Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 1 – Introduction

In her October 2021 speech, presaging the Monaco Memo, Deputy Attorney General Lisa Monaco talked at length about the importance of corporate culture. She noted, “Corporate culture matters. A corporate culture that fails to hold individuals accountable or fails to invest in compliance — or worse that thumbs its nose at compliance — leads to bad results. Let me also be clear: a company can fulfill its fiduciary duty to shareholders and maintain a commitment to compliance and lawfulness. Companies serve their shareholders when they proactively place compliance functions and spend resources anticipating problems. They do so both by avoiding regulatory actions in the first place and receiving credit from the government. Conversely, we will ensure the absence of such programs inevitably proves a costly omission for companies who end up the focus of department investigations.” These thoughts were formalized in the Monaco Memo.

What does all this mean for compliance professionals going forward? DOJ officials have emphasized that the changes laid out in the Monaco Memo and the requirements around CCO Certification are to empower compliance professionals. In the Monaco Speech, DAG Monaco stated, “Companies should feel empowered to do the right thing—to invest in compliance and culture and to step up and own up when misconduct occurs. Companies that do so will welcome the announcements today. For those who don’t, however, our Department prosecutors will be empowered, too—to hold accountable those who don’t follow the law.” However you may characterize it, I will channel my inner Glenn Fry (with a nod to Miami Vice) and simply say to CCOs and compliance professionals, “The Heat is On.”

Three Key Takeaway:

  1. The DOJ will now evaluate corporate culture in an enforcement action.
  2. You must assess, manage, monitor, and improve your culture.
  3. Corporate culture is now a key metric for regulators.
Categories
Great Women in Compliance

Great Women in Compliance – Renee Rajkumar – The Heart of Compliance

Today’s episode features Renee Rajkumar, a Risk and Compliance Manager at the University of Arts, London. Hemma was very excited to host her long-time friend and compliance mentor to talk about how compliance is the conscience of the organization. Renee shares tips on how to overcome negative perceptions of the compliance function, how to build trust, motivate risk awareness and compliance, and how to leverage the strengths of your business partners while doing so. Learn about a new form of AI in compliance called “Added Intelligence” – first coined here. Grab a blanket and a cup of tea and tune in to hear how, with a little love and care, compliance can be the heart and pulse of an organization – and create the conditions where our internal business partners are the best source of compliance intelligence and risk management.

Hailing from the warm island of Trinidad and Tobago, Renee is enthusiastic about life and the happiness of people. She believes in the value of genuinely caring for others. This is the basis of Renee’s career background. Indecisive in the earlier days of her career, Renee worked in process operations, quality, marketing, and advertising health and fire safety and has now ended up in risk and compliance. Renee’s unique skill set and approach bring fresh and easy energy to risk and compliance.

Renee is also the founder of Portal Coaching Limited, which she launched at the start of the COVID lockdown. She is trained in NLP, solution-based coaching, business coaching, and hypnotherapy. Renee started Portal Coaching Limited to work with companies and individuals to help them gain clarity on who they are, their purpose, work situations, and relationship issues. She calls herself a Liberator and has set many people free of their worries and negative thought patterns. Renee draws on these principles in her various training with a seamless cross-application into coaching and Compliance.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance-related offerings. GWIC is also sponsored by Corporate Compliance Insights, where we have a page where you can hear every episode. If you are enjoying this episode, please rate it and/or provide a review.

Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press, publishing the related book, “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review. Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review. Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

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.

Categories
FCPA Compliance Report

FCPA Compliance Report: Marco Goldberg – Creating Trust with Comprehensive Solutions

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Marco Goldberg, Managing Director of EQS Group’s North American Business, which assists organizations in navigating the complex world of compliance and building a culture of trust.

