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Adventures in Compliance

Adventures in Compliance – Lessons from A Case of Identity

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” They appeared in the Strand Magazine from July 1891 to June 1892. Over the 12 episodes, I will be reviewing each story and mine them for leadership, compliance, and ethical lessons. “A Case of Identity” was published in the Strand Magazine in August 1891 and is the third story in the collection of “The Adventures of Sherlock Holmes”.

Summary

In this case, Mary Sutherland, a typist, approaches Holmes for help after her fiancé, Mr. Hosmer Angel, mysteriously disappears on the day they were to be married. Holmes agrees to take the case. Sutherland gives Holmes a few letters written by Angel, and Holmes quickly observes that they were written on a typewriter, odd for a personal letter. Also, the writing style was similar to the letters of her stepfather, James Windibank.

As Holmes investigates, he deduces that Hosmer Angel does not exist and is, in fact, an alternate identity created by Mary’s stepfather, James Windibank. The motive for this strange charade was financial. Mary’s stepfather didn’t want to lose the income he gained from her, as her late mother left her a significant annual income which would be redirected upon her marriage.

The stepfather, who was young enough to pass as a man of Mary’s age, concocted the alternate identity to court Mary and then conveniently disappear to maintain control over Mary’s income. Holmes, however, decides not to reveal the truth to Mary to save her from further heartbreak. He suggests that Angel was a scoundrel who did not deserve her, leaving her to hope that Angel might return one day.

Compliance Lessons

1.         Empathy: Holmes was able to solve the case of identity by putting himself in the shoes of the victim and understanding her perspective. Leaders should also have empathy and be able to understand the perspectives of their colleagues, employees, or customers.

2.         Observation: Holmes used his powers of observation to gather information and uncover the truth behind the case of identity. Leaders should also be observant and pay attention to the details, as they can provide valuable insights.

3.         Problem-solving skills: Holmes used his problem-solving skills to solve the case and bring justice to the victim. Leaders should also be effective problem-solvers and should be able to find creative solutions to challenges.

4.         Communication skills: Holmes communicated effectively with the victim and the other characters in the story, and he was able to get the information he needed to solve the case. Leaders should also have strong communication skills, as they are crucial for building relationships and achieving success.

5.         Respect for the law: Throughout the story, Holmes showed respect for the law and acted within the bounds of the legal system. Leaders should also respect the law and act ethically, as they set an example for others and maintain the integrity of their organization.

Resources

The New Annotated Sherlock Holmes

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FCPA Compliance Report

FCPA Compliance Report: Miranda Zolot – Remote Work Revolution, the Distributed Workforce

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance.  Tom welcomes Miranda Zolot, General Counsel at Oyster HR in this episode. They discussed the distributed workforce and how Oyster can help businesses find the talent they need compliant and cost-effectively.

Beginning with the captivating detail that Oyster is a fully distributed company with no offices and almost 600 internal employees who all work from home or their personal co-working spaces, they discussed the concept of a distributed workforce and how businesses find the talent they need in a compliant and cost-effective way. Their discussion included the challenges of managing an outsourced workforce and the current model of distributed workforces that allows companies to find the right workers for their particular job.

Oyster’s mission is to bring meaningful work to people in different geographies, and the website offers resources for both people looking for remote work and companies looking to hire remotely. Oyster Academy offers remote best practices and helps people present themselves to the market as ready for remote work, and the company also offers a misclassification analyzer, salary information, country guides, and open policies and handbooks. Finally, Tom and Miranda discussed how to counsel a company on how to convey culture and expectations to a worker who may be across the globe. 

