Tag: Outsourced Compliance

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Innovation in Compliance

Innovation in Compliance – Steve Vincze on Building Trust: Overcoming Challenges as an Outsider

Innovation comes in many forms, and compliance professionals need to not only be ready for it but also embrace it. My guest in this episode is Steve Vincze, founder of Trestle Compliance.

Steve Vincze is a seasoned professional with a rich background as an in-house corporate commercial compliance lawyer, specializing in building trust and implementing compliance programs in businesses. His perspective on the subject is rooted in the belief that developing a human connection is key to building trust and implementing successful compliance programs. Drawing from his experience, including being recruited by Tap Pharmaceuticals to implement their first compliance program, he emphasizes the importance of modeling the behavior he wants from others and creating an environment where people feel comfortable sharing. He views compliance programs as tools to empower individuals rather than restrict them, and he strives to change the perception of compliance by demonstrating that it can be a tool for confidence and success. Join Tom Fox and Steve Vincze on this episode of the Innovation in Compliance podcast to learn more about his unique approach.

Key Highlights:

  • Establishing Trust through Human Connection
  • Experienced Professionals Providing Comprehensive Consulting Solutions
  • Expert Compliance Program Implementation Services
  • The Impact of Artificial Intelligence on Data Security

 Resources:

Steve Vincze on LinkedIn

Trestle Compliance

 Tom

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

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31 Days to More Effective Compliance Programs

Day 26 – Compliance Function in an Organization

The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. When it came to the corporate compliance function, the 2020 FCPA Resource Guide, under the Hallmarks of an Effective Compliance Program, noted the government would “consider whether the company devoted adequate staffing and resources to the compliance program given the size, structure, and risk profile of the business.” The Monaco Memo and 2023 changes to the Corporate Enforcement Policy have made this all the more critical going forward.

This Hallmark was significantly expanded in the FCPA Corporate Enforcement Policy and 2020 Update. In the FCPA Corporate Enforcement Policy, the DOJ listed the following as factors relating to a corporate compliance function that it would consider as indicia of an effective compliance and ethics program: 1) the resources the company has dedicated to compliance; 2) the quality and experience of the personnel involved in compliance, such that they can understand and identify the transactions and activities that pose a potential risk; 3) the authority and independence of the compliance function and the availability of compliance expertise to the board; 4) the compensation and promotion of the personnel involved in compliance, in view of their role, responsibilities, performance, and other appropriate factors; and 5) the reporting structure of any compliance personnel employed or contracted by the company.

The 2020 Update, Monaco Memo, and 2023 update to the Corporate Enforcement Policy all demonstrate the continued evolution in the thinking of the DOJ around the corporate compliance function. Their articulated inquiries can only strengthen a corporate compliance function specifically; and the compliance profession more generally. The more the DOJ talks about the independence of the compliance function, coupled with resources being made available and authority concomitant with the corporate compliance function, the more corporations will see it is directly in their interest to provide the resources, authority, and gravitas to compliance position in their organizations.

Three key takeaways:

  1. How is compliance treated in the budget process?
  2. Has your compliance function had any decisions overridden by senior management?
  3. Beware of compliance outsourcing, as any such contractor must have access to company documents and personnel.