Categories
Data Driven Compliance

The Uses of Data Driven Compliance: Part 5 – Compliance Successes Using Data Driven Compliance

Welcome to Data Driven Compliance. In this podcast, we discuss how to use data to improve and enhance the effectiveness of your compliance program, creating greater business efficiency, all leading to more return on investment for your compliance regime. Join host Tom Fox as he explores how data will drive your compliance program to the next level. This podcast is sponsored by KonaAI.

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. Over these five podcasts, we have discussed generative AI and ChatGPT in compliance, the profiles of a corrupt payment, making the business case for data-driven compliance, what to ask for and how to ask for it, and some success stories. In this concluding Part 5, we will look at some compliance successes using a data driven approach.

In the world of business, compliance is a critical aspect that ensures organizations adhere to legal and ethical standards. Compliance not only helps companies avoid legal troubles but also plays a significant role in improving business efficiency and profitability. In this episode, Tom and Vince considered the advanced compliance tools for fraud detection and cost savings. Our discussion entailed a comprehensive analysis of the key factors that impact advanced compliance tools for fraud detection and cost savings, exploring the tradeoffs involved, the challenges faced, and the importance of considering the impact on decision-making.

Key Highlights:

  • Invoice Price Discrepancy Detection and Recovery
  • Compliance-driven Efficiency through Fraud Risk Analysis
  • Shifting Travel Expenses for Manufacturing Observations
  • Integrating Multiple Data Sources for Fraud Detection

Resources:

Connect with Vince Walden on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

Categories
31 Days to More Effective Compliance Programs

One Month to More Effective Written Standards: Day 9 – Dynamic Compliance Policies

One of the key changes coming out of the Covid-19 pandemic is the need for dynamism on corporate policies. This message was driven home in a  MIT Sloan Management Review article,“Turbulent Times Demand Dynamic Rules”. The authors believe, “Circumstances can change rapidly in an uncertain world — organizational rules should be designed to change along with them.”

This concept is most appropriate in the compliance arena in the area of risk management. As your risks change, your management of those risks should adapt to the new reality. This is why the DOJ intoned in the 2023 Evaluation of Corporate Compliance Programs (ECCP) that you should assess your risks as they change, modify your risk protocols, monitor your risk management strategy and then update your compliance programs through continuous monitoring.

This dynamic policy process can build dynamic rules to enhance your company’s ability to anticipate and cope with risk changes. When the corporate compliance function embraces experimentation and learning in the creation and reformulation of policies, it builds flexibility into the organization’s structure, processes, and practices. This type of flexibility is essential as we have moved from disaster recovery to business resiliency to business as usual, especially in the field of risk management.

Three key takeaways:

1. After Covid-19, your policies must be as dynamic as your business.

2. There are three general areas to improve the dynamic features of policy creation and improvement; transparency, experimentation and innovation.

3. Garner feedback from your users on the effectiveness of your compliance policies.

For more information, check out The Compliance Handbook, 4th edition, here.

Categories
Blog

Geopolitical Risks and Business Opportunities: Part 5- Doing Business With and In China

I recently had the opportunity to visit with Dr. Ian Oxnevad, Director of Geopolitical Risk intelligence at Infortal Worldwide. This visit was for a podcast series, sponsored by Infortal Worldwide entitled Global Risk Review. Dr. Oxnevad is a seasoned expert in geopolitical risk intelligence, with a PhD in political science and a master’s degree in National Security Studies. In this concluding blog post we look at risks in doing business in China. In this concluding blog post 5, we consider the risks and opportunities for US companies continued business with and in the country of China.

Oxnevad’s perspective on US companies considering leaving China is rooted in his understanding of the potential challenges they face, including political instability and property confiscation. He strongly advises companies to expedite the process of moving their assets out of China, citing the high risks involved, especially in the event of a war. Oxnevad suggests alternatives such as nearshoring or reshoring to safer locations like the United States, and also highlights India as a potential investment destination due to its large domestic market and lack of political issues with the US.

