Tag: red flags

Categories
Data Driven Compliance

The Uses of Data Driven Compliance: Part 2 – Profiles of a Corrupt Payment

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 and leading to a higher 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 Kona AI.

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 corrupt payments, making the business case for data-driven compliance, what to ask for and how to ask for it, and some success stories. In Part 2, we explore the profiles of corrupt payments.

Vince Walden is an expert in identifying high-risk payments and preventing corporate corruption. His belief in the ability of data analysis and collaboration to find patterns and warning signs shapes his viewpoint on these issues. He shares his experience from a research project where companies collaborated anonymously to analyze the profiles of improper payments, using risk-scoring transactions and applying anti-corruption tests to identify high-risk attributes. Vince emphasizes the importance of transparency and access to data to proactively investigate suspicious activities, serving as a guardrail to prevent potential corruption. Join Tom Fox and Vince Walden as they delve deeper into this topic on this Data Driven Compliance podcast episode.

Key Highlights:

  • Attributes of High-Risk Payments Analysis
  • Uncovering Suspicious Sales Spikes in Poland
  • Detecting Improper Payments with Data Analysis

Resources:

Connect with Vince Walden on LinkedIn

Check out Kona AI

Connect with Tom Fox on LinkedIn

Categories
Daily Compliance News

December 17, 2022 – The Lavish Life Style Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you four compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network.

Stories we are following in today’s edition of Daily Compliance News:

  • When does a lavish lifestyle = Red Flags? (NYT)
  • Amazon agrees to business practice changes in the EU. (NYT)
  • DFS issues guidance for banks on crypto. (WSJ)
  • Crypto has made corruption worse. (The Guardian)
Categories
GalloCast

Gallocast – Episode 5

Welcome to the GalloCast. You have heard of the Manningcast in football. Now we have the GalloCast in compliance. The two top brothers in compliance, Nick and Gio Gallo, come together for a free-form exploration of compliance topics. It is a great insight on compliance brought to you by the co-CEOs of Ethico. Fun, witty, and insightful with a dash of the two brothers throughout. It’s like listening to the Brothers Gallo talk compliance at the dinner table. Hosted by Tom Fox, the Voice of Compliance.

Topics in this episode include:

  • FTX
  • Elizabeth Holmes was sentenced. End of an era in tech?
  • Compliance program incentives and clawbacks.
  • Assessing culture.
  • Monaco Memo

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program for 3rd Parties-Evaluation of Due Diligence With Candice Tal

An important part of the job duties of any compliance practitioner is clearing red flags which might appear for a proposed third-party relationship during the due diligence process. It is mandatory that not only must all red flags be cleared but there also be evidence of the decision-making process to show to a regulator if one comes knocking. Around third-parties, consider what risks you face in both your sales and supply chain. If there is a key player several tiers down the line who creates or builds a key component or delivers a critical service, you may want to put more management around that relationship from the compliance perspective.

For anything below a tier 2; you may be able to manage your risks through having your direct tier one counter-party take the lead in managing such compliance risks. But make sure that the expectation is communicated to your direct counter-party so that if the government comes knocking you can show that not only did you contractually obligate your direct counter-party to do so but that you provided them the tools and training to do so. Finally, you will need to be able to show that your direct counter-party did so.

Three key takeaways:

  1. There is no set formula for clearing of red flags or the evaluation of due diligence.
  2. Know when to say enough has been done.
  3. You must “Document, Document, and Document” your evaluation of any red flags.
Categories
Innovation in Compliance

Gini Dietrich on Spotting Red Flags


 
This week’s guest on Innovation In Compliance is Gini Dietrich, CEO and founder of Spin Sucks. Gini is a writer, blogger, speaker and all-around expert in the PR space. She recently wrote a blog post entitled, How to Spot Red Flags in New Business Relationships, which is the focus of her discussion with Tom Fox in this week’s show.
 

 
Trust Your Instincts
Tom asks Gini what inspired the blog post. She responds that she actually wrote the blog post as a reminder to herself to always look for red flags and always listen to her gut. She says that when you’re contemplating a prospective business relationship, there are a few questions you should always ask yourself. Do you see red flags? Can you get past them because there are other advantages? Should you discontinue the conversation and save yourself time, angst, money and resources in the long run? In the PR space, the most common red flag is unrealistic expectations, Gini explains.
Why? Why? Why?
Gini points out the importance of writing down red flags. For one thing, it makes them more concrete; and for another thing, you can take your questions into your meetings to remind yourself to ask certain questions if red flags arise. You should be constantly evaluating your business relationships. Ask follow up questions. Gini advocates asking why at least three times. Tom comments that the compliance industry uses that exact technique; it’s called root cause analysis.
Learn to Say No
Tom asks, “Why is the ability to say no critical for business owners and compliance professionals?” Gini responds that in business relationships if you can’t find any red flags then it’s usually going to be a good relationship. The inverse is also true: if there are red flags then the relationship is usually going to be difficult. The other reason why being willing to say no is important is that in the PR business as in compliance, you’re selling your time and you can’t scale that. So it’s critical to say no to things that will take your time away from what you should be doing. Tom mentions that part of Gini’s process is to try to disqualify every prospect. She comments that looking for reasons to disqualify a prospect, and finding them, makes it easier to say no to them. She shares tips on what red flags might look like from the employee and client perspective.
Resources
SpinSucks.com
How to Spot Red Flags In New Business Relationships