Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 21 – Managing 3rd Parties

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

On Day 21 of our series, we dive into the essential strategies for managing third-party relationships in a compliance program. We consider the significance of a structured and strategic approach in handling third parties to mitigate anti-corruption risks. As companies mature, the operationalization of compliance through third-party management becomes crucial. Key areas explored include the importance of dual and diversified sourcing, monitoring subcontractors, legal protections, and financial stability checks. Additionally, we cover the necessity of integrating performance-based compensation and regular auditing to uphold compliance standards. Join us tomorrow as we explore levels of due diligence on Day 22.

Key highlights:

  • Strategic Approach to Third-Party Relationships
  • Auditing and Ongoing Management
  • Key Takeaways

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

Categories
Innovation in Compliance

Innovation in Compliance – Navigating Accounting and Compliance with Mike Whitmire

Innovation comes in many areas, and compliance professionals must be ready to embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom Fox visits Mike Whitmire, Co-founder & CEO at FloQast, on his journey in accounting and compliance.

In this episode, Tom is in a riveting conversation with Mike Whitmire, Co-founder & CEO at FloQast. They dive into Mike’s professional journey, starting from his early days at Ernst & Young, navigating the complexities of Sarbanes-Oxley (SOX) compliance, and eventually founding FloQast. Mike shares his firsthand experiences with the challenges in accounting and compliance, such as the talent gap and behavior change within organizations, and explains how FloQast’s closed management and compliance software addresses these issues. The discussion deeply delves into risk orchestration and its critical role in modern compliance strategies.

Additionally, Mike provides insights into his passion for podcasting and touches on his book, ‘Shift Happens,’ co-authored to highlight the rise of the operational accountant. The episode wraps up with a focus on FloQast’s innovative solutions that integrate daily accounting tasks with compliance requirements, thus simplifying processes for finance professionals. Tune in to hear how a common pain point in the accounting world led to the creation of a transformative software solution.

Key highlights:

  • Challenges in Accounting and Compliance
  • Risk Orchestration and Compliance
  • Mike’s Podcast and Book

Resources:

Mike Whitmire on LinkedIn

FloQast

Purchase Shift Happens on Amazon.com.

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
SBR - Authors' Podcast

SBR – Author’s Podcast – Exploring the Future of Work, Ethics, and Compliance with Kelly Monahan, Part 2

Welcome to the Sunday Book Review, The Authors Podcast! Host Tom Fox visits with authors in the compliance arena and beyond in this Podcast Series. Today, Tom is joined by his good friend and colleague, Earnie Broughton (Earnie from Boerne), to visit with Dr. Kelly Monahan, co-author of the soon-to-be-released book Essential: How Distributed Teams, Generative AI, and Global Shifts are Creating a New Human-Powered Leader.  (Co-authored with Dr. Christie Smith) We three had such good fun that we went on for nearly an hour, so we have broken up the interview into two podcasts. If you have not checked out our first episode, you can do so by clicking here.

In Part 2, we deeply dive into effective communication tools for conveying corporate values to diverse workplace groups, emphasizing tailored training and gamification. Kelly highlights the importance of engaging, behavior-reinforcing communications through storytelling and public recognition systems. Emphasizing intrinsic motivation over financial incentives, Kelly draws on behavioral economics and the importance of fostering an environment of curiosity and context awareness for leadership roles. The discussion also addresses the nuances of generational differences in the workforce and the importance of diversity, equity, inclusion (DEI), and ESG initiatives for long-term organizational sustainability. Compliance professionals are encouraged to stay ahead of AI developments and promote positive behaviors to align with evolving business and ethical standards.

Key highlights:

  • Effective Communication Tools for Corporate Values
  • Future of Leadership in the Age of AI
  • Suspending Self-Interest and Cultivating Curiosity
  • Importance of Context in Ethical Decision-Making
  • Generational Differences in the Workforce
  • Role of Ethics and Compliance Professionals

Resources:

The Essential Website

Pre-Order Essential: How Distributed Teams, Generative AI, and Global Shifts are Creating a New Human-Powered Leader on Amazon.com

Kelly Monahan on LinkedIn

Earnie Boughton On LinkedIn

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 20 – Third-Party Risk Management Process

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

On Day 20, we delve into the third-party risk management process, a crucial aspect of corporate compliance under the FCPA. Third parties continue to pose the highest risk, necessitating an integrated and operational approach throughout the company. The episode outlines the five essential steps in the third-party risk management life cycle, as mandated by the DOJ in the 2020 FCPA Resource Guide. These steps include business justification, third-party questionnaires, due diligence, compliance terms and conditions, and post-contract management and oversight. Each step is explored in detail, emphasizing the importance of documenting business cases, performing thorough due diligence, and maintaining diligent oversight to mitigate potential FCPA violations. Key takeaways include the necessity of using the full five-step process, involving business development and ensuring all steps are operationalized with business unit representatives. Join us tomorrow for Day 21 to discuss managing your third parties.

Key highlights:

  • Introduction to Third Party Risk Management
  • The Five Steps of Third-Party Risk Management
  • Key Takeaways

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

Categories
31 Days to More Effective Compliance Programs

31 Days for a More Effective Compliance Program: Day 19 – Evaluating the Risk Management Process

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In today’s episode, we review the critical process of evaluating and translating risk assessments into actionable risk profiles. The discussion highlights the importance of prioritizing risks based on their significance and likelihood using risk matrices and heat maps. Expert insights from Ben Locwin and Bill Anathas emphasize focusing resources on high-risk employees and maintaining a robust compliance program aligned with FCPA guidelines. The episode also covers the Treasury Department’s OFAC compliance framework and offers concrete steps for continuous risk monitoring and remediation. Key takeaways include the necessity of a well-reasoned approach to risk evaluation, thorough documentation, and the implementation of a dynamic risk matrix to guide compliance efforts.

Key highlights:

  • Understanding Risk Profiles
  • Evaluating Risk Management Processes
  • Risk Matrix and Heat Maps

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 18 – Risk Assessments

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In this episode, we discuss the essential role of risk assessments in anti-corruption compliance programs. A well-structured risk assessment forms the foundation of every corporate compliance program. We explore how organizations should identify, assess, and define their risk profiles, emphasizing the need for annual risk assessments whenever business risks change. The focus then shifts to geopolitical issues, supply chain dynamics, and evolving work environments and how these should be factored into compliance risk assessments. Historical perspectives from DOJ guidelines and the importance of a robust risk identification, analysis, and management methodology are also discussed. As highlighted, documenting these processes is crucial for developing an effective compliance strategy that evolves with the company’s risk landscape. Finally, the episode outlines the steps to create a comprehensive risk management strategy post-assessment, including policy development, training, monitoring, and updating protocols.

Key highlights:

  • The Importance of Regular Risk Assessments
  • Methodologies for Risk Assessment
  • Steps in Conducting a Risk Assessment

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

Categories
10 For 10

10 For 10: Top Compliance Stories For the Week Ending – January 18, 2025

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

  • BitMEX fined an additional $100MM.  (WSJ)
  • Wells Fargo banks on compliance. (PYMTS.com)
  • China military corruption purge ‘tip of the iceberg’.  (Business Insider)
  • Cognizant defendants want to know government’s trial strategy. (Law360) sub req’d
  • What is forced labor? (BBC)
  • KPMG to open US law firm in AZ.  (Reuters)
  • SEC sues Elon Musk yet again, this time over Twitter purchase. (Bloomberg)
  • UK Minister resigns over corruption investigation in Bangladesh. (Reuters)
  • Has corporate purpose lost its purpose? (FT)
  • Return To Office compliance. (Bloomberg)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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

Connect with Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 17 – Podcasting for Compliance

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In this episode, we explore the transformative potential of podcasting in compliance training and fostering corporate culture. Harnessing the power of imaginative communication methods, we discuss the effectiveness of delivering compliance messages and training through various podcast formats. We revisit the 2012 Morgan Stanley declination to underscore the impact of consistent compliance reminders and venture into how short ethics and compliance video clips and storytelling podcasts can enhance employee engagement and regulatory satisfaction.

These podcasts are standalone training tools and can be broadcast through social media, creating a larger reach and providing valuable feedback through listener engagement metrics. Additional formats discussed include a branded podcast series featuring longer episodes that humanize compliance topics through interviews and a daily compliance news show to keep employees informed and engaged. This episode emphasizes the importance of innovative storytelling in making compliance communications memorable and effective.

Key highlights:

  • Podcast Storytelling: A New Approach
  • Branded Podcast Series for Compliance
  • The Benefits of Podcasting for Compliance

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.

Categories
Blog

Kaizen 2.0: Leveraging AI for Continuous Improvement in Compliance

In the late 1940s, engineer Taiichi Ohno introduced the world to the Toyota Production System, an operational approach rooted in the Japanese principle of Kaizen or, as we call it today, continuous improvement. By prioritizing incremental enhancements and engaging employees at all levels, Toyota transformed manufacturing with concepts like worker empowerment, just-in-time manufacturing, root-cause analysis, and total quality management. The result? Toyota became the largest automaker in the world and a gold standard for process excellence. All this and much more was found in a recent Harvard Business Review article, The Secret to Successful AI-Driven Process Redesign, by H. James Wilson and Paul R. Daugherty.

I use their article as a starting point to explore where Kaizen meets the transformative power of artificial intelligence (AI) in the compliance realm. Kaizen 2.0 empowers employees with AI tools to make data-driven decisions, streamline processes, and elevate organizational performance in this new era. For compliance professionals, the principles behind this transformation offer a powerful roadmap for managing risk, embedding compliance into your business processes, and creating resilient risk management structures.

From Kaizen to Kaizen 2.0: The Role of AI in Compliance 

At its core, Kaizen is about empowering employees to improve processes continuously. Kaizen 2.0 amplifies this with AI, making advanced tools accessible to non-technical employees and enabling them to synthesize complex data for actionable insights. For compliance teams, this means using AI not to replace human judgment but to enhance it, whether by automating routine tasks, detecting risks, or uncovering inefficiencies.

Mercedes-Benz provides an interesting example. The company’s MO360 Data Platform democratizes data access across its global production network, enabling employees at every level to make data-driven decisions. A frontline worker can query AI about assembly-line bottlenecks or supply chain delays and receive actionable real-time recommendations. Imagine a compliance professional leveraging similar tools to identify patterns in third-party transactions or track policy adherence across business units.

This democratization of information underscores a key lesson for compliance professionals. AI tools are most effective when they empower teams rather than replace them. By augmenting human expertise, compliance programs can scale their impact while fostering a culture of accountability and engagement.

AI-Driven Tools: Unlocking New Compliance Opportunities 

Incorporating AI into compliance frameworks opens the door to new possibilities. Consider the following applications for the compliance function.

  • Root-Cause Analysis

Root-cause analysis can become more powerful with AI. Generative AI tools can analyze vast amounts of data to pinpoint the underlying root causes of compliance failures. For example, training AI on high-quality data can reduce false positives in transaction monitoring, allowing teams to focus on genuine risks. Using AI in the root-cause process could allow a compliance professional to determine the root cause of every compliance failure, whether simply a hiccup or a major system failure.

  • Just-in-Time Compliance

Borrowing from Toyota’s just-in-time manufacturing, compliance teams can use AI to implement “just-in-time compliance.” AI tools can monitor real-time transactions, communications, or activities, flagging issues as they occur rather than after the fact. This proactive approach aligns with regulators’ increasing focus on continuous monitoring. Also, consider how you could send a personalized compliance message to an employee who is about to travel to a high-risk country or engage in a high-risk activity.

  • Employee Empowerment

AI-enabled compliance platforms can empower employees across the organization to identify and address risks. This offers a great opportunity to move a compliance tool directly to the first line of defense. A generative AI tool could help employees draft accurate disclosures, navigate complex policies, or report concerns anonymously and securely. By embedding compliance tools into day-to-day workflows, organizations can create a proactive compliance culture and make the process more efficient.

Reshaping Risk Management: Lessons from Kaizen 2.0 

One of the most transformative aspects of Kaizen 2.0 is how it redefines risk management. Merck uses generative AI to improve quality control in drug inspection processes in the pharmaceutical industry. By creating synthetic defect-image data, AI reduces false rejects by over 50%, cutting waste and enhancing efficiency.

Compliance professionals can take inspiration from this approach by leveraging AI to address data quality issues. For instance, AI-powered tools can identify inconsistencies in due diligence data, streamline third-party risk assessments, and ensure consistent policy application across global operations.

Similarly, companies like Colgate-Palmolive and Nestlé are using AI to drive innovation in product development. For compliance teams, these advancements signal the potential for AI to transform regulatory reporting, training, and monitoring by making these processes more adaptive and aligned with business goals.

Overcoming Challenges: Ensuring Human-Centric AI Adoption 

While AI offers immense potential, successful adoption requires careful planning and execution. Compliance professionals must address the following challenges:

  1. Employee Training and Engagement. Like Mercedes-Benz’s Turn2Learn initiative, compliance teams should invest in training employees in AI in compliance programs. Educating staff on using AI tools effectively ensures they can take part in compliance initiatives and take ownership of risk management.
  2. Data Quality and Integration. High-quality data is the foundation of effective AI tools. Compliance leaders must champion data governance initiatives to eliminate silos, standardize data formats, and ensure accuracy. This has been on the Department of Justice’s (DOJ) mind since 2020 and was reiterated in the 2024 Evaluation of Corporate Compliance Programs.
  3. Ethical AI Usage. Compliance teams must lead efforts to ensure AI tools are used ethically and transparently. This includes validating AI outputs, addressing biases, and maintaining accountability for decisions informed by AI.

The Future of Kaizen 2.0 in Compliance

The convergence of AI, digital twins, and autonomous agents will redefine process management in compliance. Autonomous agents powered by generative AI can independently execute tasks, adapt strategies, and continuously improve their performance. This means a shift from routine oversight to strategic leadership for compliance professionals.

Walmart uses autonomous agents for inventory management. Compliance teams could deploy similar agents to monitor real-time regulatory changes, update policies, and notify stakeholders of critical updates.

Looking ahead, digital twins, which are virtual models of real-world systems, could revolutionize compliance training and testing. A digital twin of an organization’s compliance framework could simulate the impact of regulatory changes, test the effectiveness of controls, and identify vulnerabilities before they become liabilities.

A Call to Action for Compliance Professionals

The principles of Kaizen 2.0 offer a roadmap for transforming compliance programs. By embracing AI and empowering employees, compliance leaders can foster a culture of continuous improvement that meets DOJ requirements and drives business success. Three key steps help the compliance professional begin.

The first is to identify opportunities for AI integration in both your compliance program and overall compliance function. You should begin by mapping compliance processes and identifying areas where AI can add value, such as risk monitoring, policy management, or training. Next is engagement with employees by fostering a culture of collaboration by involving employees in AI-driven compliance initiatives. Provide training and resources to help them contribute to continuous improvement.  The final step is to monitor and continuously improve. Establish clear metrics for compliance performance and use AI to monitor progress. Review and refine processes to ensure they remain effective and aligned with business goals. Update, refine, and improve as the data becomes available to you.

Compliance professionals have a unique opportunity to lead our organizations into the future. By leveraging Kaizen 2.0 principles and AI tools, we can create compliance programs that are effective, resilient, adaptive, and aligned with organizational values. Let’s make continuous improvement the cornerstone of a fully operationalized compliance program and demonstrate to your organization that effective compliance leads to more efficient processes, which leads to greater ROI and profitability.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 16 – Effective and Tailored Compliance Training

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be 6-8 minutes short, with three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In today’s episode, we delve into the evolution and importance of employee compliance training, focusing on fostering a culture of compliance within organizations. We discuss key guidelines from the FCPA Resource Guide 2nd Edition and subsequent updates from the DOJ and SEC, emphasizing the necessity of effectively communicating and tailoring training programs to an organization’s specific audience. Critical aspects include the importance of training in local languages, assessing the risk profile of employees, and ensuring senior management’s participation. Furthermore, we explore the concept of ‘espresso shots’ or concise training segments to enhance learning and retention. Metrics such as increased hotline use and survey feedback are essential for evaluating the effectiveness of compliance programs.

Key highlights:

  • Evolution of Compliance Training Standards
  • Measuring Training Effectiveness
  • Tailoring Training to Audience Needs

Resources:

Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast.