Welcome to the last installment of this 5-part Compliance in Finance Series, where Innovation in Compliance host, Tom Fox, talks with Philip Fry, the VP of Go To Market Strategy for Verint. Today, Phil and Tom are talking about oversight – bringing together data and analysis from across an organization.
Listen to the episode:
Phil makes the point that the success of a compliance program is dependant on your ability to see the whole picture, so gathering, combining, analysing and understanding the data created by various operational systems can keep an operation running smoothly, or run it off the rails. There are plenty of challenges in managing this month information, but Phil thinks it’s more achievable than it might look at the outset. The key is the ability to cut through all the noise created by the mountains of data, and home-in on areas of concern, of potential or real non-compliance, that require attention.
Tom and Phil discuss the different ways this oversight can be gained, and the importance of open standards across compliance solutions. They talk about Trade Reconstruction, speech analytics, surveillance, and the new technology that is bringing them together and making them accessible to compliance program managers around the world.
If you missed any episodes of the Compliance in Finance Series, click on the links below to catch what you missed, and if your organization needs a comprehensive, up to date and sustainable compliance solution, reach out to Verint to see what they have to offer.
Episode 1: Overview
Episode 2: Capture
Episode 3: Control
Episode 4: Sustainability
Tag: compliance
Welcome back to the Compliance In Podcast Series with Philip Fry from Verint! Yesterday we talked about the tools, strategies and importance of controlling the information its now possible to capture, and today, we’re getting into making that kind of activity sustainable over the long term.
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Tom starts the conversation by mentioning how common and multi-purposed the word sustainability is, so Phil gets into some detail about exactly what sustainability means from a compliance in finance standpoint. Namely, that it refers to effectively managing constant change and moving your compliance organisation and resources, technology, practices, procedures, data, skills etc. to a place where they run effectively and efficiently, without undue drama (however that might be caused) and where compliance risks are minimised.
A big part of successfully making a complex compliance program sustainable is looking back on what different tools, systems and strategies have been in place before the newest one, to help plan an attainable rout from where companies are to where they want to be. Phil talks about how this has shaped his vision of the future and the other factors that have to be considered, like the ability to cope with disruption, verifying the operation of a structure, and the attitude and will of an organization. All stakeholders need to be invested in a compliance program if it’s going to be sustainable going into the future.
In tomorrow’s fifth and final installment, Tom and Phil discuss how to get and keep oversight of the mountains of information that are generated by modern compliance programs.
If you missed any of the previous episodes – click the links below to catch up!
Episode 1: Overview
Episode 2: Capture
Episode 3: Control
Resources:
Philip Fry
Verint
What does control mean when we’re talking about compliance in finance? And how do you maintain it? That’s what Tom Fox and Philip Fry are talking about in this third installment of the 5-part Compliance and Podcast series on Innovation in Compliance. In this context, control means the tools and strategies we employ to prevent non-compliant actions from taking place or being alerted to them when they do.
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Phil mentions that if at all possible it’s better to prevent non-compliance than find it after the fact – but that isn’t always a reality. He shares some examples of the different tools and strategies available to help manage the difficulties of controlling information capture, like taking a cohesive approach to validating the collection and quality of interaction data. What can be very time and resource-intensive when done manually, can be done quickly and accurately via automation.
Tom asks Phil to apply this kind of automation capability to organizations that have a variety of different communications systems in play, and Phil talks about the importance of having open standards and taking an open approach to developing solutions that help various systems co-exist.
Another way to build better control is by staying on top of changes within the workforce, and making sure that your roster of what needs to be monitored when is kept up to date. By being flexible, but strategically using the tools available, you can have greater control overall.
In tomorrow’s episode of this 5-part series, Phil and Tom will be getting into the important issue of sustainability – and what it means in the context of compliance in finance.
Resources
Philip Fry
Verint
In this second installment of our 5-part series all about Compliance in Finance, Tom Fox is going to be talking with Philip Fry of Verint about the importance of capturing the information necessary to manage risk and compliance in a fast changing world.
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The current breed of regulations governing financial services and trading are much more comprehensive and stringent than their predecessors. In their drive to control how businesses and individuals behave, they typically require that extremely detailed information is captured and stored about every transaction. In fact, in the case of MiFID II, it is necessary to capture data about interaction that was intended to lead to a transaction – even if the final transaction did not take place. What these regulations have done is catch-up with the plethora of communication channels now available to bankers, traders, and customers when they communicate with one another.
Although things move on regularly, with new capabilities and channels becoming available, so both compliance officers and their suppliers need to be agile to keep pace, it is possible to capture all of the many available channels in a useful, and compliant way. Phil and Tom talk about how this works, and what some of the potential challenges are with enforcing it. Using proactive compliance, as you learned about in yesterday’s installment of the series, addresses many of the weaknesses and pitfalls that can be found.
Tom wonders if there are other tools and systems in play, apart from UC that need to remain a part of integrated compliance programs, and Phil explains that there is always going to be a period of overlap with legacy systems, and that nothing really exists in isolation. Embracing this diversity is the only practical, strategic and economic way of implementing a new system.
Make sure to join Phil and Tom for tomorrow’s episode of the Compliance in Podcast series, where they’ll be talking about what it means, and what is required to control this massive flow of information, and if you missed yesterday’s Overview episode, click here to listen now!.
Resources:
Philip Fry
Verint
This week on the Innovation in Compliance Podcast, Tom Fox and Philip Fry, the VP of Go To Market Strategy at Verint are releasing a conversation every day about the changes in the financial compliance industry. Philip says: “Verint are taking a unique approach to Financial Compliance. We do not accept that legacy solutions and methods are good enough for our client’s needs. As well as providing the most advanced capture and automation capabilities available within this space, we are also partnering with best-of-breed Regtech and Fintech organizations to provide customers with flexibility and options. Our approach is one of true partnership – we will be open, we will be honest, and we will share our customers’ objectives, working together to achieve them.”
Listen now:
What is Reactive, Active and Proactive Compliance?
These refer to the speed of response to compliance issues
Reactive compliance is the slowest – responding to and addressing compliance problems after they have occurred, analyzing the actions and circumstances in order to both correct the specific instance of non-compliance, and also learn lessons to help prevent reoccurrence in the future.
Active compliance might also be thought of as “in the moment” or “near real-time”.
You might call “Proactive Compliance” a “Minority Report” approach – achieved with tools and processes that focus on identifying conditions in which non-compliances are prone to occur and heading them off with automated tools that enforce communication or disclosure policies – preventing some interactions from happening at all, automatically force-feeding disclaimers into conversations or redacting content before it is transmitted and prompting employees with guidance and knowledge content to help them follow established, compliant procedures.
Capture, Control, Sustainability, and Oversight
Capture – The extent and scope of financial regulation makes it imperative that businesses can record and capture the full range of electronic communication channels used by their employees. We all know how the number of available channels has increased –instant messaging, video calls and desktop sharing for example. And yet the majority of organizations cannot capture much more than traditional voice, dealerboard, and email communications. If any of their traders are using mobile phones or tools like SfB and Cisco UC, those interactions won’t be captured and are therefore automatically in contravention of regulations such as Dodd-Frank and MiFID. So I’ll be explaining how it is possible to capture all of these channels and why this is the minimum standard businesses should be aiming for.
Control – The increased scope of the regulations – that I just referred to – mean that it is becoming increasingly unsustainable to carry out all of the necessary compliance checks using traditional, mainly manual methods. For example – if your business is placing 50 thousand calls per week, then verifying as few as one in ten of the recordings is already be a huge task. If technology or configuration issues mean that you are unknowingly failing to record just 1% of calls, then that is 500 calls a week that are out of compliance. But because of the sampling rate, you only have a 0.1% chance of discovering this! Which means that you may have thousands of non-compliant interactions by the time you discover it! Automation, is a key part of controlling the environment, can remove problems like this, as well as spotting other types of compliance violations and stepping in before they occur. We’ll look at these possibilities in more detail. We’ll also look at efficient, accurate transcription of trade-related speech recordings (something that’s much harder to achieve than you might think) and how to make all this easily identifiable, retrievable and readily available to support speedy responses to inquiries.
Sustainability – is not referring to the use of green power sources or the environment, but rather focuses on finding a way to sustain a compliant operation in the face of the very many day-to-day challenges that compliance and IT professionals face –
- Keeping up with fast-moving, multi-jurisdictional regulations and complying with regulatory requests
- Managing and sustaining acceptable levels of compliance and risk while organizations are going through widespread and wide-ranging change and transformation
- Staying on top of the issues and opportunities posed by an ever-widening range of communication streams and recording platforms
- And maintaining system health, inventory, and performance
We’re addressing the growing need to create a modern operational and systems architecture with proper levels of oversight, while also de-risking the complex projects and migrations that may form a part of those moves.
Oversight – here we’ll look at how it all comes together. The interaction data captured from new recording modes, the management of those recordings and how they are archived and how new tools and approaches can help reduce compliance risk and improve the investigation of interactions and trade-related data.
Tune in to tomorrow’s episode to learn about capturing the huge amounts of information needed to manage compliance and risk in a fast-moving world.
Resources:
Philip Fry
Verint
As Tom celebrates the Astros franchise record of 104 wins (to-date) and Jay continues to avoid talking about the Red Sox, they then turn to discuss some of this week’s top compliance and ethics stories which caught their collective eyes.
- Both Nissan and Carlos Ghosn settle SEC charges for failure to report salary. Does Nissan have a massive conflict of interest in its investigation? Sean McLain and Nick Kostov report.
- PwC gets in yet more trouble with SEC. Francine McKenna reports. Matt Kelly explores. Tom and Matt take a deep dive in Compliance into the Weeds.
- TechnipFMC settles SEC charges for FCPA violation. Harry Cassin reports.
- How do you fix a toxic culture? Mike Volkov enlightens.
- What factors influence an ethical culture? Jay continues a multipart series.
- Thinking about investiging in US real estate? Foreigners need to check in on the new rules. Doug Cornelius explains.
- 8 Prominent CCOs tackle 5 compliance questions in an interview in Compliance Week.
- What are 10 reasons compliance programs fail? Andrew Hayward and Tony Osborn consider.
- Has the fight against corruption in Mexico turned the corner? Andrew Levine, Kara Brockmeyer and Marisa Taney consider.
- Tom continues his preview of the Converge19 speakers in a special bonus series of podcasts on the Compliance Podcast Network. Check out the following: Monday-Jacki Cheslow with a testimonial of why you should attend; Tuesday-Michael Rasmussen on a SWOT analysis for CCOs; Wednesday-Stephen Martin on the role of the Board of Directors; Thursday– Dan Chapman on the new DOJ Guidance (with an assist from FCPA Monitor himself) and Friday– Ren McEachern on the power of integrated 3rd party risk management. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone, YouTube, Spotify and the Compliance Podcast Network.
- The Everything Compliance gang will be doing its first live podcast at Converge19. You should be there! Listeners to this podcast can obtain a complimentary ticket by using the promotion code foxvip, for registration and information, click here.
Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.
This episode begins on a somber note as Tom and Jay note the passing of Compliance Week reporter Joe Mont and what he meant to the greater compliance community. They then turn to discuss some of this week’s top compliance and ethics stories which caught their collective eyes.
1. Tributes to Joe Mont.
2. Mike Volkov takes a deep dive into the recent Business Roundtable Statement on the Purpose of a Corporation on Corruption Crime and Compliance.
3. Former Cognizant Technologies COO, Sridhar Thiruvengadam, settles FCPA charges. Dick Cassin.
4. Netherlands proposes nationwide AML system. John Rusch reports.
5. What is an ethical culture and why does it matter? Jay begins a multipart series.
6. What is algomerithic corporate misconduct. Milhailis Diamantis explores.
7. Despite prevaling opinions, CCO is not a ‘god’. Clara Hudson reports on the Odebrecht CCO remarks at SCCE.
8. Do UK DPAs throw individuals under the bus? Ross Dixon asks.
9. Mary Shirely tells you how to ace job interviews.
10. Tom continues his preview of the Converge19 speakers in a special bonus series of podcasts on the Compliance Podcast Network. Check out the following: Monday-Scott McCleskey on mapping the ethical risk in your company; Tuesday-Valerie Towery on cross functional collaboration; Wednesday-Kurt Stitcher on Operation Globalization; Thursday-Matt Kelly on Developing Effective Strategies for Third Parties & Data Security Risk and Friday– Anna Aster on The Future CECO: The Executive Recruiter’s Perspective. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTube, Spotifyand theCompliance Podcast Network.
11. The Everything Compliance gang will be doing its first live podcast at Converge19. You should be there! Listeners to this podcast can obtain a complimentary ticket by using the promotion code foxvip, for registration and information, click here.
Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.
For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.
In this episode I visit with podcast favorite Jim Murphy, who is the VP of Products at Hanzo. We discuss a recent article by Murphy which appeared on Corporate Compliance Insights and was entitled, The Shark in the Wave: Revealing the Lurking Danger of Slack Data.It detailed the dangers from Slack from a compliance and investigative perspective. Highlights from the podcast include:
- Murphy’s role at as VP of Products at Hanzo
- Why did you write, The Shark in the Wave: Revealing the Lurking Danger of Slack Data?
- A discussion of rise of Slack as a common business tool.
- What are the dangers in using Slack from the compliance and investigative perspectives?
- How can a company think though managing these risks?
For additional reading, see Murphy’s article, The Shark in the Wave: Revealing the Lurking Danger of Slack Data, on Corporate Compliance Insights by clicking here.
As Donald Trump invites Russia back into the G7 and plans the next summit at his resort. Tom and Jay look at that COI and discuss some of this week’s top compliance and ethics stories which caught their collective eyes.
1. How deep is the ocean? Jeff Kaplan asks that metaphorical questions as a way to introduction his piece on Trump’s conflicts of interest.
2. Why is there is no easy answer to the supply side of bribery? Jessica Tillipman explains.
3. Matthew Stephenson says it is time to retire the term “passive bribery”.
4. The use of monitors in licensing and disciplinary proceedings. Jay continues his series.
5. Deutsche Bank settles ‘sons and daughters’ hiring case..
6. Fraud allegation hits academia. Jonathan Rausch explains.
7. What happens when the middle of your organization is rotten? Mike Volkov explains.
8. What are some of the issues for AI in Compliance? Tom explores in a 4-part blog post series, all on the FCPA Compliance Report.
9. Interested in the Science of Star, Trek the Original Series? Then this week has been the week for you on the Compliance Podcast Network as Tom was joined by Ben Locwin to look at some of the science from TOS.
10. Join Tom and Jay and a host of other great speakers and guest at Converge19 in Denver October 2 & 3. Listeners to this podcast can obtain a complimentary ticket by using the promotion code foxvip, for registration and information, click here.
Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.
For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.
Welcome to the only roundtable podcast in compliance. Today, we have a quartet of Jay Rosen, Matt Kelly, Sarah Hadden and Mike Volkov. We focus on the President Trump’s putative initiative to purchase the country of Greenland. We consider the proposed purchase from the compliance perspective. Rants and shouts outs follow the commentary for this episode.
- Mike Volkov considers the proposed purchase through the lens of Mergers and Acquisitions under the FCPA. He also highlights the 2018 amendment to the FCPA Corporate Enforcement Policy on safe harbor in M&A under the FCPA. Volkov is not sure if he is shouting out to the Business Roundtable for their Statement on the Purpose of a Corporation or ranting about the Business Roundtable’s ‘profound grasp of the obvious” in releasing the Statement.
- Jay Rosen follows up on Mike’s FCPA analysis in considering how someone might look at the sale in assessing the culture of Greenland and how it would fit into the acquirer’s portfolio of purchased territories. Rosen shouts out for America to ‘get Spicy’ as former White House Press Secretary (when there was such a position) Sean Spicer joins Dancing with the Stars.
- Sarah Hadden considers how a journalist might cover the proposed purchase. She also weighs in as the Publisher of Corporate Compliance Insights on the types of compliance related stories she sees from the proposed purchase. Hadden shouts out for unplugging.
- Matt Kelly considers the proposed purchase from the internal controls and SEC reporting perspective. Kelly comes in hot to blast the Business Roundtable over its Statement on the Purpose of a Corporation.
The members of the Everything Compliance are:
- Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com
- Mike Volkov– One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at mvolkov@volkovlawgroup.com.
- Matt Kelly– Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com
- Jonathan Armstrong–is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com
- Sarah Hadden–Publisher at Corporate Compliance Insights. Hadden can be reached at Sarah@corporatecomplianceinsights.com
The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network.