Marco Goldberg is a seasoned professional in corporate compliance and investor relations solutions, with a rich background in international industrial management and an MBA from the Berlin School of Business and Entrepreneurship. The EQS Group is a leading provider of corporate compliance and investor relations solutions, serving about 9,000 customers globally. He emphasizes the importance of trust in international organizations and sees EQS Group’s mission as helping to create trusted companies through their solutions. His experiences in the industry and his active participation in hosting the ECEC, Europe’s largest compliance conference, have shaped his perspective. Join Tom Fox and Marco Goldberg on this episode of the FCPA Compliance Report podcast to learn more about his insights and experiences.

 Key Highlights:

  • Creating Trusted Companies with Comprehensive Solutions
  • IntegrityLine: Empowering Employees for Compliance
  • EU Whistleblower Protection Directive: Creating a Culture of Integrity
  • Centralizing Compliance Workflows with AI Technology
  • The Transformative Power of AI in Compliance

 Resources:

Marco Goldberg on LinkedIn

EQS Group

 Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Blog

Leadership Lessons from the Presidents of the Republic of Texas – David Burnet: Building a Republic

The Republic of Texas holds a unique place in American history as a short-lived independent nation. In this special four-part blog post series, I will be diving into the intriguing world of the presidents of the Republic of Texas, shedding light on their leadership styles, political tensions, and the challenges they faced. This blog post focuses on one of the lesser-known presidents, David G. Burnett. It highlights the key factors that impacted the presidencies and politics of the early Republic of Texas.

David G. Burnett, who served as the first President of the Republic of Texas from March 1836 to October 1836, had a complex character and a fascinating background. He was an early adopter of filibustering, lending his sword to the Bolivarians in Venezuela during the Latin American wars for independence. However, he eventually returned to the United States when factions within the revolutionary forces split.

Burnett arrived in Texas in 1826 as an impresario, but his venture as a land grant holder failed. He was also known for his solid Presbyterian beliefs, adding another layer to his character. Despite his short tenure as president, Burnett played a crucial role in the survival and legitimacy of the Republic of Texas.

One of Burnett’s notable achievements was his strategic retreats during the early days of the Republic. By moving the government promptly, he managed to avoid capture and preserve the fledgling nation’s chances of success. Additionally, Burnett’s decision to spare the life of Santa Ana, the Mexican general, demonstrated his understanding of the role Santa Ana could play in negotiations and helped maintain the credibility of the Republic of Texas.

However, Burnett’s presidency was not without its challenges. Tension and intra-personal politics characterized the power transfer from Burnett to his successor, Sam Houston. Burnett was initially reluctant to turn over the government to Houston, leading to name-calling and insults between the two. Eventually, Burnett resigned, allowing Houston to start his first term early. Despite their differences, Burnett and Houston would cross paths politically multiple times in the future.

Factions and differing visions for the nation characterized the politics of the early Republic of Texas. Burnett represented one vision, while figures like Sam Houston embodied another. These divisions extended beyond the question of independence, with debates over issues such as slavery and Indian policy. Personal politics played a significant role, with politicians openly insulting each other and even threatening duels.

Burnet’s short tenure as the first President of the Republic of Texas highlights the enduring relevance of these early political dynamics. The reality is that there is absolutely nothing new under the sun when it comes to vicious politics. The Republic of Texas, if captured on camera, would have made for great reality TV. The challenges faced by early Texas politicians resonate with the political landscape of today.

David G. Burnet’s story is one of resilience and principle. Despite personal tragedies and adversities, he remained committed to his beliefs. Burnett’s inflexibility on specific issues, such as his hardline stance on Indian policy, may have rubbed some people the wrong way. However, it is undeniable that he played a significant role in shaping the early Republic of Texas.

Exploring the presidencies and politics of the early Republic of Texas provides valuable insights into the challenges and tradeoffs involved in nation-building. The podcast series offers a comprehensive analysis of the key factors that impacted the Republic of Texas and highlighted the importance of considering historical context when making decisions about leadership and politics.

