Categories
Blog

What Data to Ask For and How to Ask for It

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. KonaAI is the sponsor of those podcasts. This blog post series will flesh out the podcast show notes over the next five blog posts, and we will discuss generative AI and ChatGPT in compliance, the profiles of a corrupt payment, making the business case for data-driven compliance, what to ask for and how to ask for it and some success stories. In Part 4, we will explore what data to ask for and how to ask for it.

As always, I am joined by Vince Walden, founder and CEO of KonaAI. There is a quiet revolution happening in the realm of compliance. It’s one that, if harnessed correctly, can turn a typically reactive process into a proactive strategy. I am, of course, talking about data-driven compliance. By using the vast amounts of data your organization collects, you can uncover potential compliance risks before they become actual problems. This approach can be a game-changer for your role as a compliance officer and your organization’s overall risk management strategy. No longer will you be caught off guard. Instead, you’ll lead the charge with real-time insights and actionable data.

Imagine a world where compliance isn’t a headache but a strategic advantage. You’re not constantly putting out fires but predicting and preventing them. It might sound like a dream, but it doesn’t have to be. How so? Well, by adopting a data-driven approach to compliance. This innovative method allows you to identify, assess, and manage potential compliance risks based on actual data. It’s about staying one step ahead, making informed decisions, and truly adding value to your organization. It’s not just about avoiding penalties and meeting regulations anymore. It’s about creating an environment of continuous improvement and proactive risk management.

Let’s paint a picture. You’re in a game of chess. But in this game, you’re not just reacting to your opponent’s moves. You’re anticipating them, strategizing, and making proactive decisions. That’s the power a data-driven approach to compliance can bring to your role as a compliance officer. It’s more than just crunching numbers and keeping up with regulations. It’s about leveraging the power of data to identify and mitigate risks before they materialize. It’s about transforming compliance from a cost center into a strategic asset. So, if you’re curious about how to make this data-driven shift, buckle up because we’re about to dive deep into this transformative realm.

Compliance monitoring and risk assessment are crucial components of any effective compliance program. In a recent episode of the podcast “Data Driven Compliance,” hosted by Tom Fox and featuring Vince Walden, the topic of continuous compliance monitoring and risk assessment process was explored in depth. This article aims to comprehensively analyze the critical factors that impact this process, discuss the tradeoffs involved in balancing different factors, and explore the challenges associated with other approaches.

Vince highlighted the importance of starting with a fraud risk assessment. This initial step allows organizations to identify high-frequency and high-impact risks and implement mitigating controls. Compliance professionals can prioritize their efforts and focus on the most critical areas by assessing the likelihood and impact of various risks on a scale of one to ten.

Data sources play a crucial role in risk assessment. Financial accounting systems and third-party data are valuable sources of information for identifying and mitigating risks. Tracking and categorizing expenses in accounting systems is significant for identifying anomalies and assigning risk scores. Vince highlighted the significance of having a centralized system, such as the Kona platform, to streamline this process.

However, relying solely on analytics without integrating them into the fraud risk assessment would be best. He emphasized the need for alignment between data analysis and risk assessment to ensure efforts are focused on addressing the identified risks. Simply conducting data analytics without considering the underlying risks may not yield meaningful results.

One of the challenges in continuous compliance monitoring and risk assessment is the availability and accessibility of data. Some data sources may need help, requiring compliance professionals to prioritize based on the ease of data acquisition and its value. For example, if faced with choosing to conduct a data analytics project in Brazil or China, Walden suggested starting with Brazil due to the relative ease of obtaining data from that region.

Another challenge lies in the scope of compliance monitoring. Walden emphasized that compliance monitoring is not a one-time, all-encompassing effort. It is a journey that involves proactively assessing risks and monitoring them from location to location. Compliance professionals should focus on demonstrating continuous improvement rather than tackling all threats at once. This approach aligns with regulators’ expectations of an effective due diligence program.

In addition to the primary focus on risk assessment, Walden highlighted the importance of considering ancillary areas of inquiry. For instance, looking at places such as charitable donations or marketing spending can provide valuable insights into potential risks of bribery or corruption. The KonaAI tool can help correlate these ancillary data points and provide a more comprehensive view of compliance risks.

