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Compliance Into the Weeds

Compliance into the Weeds: OIG Says CCO Should be Independent

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent OIG guidance for healthcare compliance professionals and healthcare compliance programs which notes that CCOs should be independent from the General Counsel’s Office.

The Office of Inspector General (OIG) has recently released guidelines that underscore the importance of independence for compliance officers in the healthcare sector. These guidelines, seen as a significant development in the field, stipulate that compliance should be separate from legal and finance departments, and outline the responsibilities of healthcare compliance officers.

Tom views this as a clear call for compliance officers to be independent and report directly to the CEO and the board. He suggests that this trend towards independence may extend beyond healthcare. Matt echoes this sentiment, highlighting the OIG’s strong endorsement of the independence of compliance officers. He believes this aligns with the emphasis on independence and autonomy that leading voices in the regulatory world have been advocating for. Join Tom Fox and Matt Kelly as they delve deeper into this topic in this episode of the Compliance into the Weeds podcast. 

Key Highlights:

  • The Importance of CCO Independence in Compliance Programs
  • The role of a healthcare CCO
  • Do you need a Law Degree to be a CCO in Healthcare Compliance
  • The Growing Significance of CCO Independence

Resources:

Matt’s blog post in Radical Compliance

Tom 

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Daily Compliance News

Daily Compliance News: November 15, 2023 – The Two Per Week Edition

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

Stories we are following in today’s edition:

  • Ukraine legislator tied to Giuliani arrested for treason.  (WaPo)
  • 2 sexual harassment claims per week at McDonalds UK (TT)
  • Can Barclay’s move beyond scandal (and Jes Staley)? (FT)
  • US drops antitrust claims over hospital hiring. (Reuters)
Categories
Innovation in Compliance

The Future of Communication in Financial Compliance: Part 3 – Data Analysis and Insight

This week, I have a special five-part podcast series sponsored by Verint on the Future of Communication in Financial Compliance. My guest in this series is Phil Fry, VP and GTM of Financial Compliance Strategy at Verint. Over this series, we will take a deep dive into the current status of communications in financial institutions, how to be or not be compliant, analysis and insight into the area, and how to avoid accentuating the negative and the human element in compliance. In this third podcast, we take a deep dive into data analysis and insights.

Phil Fry, the VP and General Manager of Financial Compliance Strategies at Verint, brings over forty years of experience in the financial compliance industry and a deep understanding of the challenges financial firms face in adhering to regulations amidst evolving communication modes. He specializes in enhancing surveillance systems through data analysis and risk management. His perspective on this topic is shaped by his commitment to bridging the gap between what is captured and what is perceived to be captured, with a focus on proactive compliance.

Fry believes that surveillance teams can make proactive and smarter decisions by utilizing early analytics and risk analysis on captured data, focusing on high-risk conversations. He also emphasizes incorporating additional metadata points, such as time, geography, and communication patterns, to enhance surveillance capabilities. Fry’s initiatives, which include plans to add emotion detection and real-time call translation capabilities, aim to provide valuable data and insights to various corporate disciplines. Join Tom Fox and Phil Fry on this episode of the Future of Communications podcast to learn more about his innovative approach to improving surveillance systems.

Key Highlights:

  • Bridging the Gap: Pre-surveillance Insights
  • Improving Surveillance Efficiency through Data Analysis
  • Uncovering Valuable Intelligence from Spoken Interactions

Resources:

Phil Fry on LinkedIn

For More Information check out Verint.

Categories
Blog

Bridging the Gap: Enhancing Surveillance Systems with Data Analysis

This week I have a special five-part podcast series, sponsored by Verint on the Future of Communication in Financial Compliance on the Innovation in Compliance podcast series on the Compliance Podcast Network. My guest in this series is Phil Fry, VP and GTM of Financial Compliance Strategy at Verint. Over this series, we will take a deep dive into the current status of communications in financial institutions; how to be or not be compliant; an analysis and insight into the area; and how to avoid accentuating the negative and the human element in compliance. In this third post, we consider the topic of improving surveillance systems through data analysis and risk management.

