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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 

Connect with me on the following sites:

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LinkedIn

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Compliance Week Conference Podcast

Vince Walden on Using Data Analytics to Improve Compliance

In this episode of the Compliance Week 2023 Speaker Preview Podcasts series, Vince Walden discusses some of his panel at Compliance Week 2023,  “Data Analytics to Improve Compliance.”

Some of the issues he will discuss in his presentations are:

  • The expectations for compliance professionals in using data analytics in their programs;
  • Insights from both sides of the coin – government and compliance professionals on lessons in creating and cultivating data-driven compliance programs; and
  • A sense of what’s coming down the pike, including technical advancements creating opportunities for compliance, ethics, and risk professionals

I hope you can join me at Compliance Week 2023. This year’s event will be May 15-17 at the JW Marriott in Washington, DC. The line-up of this year’s event is simply first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 18th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. And many others to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 75+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from the two SEC Commissioners, gain insights into the agency’s enforcement areas, and walk away with guidance on remaining compliant within emerging areas such as ESG disclosure, third-party risk management, cybersecurity, cryptocurrency, and more.
  • Bring actionable takeaways from your program from various session types, including ESG, Human Trafficking, Board obligations, and many others, for you to listen, learn and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount of $200 by using code TF200 on the link here.

Categories
Data Driven Compliance Innovation in Compliance

Daniel Villani on the Using the Right Data

Data Driven Compliance, hosted by Tom Fox, is a podcast featuring an in-depth conversation about the uses of data and data analytics in compliance programs. In this episode, host Tom Fox visits Daniel Villani from Villani Analytics. Daniel has an extensive 15-year background in technology, specifically working with medium to large businesses. They discuss Enterprise Resource Planning (ERP) and Enterprise Performance Management (EPM) software, vendor selection, audibility, and ESG reporting. Daniel emphasizes the importance of data utilization and integration, offering solutions and advice on the best solutions to stay competitive. Listeners can learn more from Daniel’s YouTube channel, Villani Analytics, and LinkedIn profile.

Key Highlights

·      ERP & EPM Explained

·      Data Privacy and Security in Financial Technology Solutions

·      Ensuring Data Accuracy and Quality Assurance Through Governance

·      The Importance of Documentation in Vendor Selection

·      Utilizing Data Analytics to Get Insights

·      Benefits of Implementing Environmental, Social, and Governance Programs

·      Building Data Streams: Connecting Siloed Data for Success

Notable Quotes

1.     ” I laugh because it sounds completely imaginative, but you’d be surprised how many organizations and some of the leading organizations and fortune 500 ones are relying on somebody’s word that their numbers are okay.”

2.     “I take the, you know, the full unbiased approach where I’m happy to recommend the system that I don’t implement just because I don’t do it for the money that comes out of it. I do it to make sure that you get the right solution for your business.”

3.     “It’s also equally important to ensure that you have the documentation around your governance in place.”

4.     “The companies that are going to bring it together in the most meaningful way are the ones that are going to better compete in their industry.”

 Resources

Daniel Villani on LinkedIn

Villani Analytics

Categories
Data Driven Compliance

Vince Walden on a Data Driven Approach to Sanctions and ESG

Data Driven Compliance, hosted by Tom Fox, is a podcast featuring an in-depth conversation around the uses of data and data analytics in compliance programs. In this episode, host Tom Fox visits Vince Walden from Kona AI to discuss data driven compliance and new areas of risk, such as trade AML and trade sanctions. Vince provides an example of a heavy equipment manufacturer using RFIDs on their products to monitor movement, and Tom warns of heavy fines for companies who fail to comply with prevailing sanctions. The conversation continues as Vince and Tom touch on topics such as ESG compliance, financial implications of green initiatives, and consortiums for sharing data. They also discuss how data analytics and text analytics can be used to track inventory and the importance of tracking energy spend to identify ESG-compliant vendors.

Key Highlights

·      Sanctions & trade compliance are the new FCPA.

·      Data-driven compliance for sanctions & trade compliance.

·      Data-driven ESG?

·      The cost of meeting ESG standards.

·      Economic benefits of sustainability.

·      Research with MIT and Integrity Distributed on the data sharing consortium.

Notable Quotes

“It’s not hard. Now they have to put the chips on, which is a variable.”

“You really have to mine the supply chain and use, you know, text analytics, text mining beyond just traditional accounting tools. To get into the weeds in that supply chain to find out where risks are located.”

“It’s funny. This is why I love our profession that we’re all in. It’s compliance and any fraud professionals, there’s always something new, always something changing.”

 “With a much broader overview. So you can see the big picture.”

 Resources

Vince Walden on LinkedIn

KonaAI

Categories
Data Driven Compliance

Ryan Hubbs on Building Out a Universe of Risks

Data Driven Compliance, hosted by Tom Fox, is a podcast featuring an in-depth conversation with Ryan Hubbs, Global Anti-Corruption and Fraud Manager at SLB. Ryan explains how internal audits have evolved over the last 5-6 years and how SLB designed dashboards and analytics to cut out manual tasks. He also explains the pre-audit survey used to measure what will come up in the final audit report. Ryan discusses how SLB tracks duplicate payments, agents, and financial, legal, and environmental risks to create a near real-time reporting module. Ultimately, monitoring these risks aims to evaluate which processes and subprocesses are increasing or decreasing in risk. Tom and Ryan share thoughtful insights throughout the podcast and explore ways to enhance your compliance program.

Key Highlights

·      Improving Fraud and Analytics With Internal Audit Reorganization. 05:35

·      Benefits of Pre-Audit Surveys and Programs. 09:20

·      Improving Fraud Detection through Data Dashboards. 12:42

·      Employee Satisfaction Survey Results. 16:21

·      Exploring Financial and Legal Risks in the Risk Universe. 19:35

·      Using Real Risk Data for Near Real-Time Reporting. 23:12

·      The Art of Conversation: Connecting with Ryan. 30:09

Notable Quotes

1.     “What would you do to make the organization better?”

2.     “Let’s automate this stuff. Let’s try to automate this and give others more time to understand the data, whether it be journal entries or fixed assets or inventory.”

3.     “We started sending that out twice a year, asking employees where you see fraud and corruption risks. Where do you see concerns? And you start to pull that data in and into internal audit as well?”

4.    “If you were the boss for the day, what would you do to improve the organization?”

Resources

Ryan Hubbs on LinkedIn

KonaAI

Categories
Data Driven Compliance

Dheeraj Thimmaiah on Creating and Using an Internal Data Analytics Tool

Data Driven Compliance is your go-to podcast to learn about the latest in business analytical tools. It is sponsored by Kona AI. In this series, host Tom Fox brings you insightful interviews with experts in digital analytics, cyber security, and more. In this episode, Tom sits down with Dheeraj Thimmaiah from AB InBev. Dheeraj talks about the development of their internal data analytics reporting tool called ‘BrewRite.’ This tool has a wide variety of applications, from its use in helping to create the compliance function’s ‘Quarterly Ethics and Compliance Assurance Report’ to alert users when activities are triggered and providing information in the case manager module. Tune in and join the conversation with Tom and Dheeraj as they talk about the future of technology and the power of data analytics in uncovering risks! 

Key Highlights

·      Using Data Analytics to Navigate the company’s compliance challenges [00:06:04]

·      AB InBev’s Internal Tool BrewRite.  [00:10:09]

·      Monitoring and Assessing Business Ethics and Compliance Risk via Quarterly Reports -[00:21:47]

 Notable Quotes

1.      “The first thing we wanted to see is, how do we kind of slowly introduce them to the concept of data program?”

2.     “For us, the words simple and effective, we want to see how people are taking their day-to-day jobs and making it much easier.”

3.     “At the end of the day, these are the people who are actually looking at a particular area, identifying the risk or mitigating risk. They’re the source of a lot of things that get done within the company. So it’s so important for us to focus on them as an audience because they’re the people who can leverage the tool to the maximum value and also, at the same time, provide us great input because the closest to the business and the transactions that are happening across the ground to evolve types of risk we are looking for so we can continue to progress.”

4.     “We want to build something like that internally, and we’ve really titled this the quarterly ethics of compliance assurance report.”

 Resources:

Connect with Dheeraj Thimmaiah on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

Categories
Blog

Using Data Analytics to Create an Effective Compliance Program-Part 3

In this conclusion of a three-part blog post series, we are considering how to create an effective compliance program through the use of data analytics. I am joined in this exploration by Vince Walden, CEO of Kona AI and we are considering the requirements laid out by the Department of Justice (DOJ) in their recent pronouncements on best practices, as well as the key trends and lessons learned from enforcement actions. Finally, we will consider the speech by Kenneth Polite on the changes to the Corporate Enforcement Policy and how to meet those requirements using data analytics. Walden articulated 10 steps you need to follow:

  1. Assess a company’s conduct;
  2. Self-disclose;
  3. Know quickly if there is a problem or not;
  4. Have access to relevant sources of data;
  5. Conduct monitoring at the beginning and throughout the lifespan of the relationship
  6. Have an on-premise application;
  7. Look up vendors and transactions quickly;
  8. Run data through a library of corruption and fraud tests;
  9. Look at a predictive model and see if it meets the profile of an improper payment; and
  10. Have visibility into data almost at their fingertips.

The 7th step involves having an on-premise application for data analytics. This is an important step, as it allows companies to keep their data secure, while still being able to use predictive analytics and other compliance monitoring tools. You should consider a platform designed to be hosted and managed as a service, meaning that companies can utilize the platform without having to move large amounts of data around each month.

Under steps 8 & 9, you should run your data through a variety of libraries and test but a key is doing so without compromising their data privacy. Using data analytics to identify anomalous payments that may be indicative of corruption or fraudulent activities. This will help your organization to meet the DOJ’s expectations for an effective compliance program. It helps improve business processes, increase transparency, and reduce the risk of improper payments. Additionally, such a data analytics platform can be used to benchmark an individual company’s compliance program by identifying attributes of an improper payment.

Finally under Step 10, your organization should use a tool which also supports data visualization and dashboards that help companies analyze their compliance data in real time by quickly identifying any irregularities or anomalies that could be indicative of corruption or fraudulent activity. Your system should also provides support for automated reporting, allowing companies to easily generate reports on their compliance program. This can help companies identify areas of improvement, as well as any potential issues that should be addressed. Such visibility can extend up to the Board of Directors level which will enhance your reporting up the organization and facilitate the Board’s requirement for oversight under the Caremark Doctrine.

This approach can be used to facilitate risk assessments, helping companies to ensure that their compliance programs are up to the standards set by the DOJ. Through ongoing monitoring, it can be  used to track activities and progress in compliance over time, providing companies with a better understanding of their compliance processes, ensuring an effective way to demonstrate your compliance program is up to the standards set by the DOJ.

Data driven compliance decisions are essential for companies to meet the expectations of the DOJ This includes having access to relevant sources of data, conducting monitoring at the start and throughout the lifespan of a relationship, having an on-premise application, and self-disclosing any potential violations to the DOJ. A data analytics platform that can help companies meet these expectations, as it will provide advanced analytics and compliance monitoring that allow companies to quickly identify areas of risk and anomalies in their data. Additionally, the platform can be used to collaborate with other companies to gain insights into attributes of an improper payments to prevent fraud or even simple over-payment of vendor invoices.

Perhaps there is no better example of a data driven approach to compliance in meeting the DOJ expectations than in the 2022 ABB, Foreign Corruption Practices Act enforcement action. In it, ABB had notified the DOJ it wanted to meet and had scheduled a meeting but before ABB could come in and self-disclose, the story of ABB corruption in South Africa broke in the local news. However the DOJ credited ABB for detecting the violations and notifying the DOJ it was coming in. This went a long way towards the excellent result ABB was able to achieve in its resolution with the DOJ.

Listen to Vince Walden on Data Driven Compliance

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Blog

Using Data Analytics to Create an Effective Compliance Program-Part 1

I recently had the opportunity to visit with Vince Walden for the inaugural episode of the newest podcast on the Compliance Podcast Network, Data Driven Compliance. Walden is a compliance professional with 15 years of experience, who left his day job and founded Kona AI, a cutting-edge innovation for compliance professionals. Kona AI is an on-premise platform to build advanced analytics and compliance monitoring that aligns with the DOJ’s expectations.

Over this multi-part blog post series, I will be discussing how to create an effective compliance program through  the use of data analytics by considering the requirement laid out by the Department of Justice (DOJ) in their recent pronouncements on a best practices, as well as the key trends and lessons learned from enforcement actions. Finally, we will consider the speech by Kenneth Polite on the changes to the Corporate Enforcement Policy and how to meet those requirements using data analytics.

It is important for compliance professionals to make informed decisions that are driven by data to ensure that the compliance program is effective and efficient. Data-driven decisions enable compliance professionals to make decisions that are backed by evidence, allowing them to make informed decisions that are based on facts and figures rather than assumptions or guesswork. Without data, compliance professionals would be unable to accurately measure the effectiveness of their compliance program or identify potential risks or areas of non-compliance.

Data-driven decisions also allow compliance professionals to identify areas of strength and opportunities for improvement. By utilizing data, they can identify trends, patterns, and correlations that can help them understand the underlying causes of compliance issues and formulate strategies to address them. Furthermore, data-driven decisions are more likely to be accepted and supported by stakeholders, as they are based on facts and have been thoroughly researched and analyzed. Ultimately, data-driven decisions ensure that compliance professionals are making informed decisions that are in the best interests of their organization. Walden articulate 10 steps you need to follow:

  1. Assess a company’s conduct;
  2. Self-disclose;
  3. Know quickly if there is a problem or not;
  4. Have access to relevant sources of data;
  5. Conduct monitoring at the beginning and throughout the lifespan of the relationship
  6. Have an on-premise application;
  7. Look up vendors and transactions quickly;
  8. Run data through a library of corruption and fraud tests;
  9. Look at a predictive model and see if it meets the profile of an improper payment; and
  10. Have visibility into data almost at your fingertips.

Under Step 1, the assessing of your company’s conduct begins with understanding the DOJ’s  expectations for an effective compliance program. Companies should have policies and procedures in place that enable them to access relevant sources of data, conduct ongoing monitoring of third-party relationships, and hold compliance officers accountable for the effectiveness of the compliance program. Additionally, companies should ensure they have the necessary technology in place to be able to quickly conduct an analysis of their data to determine if a self-disclosure is necessary. By taking these steps, companies can ensure they are meeting the DOJ’s expectations and are in a better position to successfully self-disclose if necessary.

Finally, assessing a company’s conduct should also involve an analysis of the company’s external communications. Companies should have a process in place for responding to inquiries from the public, media, and other stakeholders, and they should ensure that all communications are accurate and timely. Additionally, companies should ensure they are regularly engaging with their stakeholders to keep them informed of any changes in their compliance policies or procedures. By taking these steps, companies can ensure they are engaging in effective external communications that foster trust and confidence in their compliance program.

Self-disclosure is a key step in achieving an effective compliance program. Walden lists this as Step 2. It is important for companies to to demonstrate their commitment to compliance and avoid possible enforcement actions. Recently Kenneth Polite reiterated the importance of self-disclosure and discussed the changes to the corporate enforcement policy. Self-disclosure is viewed as a sign of good faith and can have a major impact on the DOJ’s decision to pursue or not to pursue a case.

However, to meet this requirement under the DOJ Corporate Enforcement Policy, companies need to have access to their data quickly in order to determine if self-disclosure is necessary. This means having an on-premises platform that can quickly search through transactions, identify potential corrupt payments, and compare them to a predictive model. This will demonstrate that they have an effective compliance program for the DOJ to consider them for leniency. But it requires having access to relevant sources of data and conducting monitoring throughout the relationship with third parties. Having an analytics platform can help companies detect anomalies in their data and identify patterns in the data that can help create an effective compliance program.

In addition to self-disclosure, companies must also take steps to ensure that their compliance program is effective and meets the standards of the DOJ. Companies should have access to a streamlined technology platform that helps them manage their compliance efforts. This platform should have tools to monitor third-party relationships, identify suspicious activity, and monitor compliance efforts. An effective compliance program also requires ensuring that employees receive proper training and understanding of the company’s policies and procedures. Companies should also have an audit system in place to regularly check that their compliance program is meeting the standards of the DOJ. This audit system should include periodic assessments of the compliance program and regular reviews of third-party relationships.

Of course, if you do not know you have a problem, you organization cannot self-disclose and cannot meet the mandates to demonstrate an effective compliance program. Hence under Step 3, an organization must understand if there is a problem or not which warrants self-disclosure.  With the right technology in place, companies can monitor their compliance efforts and ensure that they are meeting the expectations of the DOJ. Additionally, companies should ensure that employees are properly trained on the company’s policies and procedures. Taking these steps can help create an effective compliance program that meets the expectations of the DOJ.

Join us tomorrow where continue our exploration of using data analytics to create an effective compliance program.

Listen to Vince Walden on Data Driven Compliance.

Categories
Data Driven Compliance

Vince Walden on Taking Your Compliance Program to the Next Level Through Data Analytics

Welcome to Data Driven Compliance, the newest edition to the Compliance Podcast Network. In this podcast we will 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 the 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 Kona AI.

In our inaugural episode, I visit with Vince Walden, a forensic data analytics expert and the CEO of Kona AI, a cutting-edge compliance monitoring platform. He has a long history of consulting for white collar crime investigations and forensic data analytics. He has worked on high profile data analytical projects such as Anheuser Busch’s BrewRite platform.

Key Highlights

  1. Discover how data analytics can be used to fight global corruption and identify improper payments.
  2. Learn how data transparency and cost-effectiveness are paramount to an effective compliance program.
  3. Investigate how data analytics platforms can be used to keep organizations out of trouble and make the business better.

Notable Quotes

“Compliance professionals are now being looked at to help spearhead this initiative around business transparency, especially into their third parties or their employee activities, and sometimes even customers or distributors.”

“Getting companies to commit resources to it, it needs to be cost effective.”

“Data analytics is always a topic at the conferences, at the conferences on social media, et cetera. Gaining insights into transparency in your data is paramount to an effective compliance program.”

“Being able to make the business better by adding cash back onto the balance sheet and stopping improper payments or finding errors or stopping a corrupt payment before it’s paid, that’s all making the business better.”

 Resources:

Connect with Vince Walden on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

Categories
The Walden Pond

An Interview with Myself – How My Forensic Data Analytics Career Led Me to Kona AI

 

Host Vincent Walden goes solo as he shares his story of changing careers and discusses the direction he plans to take his new company in. Vincent is using his 20+ years as a legal, compliance and investigation technology innovation expert to lead Kona AI as its new CEO. Kona AI is the most innovative, AI-driven, cost-effective, and easy-to-use compliance and anti-fraud technology solution to mid and large companies on the market.

 

 

In the last months of his role as Managing Director at Alvarez & Marsal, he came to the realization that the Kona AI platform, which they had been using to help companies find improper payments, needed to be scaled. Now, he and his colleague Matt Galvin are collaborating with MIT to build an algorithm-sharing consortium of leading companies.

 

Resources

To learn more, and contact Vincent Walden, please visit Kona AI