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Sunday Book Review

April 18, 2021, the International Women’s Day Edition


In today’s edition of Sunday Book Review:

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Daily Compliance News

April 17, 2021 the Triple Agent? edition


In today’s edition of Daily Compliance News:

  • Can a dog-eat-dog culture change? (WSJ)
  • Value of whistleblowing culture. (WSJ)
  • Jan Marsalek-Triple agent? (FT)
  • How corrupt is British politics? (FT)
Categories
Innovation in Compliance

Smart Automation for Risk Management: Bonus Episode-Integrity Analytics Collective


Today, we wrap up our multi-part podcast series, Smart Automation for Risk Management, sponsored by Lextegrity Inc., with a special bonus episode where Parth Chanda, Founder and Chief Executive Officer (CEO), and I discuss Lextegrity’s Integrity Analytics Collective.
What is the Integrity Analytics Collective? I put that question to its founder Chanda. He related that it was launched in 2020 “in partnership with nearly a dozen partner organizations from across the world.” It’s ultimate goal is to “collaborate with thought leaders to further democratize data analytics for organizations of all sizes globally.” The Collective brings together the practitioners from member organizations “who are really ‘into the weeds’ practitioners, they are thought leaders in those organizations and they bring all of us together with as well.” What we all have in common is “a desire to raise the standard of data analytics for everyone who wants access to them.”
The Collective wants to help organizations of any size in the world to accelerate their data analytics as well as their automation efforts. At the core of the collective is building out a library of advanced data analytics, coupled with the ability to create analytics on the fly, through an out of the box solution. The Collective approaches data analytics in a way that opens up data analytics up to any organization. Chanda said, “it’s an ecosystem that we’re creating of ethics and compliance professionals to continue to add new analysis of the platform regularly, including new risk domains.”
The Collective has members from companies as small as under 100 to companies with thousands of employees. Chanda stated, “we understood very early on that this is going to be a massive a cross industry, cross ecosystem effort. Each of those partners has a different perspective on things. Some of them are focused more on behavioral science element of ethics and compliance. Others are really focused on the forensic auditing perspective, the policy and rules-based perspective. We wanted to really have stakeholders from across the knowledge spectrum.” All the while recognizing that “the baseline of analytics is fairly standard. This means if you bring in a forensic auditor to do an investigation, they’re going to have a standard tool set for fraud and corruption analytics that are fairly standard. That is the concept we’ve really democratized. Yet, with an analytics engine, while the standards are fairly democratized and standard across companies, they need to be largely configurable based on the industry, the business model and frankly historical issues.”
The goal of Lextegrity is to take insights, best practices and other information from its Collective partners and then incorporate them into your tools, modules and workflow modules. At the end of the day Lextegrity will have a more robust platform, which it will then share back with the partners or others in the compliance team. Chanda said, “part of our mission with the Collective is really to empower a lot of these expert organizations that do advisory work and provide them options to provide data analytics and automation to their clients, because they are the experts in their space. Again, it is really a difference in model for a software product company.” Moreover, “If there are new analytics, new ideas, new approaches that have worked for others, we want to know about them and make them available in the marketplace.” Chanda believes that it gives everyone a shared commitment to really move the needle forward for organizations and their risk management efforts to build this thought leadership ecosystem around data analytics.
For more on Lextegrity, check out their website here.
For more information on the Integrity Analytics Collective, click here.

