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Accountability: The Heart of Compliance

Episode 4-Delta Airlines Demonstrates Accountability

We have been getting accountability all wrong in the compliance profession. It’s not a set of tasks – it’s a way of thinking and it has to come from the heart as well as the head. On Accountability: The Heart of Compliance Tom Fox and Sam Silverstein dig into what accountability means to the corporate compliance function and business organizations and most significantly, how to make it an integral part of your culture. In this episode we consider a recent example of accountability in the corporate world, courtesy of Delta Airlines. Some of the highlights include:

  • Accountability means ‘your problem is my problem’.
  • Accountability means keeping your commitment to others.
  • When your organization is accountability to your community it inspires your employees.
  • How accountability informs your core values.

For more information on Sam Silverstein and his work on accountability, click here.

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Life with GDPR

Episode 31-Lessons Learned in Year 1 of GDPR, Part 1

In this podcast, data privacy/data security expert Jonathan Armstrong and Compliance Evangelist Tom Fox use the framework of GDPR to discuss a wide range of issues relating to these topics. They consider what the US compliance and InfoSec security expert needs to know about what is happening in the UK, Europe and beyond. In this episode, we begin a three-part series of some of the key lessons learned from the first year of GDPR. Some of the highlights in this episode include:
Do you have a plan? You need to have a plan for a data breach because it is not if but when you will be hacked. Armstrong advises you can be two plans; one for all employees which is straight-forward so that all employees will be able to understand it. You should have a second plan, which you rehearse which is for all compliance/IT/data security. It should be process driven so it allows flexibility for those responding.
Know your data and know your third parties. Many companies have disaggregated data because they have so many vendors and platforms where data is stored. You must know who has your data. Do you have visibility into 3rd, 4thand 5thparties from the data perspective? You should also capture where data is going in an organization, particularly customer and employee data. Finally, and sadly overlooked by many US companies is the question of data protection of a US parent when a UK/EU sub is audited?
Assemble your data response team now and practice, practice, practice.You need to look at your data security response. What does the A Team teach you about data response? You should strive for strength in diverse skills and practice your response. Look at PR rapid response, your compliance, your legal response all in addition to your IT/data security response. Regulators looking at share price drop off, this shows the need for a rapid, practiced response.
For more information on Cordery Compliance, go their website here.

For more information on data breaches, see here.
Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.
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Adventures in Compliance

The Creeping Man and Risk Management by the Board

We are back with another podcast on Adventures in Compliance, where we consider the intersection of Sherlock Holmes and Compliance. Today, I visit The Adventure of the Creeping Man. From this story we take the Holmes utterance to Watson “Come at once if convenient—if inconvenient come all the same”. This informs today’s discussion how Boards of Directors can be more involved in compliance through more effective oversight of risk management.
Compliance Takeaways

  1. What is the role of a company’s Board in a compliance program?
  2. A Board should not engage in management but should engage in oversight of the Chief Compliance Officer. The Board does this through asking hard questions, particularly around risk assessment, risk identification and risk management.
  3. What are 6 principles for Board oversight of compliance?
  4. Define the Board’s role.

A.Foster a culture of compliance risk management.
B. Incorporate risk management directly into a compliance strategy.
C. Define the company’s appetite for risk around compliance.
D. Execute the compliance risk management process.
E. Benchmark and evaluate the compliance process.
5. CCO reporting to the Audit/Compliance Committee must be structured carefully to promote ethics and compliance. Here are five best practices to help guide the reporting.
a. Quarterly reports.
b. Executive session.
c. Sitting in on other reports.
d. Informal relationship.
e. Annual report to full board.
Join us tomorrow as we mine the story of The Lion’s Mane for its compliance lessons.

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Daily Compliance News

Daily Compliance News: August 21, 2019-the Purpose of a Corporation edition

In today’s edition of Daily Compliance News:

  • Overall, most pro, some con. (NYT)
  • Andrew Ross Sorkin says corporations are looking back to the future. (NYT)
  • WSJ Op-Ed uses it to attack Sanders/Warren. (WSJ)
  • FT applauds and says America leads the way, yet again. (FT)
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Great Women in Compliance

Compliance Trailblazing with Kris Robidoux

There is nothing more inspiring than hearing about someone who has been there and done that.  In today’s episode we feature Kris Robidoux who was involved in the first two anti-bribery cases in Canada and led the way for those after her. Kris is a decorated Legal and Compliance professional with the title of Queen’s Counsel to her name as well as being named one of the Top 100 Women in Investigations by Global Investigations Review and One of Canada’s Top 25 Most Influential Lawyers by Canadian Lawyer Magazine. Mary was introduced to Kris by Compliance colleagues Jay Rosen and Jonathan Armstrong.  It was the beginning of a wonderful friendship.  Kris, Jonathan and Mary would go on to work together as panelists at conferences sharing global Compliance updates with able assistance from Jay who facilitated the interactive aspects of their sessions.  Throughout her time knowing Kris, Mary has considered her to be one of her Compliance role models and knows that she will always be received with a warm smile and words of wisdom when meeting Kris.
In this episode, Kris shares her thought leadership on prescience in observing gaps in the market coupled with timing your moves right for positioning yourself to lead the charge in new areas of the law, a top consideration for companies that may have to deal with the legalization of cannabis and its impact on company policies, her biggest lesson learned transitioning from a compliance and investigations practice in a global law firm to a compliance role in a corporation, dealing with possible retaliation cases when conducting investigations and working through challenges of colleagues undermining Compliance. We close this episode by canvassing the effects of microaggressions in the workplace and how you can play a part in lessening these detrimental effects.

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Compliance Into the Weeds

Episode 136- Scoping the Size of Compliance Workforce

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 Kelly  and I go into the weeds to explore size of the compliance workforce in secondary markets in the US and how that will impact compliance program enhancements going forward.
Some of the highlights include:
  • Do FASB accounting standard changes mandate new skill/talents?
  • Why are the new FASB lease accounting standards being delayed?
  • Is the role of compliance is to build better systems to govern ourselves around risk management?
  • Is the BLS definition of compliance professional still relevant or is it stuck in 1998?
  • Why is there such a divergence in secondary markets in the hiring of compliance professionals?
  • How would all this play out for compliance professionals in a recession?
For additional reading see Matt’s blog post Scoping the Size of Compliance Workforce on Radical Compliance.
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Adventures in Compliance

The Problem of Thor Bridge and Monitoring Controls

We are back with another series of Adventures in Compliance podcasts. This week I am exploring stories from The Casebook of Sherlock Holmes. In this week’s second offering, I consider The Problem of Thor Bridge. From this story we take the Holmes utterance “We must look for consistency. Where there is want of it, we must suspect deception”. This informs our discussion on monitoring controls.

Compliance Takeaways
  1. How do you determine that want of consistency? Monitoring controls is one key.
  2. Consider the fifth and final Objective from the COSO 2013 Internal Control Framework is Monitoring Activitiesas a guide.
  3. Further consider Principles 16 & 17 of the COSO Framework.
  4. Monitoring Activities should bring together your entire compliance program and give you a sense of whether it is running properly.
  5. Both ongoing monitoring and auditing are tools the CCO and compliance practitioner should use in support of this objective.
  6. The most important item to note is that all the controls need to be sustainable.
Join us tomorrow as we consider The Adventure of the Creeping Man.
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Innovation in Compliance

C-Suite Network and the Future of Podcasting with Jeffrey Hayzlett


Our illustrious guest on this week’s show is Jeffrey Hayzlett, the founder and CEO of C-Suite Network. He chats with host Tom Fox about his podcast network and what he sees as the future of podcasting.

The Evolution of C-Suite Radio
Jeffrey has had a very successful career in the corporate world: he has bought and sold over 250 businesses, completed $25 billion in transactions, was the Chief Marketing Officer for Eastman Kodak, a Fortune 10 Company. He was also a judge on the Celebrity Apprentice for 3 years, working with Mark Burnett and Donald Trump. He shares how he transitioned from his own Prime Time TV show into podcasting, eventually starting C-Suite Radio, which is now the world’s largest business podcast network.
C-Suite Network as a Trusted Source
The C-Suite Network includes C-Suite Radio, TV, Book Club and several other clubs and councils. Jeffrey wants listeners to know that they are getting an authoritative source: the network offers a breadth of knowledge as well as diversity of thought. Just like a bartender who knows what you like and has it waiting when you come in, the goal of the C-Suite Network is to serve its audience. We anticipate your needs, Jeffrey says, and aim to be there when you’re ready for it, in the way you want to have it, whether through books, podcasts, tv, or conferences.
A Broad Spectrum of Solutions
Tom remarks that he likes the C-Suite Radio Network because you can listen to and incorporate a broad spectrum of solutions into your practice. Jeffrey comments about the caliber of guests and the knowledge they bring to the shows. With over 5,000 shows per year, the C-Suite Network has a plethora of content which gives readers lots of choices to find solutions or opportunities. A listener can search for information by genre, or any other taxonomy.
The Market Development of Podcasting
Podcasting has seen major market growth in part because of the proliferation of devices. It is easier and more convenient to listen than to see. People love the ability to consume knowledge wherever they are. The marketplace has picked up on this and the valuation on podcast networks has risen, so much so that they are now trading at 100x revenue. Podcast growth is much higher than video growth.
C-Suite Conference
The C-Suite Network hosts over 60 meetings per year. Recently they had a full week of meetings, including the Capital Summit on the second day, when they rented out a former Catholic Church which is now a meeting venue, and passed the collection plates. Over half a billion dollars in funding was given out in the room. 
The Future of Podcasting
Jeffrey envisions that there will be more podcasts, availability will be easier especially with connected home devices such as Alexa and Google Home, and that more advertising will be done on shows in the future. 
Resources
C-Suite Network
Jeffrey Hayzlett on LinkedIn

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Daily Compliance News

Daily Compliance News: August 20, 2019-the dog years edition

In today’s edition of Daily Compliance News:

  • Former SEC Chair Arthur Levitt says the SEC plan to gut internal controls reporting is misplaced. (WSJ)
  • The Business Roundtable redefines “the purpose of a corporation.” (NYT)
  • BVI lawyer skewers ABA for opposing AML legislation. (FCPA Blog)
  • When employment years count as dog years. (WSJ)
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Daily Compliance News

Daily Compliance News: August 19, 2019-the Opioid Memo edition

In today’s edition of Daily Compliance News:

  • Will the Justice Department Memo on the Opioid Crisis be a turning point? (NYT)
  • Trump wants to “look at” purchasing Greenland. (WSJ)
  • More regime change and corruption investigations. (The Guardian)
  • what to look for as WeWork goes public? (MarketWatch)