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Sunday Book Review

February 12, 2023 – The True Crime Edition

In the Sunday Book Review, I consider books that interest the compliance professional, the business executive, or anyone 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, we consider some of the top ethics books which every compliance professional should read in 2023:

·      Slenderman: Online Obsession, Mental Illness, and the Violent Crime of Two Midwestern Girls by Kathleen Hale 

·       Tell Me Everything: The Story of a Private Investigation by Erika Krouse

·        Trailed: One Woman’s Quest to Solve the Shenandoah Murders by Kathryn Miles 

·       American Demon: Eliot Ness and the Hunt for America’s Jack the Ripper by Daniel Stashower 

Resources

Complete List of Mystery Writers of America 2023 Edgar Nominees in MysteryTribune.com

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Kerrville Weekly News Roundup

Kerrville Weekly News Roundup: February 11, 2023

Welcome to the Kerrville Weekly News Roundup. Each week, veteran podcaster Tom Fox and his colleagues Andrew Gay and Gilbert Paiz get together to go over a couple of their favorite stories from the past week from Kerrville and the greater Hill Country. Sit back, enjoy a cup of morning coffee and listen in to get a wrap up of the Kerrville Weekly News. We each consider two of our favorite stories and talk about the upcoming weekend’s events which will enjoy or participate in this weekend.

In this inaugural episode, Tom, Gilbert and Andrew discuss the following stories which caught their attention over the past week.

·      Tom talks about the Kerrville Police Department’s new body cameras and the Kerr County call for volunteer to assist in emergency services. He talks about the weekend ‘Friends of the Library’ book sale at the Butterworth- Library.

·      Gilbert Paiz talks about the upcoming Kerrville City Council election and the new bank coming to Kerrville. Gilbert hopes to enjoy some nice sunshine with yard work this weekend.

·      Andrew talks about the Kerrville School Board election and the number of lawsuits filed in Kerr County District Court. Andrew is looking forward to the concert at RoddyTree Ranch this weekend.

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Daily Compliance News

February 11, 2023 – The All Adani Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen 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.

Stories we are following in today’s edition of Daily Compliance News:

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Compliance Kitchen

Compliance Kitchen – The Changes in the DOJ Corporate Enforcement Policy

The Compliance Kitchen returns with a wrap-up of the week’s top trade and economic sanction issues. In today’s episode, Silvia Surman visits the DOJ revised its Corporate Enforcement Policy and the Kitchen looks at the highlights.

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Investing in the Future

Investing in the Future – Episode 1 – Tabor McMillan

How do small towns and rural counties invest in their future? Tom Fox and Andrew Gay explore this topic in their new podcast series Investing in the Future – Developing Leadership in Kerr County. Leadership Kerr County is the premier leadership program in the Hill Country which enables men and women to learn more about the issues and topics that face Kerrville, Kerr County, and the Hill Country on a daily basis; everything from education and social services to economic development and health care. Kerr County has decided to invest in its citizens to create future leaders and lay a foundation for their future involvement in the leadership of Kerrville and Kerr County. This podcast is produced and hosted by the Texas Hill Country Podcast Network.

In our inaugural episode, we visit with Tabor McMillan, current chairman of the Leadership Kerr County Steering Committee. We discuss how his involvement in LKC and his passion for local leadership. He takes pride in living and raising his family here in the Texas Hill Country. Tabor is a local banker here in Kerr County.

Highlights include:

-How did he find out or hear about LKC?

-What was his experience when he was a class participant?

-What was involved with being a class participant?

-How does he feel about our ability in our community to make a difference locally?

Resources

Tabor McMillan on LinkedIn

Andrew Gay on LinkedIn

Tom Fox on LinkedIn

For more information on Leadership Kerr County, click here.

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31 Days to More Effective Compliance Programs

One Month to More Effective Internal Controls – Mapping Internal Controls

The SEC has continued to emphasize the accounting provisions of the FCPA, specifically the internal controls provisions. The reason is straightforward; a company with rigorous internal compliance controls is better able to prevent, detect and remedy any FCPA violations that may occur. What can you do around the FCPA’s requirements for internal controls and continued SEC enforcement emphasis? You should begin with an exercise where you map the internal controls your company has in place to the indicia of the Hallmarks of an Effective Compliance Program, as set out in the 2020 FCPA Resource Guide. While most compliance practitioners are familiar with the Hallmarks, you may not be as familiar with standards for internal controls. Here, begin with the COSO 2013 Internal Controls Framework as your starting point.

As a CCO or compliance practitioner, this is an exercise that you can engage in at no cost. You simply investigate and note what internal controls you have in place and how they may be a part of your anti-corruption efforts going forward. Compliance is a straightforward exercise; this does not mean that it is easy, you do have to work at it so that you will simply not have a paper, “check the box” program. But using the excuse that you have limited resources is simply an excuse and a rather poor one at that. While the clear lesson from the BHP enforcement action is that you are required to have effective internal controls in place, by engaging in this mapping exercise you can then figure out what you have and, more importantly, what internal compliance controls that you do not have and need to institute.

Three key takeaways:

1. Learn the internal controls your company currently has in place.

2. Map your compliance internal controls to the COSO 2013 Internal Controls Framework.

3. Use your gap analysis as a basis for remediation.

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Creativity and Compliance

The Halo Effect

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network.

Ronnie’s company, Learnings and Entertainment, utilizes the entertainment devices that people use to consume information in their everyday, non-work lives, and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies and resources more accessible.

In this episode, Tom and Ronnie discuss the Halo Effect and its role in compliance communications.

Highlights include:

  • What is the importance of making training and comms shorter? What makes it more entertaining, stickier, and helps compliance professionals get increased airtime and exposure, with their messages carried forward.
  • The Halo Effect, which is that people are left with a positive impression.
  • The Halo Effect is not a residual benefit…it is the benefit!
  • The opposite of the Halo Effect is called the Horn Effect…which is that people are left with a negative impression. Hello Compliance!
  • Your compliance reputation doe matter.
  • In every interaction compliance professionals have with employees and leaders, think about Halo’s and not Horns!
  • Maya Angelo once said, people won’t remember what you say, but they’ll remember how you made them feel.

Resources:

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Daily Compliance News

February 10, 2023 – The Going to War Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen 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.

Stories we are following in today’s edition of Daily Compliance News:

  • SW blames the weather, and its pilots blame outdated tech. (Reuters)
  • 5th circuit says foreigners can be charged under FCPA for work outside the US. (Law360)
  • Starting the fight against corruption in schools. (Miami Herald)
  • Merck insurers deny payment for cyber-attack based on war exclusion. (WSJ)
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31 Days to More Effective Compliance Programs

One Month to More Effective Internal Controls – Implementing Internal Controls

Today, I consider some ways in which a compliance professional can work to implement internal controls in a multi-national organization. The first step is to convert your company’s compliance risks into internal control objectives. The internal control objectives are then given to each business unit with instructions to develop controls, which meet the objectives. This process should allow more of a fine-tuning approach within existing systems than the development of specific controls by corporate which all business units must adopt and will give the business unit a sense of buy-in and participation in the process.

Good compliance internal controls are not some standalone protective measure. They can help to make a company run more efficiently as the internal controls that prevent FCPA violations are the same ones that prevent fraud in the workplace. The presence of good internal controls saves money by preventing fraud. It is a business best practice to prevent fraud, which includes preventing corruption. One need only consider Ethisphere and its annual survey of the world’s most ethical companies because they exceed the Standard & Poor’s index of average profits and growth by a factor of 4X. A key reason such companies have better than average profitability is that they have better internal controls.
Three key takeaways:

  1. Convert your compliance risks into internal control objectives.
  2. As with many components of a best practices compliance program, tone at the top is critical.
  3. If you receive pushback from the business folks, always remember, good internal controls make for a better, more efficient and more profitable business.
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Everything Compliance

Episode 111 – The Duty of Oversight Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. Everything Compliance has been honored by W3 as the top talk show in podcasting. In this episode, we have the quintet of Jay Rosen, Karen Woody, Jonathan Marks, Tom Fox, and Matt Kelly, who review the recent Delaware Court of Chancery decision creating a duty of oversight for corporate officers. We conclude with our fan-fav Shout Outs and Rants section.

1. Matt Kelly sets the stage for our discussion and poses a question about what it all means for CCOs going forward. He rants to the State of Texas Legislature for creating a ‘Gold Card’ for physicians who have over 90% of all requested procedures covered by insurance. (1:30)

2. Jonathan Marks looks at the case from the internal audit and corporate governance perspectives. He rants about the Pentagon’s failure to shoot down a Chinese spy balloon.

3. Tom Fox shouts out to Hindenburg Research and all other short sellers who help uncover fraud, waste, and abuse.

4. Karen Woody looks at the case from a legal perspective and unpacks the court’s legal reasoning. Woody shouts to Amtrak and asks us to ‘ride the train more often.’ (11:08)

5. Jay Rosen reviews the changes wrought for CCOs over the past year, from CCO certification to the Delaware court decision. He shouts out to his twin daughters on their 15th birthday. (41:13)

The members of Everything Compliance are:

•       Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com

•       Karen Woody – One of the top academic experts on the SEC. Woody can be reached at kwoody@wlu.edu

•       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 data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at jonathan.armstrong@corderycompliance.com

•       Jonathan Marks is Partner, Firm Practice Leader – Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at jonathan.marks@bakertilly.com

The host and producer, ranter (and sometime panelist) of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.