Categories
Innovation in Compliance

Smart Automation for Risk Management: Part 5, Integrations and User Experience


Welcome to a multi-part podcast series, Smart Automation for Risk Management, sponsored by Lextegrity Inc. Over this series, we have visited with Parth Chanda, Founder and Chief Executive Officer (CEO), Andy Miller, Chief Analytics Officer, and Kara Bonitatibus, Head of Product. We have looked at the Lextegrity Product Suite, taken a deep dive into continuous risk monitoring, considered pre-approvals and third-party due diligence and integrations and user experience. In a special bonus episode, Chanda and I will discuss the Integrity and Analytics Collective. In Episode 5, I  visit with Bonitatibus on integrations and the user experience.
We began with data integration, which is one of the biggest challenges facing every Chief Compliance Officer (CCO), compliance professional and indeed corporate compliance function. Bonitatibus said the starting point is to create software solutions that are intuitive, data-driven and integrated. Lextegrity has created various integrations in the pre-approval application, core integrations include HR systems, which are used to support approval logic. It also includes routing requests to an immediate manager through workflow. Next there is a prebuilt integration with a database check of sanctions,  state owned entity and adverse media information. There can also be embedded and automated screening directly into any of the workflows. This can provide through put our third-party due diligence application process and compliance approver procedure. She ended by noting, “we have a pretty tool set that we can offer our customers with respect to integrations.”
All of this allows the Lextegrity solution to move to a true enterprise wide, risk management system, to create a truly end to end solution for Lextegrity customers. There are customer using the preapproval system, which allows them to approve payments or third parties. This can provide information in the Lextegrity monitoring solution. Bonitatibus provided the “example for a payment request; let’s say a sponsorship, our monitoring solution, can then validate whether the payment amount matches what was in the preapproval request and the approved amount.” It can also validate that the payee has not changed in the third-party space.
Another approach allows you to review third parties which have been determined to be high risk in the due diligence phase and place additional weight on their transactions in monitoring solutions. The Lextegrity solution can also validate if a “low risk supplier, for example, has payment patterns or activity that suggest either it’s not truly a low-risk supplier, or if it was misclassified or abnormal is happening.” This makes the entire process truly end to end and breaks down silos.
We ended by looking down the road for Lextegrity. Bonitatibus is very excited about some of Lextegrity’s future vision and priorities. The company is very focused on continuing to prioritize integrations across the entire product suite to really continue to evolve the end-to-end solution and continue to break down those silos of managing spend risk and risks in general. The company will also continue to expand the analytics embedded in the workflow technology. Finally, and hopefully to the delight of Lextegrity customers, they want to have more and more powerful reporting and analytics and visualizations across all of the products. Great visualizations are as much of an art as they are a science. Yet Bonitatibus sees them as a very powerful tool. Lextegrity wants compliance professionals to “think of our products as a roadmap, where everything is modular.” This allows building out an entire end-to-end solution in a manner where can start on the journey and expand out “wherever it’s most helpful and beneficial to you. We would love to work with companies to take their compliance programs to the next level.”
Join us for our concluding special bonus episode, where Lextegrity Founder and Chief Executive Officer (CEO), Parth Chanda visits with me on the company’s Integrity Analytic Collective.
For more on Lextegrity, check out their website here.

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STAKE: The Leadership Podcast

3 Stories Leaders Need to Know About Employees 


If you want to hire the right people, get them to stay, and for them to continue to perform above expectations, start by learning their stories.
Stories unlock answers to challenges leaders must overcome.
In today’s episode, we’re discussing three stories every leader needs to know and tell.
———-
If you’re looking for tangible action steps and refreshing insights to help ignite the power of your own leadership journey, sign up for my weekly leadership blog HERE.
If your business would benefit from higher-performing leaders, check out more information about the comprehensive leadership development training I do HERE.
If you want to reach out to me directly, email alyson@vanhooser.com.
If you enjoyed this episode, will you please subscribe and leave a review? Your reviews help this show get discovered by more incredible leaders just like you. I’m obsessed with helping leaders ignite their performance results and I’d love to have you help me make an impact! Thank you so much!
P.S. Share and tag me on social — @AlysonVanHooser — and I’ll share your comments and big takeaways on my feed!

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This Week in FCPA

Episode 248 – the Impact 2021 edition


As Gary Gensler is confirmed to chair the SEC, Tom and Jay are back to look at this week’s stories top compliance and ethics stories which caught their interest on This Week in FCPA. We are joined by special guest Pat Harned to talk about the upcoming ECI Impact 2021.
 Stories

  1. Environmental crime enforcement under the Biden Administration. Mike Volkov in Corruption Crime and Compliance.
  2. Jason Meyer on what the Masters means to him, on LinkedIn.
  3. Policies and Procedures not enough in compliance. Klaus Moosemeyer in the FCPA Blog.
  4. PCAOB charged with discrimination in suit. Aaron Nicodemus in Compliance Week. (sub req’d)
  5. AI in compliance. Shurti Shah and Joanthan Rusch in NYU’s Compliance and Enforcement Blog.
  6. What is audit fieldwork. Dr. Herman Murdock in XpertsLeague.
  7. DOJ to increase cross-border enforcement? Jon New and Patrick Campbell in CCI.
  8. Is moral leadership an art? Brett Beasley in Center for Ethical Leadership.
  9. FTC gearing up on enforcement. Get ready. Jaclyn Jaeger in Compliance Week. (sub req’d)
  10. More on ESG. Jonathan Marks in BoardandFraud. 

