In this episode of Excellence in Training, Tom Fox and Shawn Rogers consider just how does a company create a comprehensive compliance training program that covers its complete risk profile? Many large company faces many legal and regulatory risks, and often many of those risks are “owned” by organizations that are outside of the compliance function. This is a huge challenge for a company the size of GM. But I think this is probably faced by most companies. How do you create a risk-based compliance training program that addresses ALL of a company’s legal and regulatory risks, including the risks that are “owned” outside of the established compliance function? One possible approach is to establish a corporate compliance training governance committee that looks at the company’s overall risk profile and builds a cross-functional and comprehensive multi-year training plan that effectively addresses all of the risks in a company’s risk portfolio. This is what GM has tried to do.
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In this episode of Trekking Through Compliance, we consider the episode Whom Gods Destroy which aired on January 3, 1969, Star Date 5718.3.
Compliance Takeaways:
- Do you have audit rights and do you exercise them?
- High risk does not mean you cannot move forward, it means you must have a robust risk management strategy.
- Do you go with facts or your gut in decision making?
We are back with fan favorite Sherlock Holmes week. In this week’s special series of podcasts, I will focus on the first five from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s offer, I consider The Adventure of the Three Gable and how institutional justice in any best practices compliance program. Join us tomorrow where we conclude our week of stories from The Casebook of Sherlock Holmes by looking at the The Adventures of the Sussex Vampire and how it informs root cause analysis.
We have been getting accountability all wrong in the compliance profession. It’s not a set of tasks – it’s a way of thinking and it has to come from the heart as well as the head. On Accountability: The Heart of Compliance Tom Fox and Sam Silverstein dig into what accountability means to the corporate compliance function and business organizations and most significantly, how to make it an integral part of your culture. In this episode we consider the process for building a culture of compliance. Some of the highlights include:
- How to perform an accountability assessment?
- What is a core values evaluation?
- How can you both discover and assess your company’s core values?
- How can you establish core values?
- How can you disseminate your core values throughout your organization?
For more information on Sam Silverstein’s Consulting and Organizational Development, click here.
Welcome to the only roundtable podcast in compliance. Today, we have a quartet of Jay Rosen, Matt Kelly, Jonathan Armstrong and Tom Fox. Rants and shouts outs follow the commentary for this episode.
- Jay Rosen takes a look at the recent white paper by ECI President Dr. Pay Harned on the new DOJ Evaluation of Corporate Compliance Programs and ECI’s High Quality Compliance Programs. Jay shouts out to Preet Bharara’s podcast “Stay Tuned”.
- Jonathan Armstrong considers the Serco Deferred Prosecution Agreement the SFO’s failures in prosecuting individuals former company employees. Jonathan shouts out to those who talk about mental health issues in public.
- Tom Fox considers the lessons learned from the TechnipFMC and Microsoft FCPA settlements. Tom shouts out to his fellow Southerner Moscow Mitch and his invitation to Mr. Putin to come on over during the next presidential election.
- Matt Kelly considers the lessons from the recent Facebook settlements with the FTC and SEC. Kelly shouts out to Federal Reserve examiners who reviewed tech vendors at banks they were auditing.
The members of the Everything Compliance are:
- Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com
- Mike Volkov– One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com.
- Matt Kelly– Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com
- Jonathan Armstrong–is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com
- Sarah Hadden–Publisher at Corporate Compliance Insights. Hadden can be reached at Sarah@corporatecomplianceinsights.com
The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network.
In today’s edition of Daily Compliance News:
- Swiss bank ignores compliance officer; pays $10.7M for tax evasion. (Compliance Week)
- SFO issues guidance for corporate cooperation. (FCPA Blog)
- Why DD in the pre-acquistion phase is so critical. (WSJ)
- Colombia ordered to pay banks shuttered during Odebretch investigation. (Reuters)
In this episode of Trekking Through Compliance, we consider the episode Elan of Troyius which aired on December 20, 1968, Star Date 4372.5.
Compliance Takeaways:
- Do you perform continuous monitoring of your 3rd parties?
- How deep does your 3rd party investigation go?
- How culturally astute is your compliance regime?
We are back with fan favorite Sherlock Holmes week. In this week’s blog posts, I will focus on the first five stories from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s offering, I consider The Adventure of the Marazin Stone and how it informs storytelling in compliance. Join us tomorrow as we continue our week of stories from The Casebook of Sherlock Holmes by looking at the The Adventure of the Three Gables and institutional justice.
In today’s edition of Daily Compliance News:
- How bad is gun violence by white supremacist in America? Venezuela and Mexico issue travel warnings for coming to US. (MarketWatch)
- Why do you need employee due diligence? (WSJ)
- Is it really any wonder? Novartis accused of hiding negative data during trials. (NYT)
- Can Equifax ever be trusted again? (Washington Post)