In recent years, China’s strict COVID-19 response and aggressive foreign policy have created political challenges and global inflation. These factors have prompted US companies to consider moving their operations away from China. Smaller Asia-Pacific countries, caught in the crossfire of geopolitical risks, lack the economic stability and military capacity to handle potential conflicts. As a result, India is emerging as a more stable option due to its democratic governance and institutional safeguards. However, Pakistan, with its history of authoritarian rule, security risks, and close ties with China, presents a unique and complex business landscape.

China’s foreign policy has become increasingly aggressive, despite its internal issues with state-owned enterprise debt and lingering resentment over COVID-19. This aggressive stance has raised concerns among American companies and others, leading them to explore options for decoupling from China. The potential risks of war and the resulting instability have become a significant factor in their decision-making process. Companies are now considering near-shoring, ally-shoring, or reshoring their operations to minimize their exposure to China.

One of the key flashpoints in the region is the tension between China and Taiwan. China’s regular incursions into Taiwanese waterways and airspace have raised the possibility of a conflict erupting overnight, with no advanced warning. The situation is further complicated by China’s tensions with India in the Himalayas. Hand-to-hand battles between Indian troops and the Chinese military have occurred, highlighting the long-standing competition between the two countries. The potential for a massive war involving China, Taiwan, Japan, Australia, India, and the US is a real concern, with nuclear weapons adding to the instability.

Given these risks, US companies are exploring alternatives to China, with India emerging as a potential destination. India offers a more stable investment environment compared to China, with its democratic governance and experience with parliamentary procedures. While India has its own internal issues, such as corruption, it still maintains a commitment to democratic principles and the rule of law. Additionally, India’s large domestic market and its central location make it an attractive option for companies looking to diversify their supply chains.

However, it is important to note that India is not without its risks. The country has shown tendencies towards autocracy and strongman rule, although these tendencies are not as pronounced as in some other countries. India’s federal structure and institutional safeguards provide some protection against the consolidation of power by a strongman leader. While no country is immune to political risks, India’s democratic experience and commitment to democratic principles make it a relatively stable option compared to other countries in the region.

The potential risks in China have also raised the question of whether US companies should consider near-shoring or reshoring their operations back to the United States. The government can play a role in facilitating such efforts through tax incentives, grants, and other types of incentives. However, the decision to reshore or near-shore is not without tradeoffs. Companies must weigh the potential benefits of reduced exposure to geopolitical risks against the costs of relocating their supply chains and the potential impact on their relationships with Chinese partners and customers.

In conclusion, US companies are seriously considering leaving China amid the political challenges and geopolitical risks in the region. The potential for conflict, particularly involving Taiwan, has raised concerns about the stability of supply chains and the safety of investments in China. India is emerging as a more stable alternative, with its democratic governance and institutional safeguards. However, companies must carefully consider the tradeoffs involved in relocating their operations and the potential impact on their business relationships. The decision to leave China is not an easy one, but it is a reflection of the increasing uncertainties and risks in the region.

You can check Dr. Oxnevad in the full five-part Riskology by Infortal podcast series here.

Categories
Blog

Compliance Successes Using Data-Driven Compliance

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI for a podcast series on the uses of data driven compliance. KonaAI is the sponsor of those podcasts. This blog post series will flesh out the podcast show notes. Over the next five blog posts, we will discuss generative AI and ChatGPT in compliance, the profiles of a corrupt payment, making the business case for data-driven compliance, what to ask for and how to ask for it and some success stories. In this Part 5, we will look at some compliance successes using a data-driven approach.

As always, I am joined by Vince Walden, founder and CEO of KonaAI. There is a quiet revolution happening in the realm of compliance. It’s one that, if harnessed correctly, can turn a typically reactive process into a proactive strategy. I am of course talking about data-driven compliance. By making use of the vast amounts of data your organization collects, you can uncover potential compliance risks before they turn into actual problems. This approach can be a game-changer, not just for your role as a compliance officer, but also for your organization’s overall risk management strategy. No longer will you be caught off guard. Instead, you’ll be leading the charge, armed with real-time insights and actionable data.

Sometimes, we face unintended consequences in a business setting – consequences that occur unexpectedly because of actions taken. They could be beneficial, like improvements to the business or reduced costs. Or, they could point to underlying issues that need addressing. However, these consequences can become visible only when multiple risk triggers are considered. Here’s the interesting bit. Vince underscored the importance of considering multiple risk triggers when analyzing data. Relying on just one test or indicator won’t cut it. It isn’t just one anomaly that signals an issue. The convergence of multiple risk signals helps in identifying the potential problem areas.

