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Adventures in Compliance

Adventures in Compliance – Leadership Lessons from The Adventure of the Engineer’s Thumb

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” The appeared in the Strand Magazine from July 1891 to June 1892. Over 12 episodes, I will be reviewing each story and mine them for leadership, compliance and ethical lessons.  In this episode, I consider story of “The Adventure of the Engineer’s Thumb” which was originally published in the Strand Magazine in March 1892 and is a part of the collection ‘The Adventures of Sherlock Holmes’.

Summary

Hatherley visits Holmes with a peculiar tale. He recounts his recent experience where he was hired by a man named Colonel Lysander Stark to repair a hydraulic press at his country house. However, things take an alarming turn when Hatherley discovers that the press is not being used for its intended purpose but rather to manufacture counterfeit coins.

Realizing the danger he is in, Hatherley attempts to escape, but he is caught by Stark and his accomplice. In a struggle, Hatherley manages to free himself, but not before his thumb is severed by Stark with a cleaver. Bleeding and desperate, Hatherley seeks assistance from Holmes to bring the criminals to justice and recover his thumb.

Holmes and his trusted associate Dr. John Watson investigate the matter. They discover that Stark is a member of a criminal gang involved in counterfeiting coins. With Holmes’ guidance, Hatherley’s thumb is reattached, and the detectives devise a plan to expose Stark and his operation.

Disguised as potential investors, Holmes and Watson visit Stark’s house. They gather evidence, unravel the gang’s secrets, and narrowly escape a dangerous confrontation. In the end, the authorities apprehend Stark and his gang members, putting an end to their counterfeiting activities.

“The Adventure of the Engineer’s Thumb” showcases Holmes’ deductive reasoning and quick thinking as he helps Victor Hatherley navigate a dangerous situation. The story highlights the detective’s ability to solve complex cases and bring criminals to justice while also emphasizing the importance of the thumb as a key piece of evidence in unraveling the mystery.

Leadership Lessons

1.         Attention to detail: Sherlock Holmes is known for his attention to detail, and this is evident in “The Adventure of the Engineer’s Thumb.” He is able to solve the mystery by paying close attention to small details that others have overlooked. Compliance professionals can learn from this by focusing on the details and not overlooking anything that could be important.

2.         Problem-solving skills: Holmes is a master of problem-solving, and this is demonstrated in the story as he unravels the mystery of the engineer’s thumb. Compliance professionals can learn from this by developing their problem-solving skills and approaching challenges with a creative and analytical mindset.

3.         Teamwork: Although Holmes is the main detective in the story, he works with others, including Dr. John Watson, to solve the case. Leaders in business can learn from this by recognizing the importance of teamwork and building strong relationships with their colleagues.

4.         Adaptability: Throughout the story, Holmes demonstrates his ability to adapt to changing circumstances and adjust his approach as needed. Compliance professionals can learn from this by being flexible and open-minded, and by recognizing that there may be multiple solutions to a problem.

5.         Communication skills: Throughout the story, Holmes effectively communicates with others to gather information and solve the case. Compliance professionals can learn from this by developing their communication skills and being clear and concise in their interactions with others.

6.         Risk management: in the story, the engineer’s thumb is a result of a failed business deal. Compliance professionals can learn from this by recognizing the importance of risk management and by taking steps to minimize potential risks in their operations.

Resource

The New Annotated Sherlock Holmes

Categories
FCPA Compliance Report

FCPA Compliance Report – Jason Patel on Leveraging and Protecting Data

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom Fox welcomes Jason Patel as they delve into the critical aspects of go-to-market security, market intelligence security, and customer privacy enforcement in today’s digital world.

 They discuss the importance of protecting businesses and customers’ experiences, leveraging data for security and marketing strategies, and ensuring compliance with privacy legislation like GDPR and CCPA. They highlight the services offered by Cheq.ai, a company specializing in go-to-market security, and stress the need for real-time compliance and a transparent approach involving various stakeholders. The conversation also explores the risks of relying solely on vendors for compliance and the impact of opt-in and opt-out strategies in data privacy. Looking ahead, they predict data privacy to be a leading issue, emphasizing the need for clear and explicit internet regulations to protect businesses and consumers.

 Key Highlights

·      Check: Go-to-Market Security and Customer Privacy Enforcement

·      Designing GDPR-compliant controls

·      Real-time compliance in data tracking

·      The Impact of Opt-In vs Opt-Out Strategies

·      The Future of Internet Regulations

Resources

Cheq.ai

Tom Fox

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The Ethics Experts

Episode 156 – Virginia MacSuibhne

In this episode of The Ethics Experts, Nick welcomes Virginia MacSuibhne.
Virginia MacSuibhne (pronounced mock-swiv-na) is the VP, Global Chief Compliance Officer at Agilent Technologies in Santa Clara, California where she is responsible for managing and directing all aspects of the organization’s compliance and data protection and privacy program and related infrastructure. In addition to expertise building and managing key ethics and compliance programs, Virginia is experienced and skilled in cybersecurity, data governance, investigative processes, employment law, and ethics and compliance risk assessment and crisis management activities.
https://www.linkedin.com/in/virginia-macsuibhne-jd-ccep-599a927

Categories
Corruption, Crime and Compliance

Board Oversight and Monitoring of AI Risks

As companies rapidly adopt artificial intelligence (AI), it becomes paramount to have robust governance frameworks in place. Not only can AI bring about vast business benefits, but it also carries significant risks—such as spreading disinformation, racial discrimination, and potential privacy invasions. In this episode of Corruption, Crime and Compliance, Michael Volkov dives deep into the urgent need for corporate boards to monitor, address, and incorporate AI into their compliance programs, and the many facets that this entails.

You’ll hear Michael talk about:

  • AI is spreading like wildfire across industries, and with it comes a whole new set of risks. Many boards don’t fully understand these risks. It’s important to make sure that boards are educated about the potential and pitfalls of AI, and that they actively oversee the risks. This includes understanding their obligations under Caremark, which requires them to exercise diligent oversight and monitoring.
  • AI is a tantalizing prospect for businesses: faster, more accurate processes that can revolutionize operations. But with great power comes great responsibility. AI also comes with risks, like disinformation, bias, privacy invasion, and even mass layoffs. It’s a delicate balancing act that businesses need to get right.
  • Companies can’t just use AI, they have to be ready for it. That means adjusting their compliance policies and procedures to their specific AI risk profile, actively identifying and assessing those risks, and staying up-to-date on potential regulatory changes related to AI. As AI grows, the need for strong risk mitigation strategies before implementation becomes even more important.
  • The Caremark framework requires corporate boards to ensure that their companies comply with AI regulations. Recent cases, such as the Boeing safety oversight, demonstrate the severity of the consequences when boards fail to fulfill their responsibilities. As a result, boards must be proactive: ensure that board members have the technical expertise necessary, brief them on AI deployments, designate senior executives to be responsible for AI compliance, and ensure that there are clear channels for individuals to report issues.

 

KEY QUOTES

“Board members usually ask the Chief Information Security Officer or whoever is responsible for technology [at board meetings], ‘Are we doing okay?’ They don’t want to hear or get into all of the details, and then they move on. That model has got to change.”

 

“In this uncertain environment, stakeholders are quickly discovering the real and significant risks generated by artificial intelligence, and companies have to develop risk mitigation strategies before implementing artificial intelligence tools and solutions.”

 

“Board members should be briefed on existing and planned artificial intelligence deployments to support the company’s business and or support functions. In other words, they’ve got to be notified, brought along that this is going to be a new tool that we’re using, ‘Here are the risks, here are the mitigation techniques.’”

 

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
Blog

Speaking Up is Awesome

We are on a run of some great, informative and incredibly useful books by some super star compliance professionals. A couple of weeks ago Mary Shirley released Level Up. In her book, Mary shared forward-thinking hacks and ideas to improve the effectiveness of your Ethics and Compliance program to build a stronger, winning function, honoring psychological safety. Her manifesto for Living Your Best Compliance life contained carefully curated tips and takeaways for optimum impact and immediate action, at low or no investment, because the typical Compliance Officer is not always flush with funds and tends to make do like a corporate MacGyver.

Next week Adam Balfour’s Ethics and Compliance for Humans will be released. (It is available for presale here.) In his book, Balfour, a well-known corporate compliance expert writes why ethics and compliance departments, HR and business leaders must keep people top of mind when designing and implementing ethics and compliance programs. The human-centric programs Balfour espouses resonate with and are highly relevant to their audiences. They not only consider the human experience, but also protect those who are—or might otherwise be—harmed by wrongdoing. Or as Carsten Tams might say, it’s all about the UX.

I am thrilled to be sitting between two such compliance luminaries with the release of my second children’s book on compliance Speaking Up is Awesome. This is the second in my three-book series about compliance for children. The first Being a Compliance Officer is Awesome was released last December and within its first week was a best-selling book for children on Amazon.com. Both books were published and illustrated by Dinosaur House.

Many years ago, when my daughter was a teenager, I asked her if she knew what a whistleblower was. I told her that when I person raised their hand and spoke up after they saw something wrong, that was being a whistleblower. Her response was “That’s what we call a rat.” I have long thought about her response (and she is long past being a teenager). I have wanted to try and change the narrative for teenagers and I feel like in this book Speaking Up is Awesome I have created a way to do so.

The book is the story of our intrepid crew traveling across the galaxy to Planet Pawtastic Friends, the dog rescue planet. On Planet Pawtastic Friends, dogs receive enrichment training so they can be adopted and move to their Fur-ever homes. In enrichment training, dogs train work with rescue dogs to make them ‘super-adoptable’. On their journey, one of the crew discovers something wrong with the engine but as she is not an engineer, she is worried the ship’s engineers will be mad at her; call her a rat and punish her by not letting her come to Thanksgiving Dinner. But she listens to her gut and decided she must tell the Captain about the problem.

It turns out the problem with the engine was quite serious and her speaking up saved the ship. She listened to her gut and she learned that by doing so, it can pay big dividends when you speak up. Not only did she potentially save the ship, but her suggestion made the spaceship run more efficiently and they were able to go farther by savings on fuel. Her example led the Captain to install an anonymous hotline so that other crew members could make reports of unsafe situations or even make suggestions on how to make the spaceship run better. Everyone on the spaceship learned that speaking up is awesome.

Just like my first book, this new book, Speaking Up is Awesome is aimed for the children, families and friends of compliance professionals. Or perhaps you could take hold of the suggestion of Carsten Tams who said that my first children’s book was an excellent guide for other corporate executives who might not fully understand the role of compliance in an organization. Whoever you might want to purchase my book for; it is designed to change the narrative about how children think about whistleblowers. If we can get a generational change in this dynamic, it will make companies better about doing business in compliance and with greater ethics. Moreover,  it will allow many companies to take their speak up culture to another level.

Kyle Welch, in his seminal work Evidence on the Use of and Efficacy of Internal Reporting Systems found that when companies had a culture of speaking up, they not only sustained material cost savings but they became better run companies. The reason was simple; engaged employees felt safe in raising their hands and speaking up. When they did so with such safety, these companies became better run. It seems straight-forward and Welch’s research affirmed this.

I hope you will check out and purchase a copy of Speaking Up is Awesome and we can all change the narrative for today’s kids. Just imagine a galaxy where kids felt like they could speak up and what it would mean for corporate America when they get into the workforce.

There is yet one more reason to purchase this book. Profits go to Pawtastic Friends, the dogs enrichment center founded by my good friends Michael and Melissa Novelli. They are literally changing dogs lives with enrichment training. Pawtastic Friends is the specified non-profit partner of the Compliance Podcast Networkand also check out their podcast, The Paw Talk which appears on the CPN. In this podcast, Mike and Melissa talk about dogs available for adoption and some dogs who have found their fur-ever homes. I hope you will consider a donation to Pawtastic Friends.

Categories
Sunday Book Review

Sunday Book Review: August 27, 2023 The Internal Audit 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. In today’s edition of the Sunday Book Review, I continue my summer exploration of books on crime. Today, look at some of the top books on auditing, both for the audit professional and the compliance professional.

Categories
10 For 10

10 For 10: Top Compliance Stories For the Week Ending August 26, 2023

Welcome to 10 For 10, the podcast which 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 the compliance professional, 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.

  • Venezuela makes last ditch appeal re: CITGO. (Reuters)
  • SFO drops ENRC investigation. (FT)
  • Poverty a direct result of corruption. (Time)
  • Is due diligence over in China? (FCPABlog)
  • Ukraine institutes whistleblower bounty program. (BusinessInsider)
  • Nigerian ex-Energy Minister arrested for corruption by FCA. (Reuters)
  • Ex-Vitol employee to face FCPA charges. (WSJ)
  • ABC ex-prosecutor surges in Guatemalan Presidential race. (WaPo)
  • Lithium batteries scrutinized under UFLPA. (Reuters)
  • More Odebrecht indictments coming. (WSJ)

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

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Kerrville Weekly News Roundup

Kerrville Weekly News Roundup: August 26, 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 will enjoy or participate in this weekend.

In this episode, Tom, Gilbert and Andrew discuss the following stories which caught their attention over the past week.

·      Tom discusses Shelby Balser being name Principal of the Year in Texas and Schreiner University’s upcoming 100th anniversary.

·      Andrew discusses the Kerrville Economic Investment Council and the City of Kerrville’s request for bonding funding for lifestyle improvements in the city.

·      Gilbert talks about the ongoing drought and the more critical need for water conservation moving to Stage 4. He also discusses the upcoming 5K runs in the City.

Resources

Tom Fox on LinkedIn

Gilbert Paiz on LinkedIn

Andrew Gay on LinkedIn

Texas Hill Country Podcast Network

Categories
Because That's What Heroes Do

Firefly – Episode 14, Objects in Space – Unresolved Endings and Fan Loyalty in Firefly

Megan and I go in a different direction for our next sci-fi series as we take up the 2002 series Firefly. The show is an American space Western drama television series. The series is set in the year 2517, after the arrival of humans in a new star system, and follows the adventures of the renegade crew of Serenity, a “Firefly-class” spaceship. The ensemble cast portrays the nine characters who live on Serenity. Join the dynamic and delightful hosts Tom Fox and Megan Dougherty as they dive into the latest episode of Firefly in their podcast, Because That’s What Heroes Do!

Firefly, a beloved sci-fi series, despite its premature cancellation, has left an indelible mark on its dedicated fanbase with its intricate plot, deep character development, and the creative genius of its creator, Josh Whedon. Tom believes that Firefly was a well-orchestrated show with great character development and plot progression. He expresses disappointment over the series’ abrupt end and wishes for more exploration of the character River, an enhanced human with extraordinary abilities.

Megan another ardent fan, appreciates the show despite its short run. She highlights the unique episodic format of Firefly, where each episode can stand alone while still contributing to character and plot development. Despite recognizing the problematic aspects of the show’s creator, Joss Whedon, Megan still believes that he writes good stories. Join Tom Fox and Megan Dougherty on this episode of the Because That’s What Heroes Do podcast as they delve deeper into the world of Firefly by considering the Firefly movie version Serenity.

 Highlights

·      TV Series Firefly

·      Some Great SciFi

·      River’s Plan to Rescue the Crew

·      Fan Loyalty and Unresolved Ending

Resources

Megan Dougherty 

LinkedIn

One Stone Creative

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Tom 

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Categories
Riskology

Infortal on Risk Intelligence Part 5: Supply Chain Intelligence with Dr. Ian Oxnevad

In the final part of this week’s five-part special, Tom Fox discusses supply chain risks with Dr. Ian Oxnevad. He talks about the supply chain from a geopolitical risk perspective and the various steps companies can take to prepare themselves against those risks.

 

Dr. Ian Oxnevad is a political scientist and economist at Infortal Worldwide, a global risk firm that provides due diligence services to support key investment decision-making. Infortal Worldwide supports a lot of private equity investment, mergers, acquisitions, and any risk scenario a business may face.

  • Supply chain intelligence must first begin with a risk analysis. Companies must determine their exposure to geopolitical risks, such as political unrest, social unrest, or war. 
  • How a company de-risks its supply chain depends on which risk is the largest. “Are you looking at closing the distance and reducing logistical costs between a customer and a company?” Ian asks. Suppose your company is considering alternatives to its current supply chain system or systems outside its country. In that case, it must consider corruption, terrorism, organized crime, and ESG. 
  • Ian goes through some steps Infortal takes when counseling companies through de-risking. He describes what it takes to create a solid supply chain risk response plan. 
  • The intelligence process gives companies legal guidance and any other relevant information they need for making the right decisions while mitigating as much risk as possible.

KEY QUOTE

” Supply chain intelligence is key to understanding and avoiding hidden supply chain risks.”-  Dr. Ian Oxnevad 

Resources: 

Infortal Worldwide | Email | Tel: 1.800.736.4999