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Leveraging Machine Learning with the Right Internal Audit Solution

Visitors face an ever-expanding landscape of challenges and opportunities in today’s world. Machine learning (ML) represents a transformative force, offering new ways to enhance audit quality, efficiency, and insight. But how can internal auditors effectively integrate this technology into their workflows? The key lies in choosing the right internal audit solution that seamlessly incorporates ML capabilities, ensuring auditors are equipped to tackle today’s complexities while preparing for tomorrow’s challenges.

Machine learning (ML) is a subset of artificial intelligence that focuses on developing systems that can learn from and make decisions based on data. In internal auditing, ML can automate repetitive tasks, identify patterns in large datasets, and even predict future trends. This not only speeds up the audit process but also enhances the accuracy and depth of audit insights.

Key Applications of Machine Learning in Internal Audits:

  • Risk Assessment: ML algorithms can analyze vast amounts of data to identify risk patterns and anomalies, helping auditors focus on areas with the highest risk.
  • Control Testing: Automated ML tools can test controls more frequently and thoroughly than manual processes, increasing the likelihood of detecting control failures.
  • Fraud Detection: ML can help predict and identify fraudulent activities based on historical audit data, thereby reducing potential losses.
  • Predictive Analytics: ML can forecast potential non-compliances or areas where controls might fail, allowing auditors to be proactive rather than reactive.

Selecting the right software solution is crucial when integrating ML into internal auditing. There are some critical factors to consider. The ML-powered audit solution must seamlessly integrate with IT infrastructure and data systems. This integration ensures auditors can leverage ML capabilities without disrupting existing workflows or data integrity. As organizations grow and data volumes increase, the ML solution should be able to scale accordingly. This includes handling more extensive datasets and adapting to new audits and compliance requirements.

ML can be complex, but the user interface of the audit solution should be different. A user-friendly interface that simplifies complex processes allows auditors to utilize ML features effectively without needing specialized training. Your chosen solution should offer advanced data analytics features, including data visualization tools, which help auditors make sense of the patterns and anomalies detected by ML algorithms. These tools are crucial for translating ML insights into actionable audit decisions. Any ML solution must comply with relevant data protection regulations, such as GDPR in the European Union or HIPAA in the United States. Additionally, the solution should have robust security measures to protect sensitive audit data from unauthorized access or breaches.

If there is one overlap between ML and traditional internal audit, it is that solutions for internal audit are not static, and ML is no different. ML continuously learns from new data and auditing experiences. This capability ensures that the system evolves and improves its accuracy and effectiveness. Finally, tech support is critical, especially when deploying complex technologies like ML. The right solution provider should offer comprehensive support and training, helping audit teams fully understand and leverage ML capabilities.

Successfully implementing an ML-powered audit solution involves more than just selecting the right software; you should have a planned strategy for an effective implementation. Some strategies for effective implementation include engaging relevant stakeholders early in the process, including IT, compliance, and executive teams, to ensure alignment and address any concerns. Test before implementation so that pilot tests of the ML solution can be conducted in specific audit areas before a full rollout. This helps identify any issues and refine the system for better performance. Training on any new system is critical, especially with an advanced ML solution. You should provide extensive training and support to audit staff to help them adapt to the latest tools and processes.  But as with any new rollout, it does not stop with implementation, as there should be continuous monitoring and continuous improvement as warranted.  Change management practices can facilitate a smoother transition and higher adoption rates.

As the complexity of business environments and regulations continues to grow, the role of internal audit becomes increasingly critical. Leveraging machine learning within audit solutions offers a path forward to keep pace with these changes and stay ahead of them. By choosing the right ML-powered internal audit solution and implementing it thoughtfully, audit departments can transform operations, delivering more value and stronger organizational compliance. The future of internal auditing is not just about adapting to changes—it’s about leading the charge with innovation and insight.

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Innovation in Compliance

Innovation in Compliance: The Evolution of Compliance and Technology: An Interview with Stuart Breslow

Innovation comes in many areas and compliance professionals need to not only be ready for it but embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast.

In this episode, Tom welcomes Stuart Breslow, a member of the Board of Directors at StarCompliance., who takes a deep dive into the evolution of tech solutions for compliance.

Breslow has had extensive journey in compliance, including professional roles at Morgan Stanley, Credit Suisse, McKinsey, and Google Cloud. He was the CCO at Morgan Stanley. Our conversation takes a deep dive into the transformation of compliance through technological solutions, the evolution of Codes of Conduct, and the impact of digital tools on compliance efficiency.

Breslow advocates for the use of technology to scale compliance efforts, address evolving challenges, and integrate compliance more seamlessly with business operations. Emphasizing data analysis and proactive risk identification, Breslow believes that modern compliance tools not only enhance efficiency and effectiveness but also contribute significantly to business profitability. Breslow also explores the future role of generative AI and how StarCompliance is poised to leverage advanced data management to enhance compliance functions.

Key Highlights:

  • Evolution of Compliance Technology
  • The Role of Codes of Conduct in Compliance
  • Digital Transformation in Compliance
  • Future of Compliance with Generative AI

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StarCompliance

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Sunday Book Review

Sunday Book Review: September 1, 2024, Books on Continuous Monitoring Edition

In the Sunday Book Review, Tom Fox considers 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, we look at four books on continuous monitoring for the compliance professional.

  • Continuous Monitoring A Complete Guide – 2024 Edition by Geradus Blokdyk
  • Monitoring Continuous Phenomena: Background, Methods and Solutions by Peter Lorkowski
  • Implement Continuous Monitoring a Complete Guide by Geradus Blokdyk
  • DevOps Continuous Monitoring by Bart de Best (Author), Louis van Hemmen (Editor)

Grab the Middle Managers Tool Kit, available free from Ethico by clicking here.

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Compliance Tip of the Day

Compliance Tip of the Day: Envisioning Training

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we explore how to envision your compliance training through a set of Training Principles.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Compliance and AI

Compliance and AI: Art Mueller on Enhancing Financial Crime Programs with AI

What is the role of Artificial Intelligence in compliance? What about Machine Learning? Are you using ChatGPT? These are but three questions we will explore in this cutting-edge podcast series, Compliance and AI, hosted by Tom Fox, the award-winning Voice of Compliance.

In this episode, Tom visits with Art Mueller, a thought leader in using AI to help fight financial crime.

Art Mueller, a seasoned expert with over 20 years in compliance programs and anti-financial crime initiatives, offers a transformative perspective on the role of AI and machine learning in financial crime programs. As the current lead at WorkFusion, he emphasizes the critical shift from manual processes to AI and automated solutions, enhancing efficiency and significantly reducing false positives. Mueller champions using AI to provide valuable insights into client risks and transactions, thereby improving job satisfaction for analysts and decreasing turnover rates. Drawing on his extensive field experience, he highlights the substantial advancements and benefits these technologies bring to risk management and mitigation in the financial sector through AI.

Key Highlights:

  • Financial Crime Prevention Solutions with AI Technology
  • AI-enhanced Adverse Media Screening for Compliance
  • Enhancing Risk Management Through Anomaly Detection with AI
  • Enhancing Financial Crime Programs with AI

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Blog

Bank of America’s Corporate Culture Crisis: Part 5 – A Case Study for Compliance

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture problems are a powerful reminder of compliance’s critical role in safeguarding employees and the organization.

This week, I have explored the BoA failure around workplace culture from various perspectives articulated by the Everything Compliance gang, including Karen Woody, Jonathan Armstrong, Matt Kelly, Karen Moore, and Jonathan Marks. This exploration included the failure of internal controls, failures by the Board and senior management, culture failures around highly driven, self-selecting employees, and the cultural miasma that is BoA from a perspective from across the pond. You can check out the full Everything Compliance episode here. We conclude our series with a summary of lessons learned for compliance and how compliance can use those lessons going forward.

The scandal at BoA involving the excessive hours worked by junior employees highlights a profound crisis in corporate culture that has significant implications for compliance professionals. Despite previous promises of reform following similar incidents, BoA’s failure to address these issues effectively reveals systemic problems that transcend mere policy implementation. The tragedy of junior banker Leo Lukenas, who died after working over 100 hours a week for multiple weeks in a row, underscores the urgent need for stronger internal controls, better communication between management levels, and a culture that genuinely prioritizes employee well-being.

This situation at BoA serves as a critical case study for compliance professionals, illustrating the dangers of a disconnect between senior management’s intentions and the actions of middle management. While senior executives may set policies to limit overwork, middle managers often circumvent these rules, perpetuating a toxic work environment. BoA’s manual control system’s failure, ineffective internal audits, and HR oversight further exacerbate the problem. Compliance professionals must ensure that internal controls are implemented, actively monitored, and enforced to prevent similar issues in their organizations.

A key lesson from the BoA crisis is the importance of addressing the role of incentive structures. In high-stakes environments like investment banking, where bonuses and career advancement are tied to deal closures, there is a significant risk of overwork becoming normalized. Compliance officers must advocate for realigning incentives to balance business goals with ethical standards and employee well-being. This involves addressing the symptoms of such crises and tackling the root causes, such as toxic corporate culture and misaligned incentives.

The BoA scandal highlights the critical role of internal controls in maintaining a healthy and sustainable corporate culture. Relying on self-reporting as a key control mechanism in this high-risk environment proved ineffective, as employees were pressured to underreport their hours. Compliance professionals must recognize that self-reporting should be supplemented with independent verification methods, such as automated time tracking and regular audits, to ensure accurate data collected and controls are effective.

A holistic approach to risk management and compliance must be considered. Internal controls must be integrated into a broader framework, including solid ethical leadership, ongoing employee education, and clear channels for reporting concerns. The failure of BoA’s control environment, monitoring, and remediation efforts allowed a culture of overwork to persist, ultimately leading to repeated tragedies. For compliance professionals, this underscores the need for continuous improvement and active management of internal controls.

The role of the board of directors in overseeing corporate culture is crucial. The BoA crisis demonstrates that board members must go beyond surface-level management reports and engage directly with employees to understand workplace challenges. A proactive approach, including regular reports on employee well-being metrics and internal audits focused on workplace culture, can help prevent such crises. Moreover, creating a culture where employees feel safe to voice concerns is essential for identifying and addressing risks before they escalate.

The Bank of America scandal is a stark reminder of the human cost of a toxic work culture and the vital role that compliance professionals play in safeguarding both employees and organizations. The lessons from this tragedy should guide efforts to create healthier, more sustainable work environments. Compliance is not just about preventing legal and regulatory risks but also about fostering a corporate culture that values integrity, transparency, and the well-being of all employees. By aligning business metrics with these values, companies can achieve sustainable success that benefits their bottom line and people.

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Compliance Tip of the Day

Compliance Tip of the Day: Using Your Supply Chain to Enhance Compliance Communication

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we explore how external stakeholders, such as your supply chain, can enhance your compliance communications.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Everything Compliance

Everything Compliance: Episode 139, The Bank of America Episode

In this episode, we take up the recent imbroglio surrounding the Bank of America and its toxic workplace culture of 100+ hour work weeks. We have the full quintet of Matt Kelly, Jonathan Armstrong, Karen Woody, Jonathan Marks, and Karen Moore; all hosted by Tom Fox.

  1. Matt Kelly mines the matter for compliance lessons learned. He shouts out the GOP speakers at the recently concluded Democratic National Convention who bucked their party for the good of the nation.
  2. Jonathan Marks explores how internal controls were in place but not completely disregarded. He shouts out to researchers at the University of Pennsylvania for its work in CAR T cell therapy to treat certain types of cancer.
  3. Karen Moore considers the matter from the perspective of the Board of Directors and what their role should be. She shouts out to her students in the new semester of her class at Fordham Law School.
  4. Karen Woody takes a deep dive into the district court’s recent dismissal of the SEC complaint against Solar Winds. She shouts out the persons who ran the Democratic National Convention for a great Convention.
  5. Jonathan Armstrong reviews the entire matter from his UK perspective. He rants about Elon Musk and hate speech on X.
  6. Tom Fox shouts out to Rick Springfield and his hit song Jessie’s Girl as one of the two most well-known and sung songs from the 1980’s.

The members of the Everything Compliance are:

  • Karen Woody – Is one of the top academic experts on the SEC. Woody can be reached at kwoody@wlu.edu
  • Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com
  • Jonathan Armstrong –is our UK colleague and an experienced data privacy/data protection lawyer in London. He can be reached at his new law firm Jonathan.Armstrong@puntersouthall.law
  • Jonathan Marks can be reached at jtmarks@gmail.com
  • Karen Moore can be reached at Kmoore51@fordham.edu

The host and producer, rantor (and sometime panelist) of Everything Compliance is Tom Fox the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the award-winning Compliance Podcast Network.

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Blog

Bank of America’s Corporate Culture Crisis: Part 4 – A Tale of Metrics and Misalignment: Lessons for Compliance Professionals

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture problems are a powerful reminder of compliance’s critical role in safeguarding employees and the organization.

This week, I will explore the BoA failure around workplace culture from various perspectives articulated by the Everything Compliance gang, including Karen Woody, Jonathan Armstrong, Matt Kelly, Karen Moore, and Jonathan Marks. This exploration will include the failure of internal controls, failures by the Board and senior management, culture failures around highly driven, self-selecting employees, and the cultural miasma that is BoA from a perspective from across the pond. In Part 4, we consider a misconnection of metrics. This issue is not merely a question of productivity but a fundamental concern about corporate culture, ethics, and long-term sustainability.

In corporate governance and compliance, aligning business metrics and ethical obligations often defines a company’s culture’s success or failure. The recent Wall Street Journal (WSJ) article about BoA and its investment banking metrics sheds light on a crucial disconnect that compliance professionals must address: the disparity between business performance indicators and employee well-being.

At the heart of the issue is the nature of the metrics used to evaluate success in different industries. In investment banking, the primary focus is often on closing deals. The logic is straightforward: deals drive revenue, and revenue drives the bottom line. This singular focus on deal-making creates an environment where the end justifies the means, potentially overlooking the toll it takes on employees.

Conversely, in law firms, the metric of success is often billable hours. Lawyers are compensated and promoted based on the number of hours they bill, which can lead to a different, yet equally problematic, set of behaviors. Over-inflating hours or working excessive hours becomes the norm because that is the path to career advancement.

Both systems create perverse incentives: investment bankers might underreport hours to avoid raising HR flags, while lawyers might overreport hours to enhance their career prospects. These behaviors highlight a crucial point for compliance professionals: the metrics set at the top of an organization inevitably shape the behavior throughout the company.

One of the first steps in addressing these issues is understanding the available data and how it is used. Compliance professionals must ask themselves, “What data do we have, and how can it be used to monitor and manage risks effectively?” By focusing solely on deal closure, companies are potentially neglecting data related to employee well-being, such as hours worked or stress levels.

In contrast, law firms have systems that track the minutiae of an employee’s workday, from time spent on tasks to keystrokes made during document review. This data is invaluable for billing clients and identifying patterns that may indicate overwork or burnout. Compliance professionals in investment banking could learn from this approach, using technology to track hours worked or monitor workload distribution, ensuring that employees are kept within reasonable limits.

The core issue is more alignment between business metrics and corporate culture risks. Compliance professionals must ensure senior management acknowledges overwork as a significant risk and takes proactive steps to monitor and mitigate it. This involves tracking the traditional success metrics and implementing metrics that reflect the company’s values and culture.

For example, if overwork is recognized as a risk, metrics such as average hours worked, employee turnover rates, and employee satisfaction surveys should be regularly monitored and reported. This dual approach allows a company to pursue business success while ensuring its corporate culture remains healthy and sustainable.

The responsibility of aligning these metrics rests not solely with middle management, compliance officers, or senior management; it extends to the board of directors. The board’s oversight role is crucial in ensuring that the company’s culture is preserved in pursuing financial success. For boards everywhere, the recent scrutiny BoA received in the WSJ article serves as a lesson.

Board members must go beyond the surface level of management reports and delve into the realities of the workplace culture. This requires more than attending board meetings in luxurious settings and listening to pre-prepared presentations. It involves engaging directly with employees at all levels, understanding their challenges, and prioritizing their well-being.

A practical approach could involve the board requiring regular reports on employee well-being metrics, mandating internal audits focused on workplace culture, or even conducting anonymous employee surveys to get an unfiltered view of the corporate environment.

An effective compliance program also hinges on creating a culture where employees feel safe to voice their concerns. A speak-up culture is essential in identifying issues before they escalate into major risks. Management and the board should encourage employees to report inconsistencies between policy and practice and take these reports seriously.

For instance, if employees consistently report working beyond reasonable hours, this should trigger an investigation and subsequent action from the board. Such feedback mechanisms help identify risks and reinforce the company’s commitment to ethical practices.

Lastly, when issues do arise—such as the tragic death of a young employee in the Bank of America case—the board should conduct a root cause analysis. This analysis should not be limited to the immediate cause but should explore deeper systemic issues that may have contributed to the incident.

A comprehensive root cause analysis might reveal that the focus on deal closure at the expense of employee well-being is not an isolated issue but indicative of a broader cultural problem. The board could use this analysis to implement changes across the organization, ensuring that similar incidents do not occur in the future.

The lessons are clear: the metrics that companies use to measure success are powerful drivers of behavior. The challenge for compliance professionals is ensuring that these metrics align with business goals, ethical standards, and employee well-being. This requires a proactive approach, leveraging data to monitor business performance and corporate culture. It also requires a board that is engaged, informed, and committed to understanding the realities of the workplace.

In the end, compliance is not just about preventing legal and compliance risks but about fostering a corporate culture that values integrity, transparency, and the well-being of all employees. By aligning metrics with these values, companies can achieve sustainable success that benefits their bottom line and people.

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Compliance Tip of the Day

Compliance Tip of the Day: Asking Questions for Compliance

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we consider the technique of asking questions to improve both culture and compliance at your organization.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.