Key Highlights

·      Remote Work Solutions

·      Cross-Border Hiring

·      Distributed Workforce

·      Creating a Distributed Culture

·      Hiring Internationally

Resources

Miranda Zolot on LinkedIn

Oyster HR

Tom Fox

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Daily Compliance News

Daily Compliance News: July 17, 2023 – The Spamming Your Friends Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

  • Head of CFTC whistleblower office to step down. (WSJ)
  • Can your boss force you to spam your friends? (NYT)
  • Trade sanctions as protectionism. (FT)
  • Altice founder arrested in Portugal for corruption. (Reuters)
Categories
31 Days to More Effective Compliance Programs

One Month to Better Reporting and Investigations – Preparing for the Investigation

Under Part 1, Section D. Confidential Reporting Structure and Investigation Process stated in part, Properly Scoped Investigation by Qualified Personnel –What steps does the company take to ensure investigations are independent, objective, appropriately conducted, and properly documented? How does the company determine who should conduct research, and who makes that determination? These questions were presaged by the DOJ’s 2015 Yates Memo and the 2016 FCPA Pilot Program. The pressure on every CCO and company to get an investigation done quickly, efficiently and, most importantly, right is even greater now.
Jonathan Marks began by cautioning that when considering any well-run internal investigation, a CCO must be cognizant of the strictures laid out in the Evaluation. It all begins with who in-house is looking at the complaint and does the CCO, compliance practitioner, or legal team have the skills and capabilities to handle the matter which has arisen. Obviously, if there are esoteric accounting issues or significant internal control workarounds and overrides, a CCO may not have the skills to really understand all the issues. Similarly, if the matter is a global FCPA or equivalent bribery and corruption matter, Marks related, these “come in different flavors, and because they come in different flavors you may not have the skills or capabilities to do an investigation that would take place in say Brazil or Russia or China or India.”

Three key takeaways:

  1. Always remember your ultimate audience may be the government.
  2. You must understand both the business environment and extended business enterprise.
  3. Communication and collaboration in any investigation are critical so you should begin early and continue to do so throughout the investigation.
Categories
Corruption, Crime and Compliance

NAVEX’s 2023 State of Risk and Compliance Programs

Dare we imagine a world where companies are driven by their compliance obligations as much as they are by their financial performance? In a progressively interconnected and fast-paced digital world, compliance matters more than ever. Non-compliance can swiftly result in reputational damage, punitive fines, and compromised stakeholder trust. As such, more organizations are beginning to embrace the importance of having mature, robust compliance programs. This episode of Corruption, Crime, and Compliance with Michael Volkov dives into NAVEX’s 2023 State of Risk and Compliance report. The report delivers a comprehensive overview of the global compliance landscape and sheds light on critical trends that are reshaping the field. 

You’ll hear him discuss:

  • We’ve seen a substantial increase in organizations with mature compliance programs – 53% in 2023, compared to 38% in 2022. This is a testament to organizations worldwide waking up to the importance of compliance in their everyday operations.
  • The power of leadership: robust leadership support is crucial when it comes to fostering a thriving compliance program. Strong board and executive-level engagement have proven instrumental in driving these changes.
  • As the world becomes more digitized, cybersecurity threats have increased exponentially. Consequently, cybersecurity has skyrocketed to the top of compliance concerns, indicating how cyber threats and breaches have a far-reaching impact on organizations.
  • Compliance and information security professionals are coming together like never before. This internal partnership proves crucial in managing cybersecurity risks and ensuring the safety of organizational data.
  • The NAVEX report identified five high-stake risks that organizations should keep on their radar: cybersecurity, regulatory compliance, harassment and discrimination, anti-bribery and corruption, and diversity, equity, and inclusion. Addressing these will require diligence and strategic planning.
  • There has been a decline in middle management’s commitment to compliance compared to 2022. This dip stresses the need for targeted interventions to maintain the integrity of the compliance culture.
  • From HR to IT, effective compliance necessitates collaboration across all levels and departments.
  • With growing compliance demands, organizations are realizing the importance of purpose-built solutions. These platforms help manage third-party risks, and policy management, and provide ethics and compliance training, making them indispensable in the modern compliance toolkit.

 

KEY QUOTES:

“So 53% stated that their organization had a mature compliance program and risk management program and that was compared to only 38% in 2022. Now that to me is a really welcome sign.” – Michael Volkov

 

“I think perhaps the most significant finding in this area to me was that in recognition of the rising threat level from cybersecurity attacks, ransomware, data privacy ethics and compliance professionals are forging new and lasting internal partnerships with information security professionals.” – Michael Volkov

 

“Three-quarters of respondents reported that senior leaders encourage compliance in the organization, and nearly as many report that senior leaders demonstrate their commitment to compliance to employees. So it’s not just words, but it’s words and actions. However, there was one troubling concern, and that was with respect to middle management. …So NAVEX reported a lower commitment compared to the 2022 report with regard to middle management commitment to compliance.” – Michael Volkov

 

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

NAVEX State of Risk and Compliance Report

Categories
Sunday Book Review

Sunday Book Review: July 16, 2023 – The Privacy Edition

In the Sunday Book Review, I consider books that would interest the compliance professional, the business executive, or anyone who might be curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me. In today’s edition of the Sunday Book Review, now that summer is fully upon us, we look at books on privacy.