In conclusion, continuous compliance monitoring and risk assessment require a thoughtful and balanced approach. Organizations can identify and prioritize risks, starting with a comprehensive fraud risk assessment. Data sources, such as financial accounting systems and third-party data, play a crucial role in this process. However, aligning data analytics with the identified risks is essential to ensure meaningful results. Compliance professionals should also consider the data availability challenges and scope of compliance monitoring. Organizations can meet regulatory expectations and enhance their compliance programs by demonstrating continuous improvement and considering ancillary areas of inquiry.

Resources:

Connect with Vince Walden on LinkedIn

Check out KonaAI

Connect with Tom Fox on LinkedIn

Categories
Riskology

Infortal on Global Risk Outlook: Part 3 – Dr. Ian Oxnevad on Russia and Ukraine

“If you’re fighting off a major world power, corruption will not be on your plate. You’re going to be looking at trying to keep domestic production up and national solidarity at high levels,” says Dr. Ian Oxnevad, returning guest on this installment of the Riskology special series. Dr. Ian Oxnevad and Tom discuss the geopolitical risk landscape between Russia and Ukraine.

Dr. Ian Oxnevad is the Director of Geopolitical Risk Intelligence for Infortal Worldwide, with a background in political science and national security studies. He is also the host of The Riskology Podcast.

You’ll hear Ian and Tom discuss:

  • The impact of the Russia-Ukraine war, as well as the implications counteroffensive measures may have on both countries. 
  • Companies may face risks in doing business with Russia as they violate sanctions. Ian also discusses the proxy war between Russia and the West and between China and the West.
  • The shrinking European economy is due to higher energy costs and the impact of food supplies in other parts of the world. 
  • The risks of corruption in Ukraine.
  • How China is playing a role in filling the void left by Western investment and the need for due diligence in the post-war business landscape
  • There is potential for a “rush” of people and companies looking to capitalize on the efforts to rebuild Ukraine. This can present a potential risk in terms of corruption for Ukraine.

Resources

Infortal Worldwide | Email | Tel: 1.800.736.4999 | Podcast

Categories
Data Driven Compliance

The Uses of Data Driven Compliance: Part 3 – Making the Business Case for Data Driven Compliance

Welcome to Data Driven Compliance. In this podcast, we discuss how to use data to improve and enhance the effectiveness of your compliance program, creating greater business efficiency, all leading to more return on investment for your compliance regime. Join host Tom Fox as he explores how data will drive your compliance program to the next level. This podcast is sponsored by KonaAI.

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. Over these five podcasts, we will discuss generative AI and ChatGPT in compliance, the profiles of a corrupt payment, making the business case for data-driven compliance, what to ask for and how to ask for it, and some success stories. Part 3 discusses how to make the business case for data-driven compliance.

Vince Walden, a seasoned professional with over 25 years of experience in compliance and risk management, is the founder and CEO of KonaAI, a software company specializing in automating data management for compliance and fraud risk management. Walden believes that compliance professionals play a crucial role in data-driven risk management. He emphasizes the need for these professionals to make a business case for data-driven compliance to both risk professionals and the CFO or head of operations.

According to Walden, data-driven compliance not only aligns with regulatory expectations and avoids risks, but it also improves the overall functioning of the business by identifying hidden money, reducing costs, eliminating waste and fraud, and preventing improper payments. His perspective is shaped by his extensive experience in the field, including his work as a consultant, fraud investigator, and forensic technologist. Join Tom Fox and Vince Walden as they delve deeper into this topic on this episode of Data Driven Compliance.

Key Highlights:

  • The Importance of Data Driven Compliance
  • Effectively Conveying Compliance Value to CFOs
  • The Impact of Data Driven Compliance
  • Maximizing Compliance ROI through Risk Mitigation

Resources:

Connect with Vince Walden on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

Categories
31 Days to More Effective Compliance Programs

One Month to More Effective Written Standards: Day 7 – Policies and Procedures

There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the government comes knocking. The 2020 Update made clear that “Any well-designed compliance program entails policies and procedures that give both content and effect to ethical norms and that address and aim to reduce risks identified by the company as part of its risk assessment process.”

This statement made clear that the regulators will take a strong view against a company that does not have well-thought-out and articulated policies and procedures against bribery and corruption, which are systematically reviewed and updated. Moreover, having policies written out and signed by employees provides what some consider the most vital communication layer and acts as an internal control. Together with a signed acknowledgment, these documents can serve as evidentiary support if a future issue arises. In other words, the “Document, Document, and Document” mantra applies just as strongly to policies and procedures in anti-corruption compliance.

