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Everything Compliance

Everything Compliance-Episode 50-July Reflections Edition

Welcome to the only roundtable podcast in compliance. Today, we have the full quintet of Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Armstrong and Sarah Hadden. Rants and shouts outs follow the commentary for this episode.

  1. Jay Rosen considers why governmental entities other than the federal government benefit from independent integrity monitors in their oversight capacity. This includes state AGs, state regulators, counties, cities and school districts. Jay reflects on the anniversary of his father’s death and shouts out to his memory for all the great advice he got from him.
  1. Jonathan Armstrong considers how the ICO has bared its teeth in two recently proposed enforcement actions for data breaches; British Airways and Marriott. Jonathan shouts out to the England team which won the recently concluded Cricket World Cup and to the graciousness in defeat of the New Zealand team which lost in heartbreaking fashion.
  1. Sarah Hadden reflects on her six-month ride as owner/publisher of Corporate Compliance Insights. Hadden shouts out to a team of a female filmmakers who have formed One Vote at a Time dedicated to the eradication of gun violence. Not only do they believe in a future free of gun violence but they deploy skills to elect legislators at all levels of government to fight for it.
  1. Matt Kelly considers the compliance lessons from the Trump Administration’s detention camps on the US/Mexico border. Kelly rants about the USOC which is hiring its very first CCO. He also notes that it took him six clicks to find the USOC Code of Conduct on the Commission’s website.
  1. Mike Volkov discusses the new DOJ Antitrust Division’s Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations. Volkov shouts out to the Greater Houston Business and Ethics Roundtable (GHBER) as a model for local business ethics groups.
  1. Tom joins in a shout out to the author Andrea Camilleri, at the age of 69, took up mystery novel writing and came up with the Inspector Montalbano detective books.

The members of the Everything Compliance are:

The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network.

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Daily Compliance News

Daily Compliance News: July 25, 2019, the Video Killed the Radio star edition

In today’s edition of Daily Compliance News:

  • FTC orders compliance. Will Facebook comply? (NYT)
  • Video killed the radio star, did Amazon kill retail? (Trump administration says yes). (Washington Post)
  • SFO opens corruption investigation for work in South Sudan. (WSJ)
  • Iraq orders arrests of government officials for alleged corruption. (Kurdistan24)
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Great Women in Compliance

Promoting Public Trust-Amy Mertz Brown, Chief Compliance Officer of the SEC

For a long time, compliance was perceived as a part of the larger legal world. Today, compliance is its own profession — a place where people work tirelessly to make the world a better place, one where doing the right thing is the standard for everyone. There are a lot of amazing and inspirational women who have helped the compliance field develop into what it is today and women who are joining this field every day. They are leading the work on cutting-edge issues and breaking barriers for women. Join Mary Shirley and Lisa Fine as they talk with women in compliance who are making a difference. In today’s episode Mary visits with Amy Mertz Brown, Chief Compliance Officer of the SEC. They discussed her role and how it feels to have the responsibility of the head of the Compliance function for one of the most significant Compliance regulators in the world, her tips for success in technology implementations and her takeaways from spearheading the creation of a compliance function in a start-up federal agency. With her extensive managerial experience in legal and compliance departments, Amy also shared various approaches for addressing difficult stakeholders inside an inherited staff and how she prizes diversity as an important goal when building out her teams.

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Compliance Into the Weeds

Compliance into the Weeds: Episode 132-Internal Control Palooza

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 (the coolest guy in compliance) and I go into the weeds to explore recent SEC enforcement actions which Matt characterized as an “internal control Palooza”. We explore what went askance, how to learn from it and how to prevent it going forward.
Some of the highlights include:

  • The SEC recently had an “Internal Controls Palooza” of enforcement actions.
  • Microsoft demonstrated poor controls over third parties.
  • Why do does units need a ‘second set of eyes’ for non-standard discounts?
  • What is earnings management and why is it so risky?
  • Why do you need robust internal controls when engaging in earnings management?
  • Why must internal controls have an auditable trail?

For further reading on Conn’s see Matt’s blog posts:
Conn’s Lessons on Management Estimatesand
More on Embedding, Automating Controls
For further reading on Microsoft see Matt’s blog post:
FCPA Issues Nick Microsoft $25 Million
Finally see Tom’s blog posts
Part 1-Microsoft FCPA Enforcement Actionand
Part 2-the Bribery Schemes

Categories
Daily Compliance News

Daily Compliance News: July 24, 2019, the ‘I think we’re responsible for something’ edition

In today’s edition of Daily Compliance News:

  • Epstein moved money out of US. (NYT)
  • McKesson compliance chief-“I think we’re responsible for something”. (Washington Post)
  • Facebook settlement requires Zuckerberg to certify compliance. (WSJ)
  • SFO criticized for neglectful culture. (FT)
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Trekking Through Compliance

Trekking Through Compliance-Episode 53 – The Ultimate Computer

In this episode of Trekking Through Compliance, we consider the episode The Ultimate Computer which aired on March 8, 1968, Star Date 4729.4.
Compliance Takeaways:

  1. What is the role of compliance in innovation?
  2. What will be the role of AI in compliance?
  3. How can ComTech improve your operational efficiency?
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Innovation in Compliance

The Mindset of Culture with Arnie Malham


When you think about personal injury lawyers, is the first thing that comes to mind “what great advertising they have”? No? What about “the guys that work with these people must have an amazing company culture”? Also no? Well, today’s guest on the Innovation in Compliance Podcast has some insights that might just change your mind about that. Arnie Malham is a serial entrepreneur with a knack for solving problems – he and Tom discuss what mindset has to do with company culture, and what any of that has to do with personal injury lawyers. 

A Happy Firing
When Arnie was the new guy working at an advertising agency, he kept getting all of the legal accounts dumped on his desk – no one else wanted them! He talks about how his interest in working with these kinds of professionals ended up getting him fired from the agency. That turned out to be a blessing in disguise because he formed his own advertising agency, focusing solely on working with personal injury lawyers. Working closely with these individuals gave him insight into the specific needs and expectations they have for their support vendors, and when Arnie saw a gap in the market, he decided to fill it and formed an entirely new company to provide after-business-hours intake support for personal injury law firms.
Personal Injury Lawyers, Really?
Tom and Arnie discuss the less-than-sterling reputation that personal injury lawyers have both in and outside of the legal world, and how that impacted Arnie’s ability to find and recruit talent to his firm. He needed to create a company culture so strong, so clear and so supportive, that it would overcome the negative perception most people had about the clients. He talks about some of the surprising and interesting ways he was able to do that. Sometimes, people DO cheer for the lawyers – and that’s what he wanted his team to be able to do. 
Mindset and Company Culture
Tom mentions how difficult many new entrepreneurs find it to scale up their organizations – as teams and organizations grow, culture can be watered down. Arnie talks about how over many years of growing his business, making plenty of mistakes along the way, he learned what was required to create strong company cultures not just in his own organization, but for other companies as well. “You can smell culture when you walk in the door” is the foundation of this strategy. Culture permeates a company, and it stems from the leadership of that company. If a leader delegates or abdicates culture, Arnie believes there won’t be one. Leaders must adopt the mindset of the culture they want, model it, and integrate it with the values of the company. He explains how this works, and shares an example of how he was able to keep his own company’s culture strong over several years, and a great deal of leadership turnover. 
Resources
Worth Doing Wrong – learn more about Arnie’s company, and get a copy of his book!

Categories
Daily Compliance News

Daily Compliance News: July 23, 2019, Microsoft settles edition

In today’s edition of Daily Compliance News:

  • Microsoft settles FCPA matter. (FCPABlog)
  • Where were you during the sustainability charade? (CPA Journal)
  • Does Boeing’s legal team give it “a margin of error”? (Bloomberg)
  • Making leaders accountable for worklife balance. (FT)
Categories
Trekking Through Compliance

Trekking Through Compliance-Episode 52 – The Omega Glory

In this episode of Trekking Through Compliance, we consider the episode The Omega Glory which aired on March 1, 1968, Star Date unknown.
Compliance Takeaways:

  1. How well is your staff trained?
  2. How well are your business folks trained?
  3. What is your disciplinary process?
Categories
Daily Compliance News

Daily Compliance News: July 22, 2019, Pickers and Packers edition

In today’s edition of Daily Compliance News:

  • CVS alleged to have used compliance personnel as ‘pickers and packers’. (NYT)
  • Even head of FCA says regs to complicated. (FT)
  • Be careful out there: British Airways and Lufthansa canceled all flights to Cairo. (Washington Post)
  • Lawmakers ask Trump to get out of Pentagon contracting decisions. (Reuters)