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Compliance Tip of the Day

Compliance Tip of the Day: Compliance Training Design Objectives – Part 1

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 begin our consideration of the top 10 design objectives for any compliance training program.

 

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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

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Great Women in Compliance

Great Women in Compliance: Roxanne Petraeus and Susan Divers on Building a Listen Up Culture

In this episode of Great Women in Compliance, Hemma and Sarah visit with Roxanne Petraeus and Susan Frank Divers to talk about intentionally building a “Listen Up” culture. Tune in to hear the powerful origin stories of two great women in compliance who have been moved to drive significant impact in this space, from enterprising business solutions, to innovative learning and development strategies, to thoughtful approaches to measuring culture and employee sentiment as a measure of success.

Highlights include the ways in which listening builds trust, how to measure impact, not activity, how to achieve integrated risk management, how to design your employee training with employee experience and employee sentiment in mind, and despite our aspirational claims to be building a strong speak up culture, how our employees will always be the actual arbiter of our success.

You can learn more about Roxanne and Susan’s work at www.ethena.com.

Biographies:

Roxanne Petraeus is the CEO and Co-Founder of Ethena, a compliance training platform startup with intuitive and powerful admin tools that make required training easy, engaging, and effective.

Roxanne previously consulted for McKinsey, and before that, she was an officer in the US Army. She found that no matter the setting, whether consulting or in the military, there remained an opportunity to make compliance training better. She started Ethena in 2019 with Co-Founder Anne Solmssen.

Ethena enjoys incredibly positive word of mouth within the HR community, and is trusted by thousands of companies like Figma, Notion, Noom, Pinterest, and Carta to provide actionable training. And the employees love it: Ethena has a 93% positive rating, and over 2M positive reviews. Roxanne is a natural leader, and her eagerness to question and reinvent old paradigms is at the heart of Ethena’s ascendance.

Susan Frank Divers serves as an advisor to Ethena, Inc., an all-in-one compliance training platform that helps companies create more ethical and inclusive work cultures. Prior to joining Ethena, she was the director of thought leadership and best practices for LRN Corporation for seven years.

She has 30+ years’ accomplishments and experience in the ethics and compliance arena. This expertise includes building state-of-the-art compliance and training programs, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance.

Prior to joining LRN, Ms. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Ms. Divers’ thought leadership in the ethics field. In 2011, Ms. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program.

#GWIC is proud to announce that it has been nominated for the WomenInPodcastAwards.  This is a people’s choice award and whether you vote for #GWIC or other nominees, we ask that you send the elevator back down by voting. Voting opens August 1, 2024, and details can be found on the #GWIC LinkedIn page at http://www.linkedin.com/groups/12156164

Resources:

Join the Great Women in Compliance community on LinkedIn here.

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Compliance Tip of the Day

Compliance Tip of the Day: Compliance Training Design Objects – Overview

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 why every compliance function should have design objectives for any compliance training program.

 

For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here.

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

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Blog

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

Resources:
StarCompliance

Tom Fox

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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

Resources:

Art Mueller on LinkedIn

WorkFusion

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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.