As with Lisa’s episode last week, Mary brings a memorable former colleague onto the Great Women in Compliance show, Alexis Wermuth. Alexis is a Compliance executive at Getinge, a medical device company.
It is an exceptional few in Compliance who are creative or artistic. Alexis is one of those people and made an invaluable contribution to the internal marketing team at Fresenius Medical Care North America’s Compliance department (see episode with Sarah Hadden for more on this initiative). After talking about some of the risks in the medical device field, Alexis talks about injecting creativity into her Compliance program and reminisces with Mary about some of their favorite projects when working together with ideas for listeners to implement in their own programs.
After finishing up at Fresenius Medical Care, Alexis moved to New Jersey and discusses the considerations she weighed up when deciding to make the move and a new job opportunity. She also shares a favorite productivity hack.
Lisa and Mary wish to extend deepest gratitude to listeners and readers who heeded the call to vote for their book “Sending the Elevator Back Down: What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). The voting closed 1 December, the launch of this episode and the GWIC team eagerly awaits the outcome of the award process.
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. 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).
Tag: compliance
Welcome to a special five-part blog post series on how to unlock the gold in your program. I visit with Gio Gallo and Nick Gallo, Co-CEO’s of ComplianceLine, LLC, the sponsor of this series.
One of the ongoing issues in compliance is to demonstrate the Return on Investment (ROI) in your compliance program. One way to do so is by demonstrating the extended value of compliance literally across your entire company. When overlaid with an ESG component, you can begin to see the gold in your compliance hills. In addition to showing how you can unlock the gold in your own compliance hills, Gio and Nick discussed demonstrating ROI for your internal budgeting process which can provide to you the financial resource to strengthen and improve your compliance program. Today, in Part 3, we look at the role of the Chief Compliance Officer (CCO) and corporate compliance function in ESG investments.
We began with the basic question of why a Chief Financial Officer (CFO), or corporate finance function look at ESG investment and how it will be different than a CCO or compliance function would do so. Gio noted that finance will most probably be “considering the outcome and it is something else for me to figure out.” Yet they may well also see it as a new opportunity and a “new conversation that we can be a part of. We may be able to get to that head of the pack because through some early investments which might be in programs or just how we talk about it.” The impact is that finance types might see more opportunities in this than the E&C professional, which you should be conscious of as you enter this conversation. Gio stated, “if we can make something out of this zeitgeist it might be seen as a unique opportunity.”
Conversely, he also noted “there’s no F in the ESG, right? This means the finance lens for this opportunity might be to get better financing for the company.” This might present a funding opportunity, either through a loan, additional capital or other funding mechanisms. It might also work to lower the cost of capital because investors might see your company is really an attractive company. That is what ESG might end up meaning from the finance perspective. The beauty of this is that the approach is equally valid to a compliance-focused approach and demonstrates there are multiple reasons for implementing an ESG program.
Nick emphasized the opportunity that ESG presents. Not simply for each commercial organization but for the compliance function as well. He stated, “irrespective of whether or not your organization is serious about it, you need to take advantage of the opportunity and the window of opportunity that we have right now, because compliance speaks to every single one of those pillars in the ESG acronym.”
From the compliance perspective, there are several reasons for this. It is top of mind for investors and in mind of the marketplace. He said, “Use what you have in place already to show your organization is committed to ESG. Moreover, you probably already have 80% of this stuff done. We already have a speak-up line. We already have a training for our business ethics and corporate culture.” The bottom line is “there are probably a bunch of ESG type things that you are doing.” You can build on all of them. It is a massive opportunity. Do some research on what is publicly available on ESG reports, “grab a handful of those and start looking at what some of your competitors or what other folks in the marketplace are putting into their report. I guarantee there’s a massive overlap with some of the data points that already exist in your organization.” As a compliance professional “it’s about shifting your mindset and using this opportunistically, to take advantage of the amorphousness that is ESG right now.” Nick even compared ESG in 2021 to where compliance was in the mid-1990s after the release of the US Federal Sentencing Guidelines and the creation of the modern compliance professional. It took some 15 to 20 years for corporations to understand that compliance was a business differentiator and business positive and not simply a legal response to a long-standing law, such as the Foreign Corrupt Practices Act (FCPA). In the age of social media, the speed of the change in ESG will be much quicker. Simply witness the change from the Trump Administration which actively fought corporate ESG initiatives to that under the Biden Administration which has fully embraced ESG from a regulatory perspective.
