Tag: compliance

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Great Women in Compliance

Krista Muszak – She’s Simply the Best

Welcome to the Great Women in Compliance Podcast, hosted by Mary Shirley and Lisa Fine. It’s fitting that for this International Women’s Day that we feature one of the brightest sparks in the Ethics and Compliance space, Krista Muszak.

It can be difficult to change industries in Compliance. Some organizations look for exact industry experience and pigeonhole individuals into one track of practice. Krista is someone who manages to transition between industries with ease and offers her tips for doing so.

 She shares a bit about what it’s like to focus on SOX Compliance, as she did in her previous role and now on Mergers and Acquisitions risk, which she is doing now. Congratulations to Krista on her new role!

Mary’s favorite part of this episode is when Krista talks about who she admires (spoiler alert, it’s one of the GWIC team), closely followed by a fabulous and innovative idea Krista shares to help sales folk look at Compliance from another angle that also serves the purpose of acting as a gap analysis for Compliance. You’ll want to listen to this episode to be inspired by and leverage from Krista’s creative brilliance.

 Lisa and Mary wish everyone an amazing International Women’s Day. We are pleased to recognize our peers for your fierce and formidable accomplishments. Keep shining!

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings to listen in to.  If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it.  If you have a moment to leave a review at the same time, Mary and Lisa would be so grateful.  You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast.  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.

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.

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SBR - Authors' Podcast

Keith Read – An Unconventional Compliance Officer

Welcome to the Sunday Book Review, the Authors Podcast! On this episode, Tom welcomes special guest Keith Read, former Chief Compliance Officer at British Telecom and author of The Unconventional Compliance Officer. Keith discusses how effective measures can be taken to improve compliance within a given company, even when it comes to hard issues like GDPR, conflicts of interest, and more. He emphasizes the importance of utilizing data in compliance and reminds companies to look at the outcomes and not just inputs. He claims his book to be a wealth of resources for better understanding compliance and explains that it can be found on multiple digital marketplaces. Join Tom Fox as he dives deep into the world of compliance with Keith Read and his groundbreaking book.

Key Highlights Include

  • The Benefits of Applying Behavioral Psychology in Business [00:03:53]
  • Accessibility of Customer Hotlines [00:07:32]
  • EU Anti-Retaliation Policy for GDPR [00:11:15]
  • Shifting Focus from Inputs to Outcomes [00:15:12]
  • Exploring Positive Conflicts of Interest in the 21st Century [00:18:52]
  • Role of Data & Compliance in Modern Business Practices [00:22:49]
  • The Benefits of Data Analysis for Companies [00:26:32]

Notable Quotes

  1. “We had 99 percent of people trained on anti-corruption compliance.”
  2. “What I spend a lot of time doing is how can you turn that push into pull?”
  3. “Everybody sees conflicts of interest as negative. I mean, maybe that’s an overstatement, but if somebody suddenly sends you an email to say, we won’t report your, you know, any conflict of interest and so on. It’s, again, it’s another example of compliance push.”
  4. “What I call is the corporate shield. It was the exercises. It’s more than it’s the exercise I developed. Which was to say, you know, you could do a very quick and dirty analysis of how risk has changed.”

Resources

The Unconventional Compliance Officer

Keith Read on LinkedIn

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Blog

The Week That Was in Compliance – The Polite Speech: Part 1

We are in the midst of a multipart review of last week’s speeches from the Department of Justice (DOJ) at the recently concluded ABA’s 38th Annual National Institute on White Collar Crime, held in Miami. Compliance professionals, white collar defense lawyers and indeed corporate executives will be talking about the past week in Miami for many moons to come. The speeches were made by Deputy Attorney General Lisa Monaco (2023 Monaco Speech) and Assistant Attorney General Kenneth A. Polite (Polite Speech) and they previewed a number of initiatives by the DOJ which every compliance professional will need to study in some detail. These new initiatives included:

The Criminal Division’s Pilot Program Regarding Compensation Incentives and Clawbacks

Evaluation of Corporate Compliance Programs (Updated March 2023)

Revised Memorandum on Selection of Monitors in Criminal Division Matters

Over this series, I will be taking a deep dive into these speeches and new Evaluation of Corporate Compliance Program, Monitor Selection and Pilot Program on Incentives and Clawbacks. Today we continue with an initial review of the Polite Speech.

Polite began with a clear plea for the righteousness of being a prosecutor. Interestingly he began by describing what he saw at the ABA White Collar conference in San Francisco, “During a short afternoon walk between the hotel and the U.S. Attorney’s Office, we saw homelessness, and drug addiction, and food insecurity, and lack of hygiene, and violence.” He went on to add “Human suffering. We see it in every city where this conference gathers, be it the Tenderloin area of San Francisco, Liberty City here in Miami, or the Lower Ninth Ward in New Orleans. The same things could be found in nearly every town across this country. Across this globe. Right outside. Right around us. Right around you, if you decide to open your eyes and accept a broader definition of community.” From there he related being a DOJ prosecutor to a calling to help fix these problems but being “problem-solvers”.

He used these domestic urban ills to transition to what he called a ‘righteous’ prosecution of Claudia Patricia Diaz Guillen, the former National Treasurer of Venezuela and her husband. They were charged with accepting over $100 million “in bribes from a Venezuelan billionaire businessman for access to purchase bonds from the Venezuela National Treasury at a favorable exchange rate. All the while, millions of Venezuelans had to confront daily economic crisis, rampant inflation, and unimaginable poverty and hunger.” This is while “96% of Venezuelans lived in poverty.” He ended this section by noting the prosecution was “a virtuous case that spanned the globe to hold multiple corrupt actors accountable and remove corrupt leadership – this prosecution exemplifies what our prosecutors can do.”

Polite believes that there is a clear tie between poverty and corruption. (One reason the San Francisco remarks were so interesting.) This is why it is important to prosecute corrupt government officials such as Diaz because her actions keep the people of Venezuela in such dire economic straits. He stated, “Just as crime recognizes no borders, our efforts to combat it must be equally boundless. We need our partners – both domestic and international – to solve community problems. That is where the Criminal Division thrives.” In the Diaz case there was international cooperation at various levels. Think about that for a moment, the US and Venezuelan governments cooperating on anything, yet they apparently did cooperate on this matter. Polite added that several recent Foreign Corrupt Practices Act (FCPA) corporate enforcement matters, “Glencore, ABB, Danske, and Stericycle, among many others, underscore the successes that we’ve shared with our colleagues abroad.”

To be truly effective community problem-solvers, we have to broaden our sense of community by literally ‘spanning the globe’ to fight crime, including bribery and corruption. Polite stated, “Crime does not limit itself by country or region. Corruption’s corrosive effects are global, with the world’s poor often bearing the brunt. Bribery threatens our collective security by undermining the rule of law and providing a breeding ground for other crime and authoritarian rule.”

He pointed to this level of international cooperation which “has also been critical to MLARS’s work on the Kleptocracy Asset Recovery Initiative, which has targeted and restrained more than $3.6 billion relating to foreign official corruption and associated money laundering affecting the U.S. financial system.” As the US financial systems plays the central role in the world’s financial community and international banking system, the US MLARS Bank Integrity Unit (BIU) has worked to bring to justice “actors around the world seek to exploit the U.S. financial system, in some instances working with global financial institutions that facilitate their crimes.” Hence why the US and not Danske Bank’s home country of Denmark brought the criminal charges against the Banks for its role in a years-long money laundering operation out of its Estonia branch.

To demonstrate this commitment for the DOJ Polite stated, “since 2010, the BIU – with just 12 attorneys – has imposed more than $13 billion in financial penalties in 10 corporate criminal resolutions with global financial institutions for sanctions violations.” But more commitment is on the way as Polite pointed to “our Deputy Attorney General’s announcement yesterday of additional resources for the BIU and her focus on the intersection of national security and corporate prosecution. I know our BIU prosecutors will build upon their outstanding track record while continuing to work shoulder to shoulder with our partners in the National Security Division to achieve our united mission.”

Finally, in a most welcomed development, Polite stated “there’s no better way to broaden community than to speak your partners’ language – literally.” He announced the Criminal Division’s Office of Prosecutorial Development, Assistance, and Training – or OPDAT – will re-issue the FCPA Resource Guide in Spanish later this month. Kudos to the DOJ for taking this step.

Join me tomorrow where I take a deep dive into clawbacks and other new components of a compliance program.

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Blog

The Week That Was in Compliance – The Monaco Speech

In the ‘60s there was a television show called That Was the Week That Was. As with many great US television shows, it started in the UK on the BBC. It ran on NBC and introduced an American audience to David Frost, from the original British cast. It brought weekly and topical satire to US television and some of the contributors were among the greatest comedians of their generation. They included Henry Morgan, Phyllis Newman, Pat Englund, Buck Henry, Bob Dishy, Doro Merande, Alan Alda, Sandy Baron, Tom Bosley, Jerry Damon, Stanley Grover, Burr Tillstrom’s Puppets and The Norman Paris Orchestra. I still remember the theme song as it was sung by Nancy Ames in addition to her participating in the show.

I thought of that TV show when I looked back at the two days of speeches from the Department of Justice (DOJ) at the recent ABA 38th Annual National Institute on White Collar Crime, held in Miami. Compliance professionals, white collar defense lawyers and indeed corporate executives will be talking about the past week for many moons to come. The speeches were made by Deputy Attorney General (DAG) Lisa Monaco (2023 Monaco Speech) and Assistant Attorney General Kenneth A. Polite, Jr. (Polite Speech) and they previewed a number of initiatives by the DOJ which every compliance professional needs to study in some detail. These new initiatives included:

The Criminal Division’s Pilot Program Regarding Compensation Incentives and Clawbacks

Evaluation of Corporate Compliance Programs (Updated March 2023)

Revised Memorandum on Selection of Monitors in Criminal Division Matters

Over the next several blog posts, I will be taking a deep dive into these speeches and the new Evaluation of Corporate Compliance Program, Monitor Selection and Pilot Program on Incentives and Clawbacks. Today we begin with a review of the 2023 Monaco Speech.

Monaco began by referencing her October 2012 speech to the Fall White Collar Crime conference, noting she “directed some immediate policy changes to invigorate corporate criminal enforcement, and I did so based on a few fundamental principles: preventing misconduct before it happens; holding individual wrongdoers accountable; and deterring and punishing recidivism.”

Around that time Monaco announced the “Corporate Crime Advisory Group to recommend more advances, based on input, and this is important, input from outside as well as inside the department.” This led to the September 2022 announcement of the Monaco Doctrine as laid out in the Monaco Memo where the DOJ changed its focus to “promoting cultures of corporate compliance, while also ensuring consistency and predictability in the way the government treats corporate crime.” Her goal was to “empower companies to do the right thing, by investing in compliance, in culture and in good corporate citizenship — while at the same time empowering our prosecutors to hold accountable those who don’t follow the law.”

At the end of the day, perhaps the most significant pronouncement from Monaco was the following “in today’s complex and uncertain geopolitical – very uncertain quite frankly – geopolitical environment, corporate crime and national security are overlapping to a degree never seen before, and the department is retooling to meet that challenge.” This fits with the Biden Administration’s Strategy on Combatting Corruption, which elevated the fight against bribery and corruption through enforcement of laws such as the Foreign Corrupt Practices Act (FCPA) to a National Security Issue. Of course, the Biden DOJ has said several times in the past that “Sanctions are the new FCPA” and Monaco reiterated that in her speech last week.