·      Privacy’s Blueprint by Woodrow Hartzog

·      Re-Engineering Humanity by Brett Frischmann and Evan Selinger

·      No Place to Hide by Glenn Greenwald

·      Why Privacy Matters by Neil Richards

Resources

The TOP 21 Books in Privacy & Data Protection That You Must Read ASAP in Privacy Whisperer

Categories
10 For 10

10 For 10: Top Compliance Stories For the Week Ending July 15, 2023

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

·       EU-US agree on data sharing pact. (NYT)

·       Max Schrems slams back, vows legal challenge.  (Reuters)

·       Labor Party to back global ABC court. (The Guardian)

·       Chinese ABC probe moves to advanced stage.  (FT)

·       Did a sheriff’s corruption lead to a mass shooting? (Houston Chronicle)

·       Is your company investing in China?  (NYT)

·       Alleged fraudster said customers devised the fraud. (FT)

·       UK AML regime ‘not fit for purpose’.  (FT)

·       BOA has its own fake accounts scandal. (Radical Compliance)

·       Merrill Lynch to pay $12MM fine for failure to report.  (WSJ)

You can check out the Daily Compliance News for four curated compliance and ethics related stories each day, here.

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Blog

Mastering ChatGPT: Business Uses

Join us as we dive into the world of ChatGPT and discover how this powerful tool can revolutionize your business. Today we conclude our five-part blog post series on Mastering ChatGPT. In today’s final blog post, we look at how you can incorporate ChatGPT into various business uses for any organization. As always, I was joined in this exploration by Larry Roberts, CEO of Red Hat Media.

The transformative power of artificial intelligence tools in business processes is an unfolding narrative that every professional should be aware of. These tools, taking center stage in customer service and decision-making processes, are poised to shape the future of business operations. Businesses can offer superior customer service while making data-driven decisions by using AI for things as varied as content generation to data analytics. The result is a significant leap in customer satisfaction and a more nimble operational procedure.

Chat GPT and SEO Content Creation

In the digital era, Search Engine Optimization (SEO) is crucial in enhancing businesses’ online visibility. AI, like Chat GPT, data analysis, and content creation, could improve a company’s SEO strategy, increasing discoverability and driving more organic traffic to their platforms.  Larry’s insight into data analytics and decision-making and Chat GPT provided a new perspective on SEO content creation. He recognized the tool’s potential to analyze content and aid in data analytics through its API, although he cautioned that it may not be the most effective out-of-the-box solution for analytics.

Chat GPT and SEO Content Creation

In the digital era, Search Engine Optimization (SEO) is crucial in enhancing businesses’ online visibility. AI, like Chat GPT, data analysis, and content creation, could improve a company’s SEO strategy, increasing discoverability and driving more organic traffic to their platforms.  Larry’s insight into data analytics and decision-making and Chat GPT provided a new perspective on SEO content creation. He recognized the tool’s potential to analyze content and aid in data analytics through its API, although he cautioned that it may not be the most effective out-of-the-box solution for analytics.

Understand and Define Customer Needs

Who in a corporation is your customer? If you are in the compliance function, it is the employees and other stakeholders. This means identifying and defining customer needs is a fundamental step in tailoring your operations to meet your audience’s expectations. A deep understanding of what your customers need and prefer enables you to build products or services that resonate with them. Not only will this step increase customer satisfaction, but it also paves the way for more efficient and effective business operations. The action involves conducting meticulous research and surveys to collect invaluable data, allowing businesses to step into their customers’ shoes and view their operations from a customer’s perspective.  Just change the word customer to employee.

