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This Week in FCPA

Episode 196 – the We Won’t Screw You (Again) edition

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As the new Wells Fargo CEO tells Congress that things are really different this time, Tom and Jay reflect on the corporate scandal that may well never end and consider some of the other top compliance articles and stories which caught their eye this week.

  1. Compliance Week has a plethora of articles relating to Wells Fargo. Aaron Nicodemus considers the testimony of Charlie Scharf; Jaclyn Jaeger on Lessons Learned and Board resignations. (Even though a subscription is required for these articles, if you go to Compliance Week site and register for a free account to view four articles at no charge.)
  2. John Wood Group reserves $46MM for anti-corruption settlement. Dylan Tokar in the WSJ Risk and Compliance Journal.
  3. Is unified transaction monitoring a paneca? Sujata Dasgupta explains in CCI.
  4. Is every email a FCPA violation? Bill Steinman asks in the FCPA Blog.
  5. OCC issues some excellent guidance around 3rd Matt Kelly considers in Radical Compliance.
  6. Wow moments in compliance, Part 4. Geert Vermeulen continues his 5-part series in Risk and Compliance Platform Europe.
  7. What are the dangers of a hyper-focused sales culture? Mike Volkov explores in Corruption, Crime & Compliance.
  8. Supply Chain and coronavirus. Global Supply Chain Blog.
  9. Economic crime levy in UK. Jonathan Rausch considers in Dipping Through Geometries.
  10. Banks behaving badly, parts 3088 and 3089. SwedBank and Fifth Third.
  11. On the Compliance Podcast Network, Tom opens a new month by looking at the role of innovation in compliance on 31 Days to a More Effective Compliance Program.This week saw the following offerings: Monday-Compliance capabilities needed to use AI programs; Tuesday-4 practices for delivering an AI solution; Wednesday-Finding compliance patterns in raked leaves; Thursday-Using AI in compliance contracting; Friday-taming complexity in compliance. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. This month’s sponsor is Affiliated Monitors, Inc.

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.

Categories
31 Days to More Effective Compliance Programs

Taming Complexity in Compliance


One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. Whether a corrupt employee is working to actively hide a pot of money, which can or will be used to pay a bribe, or an improper payment slips through the cracks; complexity can work to defeat a best practices compliance program. If a compliance function does not have visibility into a business unit, how it does business and where its payments are going; it may be due to design or inadvertent complexity.
Compliance is now in an era of brisk innovation and evolution. It is prone to technological change and rapid obsolescence of the lawyer-driven, spreadsheet and word document based compliance programs. Going forward the compliance professional needs to understand that a “package of resilience, adaptability, coordination, and inimitability becomes more attractive than the package of efficiency, understandability, manageability, and predictability.” The key is to learn how to harness complexity on a sustainable basis.
Three Key Takeaways:

  1. If a business is too complex for the compliance function to understand; it is in greater danger of illegal or unethical activity.
  2. Taming complexity starts with simple operating principles.
  3. Always remember to fix, repair and prune.

 

Categories
STAKE: The Leadership Podcast

Lay Down the Law with Employees


Today’s employees are much more likely to engage better, stay longer, and perform better for leaders who are invested in their personal and professional goals.
How do you do that?
In today’s episode I’m sharing with you my simple and very effective goal setting process: Lay Down the Law. This process can be used, with a few tweaks, for yourself, even your kids…but today’s focus is your employees.
As you work through this process with your employees, they will see and feel your investment in them and more of than not, they’re going to give that investment back to you tenfold.
Take your leadership results to the next level by laying down the law with your people  today!
———-
If you’re looking for tangible action steps and refreshing insights to help ignite the power of your own leadership journey, sign up for my weekly leadership blog HERE.
If your business would benefit from higher-performing leaders, check out more information about the comprehensive leadership development training I do HERE.
If you want to reach out to me directly, email alyson@vanhooser.com.
If you enjoyed this episode, will you please subscribe and leave a review? Your reviews help this show get discovered by more incredible leaders just like you. I’m obsessed with helping leaders ignite their performance results and I’d love to have you help me make an impact! Thank you so much!
P.S. Share and tag me on social — @AlysonVanHooser — and I’ll share your comments and big takeaways on my feed!

Categories
Daily Compliance News

March 13, 2020-the All Coronavirus edition


In today’s edition of Daily Compliance News:

  • Flying today? (NYT)
  • NCAA bans spectators from March Madness. (WSJ)
  • Tips for working from home. (LinkedIn)
  • Italy locks down country. (FT)
Categories
ComplianceLIVE

ComplianceLIVE Fun-Size Episode 7: The Compliance Officer of the Future


Amanda and Cailyn discuss how compliance actually SAVES your company money, and the traits that a Chief Compliance Officer of the FUTURE must have.
Listen to the episode:

Check out more episodes and full episode videos at ComplianceLine.com, and don’t forget to subscribe on your favorite podcast platform!