Monaco set the tone for the week by identifying five general areas of DOJ focus. (1) Inspiring a Culture of Compliance; (2) Voluntary Self-Disclosure Programs; (3) Promoting Compliance through Compensation and Clawback Programs; (4) Resource Commitments to Corporate Criminal Enforcement; and (5 ) Individual Accountability.

  1. A Culture of Compliance

The Monaco Memo “emphasized the department’s commitment to finding the right incentives to promote and support a culture of corporate compliance.” Monaco hoped to do so by creating two new areas of focus in addition to those laid out in the FCPA Resource Guide,  the 2017 Evaluation of Corporate Compliance Program and its 2020 Update and Chief Compliance Officer (CCO) certification requirement. In the 2023 Monaco Speech, she stated, “I noted two new areas of particular focus: a cross-department approach to promoting voluntary self-disclosure and how compensation structures can foster responsible corporate behavior. We want companies to step up and own up when they discover misconduct and to use compensation systems to align their executives’ financial interests with the company’s interest in good corporate citizenship.”

What is interesting about these two components is that they previously existed but were made more important in the Monaco Memo. Clear rewards for self-disclosure have been a part of FCPA enforcement since 2016 with the initiation of the Pilot Program around self-disclosure. Financial incentives and penalties (carrots and sticks) have been a part of best practices compliance programs since at least 2004 and were included in the original 2012 FCPA Resource Guide. But now a company must engage in both actions to demonstrate a “culture of compliance” to obtain the presumption of a declination under the Corporate Enforcement Policy.

  1. Voluntary Self-Disclosure

Seemingly buried in the speech is perhaps the most significant statement about white collar criminal enforcement. Monaco said, “Now, with respect to voluntary self-disclosure, I am pleased to report that, for the first time, every U.S. Attorney’s Office now has, and every component I should say, that prosecutes corporate crime, now has in place an operative, predictable and transparent voluntary self-disclosure program. These policies share a common principle: absent aggravating factors, no department component will seek a guilty plea where a company has voluntarily self-disclosed, cooperated and remediated the misconduct.” She went on to add, “Let me be very very clear. I want every general counsel, every executive and board member to take this message to heart: where your company discovers criminal misconduct, the pathway to the best resolution will involve prompt voluntary self-disclosure to the Department of Justice.” Her example was an excellent one: the ABB FCPA enforcement action.

  1. Compensation and Clawbacks

Once again Monaco emphasized a part of every best practices compliance program over the past 20 years, financial incentives for doing business ethically and in compliance. However, in her 2023 Speech, she emphasized the disincentives or clawbacks. She stated, “First, every corporate resolution involving the Criminal Division will now include a requirement that the resolving company develop compliance-promoting criteria within its compensation and bonus system…Second, under the pilot program, the Criminal Division will provide fine reductions to companies who seek to claw back compensation from corporate wrongdoers.”

Monaco said the goal is “to shift the burden of corporate wrongdoing away from shareholders, who frequently play no role in the misconduct, onto those directly responsible.” The DOJ will incentivize such behavior in the following manner. “At the outset of a criminal resolution, the resolving company will pay the applicable fine, minus a reserved credit equaling the amount of compensation the company is attempting to claw back from culpable executives and employees. If the company succeeds and recoups compensation from a responsible employee, the company gets to keep that clawback money — and also doesn’t have to pay the amount it recovered.  And because we heard from stakeholders about how challenging and how expensive the pursuit of clawbacks can be, the pilot program will also ensure that those who pursue clawbacks in good faith but are unsuccessful are still eligible to receive a fine reduction.”

  1. Resource Commitments

This section of the speech deals with DOJ resource commitments but it is still significant. Here Monaco emphasized the intersection of corruption, money-laundering, sanctions and National Security. This continues the Biden Administration trend on this score. There are new and additional resources the DOJ is bringing to bear in all of these areas. This includes the international arena as well. But a huge part of this commitment is that companies are now seen in many ways as the front line of criminal enforcement through self-disclosure of illegal conduct. If the DOJ continues down this path, both the incentives for self-disclosure and cooperation as well as the pain the DOJ will bring for companies which do self-disclose will be significant.  Monaco closed her speech with the following, “Investing now in a robust compliance program is good for business, and it is good for our collective economic and national security.”

  1. Individual Accountability

As far back as 2015, in the Yates Memo, the DOJ has said they will emphasize individual accountability, through individual, as opposed to corporate, enforcement actions. In her speech, Monaco pointed to charges brought against two of the current most prominent alleged fraudsters, Sam Bankman-Fried and Carlos Watson and the convictions out of Theranos; Elizabeth Homes and Sunny Balwani. She also stated, “The Criminal Division’s Fraud Section, for example, secured more individual convictions at trial last year than in any of the previous five years.  So, our message is clear: the department will zealously pursue corporate crime in any industry, and we will hold wrongdoers accountable, no matter how prominent or powerful they are.” While this has yet not been seen in FCPA enforcement, perhaps it will be this year and beyond.

Join me tomorrow where I look at the Polite Speech.

Categories
FCPA Compliance Report

Egle Karalyte on Creating a Brand for the World

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, I am joined by Egle Karalyte, founder and CEO of Karalyte. Tom and Egle discussed branding in the corporate world. Egle explained that a brand is an expression and system that encapsulates services, products, and values that customers will resonate with going forward. A successful UX strategy can keep customers coming back for more. The conversation then shifted toward discussing how different branding rules apply to products and services. Egle discusses how the Metaverse is taking UX to new heights and why this benefits companies and customers.

Key Highlights

·      Developing a Brand: A Systematic Approach [00:05:01]

·      Branding Services vs. Products in Adobe [00:09:37]

·      The Benefits of an Improved User Experience (UX) [00:14:04]

·      The Benefits of Virtual Reality Gaming with Karalyte[00:18:55]

Notable Quotes

1. “For me, a brand is really kind of a certain belief system that is packaged into a certain package that also kind of incorporates a product, reach of service, and really consolidates everything that the customer would resonate with.”

2. “I’ve developed a system where I go through every client, a methodology where we look into the branch world from all possible angles.”

3. “It’s like falling in love. Like, you have to have certain elements in place that would then trigger the spark. So it’s the same thing with a brand. Like, the brand needs to get its foundational elements in place so that people, when they discover it, they really kind of fall in love with the brand and with the product, and then the advocacy, you know, becomes natural because when we find what we like, we simply just naturally want to share it with people.”

4. “Good UX definitely helps to make people interested in what we have to offer. When we discover a brand online and come to the website, how we experience the website will determine whether the brand will hook us in or not.”

 Episode Links

Karalyte

Connect with Egle Karalyte on LinkedIn

Connect with Tom Fox on LinkedIn

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Sports and Compliance

The Dan Snyder Indemnity Edition

Welcome to the Sports and Compliance podcast. For the longest time, I have wanted to have a podcast on the intersection of Sports and the World of Compliance and Ethics, both for those stories as the play out on the Sports Page and for the lessons they provide to business executives and compliance professionals. In this podcast series, I am joined by one of the top compliance commentators around, Stephen Martin, CCO at Skillsoft. Together will use our love of sports and competition to discuss current ethical issues in sports, look at compliance through a sports lens and determine how the world of sports and its stories can be a guide for the compliance professional.

In today’s episode, Tom and Stephen look at the sale of the team formerly known as the “team who will not be named,” the investigation surrounding Alabama Crimson Tide basketball player Brandon Miller, and MLB’s changes to the game such as the size of the bases, clocks on pitchers and hitters and outlawing shifts; all in the hopes of speeding up the game. Tom and Stephen explore the stories from different perspectives and always keeping their compliance audience in mind. Learn more with Sports and Compliance and keep up with current sports news, with a dash of compliance laid in.

Key Highlights

·       The Mary Jo White Report and Confidence in the NFL [00:03:56]

·       The Alabama Basketball Imbroglio [00:06:53]

·       The Consequences of Poor Decision Making [00:10:33]

·       The Impact of Baseball’s Rule Changes on the Game [00:13:49]

·       The Impact of the Shift on Baseball [00:17:13]

·       Baseball Speed Up: Positive Effects on Keeping Fans Interested [00:19:56]

Notable Quotes

1.    “You don’t often see it when somebody causes their own problems and then ask to be identified for them, but we’ve seen that with CEOs before.”

2.    “It’s a classic example of a couple of things we see in compliance. Star performers. Sometimes there’s just different rules for them. Right? And that’s just how it goes.”

3.    “It’s just it’s shocking to me that Alabama has done it this way.””

4.    “You can’t just say, I’m being mistreated. We’ve had that conversation in our household the last few days about what’s fair and when rules are in place, what happens? And these are all good things to understand because they’re there are consequences whether positive or negative to rule changes and you can figure them out.”

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Daily Compliance News

March 3, 2023 – The Spread The Pain Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Stories we are following in today’s edition of Daily Compliance News:

Categories
Blog

Levels of Due Diligence-Part II

In the conclusion of this blog post series on levels of due diligence, I am drawing from Candice Tal, Founder and CEO of Infortal Worldwide, in her seminal article entitled, Deep Level Due Diligence: What You Need to Know.

Level II. Level II due diligence encompasses supplementing Global Watch lists with a deeper screening of international media, typically major newspapers and periodicals from all countries plus detailed internet searches. Such inquiries will often reveal other forms of corruption-related information and may expose undisclosed or hidden information about the company; the third-party’s key executives and associated parties. I believe that Level II should also include in-country database searches. Other types of information you should consider obtaining are country of domicile and international government records; use of in-country sources to provide assessments; a check for international derogatory electronic and physical media searches, which should be performed both English and foreign-languages, in its country of domicile. Further, if you are in a specific industry, use technical specialists and obtain information from sector specific sources.

Level III. This level is a deep dive. It will require an in-country ‘boots-on-the-ground’ investigation. I agree with Tal that a Level III due diligence investigation is designed to supply your company “with a comprehensive analysis of all available public records data supplemented with detailed field intelligence to identify known and more importantly unknown conditions. Seasoned investigators who know the local language and are familiar with local politics bring an extra layer of depth assessment to an in-country investigation.” Further, “Direction of the work and analyzing the resulting data is often critical to a successful outcome; and key to understanding the results both from a technical perspective and understanding what the results mean in plain English. Investigative reports should include actionable recommendations based on clearly defined assumptions or preferably well-developed factual data points.”

Level III should also include deep dark and historical Internet searches, also known as Open Source Intelligence Investigations (OSINT). Although AI can be used for some of this work, it should be noted that AI without investigative analysis will yield less adverse information. Investigative analysis looks at hidden and undisclosed information and searches for information that should have been found but was not. It is an integrated approach incorporating ‘boots on the ground’, intelligence gathering, and due diligence investigations. Relying on basic Google searches is a certain mistake as hidden and undisclosed information are unlikely to be discovered.

But more than simply an investigation of the company, including a site visit and coupled with onsite interviews, Tal says that some other things you investigate include “an in-depth background check of key executives or principal players. These are not routine employment-type background checks, which are simply designed to confirm existing information; but rather executive due diligence checks designed to investigate hidden, secret or undisclosed information about that individual.” Tal believes that such “Reputational information, involvement in other businesses, direct or indirect involvement in other lawsuits, history of litigious and other lifestyle behaviors which can adversely affect your business, and public perceptions of impropriety, should they be disclosed publicly.”

