In today’s edition of the Daily Compliance News:
Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
In episode 47 of the Great Women in Compliance Podcast, Lisa Fine and Mary Shirley are pleased to feature Sofia El Mansouri, a native of Morocco who has spent many years practicing Compliance in the Middle East.
Sofia outlines for us the current state of the fight against corruption in the Morocco, including ambitions of the National Anti-Corruption Commission to do its part in focusing on Ethics and Compliance.
Sofia also shares the perspective of someone sitting at the desk of a Compliance function in the Middle East and highlights some of the key risk areas as well as give pointers on a couple of key aspects to be aware of to make sure you’re covering adequately if you’re a Compliance Officer outside of the Middle East region but with remit over the area.
As a veritable professional media guru, Sofia kindly shares her recipe for crafting value-add LinkedIn posts that create engagement and facilitate topical discussion as well as give the author solid professional media presence which in turn builds your profile.
Our final thought for the episode is an easy tip that you can implement now at the outset of the year that will not only make your end of year performance appraisal a breeze to complete but also serve as useful preparation for your next job interview.
Join the Great Women in Compliance community on LinkedIn here.
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 indulges me as we take a deep dive into the Houston Astros sign stealing scandal. We mine the episode for compliance and ethics lessons. It turns out there are quite a few.
Some of the highlights include:
Resources
Tom’s five blog posts (to date) in the FCPA Compliance and Ethics Blog.
Part 1-The Scandal
Part 2-Luhnow and Hinch
Part 3-Compliance Lessons
Part 4-Ethics and The Truth of the Game
Part 5–the Whistleblower and Amnesty
The Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance) was very clear about the need for continuous improvement in any compliance program. It stated quite succinctly, “One hallmark of an effective compliance program is its capacity to improve and evolve. The actual implementation of controls in practice will necessarily reveal areas of risk and potential adjustment. A company’s business changes over time, as do the environments in which it operates, the nature of its customers, the laws that govern its actions, and the applicable industry standards. Accordingly, prosecutors should consider whether the company has engaged in meaningful efforts to review its compliance program and ensure that it is not stale.”
This was further specified in the DOJ’s 2019 Guidance which listed three types of continuous improvement, each further refined with multiple attendant questions. It also added a new area of inquiry that every compliance practitioner needs to incorporate into their assessment, improvement and management cycles; culture.
Three key takeaways:
Trysha Daskam has been with Silver Regulatory Services since its inception 18 months ago. She is the in-house expert on Environmental Social Governance (ESG) at Silver and was brought in by founder Fizza Khan (guest on episode 108 of this podcast) to grow the ESG arm of the business. She chats with Tom Fox about how Silver Regulatory Associates helps their clients improve their ESG compliance.
Creating an ESG Program
Trysha defines ESG as a lens through which you comprehensively evaluate the investments that you make. It is often deemed a risk tool because it evaluates a set of environmental, social and governance risk factors that were not typically captured in traditional diligence. Tom asks Trysha to describe the steps a company should take to create an internal ESG program. She responds that companies should start by determining if they already have any ESG-related document that could form the basis of a policy. If not, then there are a few core steps to take:
How ESG Helps You See In The Dark
ESG is increasingly becoming a matter of corporate citizenship, Trysha says. It is a way for a firm to establish how it is acting responsibly towards its clients, employees and community at large. In addition, investors want to see that the ESG policies on paper are actually being implemented, that protective mechanisms were put in place to guard against considered risks. ESG should put a firm in a place where they are less surprised by things that happen, Trysha remarks; it’s another tool to help them see in the dark. Tom comments that it’s a framework to be able to not only analyze questions and manage risks, but also to give answers to multiple stakeholders.
ESG for Investment Firms
Tom asks where an investment firm should start if they want to evaluate their portfolio or potential acquisitions from an ESG perspective. Trysha responds with some questions they should ask:
Resources
SilverRegulatoryAssociates.com
Episode 108 with Fizza Khan
In today’s edition of the Daily Compliance News:
There is nothing like an internal whistleblower report about a compliance violation, the finding of such an issue, or (even worse) a subpoena from the DOJ or notice letter from the SEC to trigger the Board of Directors and senior management attention to the compliance function and the company’s compliance program. Such an event can trigger much gnashing of teeth and expressions of outrage followed immediately by proclamations “We are an ethical company.” However, it may well be the time for a very serious reality check.
Three key takeaways:
In the Episode, I visit with Dave Lefort, Editor in Chief for Compliance Week. Dave recently wrote “It’s hard to tell whether the age we’re living in is the calm before the storm or if it is the storm. One way or another, we’ll likely get some clarity in the year ahead for CCOs navigating these choppy waters.” I asked him to come on the podcast and discuss his 10 predictions on what will dominate compliance headlines in 2020.
Resources
Dave’s article Ten Things We’ll Be Talking About in 2020
Subscribe to Compliance Week here. Use the code, NEWYEAR2020 … for a $365 for a one-year membership.
Register for Compliance Week 2020, here.
In today’s edition of the Daily Compliance News:
In today’s edition of Sunday Book Review:
