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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Innovation: Day 9 – The Competitive Advantage of Data

The DOJ and SEC have both made it clear that they expect companies to be more robust in their use of data analytics in compliance programs. This means using data not only to detect and prevent illegal conduct but also in the remediation prong of any best practices compliance program through continuous improvement. In 2019, former Deputy Assistant Attorney General Matthew Miner said in a speech that the DOJ will inquire whether compliance departments have access to internal data that could help them identify misconduct and whether compliance officers make adequate use of data analytics in their reviews of companies under investigation. Since at least 2016, in the FCPA enforcement action involving Key Energy Services, Inc., the SEC has been communicating to compliance professionals the need for increased use of data and data analytics in any compliance program.

The bottom line is that it is not if but when you begin to incorporate corporate information into your compliance program to make your compliance program more efficient, and your business process run more effectively. Let’s start now to identify the data you have access to and the data to which you currently do not have access. Find a way to bridge that gap.

Three key takeaways:

  1. DOJ pronouncements mandate CCO availability to and use of data.
  2. Data can be an actionable solution across geographic and business lines.
  3. Use data as a business strategy.

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

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Data Driven Compliance

Data Driven Compliance: Rachael Ormiston on Privacy as a Business Differentiator

Are you struggling to keep up with the ever-changing compliance programs in your business? Look no further than the award-winning Data Driven Compliance podcast, hosted by Tom Fox, is a podcast featuring an in-depth conversation around the uses of data and data analytics in compliance programs. Data Driven Compliance is back with another exciting episode The intersection of law, compliance, and data is becoming increasingly important in the world of cross-border transactions and mergers and acquisitions.

We take things in a data privacy direction today as I visit with Rachael Ormiston, Head of Privacy at Osano, whose No Penalties Pledge sets them apart in the privacy industry, offering customers assurance that they won’t face fines for non-compliance. In conversations with Tom Fox, Rachael Ormiston discusses the importance of privacy as a business differentiator and the impact of GDPR. Trust is highlighted as crucial for building a positive customer experience. Osano has developed a privacy maturity model to help companies assess their progress and prioritize compliance. Their website offers valuable resources, catering to both experts and beginners in the field. Rachael emphasizes the increasing importance of data privacy and the need for companies to prioritize it at the executive level.

Highlights Include

·      Osano’s No Penalties Pledge

·      Privacy as a Business Differentiator

·      The Importance of Privacy Compliance

·      Data Privacy and Free Resources

Resources:

Osano

 

Tom Fox 

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Data Driven Compliance

The Uses of Data Driven Compliance: Part 5 – Compliance Successes Using Data Driven Compliance

Welcome to Data Driven Compliance. In this podcast, we discuss how to use data to improve and enhance the effectiveness of your compliance program, creating greater business efficiency, all leading to more return on investment for your compliance regime. Join host Tom Fox as he explores how data will drive your compliance program to the next level. This podcast is sponsored by KonaAI.

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. Over these five podcasts, we have discussed generative AI and ChatGPT in compliance, the profiles of a corrupt payment, making the business case for data-driven compliance, what to ask for and how to ask for it, and some success stories. In this concluding Part 5, we will look at some compliance successes using a data driven approach.

In the world of business, compliance is a critical aspect that ensures organizations adhere to legal and ethical standards. Compliance not only helps companies avoid legal troubles but also plays a significant role in improving business efficiency and profitability. In this episode, Tom and Vince considered the advanced compliance tools for fraud detection and cost savings. Our discussion entailed a comprehensive analysis of the key factors that impact advanced compliance tools for fraud detection and cost savings, exploring the tradeoffs involved, the challenges faced, and the importance of considering the impact on decision-making.

Key Highlights:

  • Invoice Price Discrepancy Detection and Recovery
  • Compliance-driven Efficiency through Fraud Risk Analysis
  • Shifting Travel Expenses for Manufacturing Observations
  • Integrating Multiple Data Sources for Fraud Detection

Resources:

Connect with Vince Walden on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

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Data Driven Compliance

The Uses of Data Driven Compliance: Part 4 – What to Ask For and How to Ask For It

Welcome to Data Driven Compliance. In this podcast, we discuss how to use data to improve and enhance the effectiveness of your compliance program, creating greater business efficiency, all leading to more return on investment for your compliance regime. Join host Tom Fox as he explores how data will drive your compliance program to the next level. This podcast is sponsored by KonaAI.

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. Over these five podcasts, we will discuss generative AI and ChatGPT in compliance, the profiles of a corrupt payment, making the business case for data-driven compliance, what to ask for and how to ask for it, and some success stories. In Part 4, we discuss what data a CCO needs to ask for and how to do so.

Vince Walden brings knowledge and experience in continuous compliance monitoring and risk assessment processes. Walden’s perspective on the topic is that it should be approached as a journey, not a one-time program. He emphasizes the importance of proactive risk assessments and continuous monitoring, advocating for an iterative approach demonstrating constant improvement in compliance efforts. This perspective is shaped by his belief that meeting regulatory expectations requires a diligent and ongoing commitment to improvement.

Walden also suggests that data sources should be identified based on the results of the fraud risk assessment and that the ease of obtaining the data should be considered when prioritizing analytics projects. To delve deeper into what data a CCO should ask for and how to ask for it, join Tom Fox and Vince Walden on this Data Driven Compliance podcast episode.

Key Highlights:

  • Continuous improvement through risk assessments and monitoring
  • Effective risk assessment through diverse data sources
  • Uncovering hidden relationships through expense categories

Resources:

Connect with Vince Walden on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

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Blog

What Data to Ask For and How to Ask for It

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. KonaAI is the sponsor of those podcasts. This blog post series will flesh out the podcast show notes over the next five blog posts, and we will discuss generative AI and ChatGPT in compliance, the profiles of a corrupt payment, making the business case for data-driven compliance, what to ask for and how to ask for it and some success stories. In Part 4, we will explore what data to ask for and how to ask for it.

As always, I am joined by Vince Walden, founder and CEO of KonaAI. There is a quiet revolution happening in the realm of compliance. It’s one that, if harnessed correctly, can turn a typically reactive process into a proactive strategy. I am, of course, talking about data-driven compliance. By using the vast amounts of data your organization collects, you can uncover potential compliance risks before they become actual problems. This approach can be a game-changer for your role as a compliance officer and your organization’s overall risk management strategy. No longer will you be caught off guard. Instead, you’ll lead the charge with real-time insights and actionable data.

Imagine a world where compliance isn’t a headache but a strategic advantage. You’re not constantly putting out fires but predicting and preventing them. It might sound like a dream, but it doesn’t have to be. How so? Well, by adopting a data-driven approach to compliance. This innovative method allows you to identify, assess, and manage potential compliance risks based on actual data. It’s about staying one step ahead, making informed decisions, and truly adding value to your organization. It’s not just about avoiding penalties and meeting regulations anymore. It’s about creating an environment of continuous improvement and proactive risk management.

Let’s paint a picture. You’re in a game of chess. But in this game, you’re not just reacting to your opponent’s moves. You’re anticipating them, strategizing, and making proactive decisions. That’s the power a data-driven approach to compliance can bring to your role as a compliance officer. It’s more than just crunching numbers and keeping up with regulations. It’s about leveraging the power of data to identify and mitigate risks before they materialize. It’s about transforming compliance from a cost center into a strategic asset. So, if you’re curious about how to make this data-driven shift, buckle up because we’re about to dive deep into this transformative realm.

Compliance monitoring and risk assessment are crucial components of any effective compliance program. In a recent episode of the podcast “Data Driven Compliance,” hosted by Tom Fox and featuring Vince Walden, the topic of continuous compliance monitoring and risk assessment process was explored in depth. This article aims to comprehensively analyze the critical factors that impact this process, discuss the tradeoffs involved in balancing different factors, and explore the challenges associated with other approaches.

Vince highlighted the importance of starting with a fraud risk assessment. This initial step allows organizations to identify high-frequency and high-impact risks and implement mitigating controls. Compliance professionals can prioritize their efforts and focus on the most critical areas by assessing the likelihood and impact of various risks on a scale of one to ten.

Data sources play a crucial role in risk assessment. Financial accounting systems and third-party data are valuable sources of information for identifying and mitigating risks. Tracking and categorizing expenses in accounting systems is significant for identifying anomalies and assigning risk scores. Vince highlighted the significance of having a centralized system, such as the Kona platform, to streamline this process.

However, relying solely on analytics without integrating them into the fraud risk assessment would be best. He emphasized the need for alignment between data analysis and risk assessment to ensure efforts are focused on addressing the identified risks. Simply conducting data analytics without considering the underlying risks may not yield meaningful results.

One of the challenges in continuous compliance monitoring and risk assessment is the availability and accessibility of data. Some data sources may need help, requiring compliance professionals to prioritize based on the ease of data acquisition and its value. For example, if faced with choosing to conduct a data analytics project in Brazil or China, Walden suggested starting with Brazil due to the relative ease of obtaining data from that region.

Another challenge lies in the scope of compliance monitoring. Walden emphasized that compliance monitoring is not a one-time, all-encompassing effort. It is a journey that involves proactively assessing risks and monitoring them from location to location. Compliance professionals should focus on demonstrating continuous improvement rather than tackling all threats at once. This approach aligns with regulators’ expectations of an effective due diligence program.

In addition to the primary focus on risk assessment, Walden highlighted the importance of considering ancillary areas of inquiry. For instance, looking at places such as charitable donations or marketing spending can provide valuable insights into potential risks of bribery or corruption. The KonaAI tool can help correlate these ancillary data points and provide a more comprehensive view of compliance risks.

In conclusion, continuous compliance monitoring and risk assessment require a thoughtful and balanced approach. Organizations can identify and prioritize risks, starting with a comprehensive fraud risk assessment. Data sources, such as financial accounting systems and third-party data, play a crucial role in this process. However, aligning data analytics with the identified risks is essential to ensure meaningful results. Compliance professionals should also consider the data availability challenges and scope of compliance monitoring. Organizations can meet regulatory expectations and enhance their compliance programs by demonstrating continuous improvement and considering ancillary areas of inquiry.

Resources:

Connect with Vince Walden on LinkedIn

Check out KonaAI

Connect with Tom Fox on LinkedIn

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Data Driven Compliance

Data Driven Compliance: Anselmo Guevara on Harnessing Data Analytics & AI for Compliance

Are you struggling to keep up with the ever-changing compliance programs in your business? Look no further than the award-winning Data Driven Compliance podcast, hosted by Tom Fox, which is a podcast featuring an in-depth conversation around the uses of data and data analytics in compliance programs. Data Driven Compliance is back with another exciting episode The intersection of law, compliance, and data is becoming increasingly important in the world of cross-border transactions and mergers and acquisitions.

Data analytics is a powerful tool for uncovering trends and detecting fraud – and it’s essential for compliance and internal audit roles. In this podcast episode, experts discuss how to use analytics to its fullest potential. From conducting a formal risk assessment to creating a control inventory list, to looking at suspicious payment activities, the journey of compliance monitoring is broken down and explained. Predictive analytics and artificial intelligence are also discussed as potential future developments that can be utilized. This podcast provides an insightful look into the importance of data analytics and how it can help make informed decisions.

Key Highlights

·      Data Analytics Usage

·      Compliance Monitoring Journey

·      Detecting Fraud

·      Data Analytics

·      Free Resources

 Resources:

Anselmo Guevara on LinkedIn

 Tom Fox 

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Data Driven Compliance

Data Driven Compliance – AI Tech for Data Compliance, Part 1

Are you struggling to keep up with the ever-changing compliance programs in your business? Look no further than the award-winning Data Driven Compliance podcast, hosted by Tom Fox, is a podcast featuring an in-depth conversation around the uses of data and data analytics in compliance programs. Data Driven Compliance is back with another exciting episode The intersection of law, compliance, and data is becoming increasingly important in the world of cross-border transactions and mergers and acquisitions.

Data compliance risks are a major concern for organizations of all sizes as data collection and storage grows. A key is to prevent these risks by detecting misconduct before it occurs. AI technology is used to pinpoint risk and misconduct, providing context to alerts. Searching unstructured data is a critical process for organizations to identify and mitigate hidden risks, and the right technology is necessary to incorporate multiple file types and data sources. By equipping with the right processes and technology, organizations can proactively look for hidden risks and take preventative steps to ensure compliance.

Data has become much more ubiquitous and needs to be incorporated into business processes. AI data cleansing helps to reduce false positives and provides context to alerts generated by the system. AI capabilities are divided into three categories: removing duplicative content, detecting risk, and providing context. AI-powered data cleansing strips out non-human generated content and focuses on what was sent by an individual. This helps to lower false positives in alerts generated by the system.

Regulators are now focusing on prevention as part of best practices compliance programs. A key is to prevent misconduct before it occurs by setting expectations that this behavior is not tolerated in the organization. Compliance teams can quickly take action and remediate activity when an incident is found. Consistent approach by compliance teams in quickly remediating bad behavior creates a culture where misconduct is not tolerated.

Unstructured data is data that doesn’t have a hierarchy associated with it, such as Word documents, emails, and text messages. Your app built on unstructured data analytics problems, such as responding to government requests, cyber breach response, and compliance monitoring. Organizations should have processes in place to proactively look for hidden risks. Technology is needed to search through unstructured data to find hidden risks.

 Key Highlights

·      Data Compliance Risks

·      Data Cleansing Importance

·      Preventing Misconduct

·      Detecting Risk with AI

·      Searching Unstructured Data

 Resources: 

Tom Fox 

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Data Driven Compliance

Data Driven Compliance: Christian Perez-Font on Law, Compliance & Data

Are you struggling to keep up with the ever-changing compliance programs in your business? Look no further than the award-winning Data Driven Compliance podcast, hosted by Tom Fox, which is a podcast featuring an in-depth conversation around the uses of data and data analytics in compliance programs. Data Driven Compliance is back with another exciting episode. The intersection of law, compliance, and data is becoming increasingly important in cross-border transactions, mergers, and acquisitions.

In this episode, Tom welcomes Christian Perez-Font for the first of two parts on using performance bonds and data analytics to guarantee these transactions and the legal requirements and nuances of different jurisdictions when conducting due diligence. They also discussed how technology changes how companies manage Latin American operations, how practitioners need to understand Excel spreadsheets, and how to share data to benchmark and extract the correct information. Christian’s background in engineering and economics has helped him incorporate data analytics, compliance, and law into a unique package. Tune in to Data Driven Compliance and stay ahead of the curve in the compliance world!

Key Highlights:

  • Law Compliance & Data
  • Data as Fuel
  • Data Analytics in M&A
  • Data Analytics in Compliance

Resources:

Christian Perez-Font on LinkedIn 

Thinkeen Legal

 Tom Fox 

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Data Driven Compliance

Data Driven Compliance: Vincent Walden – Analyzing the Philips FCPA Enforcement Action Using AI

Are you struggling to keep up with the ever-changing compliance programs in your business? Look no further than the award-winning Data Driven Compliance podcast, hosted by Tom Fox, is a podcast featuring an in-depth conversation around the uses of data and data analytics in compliance programs.

Data Driven Compliance is back with another exciting episode featuring the insightful Vince Walden from KonaAI. In this episode, Walden and host Tom Fox discuss how data analytics can help uncover potential FCPA enforcement actions, using the Philips case as an example. They delve into the benefits of internal controls and the segregation of duties to prevent bribery and corruption. Walden goes on to examine the customer 360 model, which focuses on analyzing customer orders to pinpoint risky transactions and potential improper payments. Additionally, they explore Kona AI’s platform, which utilizes advanced algorithms to pick up problems and highlight high-risk transactions.

The podcast also features a discussion on the use of artificial intelligence and how machine learning can help compliance professionals identify anomalies that require investigation. You won’t want to miss the exciting upcoming episode where Walden showcases real-world examples of how companies can use machine learning in 2023.  Tune in to Data Driven Compliance and stay ahead of the curve in the compliance world!

Key Highlights

·      Data analytics for FCPA compliance detection

·      Kona AI’s Customer Analytics and Risk Assessment

·      Improper Vendor Payments Tracking

·      The importance of second level reviews in internal control

·      Analytics and Investigating Fraud Potential

·      Improving Precision in Machine Learning Models

KEY QUOTES

“Just those basic type of analytics could have been easily spotted these issues.”

“These are the types of things that when you could just sort, you would be able to find those high risk transactions.”

“Nowadays the technology is there to spot these types of activities when compliance has access to the data.”

“Let’s see if this event took place. And he just did a simple Google search on the Internet couldn’t find the event.”

Resources:

Vince Walden on LinkedIn 

KonaAI

 Tom Fox 

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Data Driven Compliance

Data Driven Compliance: Dave Crozier – Everything Lies Within the Data

Are you struggling to keep up with the ever-changing compliance programs in your business? Look no further than the award-winning Data Driven Compliance podcast hosted by Tom Fox. This podcast features an in-depth conversation about the uses of data and data analytics in compliance programs.

The Data Driven Compliance features an insightful discussion between host Tom Fox and guest Dave Crozier from Certa. Dave explains how Certa’s workflow automation platform eliminates swivel chairs, data silos, and process blind spots to make the due diligence process more efficient and trustworthy. They discuss the importance of validating and fact-checking data using validation techniques and exception-based triggers. The conversation also touches on supply chain risk management and the advantages of data-driven controls. Dave emphasizes the need to tailor solutions to an organization’s requirements and resources and benchmark against industry standards. This podcast is a must-listen for compliance officers, board members, and anyone interested in improving their risk management framework. So, tune in to the Data Driven Compliance and learn from industry experts like Tom Fox and Dave Crozier!

 Key Highlights:

·      Digital Transformation and Workflow Automation for Risk Mitigation

·      Importance of Validating Information

·      Supply chain risk management and automation

·      Customized Risk Management Strategies

·      Automation and Transparency for Efficient Compliance

·      Continuous Learning and Workflow Automation in Organizations

 KEY QUOTES:

“I can tell you that, you know, from my own personal experience and our clients’ experiences, that not all data coming from all places is created equal.”

“Having different techniques that could be deployed along the way that don’t add friction to the process. It’s a breadcrumb trailer of authentications that happen for all of these data sources along the way to make sure that, you know, you’re going in the right direction.”

“Think of validating the tax ID that is valid and authentic in the eyes of the registry directly.”

“To be able to capture content and serve it, you know, fit for purpose wise to the user is a critical aspect from our perspective.”

Resources:

Dave Crozier on LinkedIn 

Certa

 Tom Fox 

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