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This Week in FCPA

Episode 172 – the Tribute to Joe Mont edition

This episode begins on a somber note as Tom and Jay note the passing of Compliance Week reporter Joe Mont and what he meant to the greater compliance community. They then turn to discuss some of this week’s top compliance and ethics stories which caught their collective eyes.
1.    Tributes to Joe Mont.
2.    Mike Volkov takes a deep dive into the recent Business Roundtable Statement on the Purpose of a Corporation on Corruption Crime and Compliance.
3.    Former Cognizant Technologies COO, Sridhar Thiruvengadam, settles FCPA charges. Dick Cassin.
4.    Netherlands proposes nationwide AML system. John Rusch reports.
5.    What is an ethical culture and why does it matter? Jay begins a multipart series.
6.    What is algomerithic corporate misconduct. Milhailis Diamantis explores.
7.    Despite prevaling opinions, CCO is not a ‘god’. Clara Hudson reports on the Odebrecht CCO remarks at SCCE.
8.    Do UK DPAs throw individuals under the bus? Ross Dixon asks.
9.    Mary Shirely tells you how to ace job interviews.
10. Tom continues his preview of the Converge19 speakers in a special bonus series of podcasts on the Compliance Podcast Network. Check out the following: Monday-Scott McCleskey on mapping the ethical risk in your company;  Tuesday-Valerie Towery on cross functional collaboration; Wednesday-Kurt Stitcher on Operation Globalization; Thursday-Matt Kelly on Developing Effective Strategies for Third Parties & Data Security Risk and Friday– Anna Aster on The Future CECO: The Executive Recruiter’s Perspective. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTube,  Spotifyand theCompliance Podcast Network.
11. The Everything Compliance gang will be doing its first live podcast at Converge19. You should be there! Listeners to this podcast can obtain a complimentary ticket by using the promotion code foxvip, for registration and information, click here.
Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.
For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.
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Daily Compliance News

September 22, 2019 Sunday Book Review edition

In today’s edition Sunday Book Review edition of Daily Compliance News:

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Daily Compliance News

September 21, 2019- the Corruption in Afghanistan it edition

In today’s edition of Daily Compliance News:
  • Shocked, shocked to find there is corruption in Afghanistan? (Fox News)
  • Criminal charges filed in Vale dam collapse. (WSJ)
  • Saudi Aramco IPO theme song-“With a Little Help From My Friends. (NYT)
  • Traveling to China, you might want to think about it. (WSJ)
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The Ethics Movement

Anna Aster on The Future CECO: The Executive Recruiter’s Perspective

CONVERGE is in its 4th 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. 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 Anna Aster, Principal at Heidrick & Struggles. We visit about her talk, The Future CECO: The Executive Recruiter’s Perspective.
As the field of ethics & compliance continues to evolve, what does it take to be a CECO in the future? Hear from the world’s top executive recruiting firm on the hiring trends in the compliance field, what recruiters are looking for, and tips on how to get your LinkedIn profile and resume noticed by headhunters. This is a session you cannot afford to miss.
For more information on Converge19, click here.

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Compliance Man Chooses the Target

Daily Compliance Actions

Welcome to Episode 9 of Compliance Man Chooses the Target with Tim Khasanov-Batirov.The goal is to highlight matters that should be on agenda of practitioners that deploy compliance programs in industries or countries of active anticorruption enforcement. In this podcast series, Compliance Man will target three specific matters that you might like to address in the course of implementation of your compliance program. Today we will focus on improvement of daily compliance activities. 
Target #1: Communications with Colleagues
It is about trust. Success of your corporate compliance program depends on whether your colleagues feel comfortable to approach you without fear. You might have a pile of policies but in the reality of any company, specifically when we talk about emerging markets personal trust to Compliance officer is essential. On practice, this allows to implement proactive rather than reactive approach, when personnel approaches compliance officer with their ethical dilemmas prior to acting.       
Target #2: Generation X & Generation Y
Recently I was teaching Compliance class at the Summer School at Baltic Federal University. I have noticed that for Gen X&Yers; and specifically for those who were born in 1990-s methods of teaching/training compliance should differ from techniques used for people of older age. The main difference is that youngsters are able and used to deploy internet search much more actively comparing to older folks. In addition generation Y feels comfortable to self-educate themselves due to availability of gadgets using which they can google virtually any compliance related information. I would suggest having in mind the above mentioned in the course of preparation of compliance trainings to young personnel.
Target #3: Keep your Compliance Eyes Open
The biggest mistake compliance officer could make is to limit himself to a couple of areas, which historically are associated with compliance department’s area of responsibility as drafting anticorruption policies for instance without paying attention to business processes, projects, corporate initiatives which might also contain FCPA risk but needs analytical efforts from Compliance officer to be spotted.  It is much easier in daily routine to look solely on gifts practices as it contains a compliance associated ‘hashtag’ GIFT than to mitigate risks integrated in business processes.  Such situation is depicted in one of the releases of Compliance Man illustrated series   http://complianceinpostussr.com/compliance-man-of-integrity-corp-episode-7-mistakes/#comment-19
The best way to manage the ‘hashtag’ approach is a compliance risk register. Just go to the process, project or corporate initiative where the FCPA risk might take place. Keep your compliance eyes open to evolving corporate reality.
Join me for the next episode of Compliance Man Chooses the Target with Tim Khasanov-Batirov. 
Learn more compliance tips from Tim Khasanov-Batirov at:
http://complianceinpostussr.com/ & http://complianceinpostussr.com/blog/

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Daily Compliance News

September 20, 2019- the Good Work if You can Get it edition

In today’s edition of Daily Compliance News:
  • Will Brazil move past its corrupt administration? (FT)
  • What if you ID audit partners? (WSJ)
  • US Bank pays $4MM to settle sanctions allegations. (WSJ)
  • Good work if you can get it. (Washington Post)
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Creativity and Compliance

Angelique Lee-Rowley on Creative Compliance Programming

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 Compliance Podcast Network. In this show, we’ll be exploring how creativity affects the world of compliance – the ways we use it, and the surprising impacts it can have on the work we do every day. From ethics to leadership, problem-solving to training – creativity permeates what we do as compliance professionals.  In this podcast we have a special quest, Angelique Lee-Rowley, CCO of GW Pharmaceuticals who visits with on the use some of the creative programming the company have rolled out this past year.
Some of the highlights include:

  • What drew Lee-Rowley to the project?
  • What were some of her hesitancies about utilizing a comedic approach?
    • It’s not about the funny, it’s about being interesting and provocative
    • It’s about being empathetic and on the side of employees
    • It’s about being provocative so they don’t just snooze their way through training
    • I’m not a fan of scare tactics.
  • How has the company utilized the programming thus far?
    • Live training
    • E-Learning
    • Paired with other training
    • Commercials
  • How has the programming been received and how has it helped your compliance efforts?
    • What were some of the reactions from the employees?
  • What are some of the lessons have you learned?
    • Don’t be afraid to try new things
    • Don’t be too precious about finding the perfect solution. Engage employees with variety and surprise…keep people on their toes.

Resources:
Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)
Learnings & Entertainments (Website)
60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.
Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.
Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.
See also, Ronnie’s article on CCI, How Corporations Can Use Comedy and Creativity to Enhance Risk Training
 

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The Walden Pond

The Compliance Podcast Network Welcomes The Walden Pond!

 

Vince Walden was the first person I interviewed for my Innovation in Compliance podcast back in March 2018. That first episode drew nearly 5000 listeners. We were clearly onto something. It took a while but I finally convinced Vince that he needed his own podcast so with no small amount of pride of ideaship, I want to introduce The Walden Pond as the latest offering on the Compliance Podcast Network. Walden has been in the forensic technology compliance and investigation field for over 2 decades, and in the Walden Pond, he is going to be exploring practical, timely and relevant information by talking to other experts in the field. Henry David Thoreau’s focus reflecting upon simple living in natural surroundings. Our world isn’t as simple as Thoreau’s Walden Pond and so in this Walden Pond, we’ll be looking at business, technology and compliance trends that are complex – but necessary for doing business. The host anti-fraud expert Vince Walden is talking to experts about the technology and compliance trends you need to know about to keep your compliance and fraud detection programs relevant. If you’re looking for insights that are practical, timely and innovative… Welcome to The Walden Pond.

 

Episode 1 – Welcome to The Walden Pond. 

 

 

In this introductory episode, host and anti-fraud expert Vince Walden talks about why he created a podcast dealing with the technology and compliance trends you need to know about to keep your compliance and fraud detection programs relevant. If you’re looking for insights that are practical, timely and innovative… Welcome to the Pond.

 
 

Episode 2 – Control When You Get Paid with Jason Lee

 

 

In this episode, host Vincent Walden talks with Jason Lee, CEO of DailyPay, a technology solution that lets employees control when they get paid. Fortune 500 companies like Kroger, Berkshire Hathaway, Adecco Staffing and McDonald’s are DailyPay clients. Jason stresses that the daily pay industry and the payday loan industry are completely different. Whereas payday loans give loans to employees which they need to pay back with interest, DailyPay makes employees’ own wages available to them, just like payroll.

 

The business model is simple. When you work, your employer reports your hours to DailyPay via their software. Your hours are converted into an available balance which you can access whenever you want prior to payday. Whatever you take upfront gets netted out of your paycheck on payday. There is no cost to your employer, but you pay a one-time transfer fee whenever you request a payment.

 

Making their wages available to employees when they need it helps to reduce cash shrinkage to almost zero. Jason has also found that time clock compliance shoots up when companies implement DailyPay.

 

Episode 3 – Automating e-Discovery with Anil Kona

 

 

Legal litigation management represents a multibillion-dollar cost for law firms and corporations. It is a labor-intensive process requiring multiple software applications. Vertical Discovery provides a complete end-to-end workflow automation solution to this problem, powered by artificial intelligence and machine learning. Their software solution, Optimum, was developed by a collaborative team of forensic professionals, e-discovery subject matter experts, legal professionals, and product development specialists from Microsoft. CEO Anil Kona speaks with host Vincent Walden about how Optimum can help law firms and corporations reduce cost and increase productivity.
 

Optimum allows you to manage your litigation matters from a single dashboard. You are able to choose best-in-breed applications for each aspect of litigation management – including HR, asset management and EDRM (Electronic Discovery Reference Model) – and Optimum integrates these tools so that they all speak to each other. In addition, Optimum is template-driven. Once you define the type of litigation matter, it automatically shows you the steps to take to meet requirements. This makes litigation consistent and repeatable across cases. You will also see ROI savings in the form of productivity increases of 55 to 60%, manual error reduction of 96 to 98%, and being able to predict the outcome of your case.
Categories
The Ethics Movement

Matt Kelly on Developing Effective Strategies for Third Parties & Data Security Risk

CONVERGE is in its 4th 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. 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 Matt Kelly, founder and editor of Radical Compliance (and the coolest guy in compliance). We visit about his talk at Converge19 on Developing Effective Strategies for Third Parties & Data Security Risk.
Most compliance functions are on the low end of the maturity curve when it comes to effective data security when it comes to third parties. Participants in this session will explore recent regulatory enforcement of data security risks related to third parties, and what regulators are saying about the issue generally; how this is a challenge of risk assessment and data management capabilities, what a ‘mature’ compliance or audit function would need to do for these risks; and some practical ideas to implement at your own business.
For more information on Converge19, click here.
For more information on Radical Compliance, click here.
Categories
Daily Compliance News

September 19, 2019- the Root Out Corruption edition

In today’s edition of Daily Compliance News:
  • White House fires Homeland Security Deputy GC. (NYT)
  • Netherlands proposes nationwide AML system. (Dipping Through Geometries)
  • Did unprepared pilots contribute to 737 MAX disasters? (NYT)
  • Why that “stupid piece of paper” still matters. (Washington Post)