We highlighted the challenges faced by surveillance teams in managing large amounts of data and identifying relevant information. It also emphasized the importance of proactive decision-making and efficient risk response in the face of ever-expanding regulations. One of the key issues discussed in the episode was the overwhelming amount of data that surveillance teams have to deal with. Fry mentioned that surveillance teams often find themselves looking for needles in haystacks, trying to find the data they need among thousands or even tens of thousands of calls in a day. To address this challenge, early analytics and risk analysis can be employed to provide proactive and smarter decision-making processes. By analyzing captured data, surveillance teams can focus on conversations that raise red flags or are deemed high risk, rather than being overwhelmed by the sheer volume of data.

To enhance surveillance systems, Fry suggested implementing “pre-surveillance surveillance” and adding additional metadata points. This includes considering factors such as geography, time, and the technology used during communication. By capturing this additional information, surveillance teams can gain a comprehensive view of spoken interactions, enabling them to respond to incidents and risks more quickly and efficiently. This approach also aligns with the need for compliance with regulations, as non-compliance consequences can be severe, including hefty fines and even imprisonment.

The episode also highlighted the value of insights derived from spoken interactions. Fry emphasized that conversations are a gold mine of information, and with the right transcription and analytic capabilities, valuable intelligence can be extracted. By combining speech and conduct insights into the core capture, compliance officers can have a single pane of glass view of all spoken interactions within their organizations. This includes detecting changes in sentiment, and language switches, and gaining an overview of conversation topics. The solution discussed in the episode has been trained for the financial domain, making it easier for surveillance teams to perform audio reviews and detect possible compliance breaches.

Furthermore, the episode touched upon the wide range of corporate disciplines that can benefit from this data. It is not just limited to compliance and audit teams but can also provide insights into functions such as Chief Financial Officers, strategic risk compliance, and operations. The data collected can be used to gain insights into how solutions are working and aid decision-making processes across various departments.

In conclusion, improving surveillance systems through data analysis and risk management is crucial in today’s regulatory landscape. The challenges of managing large amounts of data and identifying relevant information can be addressed through early analytics and risk analysis. By implementing “pre-surveillance surveillance” and capturing additional metadata points, surveillance teams can gain a comprehensive view of spoken interactions and respond to incidents and risks more efficiently. The insights derived from these interactions can be valuable to a wide range of corporate disciplines, making it a valuable asset for organizations. Continuous monitoring and improvement of surveillance systems are essential to ensure compliance and mitigate risks effectively.

For More Information check out Verint.

Categories
Career Can D0

Tapping Into Your Unconscious to Land Your Dream Job with Alex Morgan

What if you could reprogram your mind to achieve career success? Alex Morgan joins Mary Ann Faremouth on this episode of Career Can Do, to explain how we can tap into the power of our unconscious mind to unlock our limitless potential. Alex is a certified professional hypnotist and author of The Transformative Power of Suggestion. He uses hypnosis and neuro-linguistic programming to help people overcome negative emotions and achieve their goals. In this episode, he explores specific strategies to manage stress, adopt an abundance mindset during your job search, and constantly seek feedback to grow.

Our unconscious mind shapes our beliefs and behaviors. Alex remarks, “Everything begins as a thought. The chair that I’m sitting in, at some point, someone, thought of this in their mind and created this. Everything around us was created by a thought.” By tapping into the unconscious mind through hypnosis and visualization techniques, we can reprogram limiting beliefs and instill empowering suggestions.

Believe that you deserve career success. Holding empowering beliefs helps you build confidence to take risks and put yourself out there during a job search. “When you actually speak to people,” Alex points out, “you have this belief that the people you’re talking to, you’re going to find them interesting, and they’re going to find you interesting as well. And this will help build a lot of beneficial relationships.”

Mastering your mental state is key for performing under pressure during interviews and on the job. Alex recommends relaxation techniques like controlled breathing and autogenic training to relieve stress. He explains that you can reprogram your mind to be relaxed, calm, and motivated in stressful situations, using these strategies. 