Podcasts and Events

  1. Tom and Megan Dougherty are doing a special podcast series around The Falcon and The Winter Soldier, currently streaming on Disney+. Check out Episodes 1&2, Episode 3, Episode 4.
  2. Check out the 5-part podcast series, sponsored by Lextegrity on the most cutting edge use of data analytics in compliance. All on the Compliance Podcast Network.
  3. This month on The Compliance Life, Tom welcomes Jonathon Kellerman. In Episode 1, Jonathon discusses the path he took to compliance. In Episode 2, he talks about his early professional career in healthcare compliance consulting.
  4. This week on The Compliance Handbook, I visit with AMI’s Vin DiCianni and Eric Feldman on the role of culture in compliance. Check outthe video podcast here.
  5. CCI releases a new eBook, The FCPA Year in Review by the Compliance Evangelist, Tom Fox. You can obtain a copy here. Best of all its available at no charge.
  6. Join Tom and Jay at ECI’s IMPACT 2021, which will be held virtually April 20-22. Listeners to this podcast will receive a 20% discount to the event. For more information and registration details click here. Use the code Tom20for your discount.
  7. Join K2 Integrity’s financial crimes compliance professionals on Thursday, 22 April 2021, at 10 AM ET for DOLFIN’s “Ask an Expert FINQuiry” webinar, for a discussion on the impact of ongoing developments in the financial integrity community. Information and Registration here. Third-party due diligence, through creative and comprehensive gathering of information and intelligence, can help organizations better assess the third-party and associated risks and identify areas of potential concern or opportunity that would otherwise have gone uncovered. Join K2 Integrity’s Anna Gumowska and Shannon Rainey on Wednesday, 21 April as they discuss scenarios in which third-party due diligence helped uncover areas of risk and opportunity for clients. Information and Registration here.
  8. Tom announces his latest book, The Compliance Handbook, 2nd edition is available for presale purchase. Use the code FOX25 and go hereThe Compliance Handbook 2ndedition will be available in both print and eBook editions. This week on The Compliance Handbook podcast, the ladies from #GWIC join Tom for a deep dive into written standards.

Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

Categories
Daily Compliance News

April 16, 2021 the Want Wisdom, Listen edition


In today’s edition of Daily Compliance News:

  • Biden Administration brings the hammer down with Russia sanctions. (WSJ)
  • Bezos says Amazon needs culture reset. (WSJ)
  • Golden age of tax evasion over? (FT)
  • What is wisdom? (NYT)
Categories
Innovation in Compliance

