rosen’s article What Issues Should a Company Consider When Hiring a Corporate Monitor? on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. visit their website here.

Categories
Daily Compliance News

Daily Compliance News: August 12, 2019, the Ng Loses Appeal edition

In today’s edition of Daily Compliance News:

  • ICE raids against companies continue but few charges against those companies raided. (Washington Post)
  • Definition of agent big issue in Hoskins trial. (WSJ)
  • Even sweating can get companies into trouble. (NYT)
  • Ng loses appeal. (Reuters)
Categories
FCPA Compliance Report

Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part III-the Power of a Pre-Settlement Monitorship

In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of independent integrity monitors and corporate monitorships; discuss both pre-settlement and post-resolution monitorships and their different applications; considerations a company should take in hiring a monitor and cost reflections for monitorships. Today, in Part 3, we consider the power of a monitorship in the pre-settlement phase of any matter.
Some of the highlights from this podcast include:

  1. What is an Internal Cultural Assessment?
  2. How can a pre-settlement monitorship be used as a (a) Pre-emptive Strike; or (b) to prevent a suspension or debarment action?
  3. What is the power of a pre-acquisition monitor in M&A Due Diligence?
  4. How is an independent integrity monitor can be a powerful prescriptive tool?

I hope you will join us tomorrow for Part 4, where we discuss considerations when hiring a monitor.
For additional reading see Jay Rosen’s article What is the Power of a Pre-Settlement Monitorship? on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. visit their website here.

Categories
FCPA Compliance Report

Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part I-Introduction

In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of independent integrity monitors and corporate monitorships; discuss both pre-settlement and post- resolution monitorships and their different applications; considerations a company should take in hiring a monitor and cost reflections for monitorships. Today, in Part 1, introduce the role of independent integrity monitors and corporate monitorships.
Some of the highlights from this podcast include:

  1. What is a corporate monitor?
  2. What agency has oversight?
  3. Who foots the bill?
  4. What about subject matter expertise?

I hope you will join us tomorrow for Part 2, where we discuss post-settlement monitorships.
For additional reading see Jay Rosen’s article Corporate Monitorship 101: Who Are They, and What Can You Expect?on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. visit their website here.

Categories
FCPA Compliance Report

Everything You Wanted to Know About Monitors But Were Afraid To Ask: Part II-Post-Resolution Monitorships

In this five-part podcast series, we consider some of the basic questions around monitors and monitorships. I am joined in this podcast series by Jay Rosen, the Vice President of Business Development and Monitoring Specialist at Affiliated Monitors, Inc. who is the sponsor of this podcast series. In this series we introduce the role of independent integrity monitors and corporate monitorships; discuss both pre-settlement and post-resolution monitorships and their different applications; considerations a company should take in hiring a monitor and cost reflections for monitorships.  Today, in Part 2, we consider the use of monitors in the post-resolution phase.
Some of the highlights from this podcast include:

  1. What is a monitorship in the FCPA Context?
  2. Complying with Consent Decrees
  3. When does post-resolution monitorship have the impact of a pre-settlement monitorship?
  4. There are myriad of other ways a post-resolution monitorship can help a company navigate post-resolution issues with regulators.

I hope you will join us tomorrow for Part 3, where we discuss the power of a pre-settlement monitorship.
For additional reading see Jay Rosen’s article What is a Post-Resolution Monitorship? on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. visit their website here.