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Innovation in Compliance

Innovation in Compliance: Lori Darley on Conscious Leadership

Innovation comes in many forms, and compliance professionals need to not only be ready for it but also embrace it.

In this episode, Tom Fox interviews Lori Darley, a former professional dancer and current leadership coach.

Lori shares her career evolution from dance to founding Conscious Leaders, a coaching firm specializing in leadership development. She discusses the principles of self-awareness, personal responsibility, and the clearing process, which are central to her coaching philosophy.

Lori also emphasizes the importance of intentional leadership in fostering a positive corporate culture and touches on her experience in the compliance arena. Additionally, she talks about her book, ‘Dancing Naked,’ which explores her journey and insights as a conscious leader.

Key Highlights:

  • Lori Darley’s Professional Journey
  • What is Conscious Leaders?
  • The Clearing Process Explained
  • Conscious Leaders Wisdom Circle
  • Impact on Corporate Culture
  • Generational Tensions and Coaching Benefits

Resources:

Lori Darley on  LinkedIn 

Conscious Leaders

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Daily Compliance News

Daily Compliance News: June 11, 2024 – The Hands Dirty Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network.

Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

In today’s edition of Daily Compliance News:

  • Beny Steinmetz profile.  (OCCPR)
  • Try being less cynical at work. (WSJ)
  • Moelis director under scrutiny for scuffle. (FT)
  • The court brings racism back into disaster recovery loans. (WaPo)

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: AI Governance Framework

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode, we begin a weeklong look at some of the ways generative AI is changing compliance and risk management. Today, we consider how to approach a comprehensive AI governance framework.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Blog

AI in Compliance Week: Part 2 – A Comprehensive Governance Approach

We continue our weeklong exploration of issues related to using Generative AI in compliance by examining some AI governance issues. In the rapidly evolving landscape of AI, the importance of robust governance frameworks cannot be overstated. The need for comprehensive governance structures to ensure compliance, ethical alignment, and trustworthiness has become paramount as AI systems become increasingly integrated into compliance. Today, we will consider the critical areas of compliance governance and ethics governance and present a holistic approach to mitigating the risks associated with these issues.

MIA AI Governance: The Problems

Missing compliance governance can have far-reaching consequences, undermining the integrity of an entire AI-driven initiative. Businesses must ensure alignment with enterprise-wide governance, compliance, and control (GRC) frameworks. This includes aligning with model risk management practices and embedding robust compliance checks throughout the AI model lifecycle. By promoting awareness of how the AI model works at your organization, you can minimize information asymmetries between development teams, users, and target audiences, fostering a culture of transparency and accountability.

The lack of ethical governance can lead to misalignment with an organization’s values, brand identity, or social responsibility. The answer is that companies should develop comprehensive AI ethics governance methods, including defining ethical principles, establishing an AI ethics review board, and creating a compliance program that addresses ethical concerns. Adopting frameworks like Ethically Aligned AI Design (EAAID) can help integrate ethical considerations into the design process while incorporating AI governance benchmarks beyond traditional measurements to encompass social and moral accountability.

Another outcome of the lack of trustworthy or responsible AI governance can result in unintentional and significant damage. To address this, compliance professionals should help develop accountable and trustworthy AI governance methods that augment enterprise-wide GRC structures. This can include establishing a committee such as an AI Advancement Council or similar structure in your company to oversee mission priorities and strategic AI advancement planning, collaborating with service line leaders and program offices to align with ethical AI guidelines and practices, and developing compliance programs to guide conformance with ethical AI principles and relevant legislation. Finally, implementing AI-independent verification and validation processes can help identify and manage unintentional outcomes.

The Solution

By addressing the critical areas of compliance governance and ethics governance through a more holistic approach, businesses can create a comprehensive framework that mitigates the risks associated with the absence of these crucial elements. This approach ensures that AI systems comply with relevant regulations and standards and align with your company’s values, ethical principles, and the pursuit of trustworthy and responsible AI. As the AI landscape evolves, this comprehensive governance framework will be essential in navigating the complexities and safeguarding the integrity of AI-driven initiatives.

Here are some key steps compliance professionals and businesses can think through to facilitate AI governance in your company:

  1. Establish a Centralized AI Governance Body:
    • Create an AI Governance Council that oversees your organization’s AI strategy, policies, and practices.
    • Ensure the council includes representatives from various stakeholder groups, such as legal, compliance, ethics, risk management, IT, and other subject matter experts.
    • Empower the council to develop and enforce AI governance frameworks, guidelines, and processes.
  2. Conduct AI Risk Assessments:
    • Identify and assess the risks associated with the organization’s AI initiatives, including compliance, ethical, and other compliance-related risks.
    • Prioritize the risks based on their potential impact and likelihood of occurrence.
    • Develop mitigation strategies and action plans to address the identified risks.
  3. Align AI Governance with Enterprise-wide Frameworks:
    • Ensure the AI governance framework is integrated with the organization’s existing GRC and Risk Management processes.
    • Establish clear lines of accountability and responsibility for AI-related activities across the organization.
    • Integrate AI governance into the organization’s broader risk management and compliance programs.
  4. Implement Compliance Governance Processes:
    • Develop and enforce AI-specific compliance controls, policies, and procedures.
    • Embed compliance checks throughout the AI model lifecycle, from development to deployment and monitoring.
    • Provide training and awareness programs to educate employees on AI compliance requirements.
  5. Establish Ethics Governance Mechanisms:
    • Define the organization’s AI ethics principles, values, and code of conduct.
    • Create an AI Ethics Review Board to assess and monitor the ethical implications of AI initiatives.
    • Implement processes for ethical AI design, such as the Ethically Aligned AI Design methodology.
    • Incorporate ethical AI benchmarks and accountability measures into the organization’s performance management and reporting processes.
  6. Implement Reliance-Related Governance:
    • Develop responsible and trustworthy AI governance practices that align with the organization’s enterprise-wide GRC frameworks.
    • Establish an AI Advancement Council to oversee strategic AI planning and alignment with ethical guidelines.
    • Implement AI-independent verification and validation processes to identify and manage unintended outcomes.
    • Provide comprehensive training and awareness programs on AI risk management for employees, contractors, and other stakeholders.
  7. Foster a Culture of AI Governance:
    • Promote a culture of accountability, transparency, and continuous improvement around AI governance.
    • Encourage cross-functional collaboration and communication to address AI-related challenges and opportunities.
    • Review and update the AI governance framework regularly to adapt to evolving regulatory requirements, technological advancements, and organizational needs.

By following these steps, organizations can implement a comprehensive governance framework that addresses compliance, ethics, and reliance-related governance. This framework enables organizations to harness the power of AI while mitigating the associated risks. 

AI Governance Resources

There are several notable resources the compliance professional can tap into around this issue of AI governance practices. The Partnership on AI Partnership on AI is a multi-stakeholder coalition of leading technology companies, academic institutions, and nonprofit organizations. It has been at the forefront of developing best practices and guidelines for the responsible development and deployment of AI systems. It has published influential reports and frameworks, such as the Tenets of Responsible AI and the Model Cards for Model Reporting, which have been widely adopted across the industry.

The Algorithmic Justice League (ALJ) is a nonprofit organization dedicated to raising awareness about AI’s social implications and advocating algorithmic justice. It has developed initiatives such as the Algorithmic Bias Bounty Program, encouraging researchers and developers to identify and report biases in AI systems. The AJL has highlighted the importance of addressing algorithmic bias and discrimination in AI.

IEEE Global Initiative on Ethics of Autonomous and Intelligent Systems is a multidisciplinary effort to develop standards, guidelines, and best practices for the ethical design, development, and deployment of autonomous and intelligent systems. It has produced key documents and reports, such as the Ethically Aligned Design framework, which guides the incorporation of ethical considerations into AI development.

The AI Ethics & Governance Roundtable is an initiative led by the University of Cambridge’s Leverhulme Centre for the Future of Intelligence. It brings together industry, academia, and policymaking experts to discuss emerging issues, share best practices, and develop collaborative solutions for AI governance. The roundtable’s insights and recommendations have influenced AI governance frameworks and policies at the organizational and regulatory levels.

These examples demonstrate the power of industry collaboration in advancing AI governance practices. By pooling resources, expertise, and diverse perspectives, these initiatives have developed comprehensive frameworks, guidelines, and standards being adopted across the AI ecosystem. Compliance professionals should avail themselves of these resources to prepare your company to take the next brave steps in the intersection of compliance, governance, and AI.

Categories
The Ethics Experts

Episode 178 – Sarah Couture

In this episode of The Ethics Experts, Nick and Gio welcome Sarah Couture.

Sarah Couture is a collaborative and strategic compliance professional that brings clients decades of experience. Prior to her compliance career, Sarah held both frontline nursing and clinical management roles in a variety of healthcare settings.

She has since worked with scores of healthcare provider organizations to assess, develop and implement best in class compliance programs.

LinkedIn: https://www.linkedin.com/in/sarah-couture-rn-chc-chrc-chpc-367a4390/

Categories
Riskology

Riskology By Infortal™ Episode 26: Election Risk – How Polls Lie

Welcome to Episode 26 of Riskology by Infortal™ – Election Risk: How Polls Lie. 

In this episode, Dr. Ian Oxnevad and Christopher Mason, Esq., illuminate the complexities and pitfalls that bedevil the world of political polling.

Across the globe, the winds of change are blowing. From the US to the UK and beyond, from pro-business shifts to the rise of populism, the world is in a state of flux. 

With over 50% of the world’s population heading to the voting booth, companies and investors are focused even more heavily on election polling.

However, over-reliance on polling presents risks as polls often fail to provide an accurate prediction of election outcomes. Companies should avoid overrelying on polls in shaping their operational and investment strategies.  

Polling inaccuracies are often attributed to various methodological challenges, including the design of survey questions, the selection of survey participants, and the interpretation of data collected from a subset of the population.

Enhanced technology and societal shifts demand new strategies to gauge public opinion accurately. Pollsters are struggling to keep pace in a world that no longer picks up the phone.

