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Compliance Kitchen

UK and EU Sanctions on Myanmar


The Kitchen continues its coverage of the Myanmar/Burma sanctions.  This episode looks at the UK sanctions on this country and also an update from the EU in this regard.

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Great Women in Compliance

Dr. Pat Harned, Part 2


Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
One of the best parts of GWIC is that we get the opportunity to speak with some of the trailblazers in our field. In the next two episodes, Lisa talks with Pat Harned, the CEO of the Ethics and Compliance Initiative (ECI). Today, Lisa gets to learn about Pat’s background, what led her to working at ECI and how the organization evolved before and during her leadership. Pat talks about her experience as a woman in our field and as a CEO.
In this episode, we have Part 2 of Lisa’s discussion with Pat Harned, the CEO of the Ethics and Compliance Initiative (ECI). In Part 1, they discussed ECI, its mission, the recently released Global Business Ethics Survey (GBES) and Pat’s journey to her leadership of ECO.
In Part 2, Lisa and Pat discuss the IMPACT Conference, and focus on one of the keynote discussions about reporting and speaking up and retaliation. They discuss the trends identified globally and in the US in the GBES, and the analysis of the data received from the survey participants. Pat also provides guidance and insight about retaliation and the perception of retaliation both in the US and throughout the world, and how the social justice movements and COVID have impacted them.
Pat concludes the discussion with some of the knowledge and advice that she would have liked to have known when she started her career.  We are very lucky in the E&C Community to have so many strong organizations for us to build and grow our professions, and fortunate to have a woman like Pat helming ECI.
The Great Women in Compliance Podcast is proudly featured on the Compliance Podcast Network and sponsored by Corporate Compliance Insights. If you enjoyed this episode please subscribe to the podcast and rate it on your podcast player to help other compliance professionals find it. Want to hear more from us? We have a book, “Sending the Elevator Back Down: What We’ve Learned from Great Women in Compliance” (CCI Press, 2020) which is available on Amazon.com and Book Depository.
If you’ve already read the booked and liked it, will you help out other women to make the decision to leverage off the tips and advice given by rating the book and giving it a glowing review on Amazon?
As always, we are so grateful for all of your support and if you have any feedback or suggestions for our 2021 line up or would just like to reach out and say hello, we always welcome hearing from our listeners.
You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.
Join the Great Women in Compliance community on LinkedIn here.

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Compliance Into the Weeds

Biden Administration Executive Order on Cybersecurity


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. This week Matt and Tom take a deep dive into the Biden Administration’s recently released Executive Order on cybersecurity for both the federal government but also contractors who do work for the US government and their subcontractors.
Some of the issues we consider are:

  • How will there be more and better sharing of threat information?
  • How will we achieve stronger cybersecurity within the government?
  • Why will contractors will need to have stronger oversight of their SW supply chain?
  • What will be the role of compliance?
  • What will be the role of internal audit? 

Resources
Matt’s blog post on Radical Compliance: 
Parsing Biden’s Cybersecurity Order

Categories
Daily Compliance News

May 19, 2021 the Slow Start edition


In today’s edition of Daily Compliance News:

  • AML whistleblower program getting off the ground slowly. (WSJ)
  • Amazon under investigation by German anticompetition watchdog. (BBC)
  • $100MM stolen from Wirecard just before its collapse. (FT)
  • US accuses officials of corruption. (WaPo)
Categories
Compliance Kitchen

Russia Restrictions on Corporate Disclosures; OFAC updates Somalia sanctions


In this episode, we will touch on new Russia’s Restrictions on Corporate Disclosures; and OFAC’s updates to Somalia sanctions.

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Innovation in Compliance

K2’s Integrity Matters – Gabe Hidalgo on Cryptocurrency Regulation


In this special episode of K2’s Integrity Matters podcast series, I visit with Gabe Hidalgo. Hidalgo is a Managing Director at K2 Integrity. He has 20 years of legal, regulatory compliance, and Anti-Money Laundering (AML) experience working with wholesale and retail banks, FinTech companies, broker/dealers, and money services business entities. Hidalgo is a recognized subject-matter expert in the cryptocurrency and digital assets market and is able to help clients navigate and mitigate Bank Secrecy Act and Anti-Money Laundering (BSA/AML) compliance risks. In this podcast, we take a deep dive into the current issues around cryptocurrency regulation and where they may be headed down the road. Some of the highlights include:
The Current Landscape

  • Consumer and institutional push into crypto.
  • NFTs are growing in popularity. What is the significance?
  • Heavy institutional hitters buying in of late. Is the little guy now cut out?

Current Regulatory Climate

  • Alternative currency has gone from to an asset class being bought and sold for investing.
  • What are the views of Gary Gensler and where might the SEC go in terms of regulation and enforcement?
  • IRS and taxation issues.
  • What are the benefits of a strong regulatory environment for both the financial system as well as the companies in it?

Into the Future

  • Inevitability that there will be more regulatory guidance and rules; you have more and more mainstream institutions ready to buy or invest.
  • Whenever you have that much interest, the government has to get involved from a risk mitigation standpoint, and consumer protection standpoint.
  • Who is going to oversee it? Why types of products? Who falls in those product classes?

For more on K2 Integrity, check out their website, here.

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The Ethics Experts

Episode 062 — Robert Zafft

In this episode of The Ethics Experts, Nick welcomes Robert Zafft, Author of “The Right Way to Win,” to the show.

Categories
Survive and Thrive

What Do You Do To Survive a Code of Conduct Review By the SEC?


One afternoon at 4 PM, you get a call from the local Securities and Exchange Commission office, and they say they want to come by in two days to review your company’s Code of Conduct. You ask them why they want to review your Code. They tell you that it is a foundational document of your compliance program and view it as an internal control and, therefore, enforce it under the FCPA. They want to review all aspects of your Code design, implantation, training, and rollout.
What steps do you need to take to demonstrate the robustness of your Code but also your training and ongoing communications on it?
How do you dig deeper and review the Code of Conduct design, implementation, and review process?
How do you make sure facts on the ground have not changed and that your Code is still relevant?
IN THIS NEW EPISODE, Compliance Evangelist Thomas Fox and Kortney Nordrum, Regulatory Counsel & Chief Compliance Officer, Deluxe Corporation, break down the steps you need to take to survive (and ace) the Code of Conduct investigation review by the SEC.
Major takeaways discussed in the episode:
✔️ Dig deeper and review the Code of Conduct design, implementation, and review process. Show any changes or amendments, what was the process for these actions. Finally, how do you make specific facts on the ground that have not changed and that your Code is still relevant?
✔️ Build a focus group and pull in people from teams in audit, finance, I.T., business folks, and procurement to assess the current Code to identify what works, what doesn’t, and what’s missing.
✔️ Another vital step is benchmarking. Search and see examples of codes, whether a private or public company, big or small, to benchmark against and identify where you think you should be and where others are in your industry.
✔️ Develop a code that you’re proud of and that you want to display to the world. It should reflect and be tailored to fit your organization and not any other.
✔️ Approval and buy-in from the Board and top management are necessary to lend credibility and authenticity to the Code’s core message. This serves as the organization’s Bible for how to operate. 
✔️ Identify your Code of Conduct training protocol and require annual attestation that the Code of Conduct is read and understood by all employees and directors.
✔️ Checklist of evidence to present to the SEC
Creation/Design
● Focus group minutes
● Drafts and updates to prior code language
● Benchmarking data and session information
● Translations
● Code launch plan – detailing Communications, emails, mgr meetings, printouts, CEO video
Training
● Training records & attestations
● Transcript of Code of Conduct training
■  Operationalization
● Culture and compliance surveys
● The open rate on emails/click rate on Code on the intranet
● How often employees reach out with questions
● Hotline calls and investigations
● Are people making good choices? Root cause analysis of non-compliance
—————————————————————————-
Welcome to SURVIVE AND THRIVE, the newest addition to the Compliance Podcast Network. Hosted by the Compliance Evangelist Thomas Fox and Kortney Nordrum, Regulatory Counsel & Chief Compliance Officer, Deluxe Corporation. This is a podcast where we unpack compliance, crisis disasters and walk you through all the red flags which appear and give you some lessons learned going forward.
Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com.

Categories
Innovation in Compliance

Reframing The C-Suite Network with Jeffrey Hayzlett


 
Jeffrey Hayzlett is a global business celebrity, the CEO of The Hayzlett Group and the founder of The C Suite Network. He is a primetime television and podcast show host, author, and a keynote speaker. As a leading business expert, Jeffrey has shared his insight and expertise through various television networks and around the world via his travels. Tom Fox welcomes him to this week’s episode as they discuss the C-Suite Network, diversity, and the effects of COVID-19 on executives.
 

 
Pivoting in The Pandemic
The pandemic made Jeffrey and his team consider what they could do differently about their network conferences. “It really got down to the fundamental piece . . . we really don’t have to be together, meaning face-to-face to do the work that we need to do,” Jeffrey tells Tom. Tom remarks that this approach transformed the C-Suite Network as its membership grew exponentially. The key element, Jeffrey stresses, is that everyone wants to come together to do something together, and to learn and share each other’s expertise. 
 
Having the Hard Conversations
As executives, we need to have the difficult discussions surrounding diversity no matter how uncomfortable they may make us. “I think we all think we know what we know, and we all think we know what other people go through; and we don’t,” Jeffrey says. We need to have frank and open discussions around diversity, and stop trying to coach our language and just address these topics and issues. We should approach these conversations with the understanding that we don’t intend to hurt anyone.
 
The New Normal
Jeffrey tells Tom that the way we usually conduct our errands and our business will change post-pandemic. “I don’t think you’re going to have certain things go back to the way what people would say is normal, we’re going to have whatever normal is.” Business events will also be smaller in capacity, Jeffrey states. “There’s gonna be a real hybrid,” he comments: events will be partly face-to-face and partly online.
 
Resources
Jeffrey Hayzlett | LinkedIn | Twitter        
The Hayzlett Group
The C-Suite Network
 

Categories
Jamming with Jason

Bouncing Ideas off Others to Reduce Dangerous Self-Talk and Paranoia with Hal Garyn


We’re going to be talking about how sometimes we get stuck in some “self-talk” and how talking with other people and getting outside input can lead you to answers that are actually helpful to you!
Hal Garyn will be joining us for this podcast to also shed some light onto what many CAEs have been telling him regarding what they have been going through.
Not only are a lot of people becoming a little more insecure due to the covid lockdown, but some of these echo chamber type situations can lead to a bit of paranoia seeping it’s way into our work field.
Listen in at: http://www.jasonmefford.com/jammingwithjason/