Compliance is not simply about rules and regulations. It is about understanding and managing risks, ultimately leading to better business decision-making. When well-executed, it can yield great rewards or “compliance wins”. One example is identifying high-risk areas in your business and managing them proactively. A high-risk business unit in high-risk FCPA environments. By analyzing their fraud risks, the company found that salespeople wound up spending quite a bit on gifts, travel, and entertainment for foreign officials to secure a sale. The solution? Limit setting. Not only did it save them money, but decreased the sales cycle, and the cherry on top – a clientele of higher quality.

Using data analysis techniques to improve business efficiency is of utmost importance in today’s business environment. By leveraging data analysis, you have the power to identify bottlenecks, streamline processes, and optimize your operations. This not only saves time and resources but also enhances overall compliance and risk management efforts. With every step you take towards harnessing the power of data, you are paving the way for increased business efficiency and success in your industry.

Compliance is the critical aspect that ensures organizations adhere to legal and ethical standards. Compliance not only helps companies avoid legal troubles but also plays a significant role in improving business efficiency and profitability. Data driven  of advanced compliance tools for fraud detection and cost savings was discussed. This article aims to provide a comprehensive analysis of the key factors that impact advanced compliance tools for fraud detection and cost savings, exploring the tradeoffs involved, the challenges faced, and the importance of considering the impact on decision-making.

One of the advanced compliance tools discussed in the episode is Unit Price Analysis. This tool utilizes advanced technology to identify discrepancies in vendor invoices, potentially saving companies significant amounts of money. By comparing prices charged for the same product by the same vendor in different locations, contract compliance can be achieved. As Walden explained, even a small difference in unit prices can translate into substantial recoveries when multiplied by tens of thousands or hundreds of thousands of units. This tool highlights the importance of scrutinizing vendor invoices and ensuring fair pricing across different locations.

To effectively detect fraud and ensure compliance, it is crucial to integrate multiple data sources into compliance monitoring programs. As Vince Walden mentions, transparency is key, and integrating various data sources brings that transparency into play. By pulling in third-party payments, due diligence work, sanctions lists, whistleblower hotline data, and other indicators, companies can gain actionable insights and identify improper payments and risk scoring. The ability to put in multiple risk triggers and analyze data from various sources allows for a more comprehensive and accurate assessment of potential risks.

However, implementing advanced compliance tools for fraud detection and cost savings is not without its challenges. It is essential to know when to stop reviewing transactions or high-risk activities. Risk scoring frameworks help prioritize the most critical transactions, but continuous improvement is necessary to update the models and identify any missed risk triggers. Additionally, the complexity of integrating multiple data sources and implementing advanced compliance tools requires careful planning and consideration.

The impact of advanced compliance tools for fraud detection and cost savings goes beyond financial benefits. These tools can change the character of the people who interact with the company. By shifting the responsibility of travel expenses to foreign officials, the company not only achieved significant cost savings but also attracted decision-makers who came to sign contracts. This unexpected outcome demonstrates the power of compliance and fraud risk prevention in improving business efficiency and quality of customers.

In conclusion, advanced compliance tools for fraud detection and cost savings play a crucial role in ensuring legal and ethical standards are met while improving business efficiency and profitability. Unit Price Analysis and Fraud Risk Analysis are just two examples of such tools discussed in the podcast episode. By integrating multiple data sources, implementing risk scoring frameworks, and continuously improving compliance models, companies can achieve transparency, identify risks, and make informed decisions. However, it is important to consider the challenges and tradeoffs involved in implementing these tools. Ultimately, the impact of advanced compliance tools extends beyond financial benefits, positively influencing the overall business environment.

