In today’s edition of Daily Compliance News:
In our continuing series, I am joined by Mikhail Reider-Gordon, Managing Director of Institutional Ethics & Integrity at Affiliated Monitors. Mikhail’s areas of expertise include technology, privacy, cybersecurity, IP and accountability in artificial intelligence; the global anti-corruption and anti-money laundering regimes; media & entertainment; biotech and the life sciences; the public sector and international law. She is accustomed to working on extremely sensitive and high-profile matters, both nationally and internationally. In this episode, we explore the money laundering Wirecard engaged in via the project dubbed ‘Hermes’.
Some of the highlights include:
- Weekly news wrap-up on Wirecard.
- What has this done to the German political scene?
- Any talk about BaFin reforms?
- How do losses reach €20bn?
- How was the investigation “unrelated to the mandate”?
- Money laundering through Hermes.
In this episode, we talk about the uncomfortable and sometimes terrifying situation when a compliance officer must critique a member of leadership team and living to tell about it. In recent years, the expression “tone at the top” has been displaced by “conduct at the top” ushering in a new era of leadership accountability and transparency by the DOJ and other enforcement agencies in the U.S. and overseas. As a practical matter, compliance officers must on occasion investigate or critique members of the leadership team when conducting an internal investigation or assessing the ethics and compliance program. Joining me today is Matt Tanzer. For 13 years, Matt held various positions at Tyco including Chief Compliance & Ethics Officer. A position he also held after Tyco was merged into Johnson Controls.
Join us each week as we take a deep dive into the various forms of fraud across the world and discuss crime families, penny stock boiler rooms, international money launderers, narco-traffickers, oligarchs, dictators, war lords, kleptocrats and more.
Scott Moritz is a leading authority on white-collar crime, anti-corruption, and in the evaluation, design, remediation, implementation, and administration of corporate compliance programs, codes of conduct. He is also considered an authority in the establishment, training, and oversight of the investigative protocols carried out by financial intelligence, corporate security, and internal audit units.
Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
In this episode of Great Women in Compliance, Lisa speaks with Danielle Cannata, who is senior counsel at SABIC, which is the Saudi Basic Industries Corporation. In her role, she is responsible for the company-wide Compliance Program and monitoring and promoting compliance at SABIC.
Danielle is also an advocate for women around the world. In particular, she is one of the co-chairs of the of the Integrity and Compliance Taskforce for the B20, which convenes before the G20, and where the B20 taskforce will present a report to the G20 Presidency.
Danielle will talk about her work on the task force, and specifically about the recommendations for women and recommendations and tools for women to address and report wrongdoing. She also provides her perspective on working in a global role and working with Saudi and the Middle East over her 12 years at SABIC.
Join the Great Women in Compliance community on LinkedIn here.
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. In this episode Matt and Tom go into the weeds to look at the recent fine of $400 million against Citibank for its poor risk management process. Some of the issues we consider are:
· Four areas of concern(1) Poor ERM; (2) Poor compliance; (3) Poor internal controls; and (4) Data governance.
· How the OCC Order is an audit road map.
· What does that mean for compliance on the Board?
· Did the OCC push out Michael Corbat?
· Focus on the ERM Blueprint.
Resources
See Matt’s blog posts on Radical Compliance-Citigroup’s Governance Issues, Part 1 and Citigroup, Part 2-Better ERM Program
Brian and Tim drop the gavel to render verdicts on the litigation impacting the TikTok and WeChat bans and a lawsuit challenging the legal bases for the new ICC-related sanctions program. We also discuss OFAC’s recent ransomware advisory and give some thoughts on a recent OFAC enforcement action focused on Cuba. Then, in the Lightning Round, we share our initial impressions on brand new U.S. sanctions targeting Iran’s financial sector and dissect the outcome of a lawsuit challenging the foundations of the Commerce Department’s authority to enforce the export controls framework established by the EAR.
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Questions? Contact us at podcasts@milchev.com.
EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
EMBARGOED! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike, hosted by Miller & Chevalier Members Brian Fleming and Tim O’Toole. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe for new bi-weekly episodes so you don’t miss out!
Timestamps:
0:10 Introduction and Roadmap
The Rundown
5:38 Quick Check-in on TikTok and WeChat
18:54 Lawsuit Challenging ICC Sanctions
39:36 OFAC and FinCEN Randomware Advisory
53:41 OFAC Settlement with Generali Global
1:01:47 Lightning Round
1:02:05 More Sanctions Coming Against Iranian Banks?
1:12:43 FedEx v. BIS
1:25:21 Final Thoughts
***Stay sanctions free.***
In this episode I am joined by AMI Managing Director Rod Grandon. We have considered the responsibility of federal contractors to maintain their status as “Responsible Contractors” and explore the benefits of having an effective compliance and business ethics program to not only increase business efficiencies and profitability but prepare you in good stead if the regulators come knocking. In this episode, we consider how you can keep your compliance program fresh through ongoing monitoring.
To gain a better understanding of the effectiveness of corporate ethics and compliance efforts and to identify any gaps in the program’s scope, contractors are well advised to commit to an objective assessment of their ethical culture and ethics and compliance programs before a crisis occurs. Grandon stated, “part of the requirement for an ethics compliance program is that the contractor will conduct periodic reviews of the company’s business practices, procedures, policies, and internal controls for compliance with the Contractors Code of business ethics and conduct and the requirements associated with federal contracting.” Contractors should consider carefully whether the assessment can be performed using in-house resources, or whether the assessment should be performed by an independent and objective outside organization.
An independent, outside reviewer would in their report create a roadmap that a company could use to remediate any deficiencies if new risks had arisen, either in markets, products or services that could be used as a documented roadmap if a regulator ever came knocking. The company could show such regulator that “yes, we not only reviewed our program, but we have a roadmap and here are the steps we are taking based upon this roadmap to move forward into the future.”
To find out more about Affiliated Monitors, Inc. check out their website www.affiliatedmonitors.com.
Josh Turpen is the Chief Product Officer of Jama Software. He says that early in his career he came to understand the importance of good requirements and testing, and the ability to tie it all together. Their Jama Connect solution, he argues, is “the premier requirements management test and risk tool… as it brings together requirements, test and risk in a way that our customers can have good traceability and good verification.” He and Tom Fox chat about the importance of being an enabler, as well as product development lifecycle management in this week’s show.
A Larger View on Risk
Josh says that Jama’s experience in diverse industries gives them a broader view of risk. With this wide expertise, they are able to help their clients see how product requirements and tests tie back to risk, and how requirements, risk and tests change with product alterations. Tom comments that changing external risk – such as the present pandemic – calls for new risk assessments. Josh agrees. “Overall,” Josh says, “re-evaluating risk with external events in mind is a good practice. And you’ve gotta have a system that enables that.” He and Tom discuss document-based solutions versus item-based, and why he believes item-based solutions are better.
Managing Product Development
It’s important for engineers to know what they’re building and why, Josh says. He argues that it helps them make better decisions. That buy-in is a critical component of success: “One of the key enablers of success is that holistic picture that… everybody is bought in on and understand,” he says. You need to hire good people and be an enabler, he adds. “It’s not what you do. It’s what you can help your team do.” Tom asks him to define product development lifecycle management. Josh explains that it’s seeing the scope of the product development from end to end.
Resources
JamaSoftware.com
Josh Turpen on LinkedIn
Ever heard the expression “beating a dead horse?” It has nothing to do with animal cruelty, but simply means a particular effort is a waste of time as there will be no outcome.
Well there are some efforts #internalaudit continues to push that are also as big a waste of time as beating a dead horse, and in this #jammingwithjason #internalauditpodcast I’m going to talk about them in a very candid way.
If you find yourself doing these things, it’s time to STOP. You are wasting your energy and likely damaging the reputation and relevance of internal audit in your organization.
Listen in at: http://www.jasonmefford.com/jammingwithjason/ or wherever you enjoy listening to podcasts.
Jamming with Jason has interviews and discussions (jam sessions) relevant to internal audit leaders, and professionals in internal audit, risk management, and compliance. If you want to up-level your life and career you need to be listening each week.
Join the leadership program Jason mentioned in this episode here: https://jasonmefford.mykajabi.com/caebriefing