Categories
Innovation in Compliance

Exiger on the Evolution in Supplier Compliance in COVID – Spotlight on Corporations with Aaron Narva and George ‘Ren’ McEachern

Welcome to a special five-part podcast series on topics of Third-Party Risk Management to Supply Chain Risk Management: Exiger on the Evolution in Supplier Compliance in COVID. Exiger was founded to fight financial crime, fraud and terrorist financing by introducing technology-enabled solutions to the market’s biggest supply chain, risk, investigation, litigation, and compliance challenges. A global authority on risk and compliance, Exiger serves the world’s largest banks, Fortune 1000 companies and government agencies and regulators. This special five-part podcast series is sponsored by Exiger. Over the next five episodes, we will put a spotlight on Financial Institutions with Tara Loftus and Samar Pratt; focus on corporations with Aaron Narva and George ‘Ren’ McEachern; consider Federal Government and Supply Chains with Carrie Wibben and Vishnu Anantatmula; review the pillars of good compliance with Brandon Daniels and Carrie Wibben; and end with a review of third-party risk management solutions with Erika Peters and Skyler Chi.

In this Part 2, we put a spotlight on corporations and their challenges in managing third parties and with Supply Chain risk management. In this exploration I am joined by George ‘Ren’ McEachern, a Managing Director based in Exiger’s Silver Spring (DC Metro) office where he focuses on leading anti-bribery investigations and assisting multinational corporations and financial institutions with regulatory risk management. Also joining me in this episode is Aaron Narva, Head of Corporate Markets, based in Exiger’s New York office. He leads the development and delivery of Exiger’s purpose-built AI-powered solutions for anti-bribery and corruption compliance. While at Exiger, Aaron has conducted in-depth testing and review of complex financial institution compliance and anti-money laundering (AML) programs both in the US and abroad. His experience includes detailed assessment of transactions, customer due diligence, and policies and procedures. He also helped to design and develop Exiger Diligence, the investigative due diligence arm of Exiger.

Join us tomorrow where we consider areas some of the challenges the Federal Government has on Supply Chain risk management.
For more information on Exiger, click here.
For more information on George ‘Ren’ McEachern, click here.
For more information on Aaron Narva, click here.

Categories
The Ethics Experts

TEE Vendor Pain Points Bonus Episode 007: Matthew Meyers


On this special bonus episode of The Ethics Experts, we speak with Matthew Meyers about change-makers, Learning and Development challenges, and creating a learning culture.

Check out more episodes, and don’t forget to subscribe on your favorite podcast platform!

Categories
Innovation in Compliance

Helping Solve the Data Problem with David McLaughlin


David McLaughlin, founder and CEO of QuantaVerse, joins Tom Fox on this week’s show to discuss his company’s new risk management tool, Country Code Derivation. He explains that this capability was actually a part of their platform for some time, but they saw the need to offer it as a separate tool. “We found that there is a really specific and unique need for understanding the country code of transacting parties,” he says.

Identifying Risky Transactions
Tom and David discuss how Country Code Derivation assists organizations, including financial institutions, to identify potentially risky transactions. David explains that this tool is a “multimodal, layered approach of sifting through different capabilities to accurately identify where somebody’s jurisdiction is.” Determining the jurisdiction of a transaction is a core part of understanding risk, David points out. The advantages of using technology versus a manual process are obvious: technology is more accurate and efficient, can validate malformed data, and saves time and money. Tom asks if regular organizations can use this tool. David responds that it’s valuable for an organization that needs to determine the location of a party, be it vendors or customers. 
Compliance Officers Can Use It Too
Tom comments that Country Code Derivation can give compliance professionals access to data they may not have had access to before. David agrees. “It can provide compliance professionals with data that they need,” he says. “It can do it in a way that validates the accuracy of it. It can update it in a way that is automatic and systematic and regular.” Both men conclude that this tool is more important today – in the time of coronavirus – than it ever was. Many organizations have a data backlog because of the pandemic; Country Code Derivation helps to eliminate that backlog in quick time. 
Resources
QuantaVerse.net
QuantaVerse on LinkedIn
David McLaughlin on LinkedIn

Categories
The Ethics Movement

Guendeline Donde – Small budget, big impact: Scrappy compliance with limited resources


CONVERGE is in its 5th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with like-minded professionals. This year the conference has gone virtual. You will leave the conference with new resources and best practices allowing you to continue the hard work of driving ethics to the center of your business. In today’s episode I visit with Guendeline Donde, Director of Research at the Institute of Business Ethics. We visit about her panel at Converge20 on Small budget, big impact: Scrappy compliance with limited resources. 
Many organizations seek to make the move from a traditional legal program to that which marries user experience, behavioral science and technology – how difficult could it be? Guen will share practical advice from the Institute of Business Ethics’ Toolkit, developed in collaboration with subject matter experts from a variety of industries. For more registration and information on Converge20, click here.

Categories
The Ethics Experts

Episode 028–Dr. Christopher Marquis


On this episode of The Ethics Experts, Gio speaks with Dr. Christopher Marquis about B-Corps, generational purpose, and how ethics and compliance can lead this movement.

Check out more episodes, and don’t forget to subscribe on your favorite podcast platform!

Categories
31 Days to More Effective Compliance Programs

Internal controls for third parties


One of the questions GSK faced during the bribery and corruption investigation of its Chinese operations was how an allegedly massive bribery and corruption scheme occurred? Where were the appropriate internal controls? You might think that a company as large as GSK and one that had gone through the ringer of a prior DOJ investigation resulting in charges for off-label marketing and an attendant Corporate Integrity Agreement (CIA) might have such controls in place.
It would be reasonable to expect that internal controls over gifts would be designed to ensure that all gifts satisfy the required criteria, as defined and interpreted in company policies. It should fall to compliance to finalize and approve a definition of permissible and non-permissible gifts, travel and entertainment and internal controls will follow from such definition or criteria set by the company. These criteria would include the amount of the spend, localized down into increased risk such the higher risk recognized in China. Within this context, there are four general internal controls to consider. 1) Is the correct level of person approving the payment/reimbursement?; 2) Are there specific controls (and signoffs) that the gift had proper business purpose?; 3) Are the controls regarding gifts sufficiently preventative, rather than relying on detect controls?; and 4) If controls are not followed, is that failure detected?
Obviously, the use of third parties can be a powerful and effective way for a business to achieve its strategic goals. This may be one of the key reasons why third parties are still one of the leading indicia of bribery and corruption. Every compliance program should regularly review its third-party service providers and evaluate internal policies and procedures to ensure compliance.
Three key takeaways:

  1. GSK continues to be an example of the lack of internal controls for third-parties in an effective compliance program.
  2. General areas of review for compliance internal controls.
  3. Third parties are still the highest risk of corruption related issues.
Categories
Daily Compliance News

September 14, 2020-the Wonder Woman Delayed Again edition


In today’s edition of Daily Compliance News:

  • Oracle to purchase TikTok. (WSJ)
  • Is greed still good? (NYT)
  • Wonder Woman 1984 delayed (again). (WaPo)
  • Washington no closer to new name. (WSJ)
Categories
Innovation in Compliance

Exiger on the Evolution in Supplier Compliance in COVID – Spotlight on Financial Institutions with Tara Loftus and Samar Pratt


Welcome to a special five-part podcast series, sponsored by Exiger, on topics From Third-Party Risk Management to Supply Chain Risk Management: Exiger on the Evolution in Supplier Compliance in COVID. Exiger was founded to fight financial crime, fraud and terrorist financing by introducing technology-enabled solutions to the market’s biggest supply chain, risk, investigation, litigation, and compliance challenges. A global authority on risk and compliance, Exiger serves the world’s largest banks, Fortune 1000 companies and government agencies and regulators. Over this series, we will put a spotlight on Financial Institutions with Tara Loftus and Samar Pratt; focus on corporations with Aaron Narva and George ‘Ren’ McEachern; consider Federal Government and Supply Chains with Carrie Wibben and Vishnu Anantatmula; review the pillars of good compliance with Brandon Daniels and Carrie Wibben; and end with a review of third-party risk management solutions with Erika Peters and Skyler Chi.
In this Part 1, we put a spotlight in financial institutions. In this exploration I am joined by Tara Loftus, a Managing Director, who is a part of the Financial Crime Compliance Advisory practice focusing on anti-money laundering (AML) and anti-bribery & corruption (ABC) and Samar Pratt Managing Director who is also in the firm’s Financial Crime Compliance Advisory practice, specializing in audit and assurance.

Join us tomorrow where we consider areas where corporations have challenges on third parties and Supply Chain risk.

For more information on Exiger, click here.

For more information on Samar Pratt, click here.

For more information on Tara Loftus, click here.

Categories
FCPA Compliance Report

Jordan Arnold and Surjeet Mahant on the DFS Cyber Enforcement Action on First American Title

In this episode, I take a deep dive into the first cyber-security enforcement action brought by the state of New York, Department of Financial Services. It was against First American Title. In this exploration I am joined by Jordan Arnold, the Chief Innovation Officer at K2 Intelligence FIN. He is the founder and Global Chair of K2 Intelligence’s Private Client Services practice, which provides privacy and security services to ultra and high net worth families and clients in the entertainment, music, and sports industries and Surjeet Mahant, Managing Director in K2 Intelligence FIN’s Financial Crimes Risk and Compliance practice, where he leads cyber risk services. With over 20 years of experience in cybersecurity and privacy risk solutions for large institutions, Surjeet assists clients in developing the tools and strategies needed to protect the confidentiality of their data, the availability of their systems, and the integrity of their operations.
Some of the highlights include:

  • Overview of the enforcement action;
  • What are the broader consequences for the industry; significance of regulation/action; need for proactive actions;
  • What is the DFS and why is it regulating an insurance company around cyber?
  • Why has cyber become a part of the broader compliance conversation?
  • What specific steps can entities take to mitigate a violation or breach of data?
  • What can entities expect in the future from regulators in the cyber space?

For more information on K2 Intelligence FIN, click here.

Categories
Sunday Book Review

September 13, 2020, the Miscellaneous edition


In today’s edition of Sunday Book Review:

  • Summer by Ali Smith
  • Antkind by Charles Kaufman
  • God’s Shadow edited by Alan Mikhail
  • Wagnerism: Art & Politics in the Shadow of Music by Alex Ross