Resources:

Connect with Vince Walden on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

Categories
31 Days to More Effective Compliance Programs

One Month to More Effective Written Standards: Day 8: Revising Your Policies and Procedures

More than simply having a Code of Conduct, compliance policies and procedures are required. As former Assistant Attorney General Lanny Breuer articulated, “Your compliance program is a living entity; it should be constantly evolving.” The 2012 FCPA Guidance stated, “When assessing a compliance program, DOJ and SEC will review whether the company’s Guiding Principles of Enforcement have taken steps to ensure that the Code of Conduct remains current and effective and whether a company has periodically reviewed and updated its code.”

After considering these issues, you should benchmark your current policies and procedures against those of other companies in your industry. If you decide to move forward, I suggest a process that can be fully documented to include revisions to your compliance policies and procedures. These points are a useful guide to not only thinking through how to determine if your policies and procedures need updating but also taking practical steps to tackle the problem. You should begin the process now if it has been more than five years since the last update. It is far better to review and update if appropriate than wait for a massive FCPA investigation to go through the process.

Three key takeaways:

  1. You should do so now if you have not revised your compliance policies and procedures in the past five years.
  2. Set a timeline and budget and stick to it in the compliance policy and procedure revision process.
  3. Document your process of revision to demonstrate a more complete operationalization of your compliance program.

Check out The Compliance Handbook, 4th edition, here for more information.

Categories
Data Driven Compliance

The Uses of Data Driven Compliance: Part 4 – What to Ask For and How to Ask For It

Welcome to Data Driven Compliance. In this podcast, we discuss how to use data to improve and enhance the effectiveness of your compliance program, creating greater business efficiency, all leading to more return on investment for your compliance regime. Join host Tom Fox as he explores how data will drive your compliance program to the next level. This podcast is sponsored by KonaAI.

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. Over these five podcasts, we will discuss generative AI and ChatGPT in compliance, the profiles of a corrupt payment, making the business case for data-driven compliance, what to ask for and how to ask for it, and some success stories. In Part 4, we discuss what data a CCO needs to ask for and how to do so.

Vince Walden brings knowledge and experience in continuous compliance monitoring and risk assessment processes. Walden’s perspective on the topic is that it should be approached as a journey, not a one-time program. He emphasizes the importance of proactive risk assessments and continuous monitoring, advocating for an iterative approach demonstrating constant improvement in compliance efforts. This perspective is shaped by his belief that meeting regulatory expectations requires a diligent and ongoing commitment to improvement.

Walden also suggests that data sources should be identified based on the results of the fraud risk assessment and that the ease of obtaining the data should be considered when prioritizing analytics projects. To delve deeper into what data a CCO should ask for and how to ask for it, join Tom Fox and Vince Walden on this Data Driven Compliance podcast episode.

Key Highlights:

  • Continuous improvement through risk assessments and monitoring
  • Effective risk assessment through diverse data sources
  • Uncovering hidden relationships through expense categories

Resources:

Connect with Vince Walden on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

Categories
Life with GDPR

Life With GDPR: WhatsApp Breach: Hospital’s GDPR Failures Exposed

Tom Fox and Jonathan Armstrong, renowned experts in cyber security, co-host the award-winning Life with GDPR. The recent controversy surrounding Nigel Farage’s banking situation highlights the risks and compliance challenges faced by the banking industry in relation to data protection. In this episode, Tom and Jonathan discuss a data breach in a Scottish hospital during the COVID-19 pandemic.

The breach occurred when hospital staff shared patient details on WhatsApp, raising concerns about GDPR compliance. The hospital informed the ICO about the breach but chose not to notify affected patients, highlighting the need for appropriate advice and support when making such decisions. The conversation also explores communication challenges in internal investigations and the privacy and security risks of platforms like WhatsApp. It emphasizes the importance of organizations adapting to the preferences of digital native employees and conducting data protection impact assessments. The podcast also highlights the importance of effective policies, training, and proactive phishing training to prevent cyber-attacks and protect sensitive information.

 

Key Takeaways:

  • Data breach in Scottish hospital
  • The Challenges of Communication in Internal Investigations
  • Importance of Policies and Training
  • Phishing Training Effectiveness

Resources

For more information on the issues raised in this podcast, check out the Cordery Compliance News Section. For more information on Cordery Compliance, go to their website here. Also, check out the GDPR Navigator, one of the top resources for GDPR Compliance, by clicking here.

