CONVERGE is in its 5th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with like-minded professionals. This year the conference has gone virtual. You will leave the conference with new resources and best practices allowing you to continue the hard work of driving ethics to the center of your business. In today’s episode I visit with Alyson Van Hooser, Partner at Van Hooser Associates. We visit about her panel at Converge20 on Employee Engagement: Are You Prepared for a Gen Z Workforce?
Alyson is one of the most dynamic speakers around. She coaches business leaders on how to lead Gen Z’ers and coaches Gen Z’ers on what it takes to succeed in business. You will walk away from her presentation on concrete action steps to take going forward. For more registration and information on Converge20, click here.
Author: admin
Categories
DeAnna Nwankwo on CCO Skills
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 DeAnna Nwankwo who served as Corporate Compliance Officer for Core Laboratories from 2003 May 2020. In that capacity, she led Core Laboratories ethics and compliance activities.
In this second episode, we take up the some of the skills, tasks and roles that Deanna had as a CCO. She believes one of the key things that any CCO can and should do, one of which is engage in and preach integrity. It is important to understand conflict management as a every CCO will be called upon to manage conflicts. While you must be detail oriented and have good problem-solving skills, a CCO must be comfortable navigating the grey zone.
Today, I visit with Vin DiCianni, CEO and founder of Affiliated Monitors, Inc. In this episode I visit with DiCianni on the marriage of independent monitors and compliance and ethics programs. DiCianni said that the evolution away from strict regulatory compliance to a more ethics-based compliance has been one of the most significant advancements in independent monitors over the history of AMI. Early on AMI had independent monitorships in the health care industry around such issues as billing and coding. From there, AMI began to address other issues such as codes of conduct and conflicts of interest. So AMI was well suited to move into a more direct ethics-based compliance independent monitorship as the first decade progressed.
DiCianni said that over the life of AMI there have been two Memos released by the Department of Justice (DOJ) which have directly impacted the selection of independent monitors and their application. The first was the Morford Memo, released in 2008. In this Memo, the selection criteria for independent monitors was first laid out, including the need for subject matter expertise and independence and integrity of the monitor.
The second was the Benczkowski Memo, released in 2018, which discusses limiting the use of monitors to certain situations where they might be warranted. However, it does give a company the incentive to go out and evaluate their own ethics and compliance programs, compelling them to strengthen those programs so that if they are ever confronted with an investigation or a self-disclosure to the DOJ, the company can demonstrate it has a strong compliance and ethics program and perhaps get special consideration.
Welcome to a special five-part podcast series on topics of Third-Party Risk Management to Supply Chain Risk Management: Exiger on the Evolution in Supplier Compliance in COVID. Exiger was founded to fight financial crime, fraud and terrorist financing by introducing technology-enabled solutions to the market’s biggest supply chain, risk, investigation, litigation, and compliance challenges. A global authority on risk and compliance, Exiger serves the world’s largest banks, Fortune 1000 companies and government agencies and regulators. This special five-part podcast series is sponsored by Exiger. Over the next five episodes, we will put a spotlight on Financial Institutions with Tara Loftus and Samar Pratt; focus on corporations with Aaron Narva and George ‘Ren’ McEachern; consider Federal Government and Supply Chains with Carrie Wibben and Vishnu Anantatmula; review the pillars of good compliance with Brandon Daniels and Carrie Wibben; and end with a review of third-party risk management solutions with Erika Peters and Skyler Chi.
In this Part 2, we put a spotlight on corporations and their challenges in managing third parties and with Supply Chain risk management. In this exploration I am joined by George ‘Ren’ McEachern, a Managing Director based in Exiger’s Silver Spring (DC Metro) office where he focuses on leading anti-bribery investigations and assisting multinational corporations and financial institutions with regulatory risk management. Also joining me in this episode is Aaron Narva, Head of Corporate Markets, based in Exiger’s New York office. He leads the development and delivery of Exiger’s purpose-built AI-powered solutions for anti-bribery and corruption compliance. While at Exiger, Aaron has conducted in-depth testing and review of complex financial institution compliance and anti-money laundering (AML) programs both in the US and abroad. His experience includes detailed assessment of transactions, customer due diligence, and policies and procedures. He also helped to design and develop Exiger Diligence, the investigative due diligence arm of Exiger.
Join us tomorrow where we consider areas some of the challenges the Federal Government has on Supply Chain risk management.
For more information on Exiger, click here.
For more information on George ‘Ren’ McEachern, click here.
For more information on Aaron Narva, click here.
David McLaughlin, founder and CEO of QuantaVerse, joins Tom Fox on this week’s show to discuss his company’s new risk management tool, Country Code Derivation. He explains that this capability was actually a part of their platform for some time, but they saw the need to offer it as a separate tool. “We found that there is a really specific and unique need for understanding the country code of transacting parties,” he says.
Identifying Risky Transactions
Tom and David discuss how Country Code Derivation assists organizations, including financial institutions, to identify potentially risky transactions. David explains that this tool is a “multimodal, layered approach of sifting through different capabilities to accurately identify where somebody’s jurisdiction is.” Determining the jurisdiction of a transaction is a core part of understanding risk, David points out. The advantages of using technology versus a manual process are obvious: technology is more accurate and efficient, can validate malformed data, and saves time and money. Tom asks if regular organizations can use this tool. David responds that it’s valuable for an organization that needs to determine the location of a party, be it vendors or customers.
Compliance Officers Can Use It Too
Tom comments that Country Code Derivation can give compliance professionals access to data they may not have had access to before. David agrees. “It can provide compliance professionals with data that they need,” he says. “It can do it in a way that validates the accuracy of it. It can update it in a way that is automatic and systematic and regular.” Both men conclude that this tool is more important today – in the time of coronavirus – than it ever was. Many organizations have a data backlog because of the pandemic; Country Code Derivation helps to eliminate that backlog in quick time.
Resources
QuantaVerse.net
QuantaVerse on LinkedIn
David McLaughlin on LinkedIn
CONVERGE is in its 5th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with like-minded professionals. This year the conference has gone virtual. You will leave the conference with new resources and best practices allowing you to continue the hard work of driving ethics to the center of your business. In today’s episode I visit with Guendeline Donde, Director of Research at the Institute of Business Ethics. We visit about her panel at Converge20 on Small budget, big impact: Scrappy compliance with limited resources.
Many organizations seek to make the move from a traditional legal program to that which marries user experience, behavioral science and technology – how difficult could it be? Guen will share practical advice from the Institute of Business Ethics’ Toolkit, developed in collaboration with subject matter experts from a variety of industries. For more registration and information on Converge20, click here.
One of the questions GSK faced during the bribery and corruption investigation of its Chinese operations was how an allegedly massive bribery and corruption scheme occurred? Where were the appropriate internal controls? You might think that a company as large as GSK and one that had gone through the ringer of a prior DOJ investigation resulting in charges for off-label marketing and an attendant Corporate Integrity Agreement (CIA) might have such controls in place.
It would be reasonable to expect that internal controls over gifts would be designed to ensure that all gifts satisfy the required criteria, as defined and interpreted in company policies. It should fall to compliance to finalize and approve a definition of permissible and non-permissible gifts, travel and entertainment and internal controls will follow from such definition or criteria set by the company. These criteria would include the amount of the spend, localized down into increased risk such the higher risk recognized in China. Within this context, there are four general internal controls to consider. 1) Is the correct level of person approving the payment/reimbursement?; 2) Are there specific controls (and signoffs) that the gift had proper business purpose?; 3) Are the controls regarding gifts sufficiently preventative, rather than relying on detect controls?; and 4) If controls are not followed, is that failure detected?
Obviously, the use of third parties can be a powerful and effective way for a business to achieve its strategic goals. This may be one of the key reasons why third parties are still one of the leading indicia of bribery and corruption. Every compliance program should regularly review its third-party service providers and evaluate internal policies and procedures to ensure compliance.
Three key takeaways:
- GSK continues to be an example of the lack of internal controls for third-parties in an effective compliance program.
- General areas of review for compliance internal controls.
- Third parties are still the highest risk of corruption related issues.
Welcome to a special five-part podcast series, sponsored by Exiger, on topics From Third-Party Risk Management to Supply Chain Risk Management: Exiger on the Evolution in Supplier Compliance in COVID. Exiger was founded to fight financial crime, fraud and terrorist financing by introducing technology-enabled solutions to the market’s biggest supply chain, risk, investigation, litigation, and compliance challenges. A global authority on risk and compliance, Exiger serves the world’s largest banks, Fortune 1000 companies and government agencies and regulators. Over this series, we will put a spotlight on Financial Institutions with Tara Loftus and Samar Pratt; focus on corporations with Aaron Narva and George ‘Ren’ McEachern; consider Federal Government and Supply Chains with Carrie Wibben and Vishnu Anantatmula; review the pillars of good compliance with Brandon Daniels and Carrie Wibben; and end with a review of third-party risk management solutions with Erika Peters and Skyler Chi.
In this Part 1, we put a spotlight in financial institutions. In this exploration I am joined by Tara Loftus, a Managing Director, who is a part of the Financial Crime Compliance Advisory practice focusing on anti-money laundering (AML) and anti-bribery & corruption (ABC) and Samar Pratt Managing Director who is also in the firm’s Financial Crime Compliance Advisory practice, specializing in audit and assurance.
Join us tomorrow where we consider areas where corporations have challenges on third parties and Supply Chain risk.
For more information on Exiger, click here.
For more information on Samar Pratt, click here.
For more information on Tara Loftus, click here.