The specific written policies and procedures required for a best practices compliance program are well-known and long-established. According to the 2020 FCPA Resources Guide 2nd edition, some of the risks companies should keep in mind include the nature and extent of transactions with foreign governments (including payments to foreign officials), use of third parties; gifts, travel, and entertainment expenses; charitable and political donations; and facilitating and expediting payments. Policies help form the basis of expectations for standards of conduct in your company. Procedures are the documents that implement these standards of conduct.

Three key takeaways:

1. Written compliance policies and procedures, together with the Code of Conduct, form the backbone of your compliance program.

2. The DOJ and SEC expected well-thought-out and articulated compliance policies and procedures to be adequately communicated throughout your organization.

3. Institutional fairness for the application of policies and procedures demands the consistent application of your policies and procedures across the globe.

For more information, check out The Compliance Handbook, 4th edition, here.

Categories
Blog

Geopolitical Risks and Business Opportunities: Part 3 – Russia and Rebuilding Ukraine

I recently had the opportunity to visit with Dr. Ian Oxnevad, Director of Geopolitical Risk Intelligence at Infortal Worldwide. Global Risk Review, a podcast series that Infortal Worldwide sponsors was the reason for this visit. Dr. Oxnevad is a seasoned expert in geopolitical risk intelligence, with a Ph.D. in political science and a master’s degree in National Security Studies.

Over this five-part blog series, we will look at the risk profile for US Companies doing business in the following geographic regions: the Middle East, Latin America, Russia and Ukraine, Africa, and the Asia Pacific region. Over this five-part blog post series, we will review Dr. Oxnevad’s views in each one of these regions. Part 3 reviews the business opportunities and risks in Russia and the challenges and opportunities in rebuilding Ukraine.

Dr. Oxnevad deeply understands the issues in Russia and Ukraine. His belief that the upcoming rebuilding of Ukraine will spark a surge of interest from significant US corporations, the EU, and China, potentially resulting in increased corruption and geopolitical risks, shapes his perspective on the global implications and geopolitical risks. Oxnevad emphasizes the need for ongoing due diligence and monitoring by Western companies to navigate potential challenges and uncertainties, such as changes in laws and competition from different countries. He also acknowledges the significant risk of corruption in Ukraine, especially during the rebuilding process, and believes it may take time for EU institutions to mitigate this risk.

The war between Russia and Ukraine has had far-reaching consequences, not only for Europe but also for other parts of the world. Indeed, it has changed business across the globe forever.

One of the key factors to consider is the impact on global food supplies. Russia and Ukraine are major food and grain suppliers, and the war and sanctions have disrupted their production. This has put food supplies at risk, increasing food costs and inflationary pressures worldwide. Countries in Africa and the Middle East, in particular, heavily rely on these food supplies, and the uncertainty surrounding Ukraine’s ability to meet these demands raises concerns.

The rebuilding of Ukraine presents significant opportunities for major corporations from the United States, the European Union, China, and other countries. However, it also raises concerns about corruption and geopolitical risks. Ukraine has been traditionally viewed as a high-risk country for corruption, and the war has only exacerbated this issue. The chaos and emergency in the country create a greater incentive for corruption to exist. President Zelensky’s ability to address these concerns remains to be determined, and it is unlikely that corruption will disappear even if the war were to end abruptly.

From a geopolitical standpoint, the war between Russia and Ukraine has become a proxy war between Russia and the West and China and the West. This further complicates the situation and introduces additional risks. The resolution of the war and the lifting of sanctions will depend on various factors, including Russia’s political landscape and the leadership of President Putin. If Putin remains in power, the sanctions will likely stay in place. However, if there is a change in leadership, lifting sanctions could be a possibility, albeit with careful consideration of Russia’s economic and political landscape.

The rush to capitalize on Ukraine’s rebuilding presents both opportunities and risks. Many countries and corporations will be vying for a stake in Ukraine, increasing the incentives for corruption and other geopolitical risks. Competitors will be aware of the presence of different countries, further complicating the situation. It is crucial for American companies and others to carefully assess the risks associated with corruption in Ukraine and conduct thorough due diligence before engaging in business opportunities.

