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Adventures in Compliance

The Return of Sherlock Holmes – Data – Driven Compliance from The Adventure of The Dancing Men

Welcome to a review of all the Sherlock Holmes stories that are collected in the work “The Return of Sherlock Holmes.“. It is a collection of thirteen detective stories written by Sir Arthur Conan Doyle, marking the reappearance of the brilliant detective Sherlock Holmes after his apparent death in “The Final Problem.” The collection spans various intriguing cases and mysteries that Holmes and his loyal friend Dr. John Watson tackle. Today we take up the Adventure of the Dancing Men and mine its insights into data-driven compliance through pattern recognition.

The intriguing world of Sherlock Holmes’ investigative methods offers a wealth of lessons for compliance professionals. Pattern recognition, the ability to discern order in a chaotic environment, is a fascinating topic that holds significant importance in various fields, including investigations and compliance work. Pattern recognition as a critical skill in unraveling mysteries and establishing connections within a compliance program. His perspective is shaped by his emphasis on the importance of meticulous attention to detail, the study of symbols to identify patterns, and the understanding that having data is just the beginning—pattern recognition is the crucial next step in data analysis. Fox also highlights the value of specialized knowledge and skills, such as cryptology, in deciphering codes and solving complex puzzles. He underscores the need for creative thinking, collaboration, and critical analysis in the work of a compliance professional, demonstrating how these elements can enhance pattern recognition.

Data-Driven Compliance Lessons:

  • What is data-driven compliance?
  • Once you have the data, how do you use it?
  • The Importance of Meticulous Pattern Recognition
  • Decoding Symbols and Making Connections
  • Pattern Recognition and Creative Corporate Code Breaking

Resources:

The New Annotated Sherlock Holmes

Sherlock Holmes FAQ

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program – Day 28 – Data-Driven Compliance – From Cutting Edge to Table Stakes

Compliance programs play a crucial role in ensuring that companies adhere to legal and ethical standards. In today’s digital age, where data is abundant and easily accessible, the importance of data-driven compliance programs cannot be overstated. This message was driven home very forcefully in a speech in November by Nicole Argentieri, acting assistant attorney general for the Criminal Division. She stated, “I’d like to now turn to our use of data. In the Criminal Division, we too are going above and beyond in our effort to combat white collar crime. We are not just waiting for companies to self-report, or witnesses to come forward, or for anomalies to reveal themselves on a one-off basis. Let me be the first to tell you that we have proactively used data to generate FCPA cases, and we’ve only just gotten started.”

Data-driven compliance programs have moved from cutting edge and are now seen as best practices. Soon, they will simply be table stakes for companies to effectively manage compliance risks. By actively monitoring and analyzing data, companies can identify potential compliance issues, mitigate risks, and maintain their reputation and integrity. Collaboration between different departments and a formal risk assessment are key factors in establishing a robust compliance program. As technology continues to advance, the role of data analytics and AI in compliance monitoring is expected to become even more significant. It is crucial for compliance professionals to stay informed, continuously learn, and adapt to the evolving landscape of data-driven compliance.

Three key takeaways:

1. Nicole Argentieri, acting assistant attorney general for the Criminal Division, said,  “Let me be the first to tell you that we have proactively used data to generate FCPA cases, and we’ve only just gotten started.”

2. . Compliance professionals must actively analyze the data for trends, anomalies, and potential compliance risks.

3. Data-driven compliance programs have moved from cutting edge and are now seen as best practices. Soon, they will simply be table stakes for companies to effectively manage compliance risks.

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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Blog

Data-Driven Compliance – From Cutting Edge to Table Stakes

Compliance programs play a crucial role in ensuring that companies adhere to legal and ethical standards. In today’s digital age, where data is abundant and easily accessible, the importance of data-driven compliance programs cannot be overstated. This message was driven home very forcefully in a speech in November by Nicole Argentieri, acting assistant attorney general for the Criminal Division. She stated “I’d like to now turn to our use of data. In the Criminal Division, we too are going above and beyond in our effort to combat white collar crime. We are not just waiting for companies to self-report, or witnesses to come forward, or for anomalies to reveal themselves on a one-off basis. Let me be the first to tell you that we have proactively used data to generate FCPA cases, and we’ve only just gotten started.”

Anselmo Guevara, Director, Compliance Monitoring and Analytics at VMware, has emphasized the need for companies to have a compliance program that provides visibility into their data at their fingertips. It is no longer sufficient to simply collect data and have someone review and reconcile it. Compliance professionals must actively analyze the data for trends, anomalies, and potential compliance risks. This proactive approach allows companies to identify and address compliance issues before they escalate.

But as with all new initiatives in compliance, one must emphasize the importance of starting a compliance journey with a formal risk assessment. Guevara suggested collaborating with various departments within the organization, such as accounts payable, receivables, internal audit, and business operations, to understand the risks associated with different processes. This collaborative effort helps identify compliance controls that need to be in place and ensures that the data required for analysis is available.

While low hanging fruit may seem like an attractive starting point, Guevara cautioned against solely focusing on easy wins. He advised against presenting a weak business case to secure budget approval for compliance projects. Instead, he recommended conducting a comprehensive compliance risk assessment to prioritize areas that require immediate attention. This approach ensures that compliance efforts are aligned with your organization’s overall risk management strategy.

Data analytics plays a crucial role in enhancing compliance efforts. By leveraging data analytics tools and techniques, compliance professionals can identify patterns, detect anomalies, and uncover potential compliance risks. However, Guevara highlighted the importance of validating suspicious transactions before raising concerns. It is essential to conduct due diligence and thoroughly investigate any potential issues to maintain financial integrity and credibility.

Data-driven compliance programs have moved from cutting edge and are now seen as best practices. Soon they will simply be table stakes for companies to effectively manage compliance risks. By actively monitoring and analyzing data, companies can identify potential compliance issues, mitigate risks, and maintain their reputation and integrity. Collaboration between different departments and a formal risk assessment are key factors in establishing a robust compliance program. As technology continues to advance, the role of data analytics and AI in compliance monitoring is expected to become even more significant. It is crucial for compliance professionals to stay informed, continuously learn, and adapt to the evolving landscape of data-driven compliance.

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Data Driven Compliance

Data Driven Compliance: The Journeys of Albemarle and ABB to Data-Driven Compliance, Part 2

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 around the uses of data and data analytics in compliance programs. Data-Driven Compliance is back with another exciting episode. In this special second part of a two-part podcast, I co-host with Vince Walden, CEO of KonaAI, to visit with our guests Andrew McBride, Chief Risk Officer at Albemarle, and Tapan Debnath, Head of Integrity, Regulatory Affairs, and Data Privacy—Process Automation at ABB, on their respective companies’ journeys to data-driven compliance.

Debnath’s perspective on the challenges and strategies in compliance data analytics is centered on the need for clear goals, defined processes, and the importance of early planning and resource allocation. He sees compliance data analytics as a journey rather than a project, encouraging organizations to start with imperfect data and refine their processes over time. On the other hand, McBride’s perspective is focused on prioritization, resource allocation, and audience-driven decision-making. He emphasizes the iterative nature of data analytics projects and believes that a successful ethics and compliance program does not necessarily require a large data analytics team, but rather the right roles and support from the IT function. Join Tom Fox and Vince Walden as they delve deeper into these insights with Tapan Debnath and Andrew McBride on this episode of Data-Driven Compliance.

Key Highlights:

  • Navigating Data Privacy Laws Across Jurisdictions
  • Strategic Steps in Ethics and Compliance Analytics
  • Unlocking AI’s Potential in Compliance Analytics
  • Actionable Insights from Data Analytics
  • Leveraging Documentation for Enhanced Compliance and Risk Mitigation

Resources:

Vince Walden on LinkedIn

KonaAI

Tom Fox 

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Everything Compliance

Everything Compliance – Episode 127, The Awesome Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. In this episode, we have the quartet of Jonathan Armstrong, Matt Kelly, and Jay Rosen, all hosted by Tom Fox, joining us on this episode to discuss some of the topics they are watching in 2024.

  1. Matt Kelly looks at the recently enacted Foreign Extortion Prevention Act (FEPA). He rants about the SEC getting hacked around the Bitcoin ETF announcement and reminds everyone to use two-factor authentication.
  2. Tom Fox shouts out to the University of Michigan for winning the College Football National Championship.
  1. Jonathan Armstrong looks at the intersection of AI and Operational Resilience and ties it to the need for greater Board skills in these areas. He shouts out to Jay Rosen, who is in transition and would be a great addition to any compliance product or service BD team.
  1. Jay Rosen opines on the DOJ’s Expectations for Data Driven Analytics in 2024. He shouts out to Robert Kraft and the New England Patriots for paying departing coach Bill Belichick his full 2024 salary.
  1. Jonathan Marks asks, What does it mean to be on a Board in 2024? He rants about the Philadelphia Eagles.

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
  • Karen Woody – One of the top academic experts on the SEC. Woody can be reached at kwoody@wlu.edu
  • 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 data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at armstrong@corderycompliance.com
  • Jonathan Marks can be reached at jtmarks@gmail.com.

The host, producer, ranter (and sometimes panelist) of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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Data Driven Compliance

Data Driven Compliance: The Journeys of Albemarle and ABB to Data – Driven 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. This podcast features an in-depth conversation around the uses of data and data analytics in compliance programs. Data-Driven Compliance is back with another exciting episode. Today, I co-hosted with Vince Walden, CEO of KonaAI, to visit with our guests Andrew McBride, Chief Risk Officer at Albemarle, and Tapan Debnath, Head of Integrity, Regulatory Affairs, & Data Privacy—Process Automation at ABB, on their respective companies’ journeys to data-driven compliance.

We consider the importance of integrating due diligence systems with business conduct and anticipate 2024 to be a breakthrough year for data-driven compliance. McBride, recognized by the Department of Justice for his work in data-driven compliance, believes in the critical role of data in identifying and responding to risks, testing the effectiveness of compliance programs, and reporting to internal stakeholders. Debnath stressed the need for visibility and alignment with senior business stakeholders during investigations and the use of data analytics platforms to measure integrity and key performance indicators. Join Tom Fox, Vince Walden, Andrew McBride, and Tapan Debnath on this episode of the Data Driven Compliance podcast as they delve deeper into the challenges and importance of data-driven ethics and compliance programs.

Key Highlights:

  • Using data analytics to assess program effectiveness
  • Proactive risk management through continuous monitoring
  • Leveraging due diligence for proactive risk management
  • Data transparency and collaboration for compliance success
  • Transitioning from external dependencies to internal capabilities

Resources:

Vince Walden on LinkedIn

KonaAI

Tom Fox 

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 17-Adapting Compliance Programs for Cloud Technologies

As organizations transition to remote work and embrace cloud technologies, it is crucial to adapt compliance programs to ensure regulatory obligations are met.

Companies are shifting away from traditional tools like Excel or SharePoint towards centralized systems that facilitate compliance monitoring. Compliance teams can no longer rely on face-to-face collaboration and need systems to manage communication, investigations, and case management. This shift towards virtual platforms for communication has also increased the need to capture and record voice data for compliance purposes.

Adapting compliance programs for remote work and cloud technologies is essential in the current business landscape. Compliance program visibility, capturing and recording communication data, leveraging cloud technologies, and embracing AI-driven compliance monitoring are key factors to consider. By balancing these factors and focusing on risk-based approaches, organizations can ensure they meet their regulatory obligations while enabling their compliance teams to focus on their core responsibilities. The future holds even more advancements in cloud technologies and AI, promising increased defensibility and improved compliance monitoring capabilities.

 Three key takeaways:

1. Companies are shifting away from traditional tools like Excel or SharePoint towards centralized systems that facilitate compliance monitoring.

2. You must focus on the explainability  and defensibility of your AI models.

3. By focusing on risk-based approaches, organizations can ensure they meet their regulatory obligations while enabling their compliance teams to focus on their core responsibilities.

For more information on KonaAI, click here.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Data Analytics: Day 16 – AI and Data Driven Compliance for Remote Work

The COVID-19 pandemic has significantly changed how businesses operate, with remote work becoming the new norm. This shift has highlighted the crucial role of data and data analytics in compliance across various industries. Regulators now emphasize not only the need for access to data but also its utilization in a way that promotes continuous improvement. One of the key challenges compliance teams face in this new era is the vast amount of data generated by remote work. Communication channels like email and text messages and collaboration platforms like Slack and Zoom have become essential for remote collaboration. However, this explosion of data presents compliance officers with the task of proactively monitoring and understanding unstructured data to uncover hidden risks.

AI-powered data cleansing capabilities have been developed to address this challenge. These capabilities sift through content and focus on relevant and risky information while minimizing false positives. Compliance teams can efficiently concentrate on potentially dangerous content by removing duplicative content, obvious junk, and non-human-generated text. This targeted approach significantly reduces false-positives in the alerts generated by the system.

COVID-19 brought about changes that are still felt today in the business world. Some changes were temporary, but some have become permanent, and remote work is one of them. It is here to stay. The change has underscored the importance of AI and data in compliance across various industries. The shift to remote work has resulted in increased data that compliance teams must proactively monitor. AI-powered data cleansing capabilities help sift through content and focus on relevant and risky information, while AI algorithms and machine learning models aid in risk detection. By leveraging AI and data, compliance teams can enhance their prevention, detection, and remediation efforts, ultimately promoting a culture of ethical behavior and ensuring compliance with data protection laws.

Three key takeaways:

  1. The pandemic changed the corporate world in many ways. One of the permanent ones was moving to remote work.
  2. Remote work generates much more data because messaging apps and online communication tools require new and innovative compliance solutions.
  3. AI and data-driven compliance around data generated from remote work can move a company from detection to prevention.

For more information on KonaAI, click here.

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Data Driven Compliance

Data Driven Compliance: Vince Walden on DOJ Remarks on Data-Driven 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. This podcast features an in-depth conversation around the uses of data and data analytics in compliance programs. Data-Driven Compliance is back with another exciting episode. Today, I visited with Vince Walden, CEO of KonaAI, on the recent remarks by the DOJ on data-driven analytics and compliance.

Vince Walden, an expert in data-driven compliance and fraud examination, has made significant strides in the industry as the CEO of Kona AI. His perspective on the Department of Justice’s (DOJ) increasing use of data analytics for proactive enforcement is that it marks a significant shift in the DOJ’s approach to enforcement. Walden notes that the DOJ is now actively using data analytics to proactively identify risks and cases, rather than relying solely on self-reporting or anomalies. He believes that data analytics is no longer considered cutting-edge but rather an expected part of a best practices compliance program. His extensive experience in white-collar crime and FCPA cases, as well as his participation in events such as the annual FCPA conference, have shaped this perspective. Join Tom Fox and Vince Walden as they delve deeper into this topic on the next episode of the Data Driven Compliance podcast. 

Resources:

Vince Walden on LinkedIn

KonaAI

Tom Fox 

Connect with me on the following sites:

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Data Analytics: Day 11 – The Importance of Data Governance

In today’s digital landscape, compliance, data governance, and cybersecurity have become crucial aspects of running a successful business. The convergence of these three disciplines is a growing trend, emphasizing the need for collaboration and breaking down silos within organizations. The key factor that impacts the importance of compliance, data governance, and cybersecurity in business is data governance.

Data governance involves managing and organizing data for accuracy, accessibility, and compliance. With the increasing amount of data being generated for compliance and other corporate functions, it has become crucial for organizations to have effective data governance and legal technology services in place to ensure compliance with regulatory obligations. It plays a significant role in both the business and legal aspects of an organization. CCOs and compliance professionals rely on data to make informed decisions, analyze trends, and measure key performance indicators. From a legal perspective, data governance is essential for providing legal advice and meeting regulatory obligations.

 Three key takeaways:

1. Data preservation and credibility are crucial for effective compliance representation if a regulator comes knocking.

2. Compliance, data governance, and cybersecurity are intertwined in today’s business landscape.

3. As the digital landscape continues to evolve, organizations must prioritize data governance and stay compliant and competitive in the business world.

For more information on KonaAI, click here.