Smart Automation for Risk Management: Part 4, Pre-Approval and 3rd Parties


Welcome to a multi-part podcast series, Smart Automation for Risk Management, sponsored by Lextegrity Inc. Over the course of this series, we are visiting with Parth Chanda, Founder and Chief Executive Officer (CEO), Andy Miller, Chief Analytics Officer, and Kara Bonitatibus, Head of Product. We have reviewed Lextegrity Product Suite, taken a deep dive into continuous risk monitoring, considered pre-approvals and third-party due diligence and integrations and user experience. In a special bonus episode, Chanda and I will discuss the Integrity and Analytics Collective. In Episode 4, I visit with Bonitatibus on pre-approvals and third-party due diligence.
We began with a discussion of the pre-approval process and third-party due diligence monitoring tools that Lextegrity has developed. Bonitatibus initially noted that often times the business folks see the compliance function as the department of holding things up. This led the Lextegrity team to look at questions such as “how do you build a system that is easy to use, intuitive gets users in and out of the system and gets them the answers they need as quickly as possible?”
The Lextegrity platform starts from the perspective of bringing all of your business pre-approvals together in one platform. This means business users must only go to one place to interact with the compliance function and any employee only needs to learn one compliance system. This can replace the myriad of company purchases of a third-party solution, a gifts, travel and entertainment (GTE) solution, disclosure system even to perhaps a separate conflict of interests solution. Even with a GRC vendor, who might have different modules that cover all of those processes, but even they do not necessarily talk to one another.
The Lextegrity difference is that it can build workflows unique to your business. Bonitatibus noted the solution has workflows in 14 languages, soon to be 20. It can provide customers with template content, across multiple questionnaires. There is a library of content which based on an internal review of enforcement actions and other public source documents, all of which are configurable. She went on to say, “we implemented multiple workflows in over a dozen languages in a hundred countries and less than 90 days, in a new tech driven compliance program. That’s what makes our software really powerful.”
We then turned to the question of how companies are in many cases not using the pre-approval workflows efficiently. One of the pillars of Lextegrity is to be more data driven across all of our products, including in the pre-approval workflow. “The Lextegrity solution embeds analytics and thresholds directly into the preapproval process, which provides approvers with data to inform their decisions. This means you are not simply looking at the information which is provided by the submitter or the requester. It expands out to things like aggregate spend and aggregate frequency. For example, how many gifts has this government official already received? How much has this particular healthcare professional received in the context of a meal or a consulting fee?”
The important component of any such analysis is to not look at this data “in a vacuum, but rather   in context of other similarly situated requests.” Bonitatibus further explained “from a recipient perspective, compare one doctor to other doctors who are also receiving meals or consulting fees. Is this an outlier in comparison to those types of data points? Then the same analysis from a submitter perspective.” Here you might look at has a particular submitter input requests that are outside the norm of people that are in similar positions? As Bonitatibus mused, “in my former life, as an in-house compliance professional, this would have been a game changer from my perspective and have given myself and my colleagues a lot more comfort in decision-making.”
We then turned to third-party due diligence and the Lextegrity solution. Bonitatibus admitted this was her biggest frustration as an in-house compliance professional as she was responsible for her company’s third-party due diligence program. There was no “holistic third-party risk management tool around third parties.” She channeled that frustration to help create a solution to better manage this most significant of compliance risks. The information needed for a robust holistic management of third-parties includes where your third-party population resides, both by market and region. But it also includes third parties from vendors to sales agents so that you need to be able to look at “a universe of third parties.”
What the Lextegrity solution provides is a way to “pull from a vendor master or customer master lists” so that company business administrators can master the system data and ensure that it is as clean as possible. Another key differentiator for Lextegrity is that the solution allows for tracking activity at an engagement level of existing platforms out there which focus strictly on the initial engagement, a higher level of engagement such as a Master Services Agreement with a third party. If scope creep starts, with more business users or functions using that same third party to engage them for some other type of business purpose, you can be aware of it. Finally, and perhaps most significantly, the Lextegrity risk scoring component provides true end to end risk management of your third-party base care.”
Join us tomorrow where explore integrations and the user experience with Bonitatibus.
For more on Lextegrity, check out their website here.

Categories
12 O’Clock High-a podcast on business leadership

Rod Robertson on Reverse Mentorships and Leading Millennials and GenZs

 
Richard Lummis is on assignment this week so I am pleased to host Rod Robertson. Robertson is the Managing Directors at Briggs Capital. In this episode, we discuss how much Baby Boomers can learn from Millennials and GenZs and how business culture will change as they and the next generation move into the workplace. We have a special shout out to Edward Gibbon’s Decline and Fall of the Roman Empire.

  • The work of Briggs Capital.
  • What is a ‘no show’ transaction?
  • What does the phrase “dependents of the pandemic” mean?
  • Why employers should allow canines in the office.
  • Why is this issue so important to GenZers and Millennials?
  • What does this issue teach us OWG (old white guys) about listening to and managing GenZers and Millennials?
  • How does Goldman Sachs and its 100-hour work week for junior employees fit into broader context of managing Millennials?
  • What do companies and individuals need to be thinking about into 2025 and beyond regarding managing GenZers and Millennials?
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Daily Compliance News

April 15, 2021 the Farewell to Bernie edition

 
In today’s edition of Daily Compliance News:

  • Bernie Madoff dies. (WSJ)
  • Gensler confirmed. (WaPo)
  • HSBC moves senior management from London to Hong Kong. (FT)
  • The $100bn player (Coinbase). (CNN)