The international community, including the European Union, NATO, and the United Nations, may play a role in assisting Ukraine in its rebuilding efforts. Establishing the rule of law, policies, and procedures will ensure a successful reconstruction. However, the timing of international involvement is crucial. Rebuilding efforts must occur before existing EU institutions move in to address corruption, as this will help mitigate the associated risks.

In conclusion, rebuilding Ukraine has significant global implications and geopolitical risks. The disruption of food supplies, the rush to capitalize on opportunities, and the challenges associated with corruption must be carefully considered. The resolution of the war and the lifting of sanctions depend on various factors, including Russia’s political landscape. International assistance in rebuilding efforts, particularly in establishing the rule of law, will be crucial. However, it is essential to conduct thorough due diligence and assess the risks before engaging in business opportunities in Ukraine.

Please join us tomorrow when we explore geopolitical risks and business opportunities in Europe.

You can check Dr. Oxnevad in the full five-part Riskology podcast series here.

Categories
Daily Compliance News

Daily Compliance News: September 13, 2023 – The Dirty Deeds 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.

  • Businesses should disclose China risks. (WSJ)
  • DOJ ramps up National Security enforcement resources. (WSJ)
  • No timeline for climate disclosure from SEC. (WSJ)
  • New pod on corruption. (Dirty Deeds)
Categories
Compliance Into the Weeds

Compliance into the Weeds: Failure to Have Effective Compliance Program

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent DOJ enforcement action involving Verizon Business Network Services for failure to have an effective cyber security compliance program.

The recent case of Verizon’s non-compliance with cybersecurity standards and subsequent remediation efforts has sparked a significant conversation in the realm of cyber compliance. Tom views this case as a roadmap for companies to enhance their cybersecurity programs, emphasizing the importance of gap analysis and pressure testing. He draws parallels between cybersecurity compliance and the Foreign Corrupt Practices Act (FCPA) compliance, suggesting that Verizon’s case could serve as an example for other companies.

Matt applauds Verizon’s voluntary self-disclosure and extensive remediation efforts. He underscores the importance of disclosure, cooperation, and remediation in both cybersecurity and corruption cases, viewing Verizon’s actions as a positive example for other companies. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast. 

Key Highlights

·      Verizon’s Cybersecurity Program Failures

·      Enhancing Cybersecurity Compliance through Remediation Measures

·      Automating Compliance Efforts with GRC Tools

·      Potential Penalties for Non-Disclosure of Cybersecurity Issues

 Resources

Matt in LinkedIn

Matt on Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Blog

Making the Business Case for Data Driven Compliance

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. KonaAI is the sponsor of those podcasts. This blog post series will flesh out the podcast show notes. Over the next five blog posts, we will discuss generative AI and ChatGPT in compliance, the profiles of corrupt payments, making the business case for data-driven compliance, what to ask for and how to ask for it, and some success stories. Part 3 will discuss making the business case for data-driven compliance.

Vince Walden, the CEO and founder of KonaAI, is here with me as always. Walden pointed out a dual aspect to this, bringing risk and financial perspectives into play. The risk perspective aligns with meeting expectations from the Department of Justice, SEC, or other regulatory bodies, which include culture alignment and prudent data handling. The financial end deals with a knock-on effect of compliance: a potential improvement in financial performance by curtailing revenue leakage through fraud and improper payments. This is what compliance professionals do every day. In regulated industries, however, it is not simply about convincing others of the necessity. It is also about aligning the company’s tools and methods to meet the expectations of external regulatory bodies. In an ideal world, a company’s compliance goals should align with its business goals. But achieving this balance is easier said than done.

While regulatory compliance is important, businesses are about generating revenue and turning a profit. Balancing compliance with profitability can often seem like a tightrope walk. But businesses need to realize that this balance is possible and beneficial in more ways than one. Compliance and profitability could coexist with the help of a business-savvy compliance tool. Compliance professionals need to distance themselves from a narrow focus on policies and enforcement. A broader perspective, including understanding the importance of data-driven metrics and business context, can position these professionals as valuable contributors to an organization’s bottom line. Yet Walden warned against complacency, saying that professionals who only focus on regulation and leave the business aspect by the wayside can find themselves marginalized.

