Tag: compliance

Categories
10 For 10

10 For 10: Top Compliance Stories For the Week Ending August 26, 2023

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  • Venezuela makes last ditch appeal re: CITGO. (Reuters)
  • SFO drops ENRC investigation. (FT)
  • Poverty a direct result of corruption. (Time)
  • Is due diligence over in China? (FCPABlog)
  • Ukraine institutes whistleblower bounty program. (BusinessInsider)
  • Nigerian ex-Energy Minister arrested for corruption by FCA. (Reuters)
  • Ex-Vitol employee to face FCPA charges. (WSJ)
  • ABC ex-prosecutor surges in Guatemalan Presidential race. (WaPo)
  • Lithium batteries scrutinized under UFLPA. (Reuters)
  • More Odebrecht indictments coming. (WSJ)

You can check out the Daily Compliance News for four curated compliance and ethics related stories each day, here.

Connect with Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 19 – Compliance Culture At The Bottom

One of the most important focuses of the DOJ’s 2023 ECCP was around culture. This means how far has the culture of compliance been driven down into an organization. The 2019 Guidance posed the following:
Culture of Compliance – How often and how does the company measure its culture of compliance? Does the company seek input from all levels of employees to determine whether they perceive senior and middle management’s commitment to compliance? What steps has the company taken in response to its measurement of the compliance culture?
These questions point to a CCO or compliance practitioner demonstrating how a culture of compliance is being burned into the very fabric of an organization. While leadership at and from the top has long been considered by both the DOJ and compliance professionals as a key element to move compliance forward, the 2019 Evaluation has also crystalized thinking around compliance culture throughout the organization, including at the bottom
Too often, strategies to move a compliance program or even an initiative come from the top of an organization and are pushed down. To fully operationalize compliance, you must have leadership in compliance further down the organization which (hopefully) has been a part of the design process and can lead the implementation throughout an organization.

Three key takeaways:

  1. While tone at the top is critical, the tone at the bottom can work to more fully operationalize compliance.
  2. 95% of the work is done at this bottom level.
  3. Use HR to come up with a strategy to move compliance into the bottom for more complete operationalization.

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

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 18 – Operationalizing Compliance in the Middle

The DOJ has made it clear that middle management is critical to any compliance program’s success. While it does all start at the top, with the Board of Directors and senior executives setting the tone for the rest of the company, prosecutors are mandated, under the 2023 Evaluation of Corporate Compliance Programs (ECCP), to show how middle management, in turn, has reinforced those standards and encouraged employees to abide by them. Moreover, the ECCP posed several questions to middle management, including the following: What actions have middle-management stakeholders taken to demonstrate their commitment to compliance or compliance personnel, including their remediation efforts? Have they persisted in that commitment in the face of competing interests or business objectives?

The DOJ expects compliance to be operationalized down to the middle management level. Further experience has shown that employees prefer to speak to their direct supervisors about issues or potential compliance violations they become aware of. The question is: how can a corporate compliance function reach middle management? This is a key area of assistance that Human Resources can provide, as one of the ways that HR can help to operationalize compliance is to assist each level of an organization to have a proper tone, specifically the middle of an organization.
You must think about your communication lines and communication skills when conveying your message of compliance from the top into the middle of your organization.

Three key takeaways:

  1. While the tone at the top is critical, the middle tone can work to operationalize compliance more fully.
  2. How do you train middle managers?
  3. What compliance tool kit do you provide to middle managers?

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

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 17 – Promotions to Operationalize Compliance

Welcome back as we dive into the role of HR in compliance and ethics. Today, we will explore the significant role of HR in operationalizing compliance within organizations. Join us as we uncover practical advice and data-driven insights on how HR can promote ethical behavior and create effective internal controls. According to the Department of Justice, promotions demonstrate a company’s commitment to compliance and ethics. By using advertisements to reinforce these values, organizations can showcase their dedication to fostering a culture of integrity and accountability.

