Categories
FCPA Compliance Report

FTX and Risk: Part 1 – Financial Institutions

Welcome to the award-winning FCPA Compliance Report, the most senior podcast in compliance. In this episode, I begin a 2-part series on the subjects of FTX and risk. I am joined by Gilbert Paiz and Andrew Gay, principals in the Texas Hill Country Advisors. In Part 1, we consider risk and risk management through the lens of US domiciled financial institutions and how their risk management protocols help to not only assess risk, but manage risk throughout the life cycle of a banking customer relationship. In Part 2, we will consider individual risk in investing and what type of background information, questions and due diligence individuals should engage in and how these questions and background investigations apply equally to larger investments made by sophisticated investors, hedge funds  and institutional investors; who should have made them before investing in FTX but they all failed to do so.

Some of the highlights include:

·      How do banks think of risk?

·      What internal processes or controls are in place to help a bank manage its risks?

·      What types of oversight do banks and financial institutions use to help manage risk?

·      Why are levels of review so critical?

·      How do banks think about customers in terms of risk?

·      Who decides how much risk to allow a customer to engage in with a banks money, whether through loans or other capital?

·      Do bank employees receive ongoing training on risk management issues?

·      What tech is in place to facilitate the management of risk?

 Resources

Texas Hill Country Advisors

Categories
Greetings and Felicitations

Great Structures Week I: Vitruvius, the Brooklyn Bridge and Compliance

Welcome to the Greetings and Felicitations, a podcast where I explore topics that might not seem directly related to compliance but influence our profession. In this special series, I consider many structural engineering concepts are apt descriptors for an anti-corruption compliance program. In this episode 1, I consider the Roman architect Vitruvius and what makes a structure great. Highlights include:

·      The Vitruvius Triad.

·      Compliance Program formulations.

·      What are form, function, and structure

·      Continuous risk and continuous risk management.

·      Risks assessments after Covid 19.

Resources

Understanding the World’s Greatest Structures: Science and Innovation from Antiquity to Modernity,” taught by Professor Stephen Ressler from The Teaching Company.

Categories
Daily Compliance News

April 13, 2022 the Ukraine Risk Edition


In today’s edition of Daily Compliance News:

  • NY Lt. Gov charged with public corruption. (WSJ)
  • Are new rules for vetting PE investors coming? (WSJ)
  • Expanding series of risks from the Ukraine conflict. (WSJ)
  • Crypto.com hires financial crimes and compliance experts. (WSJ)
Categories
Compliance Into the Weeds

Boaty McBoat, Risk and Compliance


Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent grounding of the Ever Given in the Suez Canal, which has now been floated free. What does it mean from the risk management and compliance perspective? Some of the issues we consider are:

  • What were the controls in place to stop this failure?
  • What changed which rendered these controls ineffective and even obsolete?
  • What is your risk program around supply chain disruption?
  • Was this a Black Swan event?
  • What does this mean for compliance officers? 

Resources
Matt’s blog post on Radical Compliance: 
Less Ever Given on Risk and Control
The bank effect and the big boat blocking the Suez, Brendan Greely in the FT

Categories
Compliance Into the Weeds

CEOs Perception of Risk, Impact on Compliance


Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the 2021 PwC Global CEO Survey, including its findings about digital transformation of business processes and risk management. Some of the issues we consider are:

  • What are the top risks CEOs are worried about in 2021?
  • How has that list changed since 2020?
  • What is the digital transformation of business process and risk management?
  • How will compliance response to these new risks?
  • What does this mean for compliance officers? 

Resources
Matt’s blog post on Radical Compliance: 
Thoughts from CEOs

Categories
Across the Board

Across the Board-Episode 2, Sheila Hooda on the Board’s Role in the Oversight of Risk and Strategy

In this episode, we discuss the key role Board of Directors around oversight of strategy and risk. Mutual of Omaha Insurance Company and Virtus Investment Partners. She is a thought leader, regular contributor, and speaker on governance, strategy, and leadership. Prior to her board service, Ms. Hooda held senior operating roles at TIAA, Credit Suisse Investment Bank, Thomson Reuters, and McKinsey & Co. across the US, Europe, and Asia/India. Ms. Hooda is a lifetime member of the Council on Foreign Relations and serves on boards focusing on Education, Women’s Empowerment, and Global Policy. The Board of Directors has a key role in the oversight of strategic risk for an organization.

Categories
FCPA Compliance Report

FCPA Compliance Report – Episode 344 – Virginia Suveiu

Legal Risk Management Specialized Studies Certificate Program for UCI Extension, where she teaches for that program and the Contract Management Certificate Program. She has published articles on various business law matters, most recently for the National Contract Management Association’s Contract Management Magazine May 2015 issue, as well as for the National Center for State Courts and the Aerospace and Defense Forum. Every corporation and compliance practitioner faces a wide variety of risks. These include regulatory risks, legal risks, reputational risks, safety risks, environmental risks, and many other types of risks. We consider whether there is one process or approach to take to the over-arching concept of risk management or if the approach needs to be fined tuned by an organization. We discuss the Legal Risk Management Specialized Studies Certificate Program, including the program benefits and who should attend. We explore the approach to teaching risk management. We discuss some of her current initiatives on the study of and teaching of risk. In this episode, I discuss with Virginia Suveiu the theories of risk and the process of risk management.

Categories
Compliance Into the Weeds

Compliance into the Weeds-Episode 14, Wells Fargo and the Fraud Triangle

Fitting the Fraud Triangle to Wells Fargo
For more on the Wells Fargo, compliance and ethics disaster, see the following:

  1. What is Risk?
  2. Tones at the Top; and
  3. Wells Knew all Along.

[tweet_box design=”default” url=”http://wp.me/p6DnMo-2LH” float=”none”]Learn how the fraud triangle works for a the Wells Fargo and a variety of other corporate scandals.[/tweet_box]]]>