Culture is the Foundation with Eric Feldman and Vin DiCianni


As we witness the evolution of work environments in the new normal, what will not change is the importance of building culture. Every successful compliance program takes roots in an organization’s values and principles that determine how employees behave and approach situations. In today’s episode of The Compliance Handbook Podcast, host Thomas Fox is joined by industry experts Vin DiCianni, founder and President of Affiliated Monitors, Inc. (AMI), and Eric Feldman, Senior Vice President of AMI.
✅ Major takeaways discussed in the episode:
✔️  Feldman reminds us that culture is a foundational internal control without which all other controls will fail.  The question is not “why do people commit fraud?” but “why do people comply?”
✔️ Aspire for a culture that motivates rather than just people working for compliance. Incentivize people who make decisions based on ethics and create the kind of environment that makes people want to follow the rules.
✔️ To change an entire company’s culture, you can’t just do it at the top of the organization.Leadership needs to be brought in at different levels of the organization to make it a team approach and effectively apply ethical changes.
✔️ Independent integrity monitors need to be brought in as a third-party assessment to help companies maintain a great culture proactively.
✔️  Be constantly reminded that messaging should be consistently made from the top to the bottom of the organization to establish the culture.
✅ The “Nuts and Bolts” for Creating a Comprehensive Compliance Plan 
This chapter of this unique work lays out a succinct yet thorough one month approach to operationalizing a company’s compliance regimen. Beginning with a section on what 2020 brought to the compliance landscape, each chapter methodically outlines best practices for everything from establishing policies, procedures, and internal controls, to assessing risk, training, handling investigations, and more. Each day ends with three key takeaways you can implement at little or no cost.
✅ Understanding Compliance Responsibility Across the Organization
The Compliance Handbook also takes a close look at all professionals’ roles with compliance responsibility, from Compliance Officers and Boards of Directors to Human Resources, to Internal Audit and Internal Controls and Communications and Training professionals.
✅ In-Depth Treatment of Hot Topics and Trends
The Handbook provides an in-depth look at the latest thinking and trends for the full range of critical compliance topics, including:

  • Compliance and business ventures
  • Third-party risk management
  • The Board’s Role in Compliance
  • Continuous improvement
  • Compliance innovation
  • And much more

✅ Incorporating Current Government Pronouncements
The Second Edition incorporates the most current government pronouncements governing best practices compliance programs, including the 2019 Evaluation of Corporate Compliance Programs released by the Fraud Section of the Department of Justice, and its 2020 Update; the updated FCPA Resource Guide 2nd edition; the Framework for OFAC Compliance Commitments; and the 2019 DOJ Antitrust Division’s Evaluation of Corporate Compliance Programs in Criminal Antitrust.
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