The role of HR in corporate compliance programs should be more recognized. Suppose your company has a culture where compliance is perceived to compete or, worse yet, antithetical to HR. In that case, the company must hit all cylinders and may be moving towards dysfunction. Another way you can operationalize compliance is through HR’s involvement in employee promotion. Such compliance embedded into the promotion process can also be considered an internal compliance control. By doing so, your compliance may work to create an effective internal controls regime as mandated by the FCPA and other anti-corruption laws.

Three key takeaways:

  1. Denying a promotion or award due to an employee’s ethical lapses.
  2. Use promotions to reinforce your company’s commitment to compliance and ethics.
  3. Should you wait for great?

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

Categories
SBR - Authors' Podcast

SBR Authors Podcast: Mary Shirley – Living Your Best Compliance Life: Hacks for Engaging Compliance Programs

Mary Shirley’s conversational and authentic writing style is the focus of this podcast episode. As a compliance officer, she strives to make compliance topics more engaging and relatable. The episode delves into important aspects of compliance, such as program assessment, team building, culture and communications, and enhancing compliance programs. Mary’s book, “Living Your Best Compliance Life: 65 Hacks and Cheat Codes to Level Up Your Ethics and Compliance Program,” offers practical tips and “hacks” for improving compliance programs. The conversation also highlights the value of Compliance Week as a tool for engagement and feedback. Overall, the episode emphasizes the importance of authenticity, engagement, and continuous improvement in compliance functions.

Key Highlights Include

·      Mary’s Writing Style

·      Compliance Program Assessment

·      Enhancing Compliance Programs

·      Utilizing Compliance Week

·      Compliance Week Insights

·      Putting Advice into Practice

Resources

Mary Shirley on Linkedin

Living Your Best Compliance Life: 65 Hacks and Cheat Codes to Level Up Your Compliance Program

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Key Highlights Include

·      Mary’s Writing Style

·      Compliance Program Assessment

·      Enhancing Compliance Programs

·      Utilizing Compliance Week

·      Compliance Week Insights

·      Putting Advice into Practice

Resources

Mary Shirley on Linkedin

Living Your Best Compliance Life: 65 Hacks and Cheat Codes to Level Up Your Compliance Program

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 16 – The Exit Interview

Today, we’re diving into the significance of exit interviews in fully operationalizing a best practices compliance program. Exit interviews provide a valuable opportunity to gather unfiltered insights from departing employees, allowing organizations to enhance motivation, efficiency, and effectiveness. In this blog post, we’ll explore the practical benefits of conducting exit interviews and how they can transform departing employees into lifelong advocates for your organization.

The exit interview can be a further mechanism to operationalize compliance. This type of interview is used when someone voluntarily departs from a company, as opposed to a lay-off or reduction in force exercise. Typically departing employees are more willing to share about their experiences, concerns and issues which led to their employment departure.

Exit interviews are a powerful tool for fully operationalizing a best practices compliance program. They provide organizations with invaluable insights into employee perceptions, job design, and culture. By treating departing employees with dignity and respect, organizations can transform them into lifelong advocates, defending the organization’s reputation and recommending it to potential employees. Compliance ambassadors play a crucial role in strengthening compliance efforts, providing additional resources and support in regulatory issues. By asking detailed questions and fostering collaboration between compliance and HR, organizations can harness the power of exit interviews to enhance motivation, efficiency, and effectiveness in their compliance programs.

Three key takeaways:

  1. The exit interview is an excellent opportunity to obtain information to inform your compliance program.
  2. Use the exit interview to create advocates from departing employees.
  3. Use the exit interview for probing and insightful questions around compliance.

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

Categories
Innovation in Compliance

Innovation in Compliance – Chris Lehman on Navigating the Wild West: Digital Compliance Strategies

Innovation comes in many areas and compliance professionals need to not only be ready for it but embrace it. One of those areas is telehealth and telemedicine. My guest in this episode is Chris Lehman, CEO at Safeguard Cyber who visits with me to discuss the challenges and importance of managing risk in digital compliance.

The conversation focuses on the shift in communication channels from email to platforms like Slack and social media, highlighting the human factor as the biggest risk in compliance strategies. Lehman emphasizes the need for companies to prioritize compliance and good corporate governance in these new communication channels. To manage risk, companies should treat digital compliance as a risk management process, gaining visibility into employee communication tools, establishing policies, training employees, and utilizing technology.