In addition, elections aren’t just political; they’re potential game-changers for your industry. Staying informed can mean the difference between missing out and moving ahead. 

Instead of relying on polling alone, it is best practice to employ multifaceted analysis that incorporates polling insights, along with a comprehensive assessment of political, economic, and social trends. 

We hope you join us for this timely conversation on how your business can prepare for the upcoming election season and avoid the pitfalls of overreliance on polls. 

Resources:

Infortal Worldwide

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Dr. Ian Oxnevad on LinkedIn

Chris Mason on LinkedIn

Categories
Corruption, Crime and Compliance

Third-Party Risks and Sanctions Compliance

With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just the same as FCPA legal requirements. As we embark on a new criminal enforcement era surrounding sanctions violations, companies have to address this issue and do it correctly. 

In this episode, Michael Volkov takes a comprehensive look at third-party risks from the distribution and supply sides and outlines appropriate strategies to manage these risks.

  • Epsilon Electronics serves as a stark reminder of the financial consequences of non-compliance. The company faced an OFAC enforcement action due to a shipment to Iran, resulting in a staggering penalty of over $4 million.
  • Apollo Aviation Group settled with OFAC for $210,600 for leasing aircraft engines, which ultimately ended up being placed in to aircraft of a prohibited entity, Sudan Airways, violating sanctions regulations.
  • ELF Cosmetics settled with OFAC for $996,000 for importing false eyelash kits containing materials sourced from North Korea, highlighting supply chain due diligence failures.
  • The ELF Cosmetics case underscores the crucial role of supply chain due diligence in preventing sanctions violations. Instead of sticking their heads in the sand, companies must undertake basic supply chain due diligence when sourcing products from regions close to high-risk countries or regions.
  • “Reason to know” is now the key phrase guiding the New FCPA era. OFAC does not need to prove goods ultimately end up in a sanctioned country. When you see red flags, you must resolve them or they could be considered a “reason to know” in OFAC’s eyes.
  • Seven essential elements to boost your compliance program and effectively mitigate third-party sanctions risks include risk assessment, varying levels of due diligence, end-user documentation, monitoring, training, and red flag identification.

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
Compliance Tip of the Day

Compliance Tip of the Day: How AI is Transforming Risk Management

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode, we begin a week-long look at some of the ways Generative AI is changing compliance and Risk Management.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

Categories
FCPA Compliance Report

FCPA Compliance Report: Evie Wentink on Making Compliance Training Practical

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this edition of the FCPA Compliance Report,  Tom Fox has a fascinating visit with Iveta (Evie) Wentink, a 15-year compliance veteran. Evie has worked in the public and private sectors and has expertise in compliance training, hotlines, government contract compliance, data privacy, reporting, & due diligence.

Evie has one of the most unique opening lines for hotline training, which is ‘Do You Know Your Hotline Number?” This simple yet incredibly important question encapsulates Evie’s approach to compliance training: make it simple, direct, and practical for the listeners. (Or, as Carsten Tams would say, ‘It’s all about the UX’).

Our conversation focuses on the critical role of hotline numbers in corporate compliance programs, emphasizing the need for employees to know and trust the hotline. Evie shares insights from her career, highlights the significance of marketing compliance hotlines effectively, and discusses the broader culture of compliance and non-retaliation in organizations. She shares practical tips for improving hotline awareness and usage, making this episode a valuable resource for compliance professionals and organizations alike.

Highlights in this Episode:

  • Enhancing Trust through Active Compliance Reporting
  • Promoting Reporting Culture Through Creative Marketing
  • Ethical Culture: Encouraging Compliance Reporting Safely
  • Enhancing Compliance Programs Through Anonymous Hotlines

Resources:

Evie Wentink on LinkedIn

Evie’s Top 10 Compliance Back to Basics

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For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Adventures in Compliance

Adventures in Compliance: Compliance Lessons from The Second Stain, Part 2

Welcome to a review of all the Sherlock Holmes stories that are collected in the work “The Return of Sherlock Holmes.

It is a collection of thirteen detective stories written by Sir Arthur Conan Doyle, marking the reappearance of the brilliant detective Sherlock Holmes after his apparent death in “The Final Problem.” The collection spans various intriguing cases and mysteries that Holmes and his loyal friend Dr. John Watson tackle.

Today we conclude our exploration of the third group of short stories found in The Return of Sherlock Holmes with the second of a two-part look at the final story in this series, The Adventure of the Second Stain.

In the third season of Adventures in Compliance, the podcast reviews Sir Arthur Conan Doyle’s detective stories from ‘The Return of Sherlock Holmes.’ The season, sponsored by Ethico, delves into investigative lessons from Sherlock Holmes’ methods, including thoroughness, critical thinking, attention to detail, persistence, information gathering, and analytical skills.

The current episode analyzes ‘The Adventure of the Second Stain,‘ where Holmes retrieves a potentially catastrophic government document. Key topics include Holmes’ investigative techniques and the application of data analytics in compliance.

Key Highlights:

  • Overview of ‘The Second Stain’
  • Investigative Lessons from ‘The Second Stain’
  • Data Analytics in Compliance
  • Pattern Recognition in Investigations

 Resources:

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ

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