Some of the vital leadership lessons from Burnet include:

  1. Adaptability and Resilience: Burnet assumed office during a tumultuous time when Texas was engaged in a struggle for independence from Mexico. He had to adapt quickly to changing circumstances and make difficult decisions to ensure the survival of the fledgling republic. Compliance professionals and business leaders can learn from his ability to remain resilient and composed in adversity.
  2. Vision and Mission Focus: Burnet strongly advocated for Texas independence and had a clear vision for the republic’s future. Influential leaders articulate a compelling vision and mission that inspire their followers and provide a sense of purpose. Chief Compliance Officers should have a vision for their compliance program and constantly strive to implement it.
  3. Pragmatism: Burnet recognized the importance of practicality and pragmatism in leadership. He worked to secure international recognition and support for the Republic of Texas, demonstrating his ability to navigate complex diplomatic challenges. Business leaders and compliance professionals should be willing to adapt their strategies to achieve their goals.
  4. Commitment: Burnet’s commitment to the cause of Texas independence was unwavering. He endured personal hardships and challenges to advance the republic’s interests. Chief Compliance Officers who demonstrate dedication to their compliance vision and mission often inspire greater loyalty and commitment from their compliance teams.
  5. Communication Skills: Effective communication is a crucial leadership skill, and Burnet was known for his ability to convey the republic’s goals and needs to foreign governments and potential allies. It may go without saying, but I will say it anyway: every CCO and compliance professional must be adept at conveying their message clearly and persuasively.
  6. Collaborative Leadership: Burnet understood the importance of collaboration and worked closely with other leaders and military figures, such as Sam Houston, to achieve common goals. CCOs and compliance professionals who can build and maintain effective partnerships with the business team will achieve more significant results than those who cannot.
  7. Adherence to Principles: Despite his challenges, Burnet remained committed to liberty and self-determination. CCOs and compliance professionals uphold their core values and principles, even in the face of adversity or temptation to compromise.
  8. Graceful Transition: Burnet voluntarily stepped down from the presidency after his term, demonstrating a commitment to the democratic process and a willingness to facilitate a smooth transition of power. Business leaders should recognize when it is time to pass the torch and do so gracefully.

It is important to note that David Burnet’s leadership lessons should be viewed in the historical context of the Republic of Texas and its struggle for independence. While some aspects of his leadership may not directly apply to modern leadership challenges, the principles of adaptability, vision, commitment, and effective communication remain relevant for leaders in any era. David G. Burnett’s presidency, though short-lived, left a lasting impact on the nation. The tensions and personal politics between Burnett and Sam Houston exemplify the challenges faced by early Texas politicians. By understanding the complexities of this period, we gain valuable insights into the tradeoffs and challenges involved in nation-building.

Categories
Creativity and Compliance

Creativity and Compliance – An Ounce of Prevention

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network.
Ronnie’s company, Learnings, and Entertainment, utilizes the entertainment devices people use to consume information in their everyday, non-work lives and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies, and resources more accessible. Today, Ronnie and Tom, as they consider compliance training and communication, are being used in the best, highest use, and most effective manner.
The topic of shifting compliance programs towards prevention and engagement is compelling, as it challenges the traditional reactive approach and advocates for a more proactive, engaging strategy. Ronnie believes that most compliance programs are reactive rather than proactive. He argues that a shift towards prevention, communication, burst learning, and leadership development can mitigate risks more efficiently and make compliance training more interesting and positive. Tom echoes this sentiment, emphasizing the need for engaging, entertaining, and impactful compliance programs. He suggests that by focusing on prevention, communication, shorter training, and leadership development, companies can create a culture of psychological safety and reduce the time and money spent on investigations and problems.

Join Tom Fox and Ronnie Feldman on this Creativity and Compliance podcast episode as they delve deeper into this fascinating topic.

Key Highlights:

  • Shifting Towards Prevention: The Key to Effective Compliance
  • Using Comedy to Transform Compliance Training
  • Engaging and Time-Efficient Micro-Learning Modules
  • The Importance of Proactive Compliance Measures

Resources:

Ronnie

Categories
Compliance and AI

Compliance and AI – Caroline Shleifer on How AI Enhances Regulatory Intelligence and Compliance

What is the role of Artificial Intelligence in compliance? What about Machine Learning? Are you using ChatGPT? These questions are but three of the many questions we will explore in this exciting new podcast series, Compliance and AI. Hosted by Tom Fox, the award-winning Voice of Compliance, this podcast will look at how AI will impact compliance programs into the next decade and beyond. If you want to find out why the future is now, join Tom Fox on this journey to the frontiers of AI.

Welcome back to another exciting episode of our podcast, where we delve into the fascinating world of compliance and artificial intelligence (AI). Today, I am joined by Caroline Shleifer, CEO and founder of RegAsk. Regulatory intelligence plays a crucial role in today’s business landscape, where regulatory requirements constantly evolve. Staying ahead of these changes is not only essential for compliance but also offers a competitive advantage. In this episode, Tom and Caroline Shleifer deeply dive into how AI and other emerging technologies enhance regulatory intelligence and compliance.

Key Highlights:

  • Proactive Compliance through Regulatory Intelligence Automation
  • Streamlining Regulatory Compliance with AI
  • Leveraging Data Analytics for Proactive Compliance
  • Revolutionizing Compliance with Emerging Technologies

Resources:

Caroline Shleifer on LinkedIn

RegAsk

Tom Fox

Threads

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Into the Chair - Tales from Chief Compliance Officers

Into the Chair, Tales from Chief Compliance Officers: Anh Lam on Navigating Compliance Challenges in a Changing Landscape

Welcome to the latest edition of the Compliance Podcast Network: Into the Chair: Tales from Chief Compliance Officers, which details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to navigate the compliance waters in any company successfully? What are some of the top challenges CCOs have faced, and how did they meet them? These questions and many others will be explored in this new podcast series. Into the Chair: Tales from Chief Compliance Officers is a Comply podcast hosted by Tom Fox and is a production of the Compliance Podcast Network. In this episode, I visit with Anh Lam, Senior Vice President and Chief Compliance Officer at Sandy Spring Bank.

Anh Lam, a seasoned professional in compliance management, brings a unique perspective shaped by her personal and professional experiences. Born and raised in Vietnam, Anh’s interest in wealth management was sparked by her father’s experience with misleading investments in a country with limited regulations. Now serving as the Chief Compliance Officer for Sandy Spring Bank’s wealth divisions, Anh believes in the enduring importance of compliance but also sees a future where technology and artificial intelligence play a significant role in making compliance more efficient and effective. She envisions a future where each firm has its internal AI system integrated with different platforms to adapt to changing regulations and anticipates a global standardization of compliance regulations, akin to the GDPR for privacy regulations. Join Tom Fox and Anh Lam as they delve deeper into these topics on the next episode of the Into the Chair podcast.

Key Highlights:

  •   Protecting Investors’ Money through Compliance Expertise
  •   Navigating Compliance Challenges in a Changing Landscape
  •   The Rise of AI in Compliance

Resources:

Anh Lam on LinkedIn

Comply

Connect with Tom Fox:

Threads

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Great Women in Compliance

Great Women in Compliance – A Roundtable on Leveraging Compliance Connections

Welcome back to the Great Women in Compliance podcast. In today’s episode, we kick off our new roundtable format with two special guests joining Hemma and Lisa in discussing leveraging our connections to have an impact at scale in our work. As compliance professionals, we take on more and more and are often involved in complex and novel issues that are difficult to solve alone with confidence. Tune in to hear how Fatema Merchant and Karin Johnson have navigated this during their professional journeys and how they not only send the elevator back down but also help each other ensure they support each other when they are on their way up. Tune in to hear how Karin and Fatema have prioritized connection in their compliance work both from an in-house and outside counsel perspective.

We acknowledge that we are in an incredibly challenging moment as we watch with deep sadness and emotion what is happening in Israel, Gaza, and beyond. These events were very much on our minds during the recording of this podcast.

Karin Johnson is the VP of Ethics and Compliance at VF Corporation. VF is the parent company of iconic brands such as The North Face ®, Vans®, Timberland®, and Smartwool ®. Prior to joining VF, Karin was Vice President, Deputy General Counsel, and Chief Compliance Officer for 21st Century Fox. Fatema Merchant is a partner in the law firm Sheppard Mullin, where she is co-managing partner of the Washington, D.C. office. Fatema leads the sanctions team at the firm and is a partner in the Governmental and Corporate Investigations Practice Groups. Prior to joining the firm, Fatema seconded as a Special Assistant Attorney General with the District of Columbia Office of the Attorney General.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance-related offerings. GWIC is also sponsored by Corporate Compliance Insights, where we have a page where you can hear every episode. If you are enjoying this episode, please rate it and/or provide a review.

Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press, publishing the related book, “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review. Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review. Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

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.

Categories
Compliance Into the Weeds

Compliance into the Weeds: Szabolcs Fekete and the Consequences of Ethical Breaches

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more thoroughly, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt deeply dive into the termination of Citibank employee Szabolcs Fekete over cheating on his expense account, then lying about it and drawing out broad lessons for the compliance professional.

The importance of trust, accountability, and ethics in the workplace cannot be overstated. These elements are the bedrock of a healthy corporate culture and are crucial for maintaining a positive and productive work environment. Tom believes that a broader conversation about these topics is necessary within corporations. He emphasizes the need for employees to understand the importance of trust, accountability, and adherence to policies and procedures.

Matt echoes these sentiments. He shares a poignant story about a CEO who had to fire a cleaner for embezzlement and dishonesty, underlining the critical role of trust in upholding ethical standards. Both Fox and Kelly acknowledge the cynicism among the public and the workforce regarding ethical enforcement, and they advocate for a commitment to doing the right thing, even when it is difficult. Join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into this crucial topic.

 Key Highlights:

  • Expense Report Dishonesty and Wrongful Termination
  • Citibank’s Expense Report Policy and Trust
  • The Consequences of Ethical Breaches
  • The importance of trust and ethical enforcement

 Resources

Matt in Radical Compliance

Jane Croft in the FT

Pilita Clark in the FT

Tom 

Threads

Instagram

Facebook

YouTube

Twitter

Categories
SBR - Authors' Podcast

SBR Authors Podcast: Adam Balfour on Ethics and Compliance for Humans

Welcome to the Sunday Book Review, the Authors Podcast! Don’t miss out on this episode of SBR-Author’s Podcast, where Tom sits down with Adam Balfour on his book Ethics & Compliance for Humans.

Adam Balfour, a Scottish-born compliance professional, has been leading the compliance program for the Americas region at Bridgestone. Balfour strongly believes in the importance of ethics, compliance, and leadership within organizations, arguing that these elements can significantly contribute to financial success. He likens the role of ethics and compliance professionals to soccer midfielders, who defend and support the team’s growth. Balfour’s perspective is shaped by his experiences and passion for ethics and compliance, leading him to write a book titled “Ethics & Compliance for Humans,” providing valuable resources for compliance professionals. Join Tom Fox and Adam Balfour on this episode of the SBR-Author’s Podcast as they delve deeper into these topics.

Key highlights include:

  • The Duality of Human Nature
  • The Importance of Guiding Employees Ethically
  • Humanizing Compliance Programs: Building Ethical Relationships
  • Engaging Compliance Training through Pop Culture
  • Navigating Ethical Dilemmas in the Workplace
  • The Role of a Unifying Purpose Leader

Resources:

Adam Balfour on Linkedin

Ethics & Compliance for Humans

Tom Fox

Threads

Instagram

Facebook

YouTube

Twitter

LinkedIn