We also highlight the tension between compliance teams and line of business teams, emphasizing the need for compliance teams to be enablers and strategic partners. The conversation references recent SEC enforcement actions and the importance of taking action to enforce compliance. Overall, digital compliance and governance are crucial in the modern business landscape, and utilizing technologies like monitoring tools and natural language understanding can help businesses stay secure and compliant in the digital age.

Highlights Include:

·      Safeguard Cyber: Securing Digital Communications

·      Managing Risk in Digital Compliance

·      Managing Risk in Compliance

·      Digital Compliance and Governance

 Resources

Chris Lehman on LinkedIn

Safeguard Cyber

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 15 – Employment Separation Issues and Compliance

Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of complaints, including those for concerns that impact the compliance practitioner. Yet there are several ways that operationalization will help to protect your company as much as possible.
The reasons for these actions are to allow you to demonstrate that any laid off employee was not separated because of a hotline or whistleblower allegation but due to your overall layoff scheme. However, it could be that you may need this person to provide your compliance department additional information, to be a resource to you going forward, or even a witness that you can reasonably anticipate the government may want to interview. If any of these situations exist, if you do not plan for their eventuality before you lay off the employee, said (now) ex-employee may not be inclined to cooperate with you going forward. Also, if you do demonstrate that you are sincerely interested in a meritorious hotline complaint, it may keep this person from becoming a SEC whistleblower.

Three key takeaways:

  1. Treat departing employees with dignity.
  2. Make sure your separation documents meet SEC requirements regarding disclosures re: whistleblowing.
  3. You must check your hotline and anonymous reporting systems to make sure you do not lay off a whistleblower.

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

Categories
10 For 10

10 For 10: Top Compliance Stories For the Week Ending August 19, 2023

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

·       Ukraine ABC lessons from Afghanistan. (NPR)

·       Paxton allegedly created fake Uber account to engage in corruption.  (Texas Tribune)

·       Inotiv facing FCPA issues around importing monkeys for research. (WSJ)

·       BNSF tries to settle massive data privacy claim.  (Reuters)

·       Federal corruption investigation heating up in Ohio. (Ohio Capital Journal)

·       SEC Whistleblower Program growing pains.  (WSJ)

·       African Development Bank not using ABC funds. (FT)

·       Aide to Madagascar leader arrested for corruption.  (FT)

·       Grupo Aval settles FCPA enforcement action. (WSJ)

·       Health care corruption sweep in China. (South China Morning Post)

You can check out the Daily Compliance News for four curated compliance and ethics related stories each day, here.

Connect with Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Compliance and AI

Compliance and AI-Julie Myers Wood on Navigating the AI Compliance Landscape: Mitigating Risks

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, we have the pleasure of hosting Julie Myers Wood, CEO of Guidepost Solutions. With her extensive background in law and government positions, Julie brings a wealth of knowledge and insights to our discussion on the challenges and considerations of incorporating AI into compliance programs.

As compliance professionals, we play a vital role in ensuring the safety and security of our businesses. The integration of AI into compliance programs presents both challenges and opportunities. By understanding the tools, risks, and solutions associated with AI, we can adapt to the changing landscape and make informed decisions.

Let’s embrace this exciting era of AI while staying vigilant and proactive. The world is changing, and compliance professionals need to stay up to date to ensure the safety and security of our businesses. Thank you, Julie Myers Wood, for sharing your valuable insights, and we look forward to more enlightening discussions in the future!

Remember, compliance professionals are the co-pilots of our businesses, guiding us through the complexities of the AI revolution. Let’s not wait too long between podcasts and continue this journey together!

Key Highlights

  • Key Considerations for Compliance and AI
  • Importance of Inventorying Tools and Managing Risks
  • AI and Intellectual Property Protection
  • Challenges of Implementing AI
  • AI and Compliance

 Resources

Julie Myers Wood on LinkedIn

Guidepost Solutions

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn