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Innovation in Compliance

Frictionless and Engaging Compliance Training with Avi Singer

On this week’s episode, Tom’s guest Avi Singer talks about how to make it easier for employees to understand and complete compliance training. Compliance training refers to the process of educating employees on laws, regulations, and company policies that apply to their day-to-day job responsibilities. The goal is for everyone in an organization to have compliance training, and for it to be frictionless for employees to access and complete. 

Avi Singer is the founder and CEO of Showd.me, a company that is helping organizations provide remote and on-demand compliance training solutions, specifically in the healthcare space. He is extremely passionate about highlighting the importance of compliance training, noting that it is often required in order for organizations to comply with regulations. He is described by his colleagues as a “bright professional who can understand complex business solutions and offer creative solutions to problems.” 

 

Here are some key points Tom and Avi talk about:

  • Avi explains how he persuades clients to utilize resources from his company Showd.me to have their employees take its compliance training. 
  • Avi believes compliance training should be easy to understand and pass a quiz on. 
  • The government expects targeted compliance training to address issues like racial sensitivity or harassment, Avi explains to Tom. 
  • Avi highlights the importance of bystander intervention and mandated reporting in potentially harmful situations and the best way to execute it in a clear and nuanced fashion.
  •  If additional training or intervention is required, Avi says, companies should have an HR person who can help address investigations and create policies around compliance.
  • AVI discusses pronoun training, how it should be conducted in order to get the message to the right person, and how to ensure employees are addressed in an appropriate manner.
  • The goal is for everyone in an organization to have compliance training, and for it to be frictionless for employees to access and complete, Avi says.
  • Cost savings can be achieved by reducing liability and risk, as well as by making compliance part of the normal training process.

 

KEY QUOTE:

“You don’t have to be perfect. I think that our training is not like, ‘Hey, you need to know the nuances of harassment or the nuances of what constitutes the mandatory reporter situation or what constitutes abuse’. It’s more like, ‘The law says if you see this going on you have to do something’.” – Avi Singer

 

Resources

Avi Singer | LinkedIn | Twitter 

showd.me 

Categories
Daily Compliance News

January 17, 2023 – The I Didn’t Steal Funds 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:

  • FIFA’s corruption trial could impact Fox Sports. (NYT)
  • New FTC penalties for deceptive green marketing. (WSJ)
  • “I didn’t’ steal funds,” SBF says in a blog post. (Reuters)
  • Van Gogh’s ‘Sunflowers’ and repatriation. (Bloomberg)
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Greetings and Felicitations

Podfest Expo 2023 – Preview Podcasts – Producer Jaime on Podcast Networks

In this episode of the PodfestExpo 2023 Preview Podcasts series, I visit with Producer Jaime, CEO and founder of Flintstone Media and the Florida Podcast Network. We discuss her presentations at PodfestExpo on the power of podcast networks and the power of social networks in building out your podcast audience. Some of the issues we tackle in this podcast are:

  • Why joining a network can increase your audience.
  • Why continued growth in your learning will help build out your podcasting skill.
  • How relationships and connections can help fuel your podcast growth.

I hope you can join me at PodfestExpo 2023, hosted by Podfest Global. This year’s event will be January 26-29, 2023, at the Renaissance Orlando at Seaworld in Orlando, Florida. The line-up of this year’s event is first-rate, with some of the top names in podcasting.

Podfest Expo is a community of people interested in and passionate about sharing their voice and message with the world through the powerful mediums of audio and video. We’re proud to unite as many people as possible to learn, get inspired, and grow better together.

 PodfestExpo is so much more than just a mere conference. While we pride ourselves on featuring the most engaging speakers, exciting topics, and in-depth content, the thing that sets PodfestExpo event apart from all others is the tight-knit community we’ve been building since 2013. You don’t just attend a Podfest event – you become part of the Podfest family.

 Whether you’re new to podcasting or a veteran podcaster looking to innovate and improve your podcast, our easy-to-understand Conference Topics allow you to customize a daily agenda based on what you’re most interested in learning. No matter your skill level or experience, PodfestExpo 2023 has plenty to offer!

 I hope you can join me at the event. For information on the event, click here. As an extra benefit to listeners of this podcast, PodcastExpo is offering a discount on the registration price. Enter discount code Fox10.

 PodfestExpo 2023 is a production of Podfest Global, which is the sponsor of this podcast series.

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Career Can D0

Getting with the Times in Education with Timothy Walker

In this episode of Career Can Do, Mary Ann Faremouth chats with Timothy Walker, experienced career advisor and Instructor of Computer Networking and Telecommunications at Houston Community College. Timothy’s experience in the higher education industry and strong community and social services skills equip him to help people navigate the unique challenges of the new work world. Timothy shares how Houston Community College is doing just that.

The tumultuous nature of recent years has left many struggling to keep their heads above water, especially in the global workspace. Almost every industry has undergone changes to their operations. With these changes come new demands – demands which may no longer be satisfied with traditional methods of education. Houston Community College offers a variety of programs to help students prepare for the new work world, including certificates, degrees, and virtual internships. Their professors are highly committed to their students, providing excellent and relevant training, as well as support. 

 

To nurture flexibility and the ability to adapt to future changes, Houston Community College keeps an eye on developments in various industries. This is where traditional education has always been lacking, Timothy comments. Traditional education has historically always lagged behind industry.

 

Resources

Faremouth.com

Categories
Corruption, Crime and Compliance

2022 FCPA Year in Review Featuring Tom Fox

2022 saw higher numbers of FCPA enforcement actions, settlements, and criminal prosecutions of individuals. One of the most important developments was the update of policy in the Monaco Doctrine, which was elaborated on in the Monaco Memo, providing important guidance for compliance professionals. Tom Fox joins Michael Volkov to discuss some of the more interesting cases from the past year.

Tom Fox is hailed as the Voice of Compliance, serving and evangelizing for the compliance community for over 15 years. He is the founder and creator of the Compliance Podcast Network where he hosts various podcasts, such as Innovation In Compliance and the ESG Report, and the Executive Leader at the C-Suite Network. 

 

Some ideas you’ll hear them explore are:

  • The DOJ is getting better at communicating with the compliance community through resolution documents like DPA, NPA, and, occasionally, declinations. These documents provide insight into the DOJ’s thinking and approach to cases, which compliance professionals can use to gain a better understanding of how to approach compliance issues.
  • In Tom’s upcoming book, “FCPA Year in Review 2022,” he highlights the KT Corp bribery case, which went back to the basics in its old-school rendition of corruption: bags of cash money. The lesson here is that bribery can be as simple as a $50 slipped into a handshake.
  • In the curious case of Glencore, the FCPA enforcement action taken against them reflects the DOJ’s focus on defective cultures within companies. This case involved multiple enforcement agencies across multiple countries and multiple bribery schemes, rounding up fines and penalties totalling up to $1.1 billion, with $700M for FCPA violations, and $441M for price and market manipulation. Glencore had a culture that was committed to profit at any cost, and the company paid over $100M to third parties knowing that some of the money would be used to bribe officials in various countries.
  • The Oracle case involving bribery and corruption involving gifts, travel, and entertainment should serve as a reminder to companies to review their gift, travel, and entertainment policies and ensure they are aware of how their business officials are spending their travel, per diem, and entertainment money.
  • Avoid hiring third-parties recommended by or at the direction of a state-owned official or executive.
  • The Lisa Monaco memorandum emphasizes the need for effective compliance programs and the benefits of voluntary disclosure, full cooperation, and timely and appropriate remediation. 

 

KEY QUOTE

“Internal controls are not simply due diligence, distributors, et cetera. It goes down to your payments, schemes and how you pay your vendors should all be a part of your internal controls.” – Tom Fox

 

Resources

Tom Fox on the Web | LinkedIn | Twitter | Blog

Categories
Daily Compliance News

January 16, 2023 – The 10% Committing Fraud 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:

  • The LIBOR imbroglio continues. (WSJ)
  • Ethics reforms coming to EU Parliament. (FT)
  • SCt to look at key whistleblower standards. (Reuters)
  • A new report shows 10% of public companies commit fraud annually. (NYT)
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31 Days to More Effective Compliance Programs

Day 15 – How do you evaluate a risk assessment?

