Categories
Compliance and Coronavirus

Dan Zitting on Stakeholder Engagement in the Era of Covid-19


Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. In this episode, I am joined by Dan Zitting, Chief Product & Strategy Officer at Galvanize. Dan joins me to discuss issues and challenges around stakeholder engagement brought on by Covid-19.
Some of the highlights include:
·      Role at Galvanize?
·      What does the Galvanize solution bring?
·      What is the HighBond platform and what role does it play?
·      How can these solutions assist a compliance professional?
·      You have said, your “purpose is to “challenge the planet’s organizations to maximize ‘total stakeholder impact’ by operating with a conscience”. What does this mean?
·      How did Galvanize assist , UnitingCare, an Australian largest non-profit health, aged care, disability, and community service providers
 Resources
Check out the Galvanize COVID-19 Toolkit

Categories
Great Women in Compliance

Dr. Mary Gentile, Giving Voice to Values-Part 1


Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
In this Part 1 of a special two-part series, Lisa welcomes Dr. Mary Gentile who is the creator and architect of Giving Voice to Values (GVV), which is a globally recognized program which shifts the focus from ethical analysis, to ethical implementation.  This aligns with the manner in which many ethics and compliance professionals look to support their organizations by helping people act ethically.  In this first episode, Lisa talks with Dr. Gentile about how GVV started from her review and analysis of how everyone has internal and external pressures surrounding their decisions, and that some people do voice and act on their values, and some do not.
Dr. Gentile’s research led to the development of GVV to give practical tools to help people make better decisions. She talks about how to and build a practice to help people move from knowing what the ethical thing is to do, to having the ability to effectively respond when challenged.  She discusses global challenges and challenges for women when being pressured to act unethically and the tools that GVV provides in those situations.
Have you heard that Lisa and Mary have published a book?  Yes, you can get your very own copy of “Sending the Elevator Back Down: What We’ve Learned From Great Women in Compliance” (CCI Press, 2020) on Amazon right now!  Enjoyed your copy?  Don’t forget to leave a review!
Join the Great Women in Compliance community on LinkedIn here.

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Compliance Into the Weeds

Compliance Under the Biden Administration


Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at issues relevant to the next administration. Some of the issues we consider are:

  • What are some of the key appointments to follow?
  • Where will FCPA enforcement go?
  • Will use of monitors increase?
  • How might the tone of SEC initiative and enforcement change under the Biden Administration?
  • There has been increased scrutiny by the OCC and Fed on financial institutions compliance program. Will it continue?
  • The Trump Administration attacks on Diversity and Inclusion training will end.

 Resources
See Matt’s blog posts on Radical ComplianceThe Biden Administration and Compliance

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Daily Compliance News

November 11, 2020-Veterans’ Salute edition


In today’s edition of Daily Compliance News:

  • Boeing in line for additional penalties? (WSJ)
  • UK to require companies to report on climate change by 2025. (WSJ)
  • EU targets Amazon. (NYT)
  • Call up a veteran and thank him or her.
Categories
The Compliance Life

Katie Smith on helping the next generation of compliance professionals


The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Katie Smith who is the Vice President for Ethics at Assurance.  She previously served as Assistant Vice President and Chief Ethics Officer for USAA and Executive Vice President and Chief Compliance and Ethics Officer at Convercent.
Katie is passionate about compliance, having worked in the field for 20 years, building high-performing teams and increasing employee engagement by up to 300%. She has proven expertise in building and promoting talent, creating a trust-based culture, anti-corruption, code of conduct, conflict of interest, marketing internal programs, training and awareness, investigation excellence, data privacy and process efficiency. She is a much sought after public speaker and contributor featured in Wall Street Journal, Time, Fortune, NBC and Compliance Week. Katie’s commitment to the compliance profession is well as she currently sits on the Board of Directors of the Ethics and Compliance Initiative (ECI).
In this second episode, we take up the some of the skills, tasks and roles that Katie used in her CCO/CECO roles. She discusses how the compliance profession and compliance professionals have evolved over the past two decades. We move into some of the challenges Ethics and Compliance functions face in the Covid-19 world. We conclude with some of Katie’s thoughts on how persons just getting into the compliance field can garner mentors.

Categories
Innovation in Compliance

Engineering the Future with AI with Simon Moss


Tom Fox welcomes Simon Moss to this week’s show. Simon – who describes his background as “eclectic”, having worked in and led many companies over his career, including IBM –  is now the CEO of Ayasdi, one of the most innovative companies in the artificial intelligence space. Simon and Tom discuss the important work Ayasdi is doing for its clients.

