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Adventures in Compliance

The Memoirs of Sherlock Holmes – The Adventure of The Resident Patient

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Memoirs of Sherlock Holmes.” They appeared in the Strand Magazine from December 1892 to December 1893. Over the next 12 episodes, I will be reviewing each story and mine them for leadership, compliance, and ethical lessons.  In this, we look at the story The Adventure of the Resident Patient. 

The Adventure of the Resident Patient” is a captivating Sherlock Holmes murder mystery that delves into themes of truth, justice, compliance, and personal responsibility. Tom Fox, a renowned Sherlock Holmes enthusiast, holds a positive perspective on this adventure. Fox’s appreciation for the story is deeply rooted in the compliance lessons it imparts, such as the importance of trust but verification, due diligence, and personal responsibility. Join Tom Fox in this episode of the Adventures of Sherlock Holmes podcast as he delves deeper into this intriguing investigation. 

Key Highlights

  • The Story
  • Due diligence in business partnerships
  • Trust but verify
  • Internal Reporting and speaking up
  • Role of Dr. Watson

Resources

The New Annotated Sherlock Holmes

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FCPA Compliance Report

FCPA Compliance Report -The Culture Audit™ for Culture Assessments

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Sam Silverstein to talk about the new software product, The Culture Audit™ which allows a compliance professional to perform a culture assessment as required by the Department of Justice.

In the ever-evolving corporate world, the importance of assessing and improving corporate culture cannot be overstated. This is the focus of The Culture Audit™, a software tool that provides a comprehensive assessment of a company’s culture, identifying potential risks and areas for improvement, developed by Sam Silverstein and the Accountability Institute. Tom views The Culture Audit™ as a valuable tool, especially in light of the Department of Justice’s focus on corporate culture in white-collar enforcement actions. He sees culture as a risk that can be assessed, managed, and continuously improved.

Sam shares this perspective and with his extensive experience in accountability and leadership, he emphasizes the importance of regular culture assessments, which can lead to a better bottom line by fostering a culture of high ethics, employee engagement, and quality decision-making. To learn more about the Culture Audit and how it can benefit your organization, join Tom Fox and Sam Silverstein on this episode of the FCPA Compliance Report podcast.

 Key Highlights

  • Culture Assessment and Risk Identification Tool
  • Multilingual Communication Tool for Global Organizations
  • Creating a Data-Driven Workplace Culture
  • The Culture Audit™: Assessing and Improving Workplace Culture
  • Measuring Relational Commitments for Organizational Success

Resources

Culture Audit

Set up a call to discuss the Culture Audit, click here

Sam Silverstein and the Accountability Institute

Sam Silverstein on LinkedIn

 Tom Fox

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Data Analytics: Day 2 – Data-Driven Solutions for Compliance and Risk Management

In today’s rapidly evolving business landscape, compliance and risk management have become critical components of any successful organization. With the increasing complexity of regulations and the growing need for transparency, companies are turning to AI and data-driven solutions to enhance their compliance programs and mitigate risks. A key to this approach is the user adoption of AI-driven compliance tools.

AI and data-driven solutions have the potential to revolutionize compliance and risk management practices. By leveraging advanced analytics, machine learning, and automation, organizations can enhance decision-making processes, improve efficiency, and proactively address compliance risks. However, it is essential to prioritize user adoption, consider the impact on user experience, and strike a balance between automation and human judgment. With the right approach, AI and data-driven solutions can become valuable assets in the pursuit of effective compliance and risk management.

 Three key takeaways:

1. Compliance, risk management and corporate legal can all benefit from a data-driven approach to risk management.

2. By setting up alerts, compliance officers can be notified in real-time about potential risks or non-compliant activities.

3. There will always be the need for a balance between automation and human judgment.

For more information on this month’s sponsor KonaAI, check out their website, here.

Categories
Daily Compliance News

Daily Compliance News: December 4, 2023 – The ABC as Weight Loss Program 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:

  • Mallinckrodt escapes an SEC fine. (SEC)
  • Biden announces Supply Chain Task Force. (Bloomberg)
  • Holiday season=workplace romances? (FT)
  • ABC slims down Chinese fatcats. (The Guardian)
Categories
Corruption, Crime and Compliance

DOJ Settles FCPA Cases with Two UK- Based Reinsurance Companies

In the 300th episode of Crime, Corruption, and Compliance, Michael Volkov examines the recent FCPA settlements with two major UK reinsurance brokers – Tysers and H.W. Wood – for their involvement in a bribery scheme in Ecuador. The DOJ took an unorthodox approach by going after individual people before the companies. This helped them get cooperation and gather evidence, resulting in over $36 million in fines and forfeited money. However, it also highlights common issues in FCPA cases, such as a lack of supervision and effective controls that let corruption happen.