After completing your risk assessment, you must translate it into a risk profile. If your estimate of where your bribery risk is greatest is wrong, it will be an effort to address it. As Ben Locwin explained in his  BioProcess International article entitled “Quality Risk Assessment and Management Strategies for Biopharmaceutical Companies”:
Once we have assessed risks and determined a process that includes options to resolve and manage them whenever appropriate, we can decide the level of resources with which to prioritize them. There always will be latent risks: those that we understand are there but that we cannot chase forever. But we need to make sure we have classified them correctly. With a good understanding of each of these, we are better positioned to speak about the quality of our businesses.

William C. Athanas, in his Industry Week article, “Rethinking FCPA Compliance Strategies in a New Era of Enforcement,” posited that companies assume that FCPA violations follow a bell curve in which most employees are responsible for most of the violations. However, Athanas believed that the distribution pattern more closely follows a hockey-stick distribution, where just a few people commit virtually all violations. Athanas concluded by noting that it is this limited group of employees, or what he terms the “shaft of the hockey stick,” to which a company should devote most of its compliance resources. With a proper risk assessment, a company can then focus its compliance efforts, such as intensive training sessions or detailed analysis of key financial transactions involving those employees with the greatest means and motive to commit a violation.
The priority risks are the most significant risks with the greatest likelihood of occurring. These become the focus of your most significant risk management efforts, coupled with ongoing audits and monitoring. A variety of tools can be used to monitor risk going forward continuously. Consider providing employees with substantive training to guard against the most significant risks coming to pass and to keep the key messages fresh and top of mind. It is important to create a risk control summary that succinctly documents the nature of the risk and the actions taken to mitigate it. Finally, let this risk assessment and evaluation inform your compliance program rather than letting the compliance program inform the risk assessment.
Three key takeaways:

  1. Even after you complete your risk assessment, you must evaluate those risks for your company.
  2. The DOJ and SEC are looking for a well-reasoned approach to how you evaluate your risk.
  3. Create a risk matrix and rank your risks; then remediate and monitor as appropriate.
Categories
Sunday Book Review

January 15, 2023 – The Top Business Books to Read in 2023 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 business books which every compliance professional should read in 2023:

·       How to Win Friends and Influence People by Dale Carnegie

·        Influence, New and Expanded: The Psychology of Persuasion by Robert Cialdini

·       The Compound Effect: Jumpstart Your Income, Your Life, Your Success by Darren Hardy

·        Tools of Titans: The Tactics, Routines, and Habits of Billionaires, Icons, and World-Class Performers by Tim Ferriss

Resource

The Best Business Books to Read in 2023 By Hal Kitzmiller

Categories
31 Days to More Effective Compliance Programs

Day 14 – Risk Assessments

One cannot say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based upon a risk assessment to understand your organization’s business from the commercial perspective, how your organization has identified, assessed, and defined its risk profile, and, finally, the degree to which the program devotes appropriate scrutiny and resources to this range of risks. Yet the 2020 Update added a new emphasis that Risk Assessments should not be done not less than annually but, in reality, should be done each time your risk change. Over the past couple of years, every company’s risks changed from Work From Home to Return to the Office to Hybrid Work environments. Have you assessed these new paradigms for risks from the compliance perspective?

As far back as 1999, in the Metcalf & Eddy enforcement action, the DOJ has said that risk assessments that measure the likelihood and severity of possible FCPA violations should direct your resources to manage these risks. The 2012 FCPA Guidance succinctly stated, “Assessment of risk is fundamental to developing a strong compliance program and is another factor DOJ and SEC evaluate when assessing a company’s compliance program.”
There are a number of ways you can slice and dice your basic inquiry. As with almost all FCPA compliance, your protocol must be well thought out. If you use one, some, or all of the above as your basic inquiries for your risk analysis, it should be acceptable for your starting point. 

Three key takeaways:

  1. Since at least 1999, the DOJ has pointed to risk assessment as the start of an effective compliance program.
  2. The DOJ will now consider your risk assessment methodology for identifying risks and gathering evidence.
  3. You should base your compliance program on your risk assessment.
Categories
Daily Compliance News

January 14, 2023 – The Crackdown on Crypto 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:

  • SEC cracks down on crypto. (NYT)
  • Musk wants a change of venue. (WSJ)
  • Trump org fined $1.6MM for tax fraud. (Reuters)
  • EU subcommittee on human rights hub of EU corruption investigation. (Political)