Customer Service

Sticking with the insight that your compliance customers are your employees, in the world we live in today, consistent advancement in technology brings about powerful tools businesses can use to enhance their operations. One such tool is the application of artificial intelligence (AI) in customer service. AI has presented a massive potential for improving how businesses interact with their clients, making processes faster, better, and more efficient. One critical aspect is deploying AI tools like ChatGPT to deliver efficient customer service interactions. These tools can be incorporated into platforms to provide automatic responses to customer inquiries promptly and accurately.

Chat GPT in Email Communication

Email communication remains a vital element of business operations. AI tools like ChatGPT can enhance this aspect of the business by automating tasks such as summarizing lengthy emails or drafting responses. AI can significantly save time and increase overall productivity for businesses.  From his professional experiences, Larry commended how ChatGPT could be utilized in email communication. The tool’s ability to summarize extensive emails and draft others based on inputs underscores its potential to streamline professional communication processes.

But remember, simply implementing ChatGPT does not guarantee success—it requires perseverance, adaptability, and continuous improvement. By staying committed to refining and optimizing the use of ChatGPT, businesses can unlock their full potential and achieve remarkable results. So, dive in, explore the possibilities, and witness the transformative impact ChatGPT can have on your business.

In an increasingly digital age, leveraging AI technology to enhance customer service and improve decision-making is a crucial advantage for business professionals. Central to this is understanding and defining customer needs, allowing personalized products and services. Further, using AI tools like ChatGPT for customer service can provide prompt and efficient responses to customer inquiries. Coupled with machine learning for content generation, this can significantly boost a business’s marketing efforts. Additionally, ChatGPT can aid in data analytics, underscoring the importance of data in driving business decisions. With this knowledge, you can embark on a journey toward business transformation, leading to higher customer satisfaction and operational efficiency.

For more information on Larry Roberts, check out Red Hat Media.

Categories
Compliance and AI

Mastering ChatGPT: Part 5 – Business Uses for ChatGPT

Welcome to a special five-part podcast series on mastering ChatGPT. My special guest throughout this journey is Larry Roberts, an accomplished professional with over 25 years of multifaceted experience. Having initiated his career in the corporate training sphere, he exhibited a remarkable shift to IT, contributing greatly as a Business Intelligence Analyst. His proficiency in harnessing predictive analytics for inventory and sales projections led him to tap into the realm of AI. In 2021, Larry chose to cozy up with podcasting and content creation. His journey with ChatGPT began in November of the same year, and he has been fully engrossed with it since then. His insights into data models, large language models, and his overall passion for AI are certain to illuminate any forum. In this concluding Episode 5, we set out some strategies for streamlining business operations using ChatGPT.

The transformative power of artificial intelligence tools in business processes is an unfolding narrative that every professional should be aware of. These tools, taking center stage in customer service and decision-making processes, are poised to shape the future of business operations. Businesses can offer superior customer service while making data-driven decisions by using AI for things as varied as content generation to data analytics. The result is a significant leap in customer satisfaction and a more nimble operational procedure.

In this episode, you will be able to:

  • Understand the scale of AI’s impact on boosting operational efficiency and refining decision-making across sectors.
  • Navigate the ethical quandaries surrounding AI, elucidating the need for transparency, accountability, and human vigilance.
  • Explore the exciting trajectory of AI, delving into the game-changing phenomena of deep learning and neural networks.
  • Dispel fears and myths about AI’s impact on employment, focusing on the promise of reskilling and upskilling.
  • Grasp the capabilities of AI to supercharge human capacities, ushering in a new era of augmented intelligence and unprecedented creativity.

Key Highlights:

  • Machine Learning and ChatGPT
  • ChatGPT in Marketing and Advertising
  • ChatGPT in Email Communication
  • ChatGPT and SEO Content Creation

Resources:

  •  Larry Roberts

Larry Roberts on LinkedIn

Red Hat Media

  •  Tom Fox

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Daily Compliance News

Daily Compliance News: July 14, 2023 – The Letter to the Editor Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

  • GOP demands more regulation of big tech, then investigates FTC for doing so. (WSJ)
  • Is your company investing in China? (NYT)
  • Alleged fraudster said customers devised the fraud. (FT)
  • UK AML regime ‘not fit for purpose’. (FT)