You’ll hear Michael discuss:

  • The settlements with Tysers ($36M fine + $10.5M forfeiture) and Wood ($508K fine + $2.3M forfeiture) resolve a multi-year FCPA investigation in Ecuador.
  • Several individuals were prosecuted first, including the chairman of two state-owned Ecuadorian insurance firms who pleaded guilty in 2020. This allowed the DOJ to build up cooperators and evidence.  
  • A third-party intermediary played an instrumental role, serving as the “glue” that coordinated all aspects of the scheme in exchange for significant profits.
  • Neither Tysers nor Wood voluntarily disclosed. Tysers received a 25% discount for cooperation and remediation; Wood’s fine was reduced to $508K based on inability to pay.  
  • The intermediary demanded a large split of commissions to funnel payments to officials, which Tysers and Wood accepted, triggering disputes among Tysers’ own employees. 
  • The parties used coded language and fake investment contracts to disguise corrupt payments to officials’ offshore accounts.
  • The lack of financial controls and oversight of third-party payment allocations enabled suspicious activity to occur unchecked. Massive “commissions” paid to intermediaries raised obvious red flags that went unheeded.
  • Going after individuals first and securing a declination for one company yielded major penalties for Tysers and Wood, proving the DOJ’s strategy highly effective.
  • The facts underscore the need for vigorous third-party due diligence and monitoring controls to detect and halt potential corruption.

KEY QUOTES

“DOJ has had a slow year in FCPA enforcement. Everybody knows that we may see a few more coming in the next few weeks before the end of the year…” – Michael Volkov

“Unlike most third-party FCPA cases, where a third party may be enlisted to further a bribery scheme by funneling payments directly to a foreign official, the intermediary in the Tysers and Wood cases played an instrumental role in arranging, managing and overseeing the bribery payments and overall scheme. The intermediary company truly operated as the glue that put together a large bribery operation from which it earned significant profits.” – Michael Volkov

“…the timing of the corporate individual resolutions is certainly a unique pattern for DOJ to execute on and certainly raises the prospect that we may see other cases where individuals get prosecuted first and then you see a corporate resolution coming towards the end. So DOJ clearly here built up a reservoir of cooperators and information and intelligence that resulted in them being able to impose significant penalties against Tysers and Wood.” – Michael Volkov

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
Sunday Book Review

Sunday Book Review: December 3, 2023 The Top Thrillers Edition

In the Sunday Book Review, I consider books that would interest the compliance professional, the business executive, or anyone who might be curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me. Over the month of December, we will review some of the best books reported by the Financial Times in various categories. In today’s edition of the Sunday Book Review, we consider the top thrillers from 2023.

  • “Year of the Locust” by Terry Hays
  • “Kennedy 35” by Charles Cumming.
  • “White Fox” by Owens Matthews.
  • “A Line in the Sand” by Ken Powers.

Resource

Best Books of 2023-Thrillers

Categories
Kerrville Weekly News Roundup

Kerrville Weekly News Roundup: December 2, 2023

Welcome to the Kerrville Weekly News Roundup. Each week, veteran podcaster Tom Fox and his colleagues Andrew Gay and Gilbert Paiz get together to go over a couple of their favorite stories from the past week from Kerrville and the greater Hill Country. Sit back, enjoy a cup of morning coffee, and listen in to get a wrap-up of the Kerrville Weekly News. We each consider two of our favorite stories and talk about the upcoming weekend’s events, which we will enjoy or participate in.

In this episode, Tom discusses the following stories that caught their attention over the past week:

  • The potential water war between the City of Kerrville the Headwaters Groundwater Conservation District and the Doyle District’s Glory Community Garden new building. He shouts to Hill Country Swap Meet and Kerr County Market Days, the Farmers Market at River Hills Mall Parking Lot, and the Hill Country Gun Show.

Resources

Tom Fox on LinkedIn

Gilbert Paiz on LinkedIn

Andrew Gay on LinkedIn

Texas Hill Country Podcast Network

The Lead

Kerrville Daily Times

Categories
10 For 10

10 For 10: Top Compliance Stories For The Week Ending December 2, 2023

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes, hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for compliance professionals, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  • The DOJ will use more data-driven enforcement in FCPA cases. (DOJ Press Release)
  • Sam Altman outlines plans for OpenAI going forward. (NYT)
  • Russian soldiers are using bribery to escape combat. (Novaya Gazetta)
  • Will SC gut SEC enforcement? (Reuters)
  • Salt Lake City Olympic corruption scandal, 25 years later (Salt Lake Tribune)
  • Elon Musk tells advertisers who disagree with him to ‘Go-F themselves’. (NYT)
  • The Indonesian anti-corruption chief was fired for corruption. (BBC)
  • Blood renewables in Western Sahara (Forbes)
  • Undercover cop William Casey dies. (NYT)
  • UK defendants say bribes were approved by the UK government. (Bloomberg)

You can check out the Daily Compliance News for four curated compliance and ethics-related stories each day, here.

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Because That's What Heroes Do

Loki, Season 2, Episode 5-Science Fiction

Get ready for an exciting new season of Because That’s What Heroes Do. In it Tom and Megan review Loki, Season 2. In this episode, we discuss the penultimate Episode 5-Science Fiction, taking a deep dive as we move towards the conclusion of this time-bending series.

In the fifth of six episodes of Loki-Season 2, viewers are taken on a journey through the origin stories of various characters, delving into their backgrounds and relationships. This episode not only explores the emotional and spiritual growth of Loki but also highlights his deep desire for family and connection. Tom found the episode intriguing, particularly appreciating the theme of family and growth for Loki. He also notes the development of Loki’s relationship with Sylvie and his newfound hope to save everyone.

Megan expressed delight and appreciation for the episode, praising the portrayal of everyone’s origin story and the significant character development of Loki. She also draws parallels between the emotionally impactful scenes in this episode and those in “Avengers: Infinity War”. Join Tom Fox and Megan Dougherty as they delve deeper into the intricacies of Loki episode five on the Because That’s What Heroes Do podcast.

 

Highlights

  • The Significance of Loki’s Desire for Family
  • Loki’s Journey to Build a Family
  • Loki’s Origin Stories Unite in Emotional Finale

Resources

Megan Dougherty

LinkedIn

One Stone Creative

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Tom

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Career Can D0

AI and The Future of Work with Jonathan Green

AI expert Jonathan Green joins host Mary Anne Faremouth for an in-depth discussion on how artificial intelligence and tools like ChatGPT are transforming careers. Jonathan has a master’s degree in AI from King’s College London and now works as an AI consultant, helping businesses implement AI systems and processes. He shares insights from his book, ChatGPT Profits, on how professionals at any career stage can leverage AI to work more efficiently, free up time, and future-proof their careers in an AI-driven job market. 

 

Jonathan first took notice of AI about two years ago when the quality improved dramatically, especially with the release of ChatGPT version 3.5. He was struck by how readable the content was compared to previous AI-generated text. When he tested the newest AI tools, he found he could customize prompts to get better results than default settings. Jonathan began experimenting with tweaking parameters and sharing techniques with his community, ultimately developing his own formulas and processes to get the most strategic value from AI. He noticed gaps in how others were using the tools and believed drawing on his approach to writing books, courses, and blogs would allow him to use AI in a more optimized way.

Jonathan emphasizes that AI works best in cooperation with humans, not as a replacement. Instead, Jonathan recommends a collaborative working relationship where AI generates drafts and surfaces ideas while humans provide judgment, nuance, ethics, and creativity. He believes this approach enhances human skills and capabilities. Thoughtfully integrating AI to amplify uniquely human traits like strategy, innovation, leadership, and purpose can usher in a new era of productivity and meaning. 

When evaluating where professionals can apply AI in their daily work, Jonathan suggests starting by identifying repetitive tasks that are time-intensive but do not require critical thinking, such as answering routine emails, compiling metrics or status reports from multiple sources, and converting information from one format to another. These mundane administrative tasks are prime for automation so knowledge workers can focus energy on higher-value work. Jonathan shares examples from his own business like using AI to generate show notes from transcript recordings. He emphasizes maintaining quality by reviewing AI-generated drafts before sending them to finalize. The goal is not to eliminate the human but rather change their role from production to oversight, saving time while preserving accuracy.

Mary Anne asks Jonathan how job seekers can leverage AI, specifically ChatGPT, to prepare for upcoming interviews. Jonathan suggests doing mock interviews with ChatGPT customized to the hiring manager and company. He explains that ChatGPT has detailed data on many major companies’ interview practices and also on common interview styles. Users can request mock interviews with ChatGPT while role-playing as the actual interviewer they will be meeting with. He emphasizes customizing questions to the position as this elicits tailored responses from ChatGPT. Rehearsing interview questions ahead of time helps reduce some nerves since expected questions won’t feel as intimidating.

Resources

Jonathan Green on LinkedIn | ChatGPT Profits

Faremouth.com