Connect with Tom Fox

Connect with Jonathan Armstrong

Categories
Blog

Geopolitical Risks and Business Opportunities: Part 4 – Factors Impacting European Financial Integration

I recently had the opportunity to visit with Dr. Ian Oxnevad, Director of Geopolitical Risk Intelligence at Infortal Worldwide. This visit was for a podcast series sponsored by Infortal Worldwide entitled Global Risk Review. Dr. Oxnevad is a seasoned expert in geopolitical risk intelligence, with a Ph.D. in political science and a master’s degree in National Security Studies.

Ian Oxnevad is a seasoned expert in geopolitical risks impacting European financial integration and opportunities, with a profound understanding of Europe’s internal and external crises since 2008. We will consider factors affecting European financial integration in Part 4 of this five-part blog post series. Oxnevad’s perspective is that Europe has been grappling with constant internal stressors and external crises, such as banking crises and political upheavals, which pose significant risks to European financial integration. He underscores the need for enhanced risk analysis at the national level and geopolitical risk intelligence to navigate the uncertainties in Europe.

However, Oxnevad also identifies opportunities for US companies, particularly in the energy sector, to export to Europe, especially in the context of a stronger Euro. He further discusses the regulatory risks posed by GDPR and ESG laws in Europe and how US companies must manage these risks. In this blog post, we deeply dive into these complex and evolving geopolitical risks in Europe and their potential impact on financial integration and opportunities.

Europe has been facing many challenges impacting its financial integration and potentially altering the European Union (EU) and the Euro in a recent episode of the Riskology podcast hosted by Tom Fox and featuring Ian Oxnevad, the discussion centered around the geopolitical risks that Europe is currently grappling with and the opportunities that arise amidst these challenges.

One of the key factors affecting European financial integration is the ongoing Russia-Ukraine war. This conflict, coupled with rising energy prices, Middle East instability, and unchecked migration, puts pressure on the region’s financial integration and potentially changes the EU and the Euro as a monetary unit. These external pressures, along with internal populism, ongoing inflation, and high energy costs, are fueling resentment and could significantly impact European integration and its governing laws.

The Russia-Ukraine war has spilled energy inflation, creating monetary instability and supply chain issues. Annual inflation rose by 40% in June 2022 due to the invasion, and it remains high at 16.6% as of February this year. This inflationary pressure affects various aspects of the economy, including consumer spending capacity, production capacity, and manufacturing affordability. Governments have increased spending to offset these costs, further straining the Euro and limiting the ability to navigate these challenges through monetary means.

The pressures Europe faces are not limited to the EU as a whole but extend to the national level. This shift necessitates a greater focus on risk analysis at both levels, as the rules and regulations governing European integration may change suddenly and overnight. The emergence of populism across the EU, as seen in France and the Netherlands, indicates growing animosity towards incumbents and a desire for change. This political upheaval poses risks and uncertainties for businesses operating in Europe, as regulations, taxation, and even the monetary unit itself may be subject to change.

Despite these challenges, there are opportunities for US energy companies to export to Europe. The weakening of the dollar and the strength of the Euro make Europe an attractive export location for US goods and services, including energy. However, regulatory risks and challenges must be carefully considered. Europe’s robust data protection and privacy laws, such as the General Data Protection Regulation (GDPR), and its focus on environmental, social, and governance (ESG) factors present potential risks for US companies. Compliance with these regulations requires careful risk management and due diligence.

ESG initiatives, particularly the push for renewable energy, present countervailing risks. While there is a regulatory push for green energy, the inefficiencies and costs associated with these technologies and the reliance on minerals from regions with questionable labor practices create challenges. Balancing the environmental (E) aspect of ESG with the social (S) and governance (G) aspects requires careful consideration and geopolitical risk intelligence.

The banking sector is also facing turmoil, with institutions like Deutsche Bank and Swiss banks experiencing challenges. While it is unlikely that the German government would allow Deutsche Bank to fail, the stability of these institutions and their role in global monetary and fiscal policy is a concern. The European Central Bank, the Bank of England, and the US Federal Reserve play crucial roles in stabilizing the financial systems, but their ability to navigate these challenges remains to be seen.

In conclusion, the geopolitical risks impacting European financial integration and opportunities are complex and multifaceted. Europe’s response to the Russia-Ukraine war, rising energy prices, Middle East instability, and unchecked migration will shape the future of the EU and the Euro. Balancing the tradeoffs involved in managing these risks, such as the need for defense spending versus protecting consumers, requires careful analysis and risk intelligence. US companies can find opportunities in exporting to Europe, but they must navigate regulatory risks and consider the contradictions within ESG mandates. The banking sector’s stability and global institutions’ role in stabilizing the financial systems are also areas of concern. As Europe faces these challenges, it is crucial to consider the impact on financial integration and opportunities when making decisions.

Please join us tomorrow when we explore geopolitical risks and business opportunities in China and the greater Asia Pacific region.

You can check Dr. Oxnevad in the full five-part Riskology podcast series here.

Categories
Data Driven Compliance

The Uses of Data Driven Compliance: Part 3 – Making the Business Case for Data Driven Compliance

Welcome to Data Driven Compliance. In this podcast, we discuss how to use data to improve and enhance the effectiveness of your compliance program, creating greater business efficiency, all leading to more return on investment for your compliance regime. Join host Tom Fox as he explores how data will drive your compliance program to the next level. This podcast is sponsored by KonaAI.

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. Over these five podcasts, we will discuss generative AI and ChatGPT in compliance, the profiles of a corrupt payment, making the business case for data-driven compliance, what to ask for and how to ask for it, and some success stories. Part 3 discusses how to make the business case for data-driven compliance.

Vince Walden, a seasoned professional with over 25 years of experience in compliance and risk management, is the founder and CEO of KonaAI, a software company specializing in automating data management for compliance and fraud risk management. Walden believes that compliance professionals play a crucial role in data-driven risk management. He emphasizes the need for these professionals to make a business case for data-driven compliance to both risk professionals and the CFO or head of operations.

According to Walden, data-driven compliance not only aligns with regulatory expectations and avoids risks, but it also improves the overall functioning of the business by identifying hidden money, reducing costs, eliminating waste and fraud, and preventing improper payments. His perspective is shaped by his extensive experience in the field, including his work as a consultant, fraud investigator, and forensic technologist. Join Tom Fox and Vince Walden as they delve deeper into this topic on this episode of Data Driven Compliance.

Key Highlights:

  • The Importance of Data Driven Compliance
  • Effectively Conveying Compliance Value to CFOs
  • The Impact of Data Driven Compliance
  • Maximizing Compliance ROI through Risk Mitigation

Resources:

Connect with Vince Walden on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

Categories
31 Days to More Effective Compliance Programs

One Month to More Effective Written Standards: Day 7 – Policies and Procedures

There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the government comes knocking. The 2020 Update made clear that “Any well-designed compliance program entails policies and procedures that give both content and effect to ethical norms and that address and aim to reduce risks identified by the company as part of its risk assessment process.

This statement made clear that the regulators will take a strong view against a company that does not have well-thought-out and articulated policies and procedures against bribery and corruption, which are systematically reviewed and updated. Moreover, having policies written out and signed by employees provides what some consider the most vital communication layer and acts as an internal control. Together with a signed acknowledgment, these documents can serve as evidentiary support if a future issue arises. In other words, the “Document, Document, and Document” mantra applies just as strongly to policies and procedures in anti-corruption compliance.

The specific written policies and procedures required for a best practices compliance program are well-known and long-established. According to the 2020 FCPA Resources Guide 2nd edition, some of the risks companies should keep in mind include the nature and extent of transactions with foreign governments (including payments to foreign officials), use of third parties; gifts, travel, and entertainment expenses; charitable and political donations; and facilitating and expediting payments. Policies help form the basis of expectations for standards of conduct in your company. Procedures are the documents that implement these standards of conduct.

Three key takeaways:

1. Written compliance policies and procedures, together with the Code of Conduct, form the backbone of your compliance program.

2. The DOJ and SEC expected well-thought-out and articulated compliance policies and procedures to be adequately communicated throughout your organization.

3. Institutional fairness for the application of policies and procedures demands the consistent application of your policies and procedures across the globe.

For more information, check out The Compliance Handbook, 4th edition, here.