Increasingly, companies realize the value of having multiple perspectives at the decision-making table. While finance and internal audit have always been pivotal, including compliance in these discussions provides a more rounded view. This broad-based approach can unlock novel insights into operational efficiency, risk mitigation, and more. The dialogue between compliance, finance, and procurement has been improving. Industries like telecommunications, oil and gas, technology, and pharmaceuticals are leading this change, recognizing the value of integrated discussions. Vince stresses the need for transparency in transactions that pose risks to the organization and sees compliance professionals playing a significant role in these discussions.

One of the greatest challenges of being a compliance professional is speaking the language of the CFO and financial stakeholders. Convincing them about the monetary benefits of compliance involves more than just throwing around regulation jargon – it requires the ability to present your case strategically. Compliance professionals understand their audience and tailor their discussions accordingly. He advises professionals to focus on how data-driven compliance can save money, improve efficiencies, and prevent improper payments. This is how to get the CFO and other financial stakeholders on board and win them over with the business case for compliance.

Walden emphasizes the importance of understanding the CFO’s financial language to argue for effectively implementing data-driven compliance. Compliance professionals must demonstrate the return on investment and the success of compliance and fraud risk management programs. Key performance indicators such as dollar recoveries and risks avoided can be used to measure the impact of data-driven compliance. Walden also highlighted the significance of finding hidden money and stopping improper payments before they occur. By utilizing data-driven metrics, compliance professionals can identify the riskiest transactions and prevent fraud, waste, and abuse. This not only aligns with the DOJ’s expectations but also improves the overall functioning of the business.

Also of significance is the role of compliance professionals in finance and procurement. More and more companies are recognizing the need to have compliance professionals at the table when making financial decisions. Compliance professionals must be able to speak the language of CFOs and help them understand the importance of compliance in reducing costs, eliminating waste, and preventing improper payments.

To make a compelling business case, compliance professionals should focus on the financial benefits of data-driven compliance. For example, if a company disburses hundreds of millions or billions of dollars in accounts payable payments to third parties, implementing a risk scoring system can help identify the top ten riskiest transactions at risk for fraud, waste, and abuse. The company can recover millions of dollars by investing a relatively small amount, such as $200,000, resulting in a significant return on investment.

It is also important for compliance professionals to collaborate with finance, procurement, and internal audit teams. The Association of Certified Fraud Examiners (ACFE) and COSO collaborated on writing the COSO Fraud Risk Management Guide, which offers useful advice for running a fraud risk management program. The principles outlined in this guide align with the DOJ’s guidance on effective compliance programs. Compliance professionals should take the initiative to engage with CFOs, heads of accounting, and heads of internal audit to foster collaboration and ensure compliance efforts are aligned with overall business objectives.

Compliance professionals play a vital role in data-driven risk management. By making a compelling business case for data-driven compliance, they can demonstrate the financial benefits, such as preventing fraud, improving cash flow, and uncovering hidden funds. Collaboration with CFOs and other key stakeholders is crucial to ensure compliance efforts are integrated into overall business strategies. Compliance professionals must continue to adapt and evolve their understanding of finance and procurement to effectively communicate the importance of data-driven compliance in mitigating risks and driving business success.

Finally, remember that data-driven compliance can improve financial performance and ROI. By harnessing the power of data to inform compliance activities, professionals in regulated industries can effectively navigate complex regulatory landscapes, minimize risks, and optimize business operations. The steps in making a business case for data-driven compliance lay the foundation for success, enabling professionals to leverage data insights, drive informed decision-making, and, ultimately, drive better business outcomes. Embrace data-driven compliance and unlock the potential for improved financial performance and ROI—within your reach.

 Resources:

Connect with Vince Walden on LinkedIn

Check out KonaAI

Connect with Tom Fox on LinkedIn

Categories
Riskology

Infortal on Global Risk Outlook: Part 2 – Dr. Ian Oxnevad on Latin America

“From a due diligence and geopolitical risk intelligence standpoint, Mexico and Latin America in general don’t get enough attention because a lot of people in the political world view Latin America as off to the sidelines from major events around the world but it’s anything but,” says Dr. Ian Oxnevad, returning guest on this installment of the Geopolitical Risk Series of Riskology. He and Tom discuss in this episode the risk landscape of Latin America, and how companies can navigate them.  

Dr. Ian Oxnevad is the Director of Geopolitical Risk Intelligence for Infortal Worldwide, with a background in political science and national security studies. He is also the host of The Riskology Podcast. 

 

You’ll hear Ian and Tom discuss:

  • The rise of authoritarianism, corruption and a greater presence of China in Latin America post-2020. Brazil in particular is China’s largest trading partner and they’re not trading with the US dollar but instead the Chinese yuan. Despite this, Brazil is unstable domestically.
  • The risks of nationalization and crime dynamics in Mexico, as well as similar risks in Central America. 
  • Venezuela’s inability in the foreseeable future to be any sort of trading partner for the US due to its lack of legitimacy. 
  • The potential of Cuba to become the financial stronghold of Latin America if it can achieve economic reform and attract investment. 
  • Chile’s pro-business laws make it attractive to business trade and it is the safest, but there are increasing pushes for authoritarianism. 

 

Resources

Infortal Worldwide | Email | Tel: 1.800.736.4999 | Podcast

Categories
Principled Podcast

Season 10 Episode 1 – How Does the US Department of Justice Evaluate Ethics and Compliance Programs?

What you’ll learn on this podcast episode

The US Department of Justice Criminal Division has been increasingly vocal about what makes organizations’ ethics and compliance programs effective. This input on program effectiveness takes the form of guidance to prosecutors about what questions to ask when companies negotiate to resolve DOJ investigations into corporate wrongdoing on favorable terms. What does this guidance on program effectiveness mean in practice for E&C professionals? In the season 10 premiere of LRN’s Principled Podcast, host Susan Divers speaks with John Michelich, who retired last November after 35 years as a federal prosecutor with the Department of Justice’s Criminal Division. Listen in as they explore how the DOJ evaluates E&C programs, as well as best practices for companies settling misconduct investigations. 

Guest: John Michelich

John Michelich – Grayscale

John Michelich is a retired career prosecutor, who has served at the state, federal, and international levels for 45 years. A native of Illinois, John received his undergraduate education at Illinois Wesleyan University and then attended Drake University Law School in Des Moines, Iowa. For 10 years, John served as Assistant State’s Attorney and First Assistant State’s Attorney in Springfield, Illinois, where he prosecuted all types of state criminal felony violations including armed robbery, aggravated sexual assault and capital murder.   

In 1988, John moved to Washington, DC where he began his 35-year career as a prosecutor with the US Department of Justice, Criminal Division. As a federal prosecutor, John has handled a wide variety of cases including child pornography and obscenity, narcotics distribution and all types of white-collar criminal cases. John served for 30 years as a prosecutor with the Fraud Section of the Criminal Division where he handled numerous cases including health care fraud, bank fraud, telemarketing fraud, commodities and securities fraud and violations of the Foreign Corrupt Practices Act. Because Washington DOJ lawyers are traveling prosecutors, John has handled grand jury proceedings or jury trials in more than two dozen federal districts nationwide from Guam and Hawaii to Puerto Rico, and California to New York. Over his long career, John has tried dozens of jury trials to verdict.  

In 1998, the Justice Department sent John on loan to the United Nations’ International Criminal Tribunal for the Former Yugoslavia, also known as the War Crimes Tribunal, in the Hague, Netherlands, where he handled investigations and Tribunal proceedings involving crimes against humanity and serious breaches of the Geneva Convention that occurred during the Yugoslavian civil war.   

For over 40 years, John has been an active instructor of Trial Advocacy and has appeared regularly on the faculty of the NITA Trial Practice course offered at Georgetown University Law Center. In addition, John has served as an Adjunct Professor at Georgetown, teaching Trial Practice courses to third-year law students. In his retirement, John is available as a legal consultant to trial lawyers to advise them in preparation for jury trials and to consult with corporate counsel concerning internal investigations and to advise them on how to approach the government when there are allegations of wrongdoing, especially foreign bribery. 

John is licensed to practice in the states of Illinois and Iowa, and several federal courts, and is a licensed Solicitor of the Senior Courts of England and Wales.   

Host: Susan Divers

Headshot_Susan_Divers_S7E18_Principled_Podcast

Susan Divers is a senior advisor with LRN Corporation. In that capacity, Ms. Divers brings her 30+ years’ accomplishments and experience in the ethics and compliance area to LRN partners and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance and substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance.

Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program.

Mrs. Divers’ background includes more than thirty years’ experience practicing law in these areas. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.

Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008.

She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics. Mrs. Divers’ most recent publication is “Balancing Best Practices and Reality in Compliance,” published by Compliance Week in February 2015. In her spare time, she mentors veteran and university students and enjoys outdoor activities.