Resources

Alex Morgan on LinkedIn | The Transformative Power of Suggestion

Faremouth.com

Categories
31 Days to More Effective Compliance Programs

One Month to More Effective Compliance Through Culture: Day 11 – Psychological Safety in the Middle

Advancing ethical culture through psychological safety can be a powerful tool. But how can you determine the state of psychological safety in your organization? Once again using the article “Fostering Ethical Conduct Through Psychological Safety” as a starting point, “there are a number of things organizations can do to make it more likely that people will speak up when they observe unethical behaviors.” But one key is psychological safety, defined by co-author Edmondson as “a shared belief held by members of a team that the team is safe for interpersonal risk-taking” — or, put another way, that “we can say what we think” or “be ourselves around here.”

There is a non-siloed nature of psychological safety at the workplace. Ethics, risk management, legal and compliance functions, plus HR all share an interest in fostering such an environment. This mandates a cross-functional approach as an essential requirement of molding an organization’s culture to include psychological safety. The authors believe, “Managers throughout a company must become aware of the blind spots created by a psychologically unsafe environment, along with the associated risk of underreported misconduct.” They also caution that a formal program such as a reporting hotline “may capture only a fraction of the problematic behaviors that occur.” This leads the authors to posit that gauging psychological safety “may help companies determine whether misconduct is being reported and, in turn, enhance the effectiveness of their formal speak-up programs.”

The authors also confirmed a greater problem which is that “in a global context, psychological safety is not uniform across nations.” Survey respondents from “the Americas and Europe tended to score higher on psychological safety than respondents from Asia.” This suggests to the authors that “the potential effectiveness of tailoring interventions that promote speaking up in order to address the specific circumstances of different groups of employees.” Moreover, “global organizations that seek to build psychological safety must assess its various region-specific drivers and derailers to adjust their activities to specific seniorities and cultures.”

 Three key takeaways:

1. How can you determine the state of psychological safety in your organization?

2. Psychologically safety at the workplace is non-siloed.

3. Middle managers are critical.

Do you want to improve your culture? How can you assess your culture and develop a strategy to improve it going forward? In this free webinar on the new tool, The Culture Audit with Tom Fox and Sam Silverstein on Tuesday, November 28, 12 CT. For more information and registration, click here.

Categories
Principled Podcast

Principled Podcast – S10E10: What are the E&C Priorities for Companies in the Middle East?

What you’ll learn on this podcast episode

In the nearly 10 years of running our annual program effectiveness research, LRN has had the good fortune to discuss trends in E&C with leaders from across the world. The Middle East is one such region. How do business practices differ in this region compared to other parts of the world? Who are the like-minded professionals that E&C leaders can connect with in the Middle East? In this episode of LRN’s Principled Podcast, host Amy Hanan is joined by Elvis Angyiembe, the co-founder of the Middle East and Africa Compliance Association (MEACA). Listen in as they discuss Elvis’s experience working in the Middle East for various multinational companies, what led him to start MEACA, and what the E&C priorities are for companies in the Middle East. 

Are you an E&C professional based in the Middle East? Take this 10-minute survey and share your experiences for LRN’s 2024 E&C Program Effectiveness research. Results will be published in February.

Guest: Elvis Angyiembe

Elvis Angyiembe – Grayscale

Elvis Angyiembe is co-founder and co-chair of the Middle East and Africa Compliance Association (MEACA). He has significant experience working for multinational companies helping them manage significant legal and compliance matters. He has supported three companies under deferred prosecution agreements with the US Department of Justice. He has lived in Cameroon, Germany, US, South Africa, and currently in Dubai. He holds a Juris Doctorate (JD) from Thurgood Marshall School of Law in Houston, Texas, and a bachelor’s degree in criminology from the University of Maryland in College Park, Maryland.

Host: Amy Hanan

Amy Hanan – Grayscale

Amy Hanan is the chief marketing officer at LRN. A B2B digital marketing leader, Amy has a nearly 20-year track record in product, brand, lifecycle, and demand-generation marketing as well as corporate communications for media, professional services, and technology companies. One of her central areas of expertise is executing tech-enabled marketing initiatives for growth. Before joining LRN, Amy was the chief digital officer at Baretz+Brunelle, a marketing and communications agency serving the legal and financial services industries. Her previous experience includes Reorg Research, ALM Media, and The Associated Press. She holds a Bachelor of Arts degree from Northern Arizona University.