We concluded by considering many of the tasks that a CCO and compliance professional are already doing. Nick provided the following examples, “You can pull that out of your case management system and look at some of the following issues: How many discrimination and harassment claims did you have last year? How many did you have this year? What were the turnaround time on those? How many days did it take you to close those? What can you take credit for? That’s really what ESG is kind of about.” The same is true for your basic risk management strategies involving your third parties and other business ventures.
It is a function of getting an understanding of who your audience is. From the compliance perspective do not simply focus on an audience of one, the government. Look at in the way the Business Roundtable did with their Statement on the Purpose of an Organization. There are multiple stakeholders that you can engage with and work with to satisfy their ESG concerns.
Check out the full podcast series this blog post series is based upon.
Episode 1
Episode 2
Episode 3
Welcome to a special five-part podcast series on how to unlock the gold in your program, hosted by Tom Fox with guests Gio and Nick Gallo from ComplianceLine. One of the ongoing issues in compliance is to demonstrate the Return on Investment (ROI) in your compliance program. One way to do so is by demonstrating the extended value of compliance literally across your entire company. When overlaid with an ESG component, you can begin to see the gold in your compliance hills. In addition to showing how you can unlock the gold in your own compliance hills, Gio and Nick walk you through how demonstrate ROI for your internal budgeting process which can provide to you the financial resource to strengthen and improve your compliance program.
Join us for the full 5 episodes and learn to see your compliance program in an entirely new light. In this Part 2, we consider how compliance can be seen as extending the value of compliance across your entire organization.
Some of the highlights of this episode include:
- How might a finance professional view things differently from a compliance professional?
- Just as CCOs plan for integrated risk across an organization, CFOs do the same for financial return.
- How should a compliance professional look differently at their work, through a finance lens?
- Why is rice on the chess board so apt?
- What is the compliance professional missing about compound interest?
Resources
Gio Gallo on LinkedIn
Nick Gallo on LinkedIn
ComplianceLine
Digital Assets: Trading & Compliance for Cryptocurrency
In this episode, Director of Registered Investment Company Services, Allison Fraser and Director of Broker-Dealer Services & Private Funds, John Gentile discuss the latest on digital assets and cryptocurrency. Are they considered securities, what does the SEC’s risk alert mean for digital assets, and how should investment managers be thinking about cryptocurrency trading and compliance?
About Our Guest Speakers:
E.J. Yerzak CISA®, CISM®, CRISC™ assists firms in assessing and managing their cybersecurity risk – from network vulnerability scanning and penetration testing to onsite cybersecurity assessments and assistance in implementing the NIST cybersecurity framework. E.J. has authored articles and alerts on emerging regulatory and technology issues, and is regularly requested to speak as a cybersecurity expert at industry conferences.
Mike Farrell is a Certified Information Systems Auditor (CISA®) and Certified Information Security Manager (CISM®), and Cybersecurity Consultant at CSS. He analyzes data and conducts cybersecurity risk assessments, policy gap analyses, vulnerability scanning and social engineering testing. His Information technology experience includes network installations and management, hardware and software configuration, and troubleshooting.
Welcome to a special five-part podcast series on how to unlock the gold in your program, hosted by Tom Fox with guests Gio and Nick Gallo from ComplianceLine. One of the ongoing issues in compliance is how to demonstrate the Return on Investment (ROI) in your compliance program. One way to do so is by demonstrating the extended value of compliance literally across your entire company. When overlaid with an ESG component, you can begin to see the gold in your compliance hills. In addition to showing how you can unlock the gold in your own compliance hills, Gio and Nick walk you through how demonstrate ROI for your internal budgeting process which can provide to you the financial resource to strengthen and improve your compliance program.
Join us for the full 5 episodes and learn to see your compliance program in an entirely new light. In this Part 1, we consider how compliance can be seen as a corporate ROI multiplier by looking at the impact of compliance across your entire organization.
Some of the highlights of this episode include:
- The financial principles in unlocking the ROI of compliance.
- Why the alignment of compliance with other disciplines in your organization is not only critical but a key to unlocking compliance gold.
- Compliance budgeting is not simply about a cost center mentality. It requires a different type of discussion.
- Frameworks for improving your thinking about compliance.
- Building a complex and transparent case to OPEN the discussion about your assumptions rather than only including unobjectionable assumptions.
Resources
Gio Gallo on LinkedIn
Nick Gallo on LinkedIn
ComplianceLine
Welcome to a special five-part blog post series on how to unlock the gold in your program. I visit with Gio Gallo and Nick Gallo, Co-CEO’s of ComplianceLine, LLC, the sponsor of this series. There is also a podcast on this topic and the link is listed below.
One of the ongoing issues in compliance is to demonstrate the Return on Investment (ROI) in your compliance program. One way to do so is by demonstrating the extended value of compliance literally across your entire company. When overlaid with an ESG component, you can begin to see the gold in your compliance hills. In addition to showing how you can unlock the gold in your own compliance hills, Gio and Nick discussed demonstrating ROI for your internal budgeting process which can provide to you the financial resource to strengthen and improve your compliance program. We begin Part 1 by considering how compliance can be seen as a corporate ROI multiplier by looking at the impact of compliance across your entire organization.
One of the most ubiquitous issues in compliance is making a case for ROI. Every compliance professional must be able to be able to justify not only their spending but their budgeting requests. However, as Gio believes, compliance professionals are “literally leaving some money on the table because there’s a lot more to this game than meets the eye.” It is important to understand not simply the numbers but also who you are talking to about ROI or budgetary requests. Also is the zero-mindset which is usually brought to the budgetary process. Many corporate officers feel that if their department does not receive funding those dollars go to another department, and vice-versa.
Gio emphasized that budgeting “is not a zero-sum game. If you can understand that being aligned with other departments, having some positive externalities that help someone else get their job done, or take some work from someone else’s plate, these are all things that you can align with this full company view.” Moreover, this allows you to portray you are not simply competing for dollars but putting in a richer attempt to serve the overall company mission. He emphasized it really takes a “broadening of your mindset not simply thinking about risk in the full company, but also thinking about the compliance budget as part of the whole.”
Nick added that many Chief Compliance Officers (CCOs) who come from a legally trained professional backgrounds handle budgets “like they are running a nonprofit, by minimizing spending, as opposed to like an abundance or growth mentality.” A CCO really does need to use a different set of frameworks when it comes to thinking through compliance ROI and budgeting, “fundamentally different than the binary sort of risk aversion frameworks that you’ll apply to managing an ethics and compliance department or building an FCPA policy or the like.” He concluded that it is all about taking a calculated risk.
Nick acknowledged that this might require making some assumptions, but it is also about doing some of the same things a compliance professional must do each and every day. We talked through the example of hotlines. Here you begin with a mandatory requirement for US public company for a hotline in Sarbanes-Oxley (SOX) all the way through a best practices compliance program, formulated by the Department of Justice (DOJ) in its most recent Update to the Evaluation of Corporate Compliance Programs. From the installation of the hotlines, all the way through the benefits of a speak up culture, a CCO should begin to show and build a picture that can be taken to senior management or the Board to represent the benefits internally and the types of ROI.
Nick noted this is “the exact arithmetic that we want to utilize. If you have a strong culture that people are engaged with their purpose is resonant with the organizational purpose. This means people expend more discretionary effort which falls directly to the bottom line. Moreover, if you love your work and you feel like your voice matters, and you’ve worked other places where your voice doesn’t matter, then you’re going to feel a particular allegiance to that organization. You’re going to appreciate that. Turnover is going to drop a little bit. All of those benefits will go directly to directly to the bottom line.”
But the conversation does not end there. Gio said, “part of this is a persuasion path, pointing to those outcomes, based on these inputs, which are a hotline or an improved case management system. Those are in my mind, extremely credible, especially when you can start to bring the finance people who are controlling purse strings into that calculation. And that’s what the basis of a lot of our ROI coaching has been not only getting those assumptions dialed in, but also building the persuasion path around the delivery of that message so that it lands in a way that is resonant with the you want to loosen those purse strings up.”
The bottom line is that as compliance leaders, we are “great at communicating the clarity that we have standing in and CCOs are also very good at dealing with the gray areas in the domain of risk management.” If, as the compliance professional, you can demonstrate the compliance function will “move the needle, from a risk management standpoint to not simply rectify the causes of those faster” but make the company run more efficiently, you can make a good case for increased budgeting and greater resources for your compliance program.
Check out the full podcast here.
Categories
Crisis Week: Part 3 – Compliance Resiliency
Perhaps the most prescient comment I heard during the height of the pandemic came from Jed Gardner, Group Director of Transformation at Linedata, which was that we have moved from disaster recovery to business continuity to business as usual. It appears that not only was the comment correct but now we are moving in the business world from crisis to crisis to crisis. This month’s Harvard Business Review magazine dedicated its Big Idea Series to the topic of crisis. Over this short week I am exploring what this new reality means for the compliance professional. Monday we looked at compliance as a trip wire to alert businesses a crisis is on the horizon, through the article A New Crisis Playbook for an Uncertain World. Tuesday, through the article Building a Culture That Can Withstand a Crisis, we considered the role of culture in dealing with a crisis.
Today we consider how to make sure your compliance program is resilient. Our starting point for today is the article 6 Types of Resilience Companies Need Today by Paul Polman and Andrew Winston. As every compliance professional knows, resilience must be built into every compliance program. The reason is simple, in today’s volatile and uncertain world, corporate compliance programs will face many crises. It could be a Foreign Corrupt Practices Act (FCPA) violation, but it could also range from a natural disaster which destroys property and disrupts operations, to the discovery of human rights abuses in a supply chain which breaks consumer trust earned over years. It can also range from an activist shareholder who presents a hostile takeover bid which shakes a business to the core to new competitors and technologies upending the industry. As we all know, a global pandemic or a new social justice movement can emerge to change everything.
In their article, the authors looked at decisions made by the multinational Unilever PLC to create both “traditional forms of resilience (financial flexibility, portfolio diversity, and organizational agility) and less-obvious forms (driven by purpose, trust, and stakeholders) that changed the company more deeply, we aim to show how leaders can best prepare for the world ahead.” I have adapted their prescriptions for the Chief Compliance Officer (CCO) and compliance professional.
The traditional building blocks of corporate resiliency include financial flexibility, portfolio diversity and organizational agility which the authors believe are “essential preparation for sudden shocks and long-term crises.” Compliance must contribute to getting and keeping businesses moving, as “only companies with already healthy balance sheets can weather such storms.” Obviously in your compliance portfolio there must be a variety of agents on the sales side which are fully vetted and approved. The same is now true on for vendors in the Supply Chain. That is one of the key features in the five steps in the lifecycle of third-party risk management. If one step cannot be fully utilized, it does not mean you cannot use that third-party, it just puts more pressure on the other steps. In other words, greater risk management resiliency. Compliance function agility lends itself to structural changes to build organizational-wide compliance resilience, with the compliance function getting faster feedback from regions about what is working and where more compliance resources need to be delivered. Through this approach you can identify possible problems before they become crises.
The authors real insight comes from what they see as the “larger opportunity is in making a company more broadly crisis-resistant for the long term, because doing so serves multiple stakeholders — not just shareholders. We argue that the strongest organizations today and in the future will thrive by giving more than they take from the world. We call this kind of company “net positive” because it seeks to improve the well-being of everyone it touches through its operations, value chain, products, services, and influence. Organizations that have a clear purpose, build strong relationships that reinforce each other, and amass a reservoir of trust will have deeper sources of strength when they need them most.” That sounds like exactly the function of a CCO and corporate compliance program.
Purpose
A company that knows its reason for being, and consistently backs it up, is both tougher and more flexible during a crisis. If this is not a mere add-on but strategy your company will be exponentially stronger. Here compliance plays a, if not the, key role in communicating a corporate strategy of not simply doing business ethically and in compliance but also following the outline laid out in the Business Roundtable’s Statement on the Purpose of a Corporation by listening to and incorporating information from all stakeholders in an organization. Of course, building out internal controls fully as laid out in the COSO 2013 Framework for Internal Controls can build out the backbone of this effort.
Trust
Trust is an absolute key for any compliance program. You must build trust through institutional justice and institutional fairness. But now take that same concept and apply it out to all your stakeholders. It may require a level of transparency your organization has not previously engaged in but through trust you will be able to foster an entire culture of not simply speak up but also listen up. As the authors note, “Transparency is a great tool to ensure consistency and engender trust. Rather than rebelling against tough questions and pressure, business leaders should embrace them and use them to build a stronger organization.”
Engage All Stakeholders
I have mentioned the Statement on the Purpose of a Corporation several times. Most compliance functions typically do not deal directly with all stakeholders. Now imagine if they led such an effort, from a corporate culture perspective. The authors believe, “Net-positive companies build better connections with stakeholders besides employees as well.” If compliance can help to engage a wide variety of stakeholders, those same stakeholders that are engaged through the compliance function, such as through due diligence and contracting; you will likely have a wider variety of stakeholder, “bound by purpose and all trusting and working in partnership with the company, provides a diverse bank of support.” All of this can act as a “large, spread-out root system — not just one anchor but many that can take a lot of pressure.”
When the biggest crises hit, compliance or otherwise, all six forms of resilience help you move quickly and effectively. The authors conclude, “No company can prepare for every outcome, but these six forms of resilience, put together, can provide a serious buffer. They also allow organizations to work in larger coalitions on the biggest issues, such as climate change and income inequality. Net-positive businesses don’t just endure or bounce back from crises; they also anticipate and prevent them.” All of these strategies are not simply in the compliance wheelhouse, but they are part of the ever-evolving best compliance regimes. They will make you a better company in times of great change, disruption and upheaval.
Perhaps the most prescient comment I heard during the height of the pandemic came from Jed Gardner, Group Director of Transformation at Linedata, which was that we have moved from disaster recovery to business continuity to business as usual. It appears that not only was the comment correct but now we are moving in the business world from crisis to crisis to crisis. This month’s Harvard Business Review magazine dedicated its Big Idea Series to the topic of crisis. Over this short week I am exploring what this new reality means for the compliance professional. Yesterday we looked at compliance as a trip wire to alert businesses a crisis is on the horizon, through the article A New Crisis Playbook for an Uncertain World. Today we look at cultures that are built to sustain during a crisis.
Our starting point for today is the article, Building a Culture That Can Withstand a Crisis by John E. Katsos, Jason Miklian, and Patrick L. McClelland. This article is based upon an interview the authors did with Alice Laugher, the head of Committed to Good (CTG), a private company founded in Afghanistan and based in Dubai, that provides specialist staffing and logistics to the humanitarian community. Since the company’s founding in 2006, its clients have included most major humanitarian organizations; it now operates in 26 countries. In 2019 Laugher was awarded the prestigious Oslo Business for Peace Award. In the article, the authors visited with Laugher on “what she and her team have learned about uncertainty through working in crisis zones, and how this might help managers new to the type of crisis leadership our tumultuous time requires.” It turned out she had some very interesting insights for the compliance professional to help a company in times of crisis.
1.When a New Crisis Appears
The most current crisis CTG is facing is in Afghanistan. Here Laugher said, “We navigate a new normal every day. The situation, the rules, the regulations, and the needs of the local population shift constantly. Can you imagine running a business in a place where banks are not operating? Or where corporate accounts are frozen? There is still active fighting and hostility in parts of Afghanistan where we have staff. How do you deliver salaries and make payroll to thousands of employees scattered across the country in such an environment? When the Taliban took over, we were forced to reevaluate our core objectives, achievements, and progress.” She said it “test[s] how strong our relationships with our staff, clients, and partners really are. We ride the waves together. It’s as simple as that. We share the same goal: to build humanitarian projects so that aid can get to the people who need it no matter the danger or challenge involved in getting it there.”
Compliance Lesson
Everyone in your compliance function must be on the same page. If an ethical issue arises, everyone must know what the corporate response should be; that is, we will only do business ethically and in compliance with not simply our policies and procedures but our culture and mission. So, are you communicating that message? Here I recall Louis Sapirman when, when he was Chief Compliance Officer (CCO) at Dun & Bradstreet, used the phrase Do the Right Thingto communicate the culture and values of the organization as it navigated a Foreign Corrupt Practices Act (FCPA) enforcement action. Does your compliance function and indeed entire organization have such a succinct, forceful and clear statement of culture values?
2. Uncertainties During a Crisis
When asked about dealing with uncertainties during crisis, Laugher said, “Each country is radically different, but preparation goes a long way everywhere we operate. You have to navigate local laws, some of which may be unpublished. In one country, the tax law is from 1921, so it certainly cannot be found easily and downloaded from the internet! And meeting tax obligations — something that is considered a back-office task — has much more serious consequences in conflict zones.”
Compliance Lesson
Here the lesson is you must have local compliance support ready and able when called upon by the business team or the greater organization. If you cannot have your compliance team embedded in high-risk areas, you should have local compliance assets trained to provide such support. A Regional Compliance Committee can be of great assistance here as they will have an ear closer to the ground. Indeed, Laugher noted, “it’s so important to have local staff members as part of your core team. They can help navigate the nuances and sensitivities of their country, and they have a deep understanding of their environments, a level of insight that can’t be matched by outsiders no matter how much research they do.”
It’s Really About Culture
Laugher believes that the culture at CTG drives the entire organization. She stated, “We have a culture that encourages people to go the extra mile because of the value of the work that we are enabling. We believe in what we are helping to deliver. Our people share a fundamental desire to make a difference and help those in need. Everyone trusts that we will jointly make the right decision for security and safety based on local knowledge and information, while still getting the job done. CTG is not a “look to the CEO for the answer” culture. I don’t pretend to have all the answers. Instead, we work together to find solutions to complex problems.”
Compliance Solution
Once again you have to drive your compliance message throughout the organization. Even when you do not have the answer immediately, compliance should be seen as a function to go to when you need to solve a problem. This is not simply being Dr. No from the Land of No but affirmatively being seen as a business enabler. As Laugher stated, “We embed it in everything we do.” As a CCO you should do so as well.
4. The Speed of Change
Covid-19 highlighted the speed of change. In literally a few days, companies had to figure out how to do business remotely, literally across the world. CTG was no different. How are you going to respond to the speed of a crisis, such as one that might damage your organization’s reputation in literally days across the world? Laugher said, “We have several plans of action as part of our day-to-day business in each country. Nonetheless, a lot of times our emergency plans do have to be used. So, we must remain versatile at both the local and leadership levels, and our culture and the trust we have in our team approach are essential.”
Compliance Lesson
Long term preparation is the key. Not only should you have plans in place, but have you cultivated and built relationships? Do you have relationships with the local, regional and state communities you are working, do you have relationships with both your outside sales agents and Supply Chain vendors who all may well be a part of the solution you need to have to activate? But building those relationships take time, effort, and care. You cannot start during the throes of a crisis; you must do so now.
The bottom line that the time to prepare for a crisis is now. Learn to work together as a team. As a CCO you will have to rely on your entire compliance team, from the most junior to the most senior. Know everyone and everyone’s role before crisis hits. Know who your key resources and assets will be throughout your company if you need to call upon them. Built up that trust with internal and external stakeholders.
Special Episode with the Deputy Commissioner, Securities Division of the Vermont Dept. of Financial Regulation
In this special episode, CSS’s Director of Retail Wealth Manager Services Korrine Kohm and William R. Carrigan, Deputy Commissioner, Securities Division of the Vermont Department of Financial Regulation discuss the latest news for registered investment advisers, including what will be required in 2022 surrounding continuing education requirements, the implementation of the new Marketing Rule and what’s next for Form CRS.
About Our Guest Speakers:
Korrine Kohm is CSS’s Director of Retail Wealth Manager Services. Prior to CSS, Korrine was the Chief Compliance Officer and Head of Operations at Estabrook Capital Management where she was responsible for all compliance functions of this SEC-registered, $2.1B investment advisory firm. Korrine began her regulatory career while working at Allied Irish Bank (NY) in the Operations Department where she was a key member of AIB’s Compliance Committee, responsible for ensuring compliance with Federal and State regulations. An active member of the National Society of Compliance Professionals for over 10 years, Korrine earned her Investment Adviser Certified Compliance Professional (IACCPTM) designation in 2006, is a member of the Association of Certified Fraud Examiners, and obtained her Certified Fraud Examiner designation. In addition to her experience in compliance and banking, Korrine began the 16-week intensive training course in Quantico, Virginia, to become a Special Agent with the Federal Bureau of Investigation. She has particular experience in crafting customized policies and procedures, developing and implementing compliance programs, conducting on-site compliance reviews, acquisition due diligence reviews, risk assessments and mock SEC examinations. She routinely councils clients on various regulatory matters, including SEC registration issues, social media and advertising, policies related to diminished financial capacity, disclosures and the annual review process.
William R. Carrigan was appointed Deputy Commissioner of the Securities Division in July 2016. He has worked at DFR since 2007 serving as Director of Examinations and Enforcement and Investor Education Coordinator. A Certified Fraud Examiner, he worked closely with the FBI and IRS to expose the $28 million Mac Parker Ponzi scheme, which involved hundreds of investors, and he was a member of the team that investigated the recent Jay Peak EB-5 matter that resulted in federal and civil lawsuits. Carrigan also spearheaded the inquiry that led to the recent $5.9 million settlement with Raymond James and Associates. He has 20 years of experience in the securities industry and held various positions prior to joining the division. He holds a bachelor’s degree in business management from Johnson State College and a master’s degree in forensic studies from Stevenson University in Maryland. He is a member of the Association of Certified Fraud Examiners and the North American Securities Administrators Association.