Andrea Falcione and Tricia Cornell of Rethink Compliance, one of the most innovative companies in the compliance space, join Tom Fox in this week’s show. They discuss their compliance journeys, and how content is reshaping the world of compliance.
Their Compliance Journeys
Andrea is a lawyer by profession. In 2004 she transitioned into compliance; she joined Rethink Compliance about a year ago. Tricia comes from the marketing and advertising world. The founder of Rethink, Kirsten Liston, asked her to join the company two years ago to bring her expertise in creating pieces of content to persuade people to think differently about commercial products, into the compliance space.
Content is King
Tom asks the guests to explain what ‘Content is king’ means, and why it’s so important and innovative in compliance. Tricia explains that it means that people are curious: they want to read, listen, and view videos, so compliance experts have to make their content consumable and desirable, and through that get their brand message out there. Andrea says that legal and compliance professionals find this idea difficult because they are essentially risk averse. When they send a message, it’s more about mitigating risk than engaging their audience. However, many organizations are getting negative feedback from their content consumers, so there is a need to create content that is relevant and engaging. This is becoming more and more critical, as regulators are looking at the effectiveness of companies’ efforts.
Building Trust with Content
Andrea and Tricia share a piece of content created by ReThink Compliance in response to the Me Too Movement, is helping to change perceptions. Compliance officers should think about using content in different ways to get people to trust the process and the people involved in it, Andrea says.
A Holistic Approach to Content
Tricia advises that a holistic approach to content starts with reaching your audience where they are. What are their attitudes? What are they looking for from their work? If you start with where they are and understand what they need from you, you’ll reach them more effectively with your message. Always think about how you can make your message relevant to your people. This can help build trust too, Andrea adds. If you think about what your audience needs to hear from you, they will begin to trust you more.
Revamping the Code of Conduct
Tom asks, how or why can a code of conduct revamp be a powerful tool for a compliance practitioner. Andrea responds that the code of conduct is the cornerstone of every compliance program. As such, it needs to be a document that employees actually use, one that is meaningful and resonates with them. It all comes back to thinking about what your audience needs, Tricia emphasizes. If you want the code of conduct to be a resource, then you must think about where and when your people will need it. What questions might they have? How can you answer those questions in a way that’s easy for them to find the information they’re looking for? She points out that you need to make sure that information is easy to find, and written in language that’s easy to understand, so that they can make the right decision in the moment.
Resources
RethinkComplianceCo.com
LinkedIn: Andrea Falcione | Tricia Cornell | Kirsten Liston
Author: admin
In today’s edition of Daily Compliance News:
- Lebanese President bows to anti-corruption fervor. (NBC)
- Softbank rescues WeWork. (WSJ)
- What else haven’t they told us? More trouble for Boeing. (NYT)
- Why we need more storytellers (and less economists)? (Washington Post)
From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Coconuts and how it informs the OFAC Compliance Framework. Highlights from the podcast include:
- Why has Mike Volkov called the OFAC Compliance Framework a ‘game-changer’?
- How does the OFAC Framework illustrate regulatory convergence?
- What are some of the highlights of the OFAC Framework?
- What are some of the key lessons learned for the ABC compliance professional?
- How does data analytics as mandated in the OFAC Framework inform ABC compliance programs going forward?
- What are the mandates built into the OFAC Framework?
- How can an ABC compliance practitioner use the OFAC Framework if their company is under FCPA scrutiny?
Resources
- From Tom Fox-see articles on the OFAC Compliance Framework.
- Introduction
- Management Commitment
- Risk Assessment
- Internal Controls
- Testing, Training and Auditing
- From Mike Volkov-See article on the OFAC Compliance Framework.
- Introduction
- Risk Assessments and Internal Controls
- Testing and Auditing and Training
- Review of Lessons Learned
- Download a copy of the OFAC Compliance Framework, here.
Marx Brothers
Coconuts-the full movie on YouTube.
In this episode I visit with one of my favorite people, Francine McKenna, a reporter at MarketWatch. We check in on the current developments in the KPMG-PCAOB scandal including recent guilty pleas, sentencing and where the matter might finally be headed. Some of the highlights include:
· A review of the Indictment and underlying facts.
· A review of the horrendous facts about KPMG that came out during the March trial.
· What does it say about the PCAOB that two of its former Board members were witnesses for the defense in the trial?
· What did all this mean for KPMG head Lynne Doughtie? What does all this mean for audit independence, particularly in the Jay Clayton era at the SEC?
· Where can listeners go for more information?
Resources
Francine McKenna on MarketWatch
MarketWatch website
Re: The Auditors blogsite
In today’s edition of Daily Compliance News:
- Will the first opioid case go to trial on Monday or settle? (NYT)
- More bad news for Boeing. (WSJ)
- What happens when an investigation gets too close to the BOE? (BBC)
- Is there ‘Hanky Panky’ going on regarding insider trading and the Trump Administration? (Vanity Fair)
In today’s edition Sunday Book Review edition of Daily Compliance News:
- The Demon in the Machine by Paul Davies
- The Cabinet of Liguistic Curiosities by Paul Anthony Jones
- American Warsaw by Dominic Pacyga
- Arthur Vandenberg-Hendrik Meijer
In this podcast series, recovering screenwriter (and Mr. Monitor) Jay Rosen and Tom (the Compliance Evangelist) indulge in passion for the movies by looking at them through the lens of compliance. Jay is a contemporary movie fan and I am more of a classic movie maven so we present a well-rounded view of the movie fandom. If you want to indulge in your love for the movies with two guys who are passionate about Hollywood and get some ideas for your compliance program, this is the podcast series for you. For this offering, we consider the Star Trek-The Motion Picture.
Some of the highlights include:
- Why was the plot so special effects driven?
- Why did the movie take so long to make?
- Did it make money (or not)?
- What are some of the leadership lessons?
- What are some of the compliance lessons?
- Tom gives the Inside Hollywood story of the production.
- Tom gives the movie a full bucket of Popcorn. Jay tepidly gives the movie 1/2 bucket of stale popcorn.
Join us again where in our next episode of Popcorn and Compliance, we consider Star Trek II-The Wrath of Khan.
In today’s edition of Daily Compliance News:
- There’s a reason Mother said don’t tell lies. (Business Insider)
- You shouldn’t even lie unintentionally. (WSJ)
- Pharma CEOs going to the woodshed? (NYT)
- Will SEC move towards more direct listings? (FT)
As Tom revels in the Astros inexorable march towards the World Series, he and Jay reflect on Doobie Brothers nomination to the Rock N Roll Hall of Fame and also discuss some of this week’s top compliance and ethics stories which caught their collective eyes.
1. Is disclosure of a COI enough or should companies go further? Jeff Kaplan.
2. What is the ‘last mile of finance’ and how is it achieved? French Caldwell explains.
3. Ex Credit Suisse bankers to testify in Mozambique corruption case. Patricia Hurtado reports.
4. French anti-corruption agency issues guideline for T&E, in a White & Case client alert.
5. When COIs get people killed. Matthew Stephenson on Trump and his business interests in Turkey.
6. Were Wells Fargo fraudulent accounts tactics used by AT&T? Jaclyn Jaeger explores.
7. Richard Bistrong explains what channel stuffing is, how he used it to make his numbers and why it’s accounting fraud.
8. Is it time for Boards to revisit their compliance obligations? Posted by Robert Biskup, Krista Parsons, and Robert Lamm, opine.
9. Doobie Brothers head (Tom’s) nominations for the 2020 inductees into the Rock N Roll Hall of Fame. Andy Greene reports.
10. This week Jay joins Tom in a five-part podcast series exploring ethical culture in a corporation, sponsored by AMI. Check out the following lineup: Monday-What is Ethical Culture; Tuesday-Factors Influencing Ethical Culture; Wednesday-The Role of the CCO; Thursday – Assessing Ethical Culture; Friday– the Role of Ethical Culture in an Overall E&C Program. The podcast will be available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone, YouTube, Spotify and theCompliance Podcast Network.
11. Popcorn and Compliance is back as Tom and Jay return to take a look at Star Trek-The Motion Picture. Its posts Saturday, October 19 at 7 AM.
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.
Welcome to this special five-part podcast series with Jay Rosen, VP of Business Development for Affiliated Monitors, Inc. (AMI), who is the sponsor of this podcast series. Corporate culture exists in the space between what an organization professes and what it does. In this series Jay and I will be exploring key aspects of corporate culture, including why it matters, what influences culture, the CCOs role in culture, assessing corporate culture and how to use that information to improve culture. In this concluding Part V, we consider how an ethical culture is a part of an overall ethics and compliance assessment.
Highlights include:
- Begin with framework for such an assessment, usually the compliance program itself.
- Is your training both focused and effective?
- Is there institutional fairness in your promotion and compensation programs?
- Is there institutional justice around reporting, discipline and investigations?
- Is your compliance program a paper program or is it fully operationalized?
- Is there accountability in your organization?
For more information see Jay’s blog post How is ethical culture a part of an overall ethics and compliance assessment? on Corporate Compliance Insights.
For more information on Affiliated Monitors, Inc. check out their website here.