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Daily Compliance News

Daily Compliance News: November 14, 2023 – The Supreme Court 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.

Stories we are following in today’s edition:

  • The Supreme Court issued its first-ever Ethics Code. (WSJ)
  • Chinese corruption in Nepal? (NYT)
  • The FDIC hires a law firm to investigate allegations of a toxic workplace. (FT)
  • The law firm said it didn’t know the partner was living with the judge. (Reuters)

 

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 10 – Improving Culture Through Investigations

Meric Bloch strongly emphasizes the importance of workplace investigations and fostering a culture of employee compliance. He believes that merely setting up a hotline and establishing policies is insufficient; companies must actively engage with employees to understand their motivations for speaking up or remaining silent. Bloch also underscores the need for accountability and a critical evaluation of the effectiveness of compliance programs. His experiences with multinational companies have shaped his understanding of the challenges they face, particularly the fear of being perceived as incompetent and the difficulties in reporting.

One of the key points raised by Bloch is the importance of making speaking meaningful and credible. He pointed out that companies often fail to communicate what should be reported, leading to confusion among employees. Bloch also highlights the lack of follow-up interviews and training for reporters as a problem. He stressed the need for organizations to engage with reporters and gather additional information to better understand the context and potential gaps in the initial report. Bloch also discussed the importance of addressing friction points within organizations. He mentioned that employees often hesitate to speak up due to concerns about the involvement of headquarters or fear of retaliation. Organizations must actively address these concerns and create an environment where employees feel safe and supported when reporting issues.

To create a culture of speaking up, organizations must move beyond passive measures such as hotlines and policies. They need to actively engage with employees, educate them about their role in the process, and provide clear guidance on what should be reported. By doing so, organizations can foster a culture of compliance where employees feel empowered to speak up and contribute to maintaining ethical standards.

Three key takeaways:

1. Your investigation process must go beyond simple policies and procedures.

2. Seeking additional information from a reporter will enhance the investigative process and your culture.

3. Remove friction points in the speak-up and investigative processes.

Do you want to improve your culture? How can you assess your culture and develop a strategy to improve it going forward? In this free webinar on the new tool, The Culture Audit with Tom Fox and Sam Silverstein, on Tuesday, November 28, 12 CT, For more information and registration, click here.

Categories
Innovation in Compliance

The Future of Communication in Financial Compliance: Part 2 – To Be or Not To Be Compliant

This week, I have a special five-part podcast series sponsored by Verint on the Future of Communication in Financial Compliance. My guest in this series is Phil Fry, VP and GTM of Financial Compliance Strategy at Verint. Over this series, we will take a deep dive into the current status of communications in financial institutions, how to be or not be compliant, analysis and insight into the area, and how to avoid accentuating the negative and the human element in compliance. In this second podcast, we consider how to be compliant.

Phil Fry, the VP and General Manager of Financial Compliance Strategies at Verint, brings over forty years of experience in the financial compliance industry and a deep understanding of the challenges financial firms face in adhering to regulations amidst evolving communication modes. He believes the shift towards these models has increased the need for digital compliance solutions, as communication and collaboration have become predominantly digital.

Fry emphasizes the importance of capturing data from Unified Communications (UC) tools and enhancing them with AI-based features to support businesses in maintaining compliance. He introduces the concept of “human compliance,” which involves monitoring a regulated user’s interactions across channels and locations to prevent misconduct. Fry’s perspective is shaped by his experience at Verint, where he saw the company’s investment in AI technology to enhance compliance features. Join Tom Fox and Phil Fry on this episode of the Future of Communications podcast to learn more about the need for comprehensive and proactive digital compliance solutions in the context of hybrid work models.

Key Highlights:

  • The Impact of Hybrid Working on Business and Compliance
  • Revolutionizing Communication Capture in the Digital Age
  • Verint’s Comprehensive Financial Markets Website

Resources:

Phil Fry on LinkedIn

For More Information check out Verint.