The Data Problem
Tom asks why AI can’t seem to keep up with the volume of data that needs to be reviewed for AML, ABC and trade sanctions. Simon disagrees that it’s an issue of volume. The problem is diversity and distribution. He says, “The problem with data now is that it is so diverse, so distributed, and we’re still trying to deploy products of extraordinary innovation – including AI products –  in the same ways as we did in the 1970s.” He laments that we try to homogenize data into a construct, which uses 80% of our data management resources. “We have institutionalized redundancy in data management, and it is getting worse because of the proliferation of data sources.” While this structure works for data at rest, it is unsuitable for unstructured data and data in use.
A Unique Approach
“We don’t use the data model approach,” Simon remarks. Ayasdi believes that a company is represented in its data, so they create a model that is unique to each client. “…it knocks 40 to 50% off the time to actually deploy innovation,” he says. He explains why machine learning cannot effectively predict or discover crime or compliance issues. “Hypothesis-based machine learning is brilliant for finding a needle in a haystack… The problem with compliance is you’re looking for a needle in a stack of needles.” Ayasdi’s approach, on the other hand, is to let the data tell the story. “The breakthrough that Ayasdi uses,” Simon says, “is what’s called unsupervised learning as part of a machine learning process. In other words, we are not going to give the software a hypothesis of what to look for. We simply say, ‘Go find interesting stuff.’ Let the data tell us the story.”
Innovating for the Future
Ayasdi is engineering the operational diligence and deployment needed for the future. It was technology that drove the blue collar transformation of the early 2000s, and it is technology that will drive the transformation of the white collar industry over the next decade. “We’re engineering our technology to make sure that we can service a customer expectation in the future,” Simon says. Tom comments, “It strikes me that the insights that could be generated [go] really far beyond the anti money laundering and fraud and corruption.” Simon agrees. He shares three examples of how Ayasdi has helped their clients gain valuable insights and profit from them. “What we’re doing is we’re creating true Alpha. We’re creating true opportunity and we’re creating true transparency. When those decisions are made, you know that the decision that has been created has all the explainability, all the referential insight that’s needed, all the appropriate data, so that when a regulator comes in and says, Why did you do this? It’s all completely supported.”
The true challenge of innovation, Simon argues, is that a solution works at scale. “The challenge is, How do you optimize the operating model of an institution? And you do that by looking at the institution as a whole.”
Resources
Ayasdi.com
Simon Moss on LinkedIn

Categories
Daily Compliance News

November 10, 2020-Full Disgorgement edition


In today’s edition of Daily Compliance News:

  • Softbank takes steps to improve corp goverance. (FT)
  • Was all of Robert Smith’s wealth fraudulent? (WaPo)
  • Apple places key contractor on probation. (NYT)
  • Should CEOs continue to speak out? (NYT)
Categories
FCPA Compliance Report

Mike DeBernardis on Q3 FCPA Enforcement and Related Issues

In the Episode, I visit with Mike DeBernardis, Counsel and Hughes Hubbard. We take a look back at the FCPA world in Q3. It started off with a bang and never slowed down. Some of the highlights include:

  1. The quarter started off with a bang-Novartis US and never slowed down.
  2. How and why did Novartis US, First Energy in Ohio and Commonwealth Ed in Illinois change the discussion around domestic corruption?
  3. What were some of the key lessons from the Herbalife FCPA enforcement action? Why is it so important to obtain experienced White-Collar Counsel in a serious FCPA matter?
  4. What were top 3 takeaways from the release of the FCPA Resource Guide 2nd edition?
  5. Sargeant Marine was a rare criminal FCPA plea. What is the significance of the case?
  6. The Alexion SEC enforcement action in July was relatively small but had some interesting lessons. What were key takeaways from the case?
  7. Do you see continue aggressive FCPA enforcement by the DOJ/SEC?
  8. What are you telling clients about their compliance programs going into the next 12 months?
Categories
Daily Compliance News

November 9, 2020-Farewell to Trebek edition

In today’s edition of Daily Compliance News:

  • SFO looking into Bombadier. (WSJ)
  • OECD presses Netherlands on whistleblower protections. (WSJ)
  • Pfizer receives FCPA inquiry from the SEC. (WaPo)
  • Alex Trebek dies. (NYT)
Categories
Innovation in Compliance

The Six Elements of an Effective Compliance Program: 5 – Oversight and Reporting and Response and Enhancements


Welcome to a special five-part podcast series, The Six Elements of an Effective Compliance Program. This podcast series is sponsored by StoneTurn. To celebrate Corporate Compliance and Ethics Week, we will consider each of the six elements required for an effective compliance program. They include: Risk Assessment, Governance and Structure, Policies Procedures and Controls, Training and Education, Oversight and Reporting, and Response and Enhancements. Over this five-part podcast series, I will be joined by Stephen Martin and Valerie Charles, Partners at StoneTurn and Toby Ralston and Jamen Tyler, Managing Directors at StoneTurn. In this fifth episode, I visit with Valerie Charles on the twin topics of  Oversight and Reporting: The Board’s Role in Compliance and Having a Speak Up Culture and Response and Enhancements: Continually Improving Your Compliance Program. Highlights include:
Oversight and Reporting-the Board’s Role in Compliance and Having a Speak Up Culture

  • What is the relationship between whistleblowers/hotlines/internal reporting/Speak Up culture and Internal Investigations?
  • 3Rd Parties are still the highest FCPA risk. How and why has Due Diligence become even more important in the era of Covid-19.
  • How should a CCO educate the Board on their role within the Compliance framework?
  • How does a Board walk that fine line between management and oversight?
  • What types of questions should a Board be asking a CCO?

Response and Enhancements- Continually Improving Your Compliance Program

  • What are some of the key elements of Third-Party Risk Management?
  • In the 2020 Update, the DOJ strongly emphasized not simply oversight but continuous monitoring and continuous improvement. How can a CCO think through continuous monitoring and then using that information to improve a compliance program?
  • What are some strategies for Continuous Monitoring?
  • The 2020 Update mandated greater use of data by a CCO. Yet even with data, why is the human element so critical in any data-based solution?
  • Root cause analysis is now a separate Hallmark of an Effective Compliance Program. How should a CCO use root cause analysis in response and enhancements?

Resources
For more information on StoneTurn, click here.