Further, you may need to engage a foreign law firm to investigate the third-party in its home country to determine their compliance with its home country’s laws, licensing requirements and regulations. Lastly, and perhaps most importantly, you should use a Level III to look the proposed third-party in the eye and get a firm idea of his or her cooperation and attitude towards compliance as one of the most important inquiries is not legal but based upon the response and cooperation of the third-party. More than simply trying to determine if the third-party objected to any portion of the due diligence process or did they object to the scope, coverage or purpose of the FCPA; you can use a Level III to determine if the third-party is willing to stand up with you under the FCPA and are you willing to partner with the third-party?

There are many different approaches to the specifics of due diligence. By laying out some of the approaches, you can craft the relevant portions into your program. The Level I, II and III trichotomy appears to have the greatest favor and one that you should be able to implement in a straightforward manner. But the key is that you must assess your company’s risk and then manage that risk. If you need to perform additional due diligence to answer questions or clear red flags you should do so. And do not forget to “Document, Document, and Document” all your due diligence.

Categories
Great Women in Compliance

Tracy Saale-From Law Enforcement to In-House

Welcome to the Great Women in Compliance Podcast, hosted by Mary Shirley and Lisa Fine. In today’s episode, Lisa speaks with Tracy Saale, who is Conduct Risk Management, Managing Director and Corporate Responsibility Officer at Charles Schwab.

This is her second career, and while we often hear from attorneys who have gone in-house, or were assigned to compliance, Tracy started out as a prosecutor and then at the U.S. Federal Bureau of Investigations (FBI), where she worked all over the globe, and advised in ethics and compliance during her career there. She discusses the importance of advising law enforcement officials on what is – or is not – permissible, particularly when they are dealing with criminal behavior and security issues. When she started at the FBI, they had approximately 14% women agents, and while that has increased into the 20% range, there is a way to go, so she recounts her experiences.

While Tracy was a bit guarded given her experiences with corporate malfeasance, she also was impressed with Charles Schwab, and joined them in part for that. In her in-house career, she is now seeing what so many of us see – that the majority of people are trying to do the right things – a more positive side of corporate life.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings to listen in to.  If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it.  If you have a moment to leave a review at the same time, Mary and Lisa would be so grateful.  You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast.  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.

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
Creativity and Compliance

Do It Right Rick and Creating a Custom Character

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – 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.

In this episode, Tom and Ronnie visit with Katherine Hill, Legal Compliance Manager at Ferguson Enterprises. We discussed the compliance program rebranding that Ronnie and his creative team at Learnings & Entertainment helped Katherine put together. They discuss the unique challenges for a blue-collar workforce and how Learnings & Entertainment was able to help Katherine and her team drive engagement through the creation of ‘Do It Right, Rick.’

Highlights include:

  • Why a Custom Character?
    • Improving the image
    • putting a friendly face on the program
    • highly customized messaging
  • What was involved?
    • Brainstorming and coming up with the ideas
  • How is it being deployed?
  • Lessons Learned.

Resources:

  • Learnings & Entertainments (Website)
  • Compliance Confessions – inspired by “Mean Tweets,” these 90-second commercials address misconceptions and excuses to promote speak-up culture and the E&C team as positive and helpful.
  • E&C Training Jams – a soulful singer banters with ethics & compliance, explaining policies, sharing examples, and debunking excuses. 
  • Tales from the Hotline – Real speak-up-themed stories about workplace behavior gone wrong.
  • Workplace Tonight Show! – E&C meets SNL Weekend Update explaining corporate risk topics and why employees should care.
  • 60-Second Communication & Awareness Shorts – A variety of short, customizable, music and multimedia, quick-hitter “commercials” promoting integrity, compliance, speaking up, and the E&C team as helpful advisors and coaches.
  • Custom Live & Digital Programming – Custom creative programming that balances the seriousness of the subject matter with a more engaging delivery. After all, you can’t bore people into learning.