Categories
31 Days to More Effective Compliance Programs

Using AI in Compliance Contracting


In the compliance world, consistency is one of the keys to a successful compliance program. One of those areas where consistency is mandated is in contracting. Having consistency in the compliance terms and conditions of any contract is a critical aspect of the compliance professional. While there will certainly be negotiation over a wide variety of terms and conditions, from the financial and payment terms, to the operational terms, to the legal terms, companies need consistency with their compliance terms and conditions. This is particularly true given the paucity of compliance terms which should be put in place.
For the compliance professional this means that less may well slip through the cracks and you will not be in an after the fact position of finding out that your agent or distributor in a high-risk venue does not have an audit clause.
Three Key Takeaways:

  1. AI contracting software can make you contracting process more efficient.
  2. AI contracting software is scalable.
  3. AI contracting software can allow you to move from a detect to preventative mode.

 

Categories
Trekking Through Compliance

Picard-Episode 6, The Impossible Box


Welcome to a special series of Trekking Through Compliance, the podcast series inspired by my review of Star Trek, the Original Series. In this special series I am joined by another uber Star Trek maven, Megan Dougherty, co-founder of One Stone Creative. In this series we will review the new television show Picardwhich is currently streaming on CBS.
SPOILER ALERT-Although we will review each episode after it appears, we will discuss each episode in depth.
Episode 6, The Impossible Box. Soji is experiencing a recurring dream of her childhood. Narek believes that exploring her dream will reveal the location of her homeworld. Aboard La Sirena, Jurati tells Picard Maddox died as a result of his injuries on Freecloud. Raffi persuades a Starfleet contact to issue Picard temporary diplomatic credentials, so the Romulans will let him visit the Artifact and meet with Hugh. Narek continues sowing seeds of doubt with Soji about her identity; she scans her belongings and is shaken to find that none of them are older than 37 months. Narek helps her meditate to explore her dream, while his sister is secretly monitoring the room. In the dream, Soji sees herself as a doll; when she looks up, she sees two red moons and a stormy sky. That is enough for Narek and his sister to start looking for her planet. Narek tries to kill Soji, but she escapes and meets Picard and Hugh. Hugh takes Picard and Soji to an emergency long-distance transportation device, allowing them to escape the Artifact. Romulan guards try to stop them, but Elnor appears and kills them, before staying behind with Hugh to hold off the pursuers.
 Highlights, speculations and questions include: 

  1. Have we been wrong about the Borg all along.
  2. Does Locutus of Borg still exist?
  3. What are some of the cookies in this show?
  4. Is it just a job for Narek?
  5. What are we to make of Hugh? Why did he tell Picard he would do anything for him?
Categories
Daily Compliance News

March 12, 2020-the Banks Continue to Behave Badly edition


In today’s edition of Daily Compliance News:
·       Malaysia names new anti-corruption head. (Bloomberg)
·       Former Wuhan official charged with corruption. (StraitTimes)
·       SwedBank self-discloses. (WSJ)
·       Boeing has new headache: coronavirus. (WSJ)

Categories
12 O’Clock High-a podcast on business leadership

Episode 132-Alyson Van Hooser on Gen Z Leadership Perspectives


Richard Lummis is on assignment this week so I am pleased to host Alyson Van Hooser, who was recently in Houston. We sat down for a live recording about her recent LinkedIn post, “3 Gen Z Perspectives Leaders Need to Know”.
Highlights of this podcast include:

  1. Why are you in Houston?
  2. Why did you write the article?
  3. How is Gen Z leadership different from Boomer leadership?
  4. Why do leaders need to learn from stories from their people, not statistics about them?
  5. How does the style of Gen Z parenting different from that of Gen X (or Boomers) and why is that important to a business leader?
  6. Why do you advise Gen Z leaders not to roll up their eyes but to roll up their sleeves?
  7. Why is connecting fast so important to training and communications?
  8. Why are you so passionate about leadership?

 Resources
Alyson’s weekly leadership blog HERE.
If your business would benefit from higher-performing leaders, check out more information about the comprehensive leadership development training Alyson does training,  HERE.
If you want to reach out to Alyson directly, email alyson@vanhooser.com.
P.S. Share and tag Alyson on social — @AlysonVanHooser

Categories
31 Days to More Effective Compliance Programs

Finding compliance patterns in raked leaves


We previously considered how AI can be used as a business advantage for compliance. The power of AI can extend the more traditional functions of prevention, detection and remediation. The first way is in simply the mass amount of data which could inundate a compliance practitioner. Many compliance practitioners are overwhelmed about the amount of data available to them and do not know how or even where to begin.
Patrick Taylor has said that AI allows the compliance practitioner to understand the “subtle clues in that pattern of activity that will clue me in to take a different look.” He likened it to seeing “patterns in raked leaves” which allows you to then step in and take a deeper and broader look at an issue, either through an audit or investigation. This is where compliance practitioner can step back and literally keep an eye on the big picture and longer term as opposed to just the immediate numbers and information in front of them. It may also be the best hope for finding that kind of systemic fraudulent behavior
Three key takeaways:

  1. Do you know what your information means?
  2. AI can help both the detect and prevent prongs in a best practices compliance program.
  3. AI can help you to see the patterns in raked leaves.