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Innovation in Compliance

The Salus Blueprint: Episode 5 – The Decision No Dashboard Can Make

What questions might a leader face on a difficult morning? In this special podcast series, Marc Duncan, Bridget Lee-Young, and Scott Pickett of Salus Solutions explain one useful idea for a variety of corporate professionals, such as risk and compliance leaders and anti-bribery and corruption professionals, and then demonstrate how that idea changes a decision. This podcast is also for police and fire chiefs, emergency managers, finance and operations executives, CEOs, boards, and leaders of commercial, public, and private organizations. Over the next four weeks, we’ll run this special series.

In Episode 5, we consider documenting risk decisions, ownership, and insurance in continuity gaps. Today, the panel discusses leadership authority and decision ownership when a business continuity gap is identified, emphasizing options beyond “do nothing” or “buy something.” They describe remediation through procedural fixes (fallback procedures, contact lists, temporary workarounds, alternate communications), durable fixes (redundant vendors, schedule changes, pre-positioning resources), and deliberately accepting risk if it is documented, revisited, and informed by changing time horizons. The panel stresses documenting decision factors and dissenting views and using specialized experts, including insurance carriers, to compare coverage costs with outage losses and to address insurability gaps identified through assessments. They introduce pivot plans, tripwires/decision gates, and mandatory leadership sign-offs for policy exceptions and explain SAL CAPA as a tool to record who decided what, assign owners and deadlines, and preserve rationale without replacing leadership. The episode ends with a RiverBend scenario recap and a teaser on turning plans into real capability.

 

Key highlights:

  1. What options should leadership see besides “buy something” or “do nothing” when a continuity gap has been identified?
  2. How do you explain the evidence, uncertainty, cost, operational effect, and remaining risk of each option in language a board can use?
  3. Who may recommend an action, who may authorize it, and who is responsible for executing it?
  4. If compliance and operations disagree about urgency, how can they surface the disagreement constructively?
  5. What does a defensible decision record capture: what was known, assessed, recommended, decided, assigned, and completed?
  6. What does it mean for a leader to knowingly accept residual risk, and when should they revisit that choice?
  7. How does SalCAPA help coordinate information and responsibilities without substituting for leadership?
  8. What would a finance officer need to see to fund a near-term workaround while a more durable solution is assessed?

Questions for Our Listeners: A signed decision can still leave people exposed if no one can perform it on a difficult day. Who will turn your approved plan into working capability? Next time, we follow the action.

About Salus Solutions: “Salus helps organizations understand what matters, make informed protective decisions, and carry them into action. SalCAPA is the method and coordination environment that connects those steps.”

Salus Solutions sponsors this podcast series.

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Innovation in Compliance Uncategorized

Innovation in Compliance: The Salus Blueprint: Episode 3 – What Do We Actually Know

What questions might a leader face on a difficult morning? In this special podcast series, Marc Duncan, Bridget Lee-Young, and Scott Pickett of Salus Solutions explain one useful idea for a variety of corporate professionals, such as corporate risk and compliance leaders and anti-bribery and corruption professionals, and then demonstrate how that idea changes a decision. This podcast is also for police and fire chiefs, emergency managers, finance and operations executives, CEOs, boards, and leaders of commercial, public, and private organizations. This is Episode 3 of our four-week special series.

In Episode 3, the panelists move from reports to decision-grade intelligence. Continuing the River Bend scenario, they explain how raw reports become actionable intelligence for leaders. They distinguish information from intelligence by emphasizing verification, context, confidence levels, and the need to answer “so what,” including triaging fast-moving inputs during response versus slower mitigation phases. They consider “trust but verify,” using multiple sources and alternatives such as forensic data, open-source information, satellite imagery, and patterns of life when human intelligence is unavailable, while clearly stating what is known, believed, unknown, and what would change the assessment. They stress building trusted relationships before crises, integrating functional areas like legal and accounting into decisions, and recognizing differing board risk tolerances through facilitation and reflective questioning. They also address how to maintain credibility when assessments change by issuing complete corrections to all prior recipients.

Key highlights:

  1. “What changes when a raw report becomes intelligence a decision-maker can responsibly use?”
  2. “If three people repeat the same unverified story, have we gained three independent sources?”
  3. “How do you assess whether a system interruption is recent, confirmed, relevant to Riverbend, and likely to affect an essential service?”
  4. “How do you handle a potential vendor integrity concern without accusing anyone prematurely or compromising a legitimate review?”
  5. “What should an intelligence briefing say about confidence, limitations, and missing information?”
  6. “When would you call in a technical specialist, an investigator, or a local public-safety partner rather than generalize beyond your expertise?”
  7. “What does SalINTEL provide that a search engine, an alert feed, or a dashboard cannot determine on its own?”
  8. “What new fact would make you change your mind, and how should that update reach the people who acted on the earlier assessment?”

Question for Our Listeners: Even if the warning is credible, can you show which consequence matters most and whether your people can handle it?

Next time, we turn understanding into risk and capability priorities.

About Salus Solutions: “Salus helps organizations understand what matters, make informed protective decisions, and carry them into action. SalCAPA is the method and coordination environment that connects those steps.”

Salus Solutions sponsors this podcast series.

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Innovation in Compliance

Innovation in Compliance: The Salus Blueprint: Episode 2 – The Signal Lost Between Departments, Things Go Wrong?

What questions might a leader face on a difficult morning? In this special podcast series, Marc Duncan, Bridget Lee-Young, and Scott Pickett of Salus Solutions share one useful idea for corporate professionals, including risk and compliance leaders and anti-bribery and corruption professionals, and show how it changes decision-making. This podcast is also for police and fire chiefs, emergency managers, finance and operations executives, CEOs, boards, and leaders of commercial, public, and private organizations. Over the next 4 weeks, we’ll run this special series.

In Episode 2, we explore how to break silos with tripwires and dashboards and how organizations should evaluate and act on third-party and operational warnings, using repeated contractor communication failures as a potential red flag. We emphasize forensic assessment to determine whether issues are human, process, or technical, and the importance of timely, credible information and formalizing informal communication channels. This podcast highlights that third parties are often the highest risk and that companies must perform and test vendor due diligence beyond tabletop exercises, distinguishing mistakes from potentially criminal conduct through evidence, paper trails, and investigative techniques. Salus describes a multidisciplinary approach that integrates operational, financial, legal, and supply-chain risks; documents findings for defensibility; and helps leaders interpret data through predefined triggers/tripwires and business rules. They also address board oversight needs through dashboards, common operating pictures, and framing updates as confirmed, validating, and unknown, previewing the next episode on separating credible warnings from rumors.

Key highlights:

1. “A staff member says the contractor’s communications system has failed twice. What makes that report useful rather than a vague complaint? ”

2. “What minimum context do you seek: time, place, affected service, source, what was observed, what was inferred, and who already knows? ”

3. “What is the difference between a report of an irregular vendor request and an allegation of bribery? How do we avoid prejudging it? ”

4. “What happens when operations knows of an interruption, compliance knows of a vendor concern, and emergency management knows a storm is coming, but no one sees all three?”

5. “Who should see what information, and how does an organization protect confidentiality while connecting the right people? ”

6. “What does SalCAPA do to help people exchange observations, requests, records, and status? What must a human still decide? ”

7. “What should a leader do when a report is incomplete but potentially consequential? ”

Questions for Our Listeners: Write down one current concern, capture who reported what, when, the potential effect, and the next person responsible for checking it. Could your organization tell the difference between a credible warning and a convincing rumor before making a costly or dangerous decision? Next time, we show how information becomes qualified intelligence.

About Salus Solutions: “Salus helps organizations understand what matters, make informed protective decisions, and carry them into action. SalCAPA is the method and coordination environment that connects those steps.”

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Innovation in Compliance

Innovation in Compliance: The Salus Blueprint: Episode 1 – What Must Keep Working When Things Go Wrong?

What question might a leader face on a difficult morning? In this special podcast series, Marc Duncan, Bridget Lee-Young, and Scott Pickett of Salus Solutions share one useful idea for corporate professionals, including risk and compliance leaders and anti-bribery and corruption professionals, and show how it changes a decision. This podcast is also for police and fire chiefs, emergency managers, finance and operations executives, CEOs, boards, and leaders of commercial, public, and private organizations. In Episode 1, we take a deep dive into what matters most: mission-critical dependencies and Salus Solutions’ Preparedness Toolkit.

Key Highlights:

  1. “If I run an organization and tell you, ‘We have a risk register and an emergency plan,’ what would you ask first to learn whether I know what matters most?”
  2. “What does ‘protect the mission’ mean for a hospital support service, a school, and a commercial operator in everyday terms?”
  3. “Who must be in the first conversation besides the chief executive? What will the front-line operator know that the board may not?”
  4. “Where do dependencies such as communications contractors, utilities, responders, or key individuals enter that conversation?”
  5. “Can you explain SalINTEL, SalTHIRA, SalCAPA, and SalOPS without an acronym chart, using this one organization?”
  6. “What decisions remain with the client, and what work can Salus advise on or support?”
  7. “If a board has only ten minutes, what one question should it ask management to expose an assumption about continuity?”

Questions for Our Listeners: Write down one essential service and ask what people, systems, outside organizations, and decisions it depends on. “If a worker reported a failing dependency tonight, could your organization capture it and get it to someone who understands its significance before the service stops?” Next time, we examine how to collect what matters.

About Salus Solutions (https://salus.solutions): “Salus helps organizations understand what matters, make informed protective decisions, and carry them into action. SalCAPA is the method and coordination environment that connects those steps.”

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FCPA Compliance Report

FCPA Compliance Report: Navigating Security Threats In Venezuela with Marc Duncan – A Comprehensive Approach to Risk Management

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Marc Duncan, Chief Operating Officer at Salus Solutions, joins Tom to discuss security issues that US companies returning to Venezuela need to address upon reentering the country.

They deep dive into understanding and managing security threats across domains such as finance, personnel, corporate structure, and cyber operations. Duncan discusses the importance of viewing problems abstractedly, conducting full-scale threat assessments, and the crucial role of continuous monitoring. He shares insights into working with local communities, ensuring physical and operational security, and developing crisis communication strategies. The conversation also touches on insider threats, technical surveillance countermeasures, and the need for a responsive, flexible security team. Learn how companies, including those operating in high-risk environments such as Venezuela, can effectively prepare for and mitigate risks.

Key highlights:

  • Comprehensive Threat Assessment
  • Corporate Security and Board Involvement
  • Assessing Organizational Risk Culture
  • Insider and External Threats
  • Logistics and Local Partnerships
  • The Importance of Crisis Communication Training
  • Final Thoughts and Recommendations

Resources:

Marc Duncan on LinkedIn

Salus Solutions

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Returning to Venezuela on Amazon.com

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Blog

Returning to Venezuela: Part 4 – From Physical Security to Enterprise Risk

In this five-part series, I have walked through the core compliance risks US energy companies will face as they consider a return to Venezuela. We began with bribery and corruption and the long shadow of PDVSA (Parts 1 & 2), then moved to export controls (Part 3).

Today, we consider the security risks and the broader operational and strategic challenges of working in one of the most complex risk environments in the world. For many compliance professionals, “security” still conjures images of guards, gates, and cameras. It is treated as an operational afterthought or a line item buried somewhere between facilities and travel. The conversation I recently had with Marc Duncan, COO at Salus Solutions, should permanently disabuse compliance officers, boards, and senior executives of that narrow view. As Duncan describes it, security is not a physical function. It is an enterprise risk discipline. It is continuous monitoring at its purest. And it is inseparable from culture, governance, and decision-making authority.

For compliance professionals, especially those operating globally or in volatile environments, this conversation offers a masterclass in how risk really works when theory collides with reality.

The First Compliance Failure: Thinking You Already Know the Risk

One of the most striking observations Duncan makes is also one compliance professionals hear far too often after a failure: “We did not see that coming.” As Duncan notes, that usually means the organization was not looking. They had a preconceived notion of their threats, locked onto a narrow risk model, and failed to challenge their assumptions. This is a classic compliance failure. Risk assessments that confirm management’s beliefs instead of testing them are not risk assessments. They are comfort exercises.

True threat assessment, whether physical, cyber, financial, or reputational, begins with abstraction. You step back, examine the environment holistically, and then break it down across functions. Duncan’s approach mirrors what the DOJ expects from a mature compliance program: financial risk, personnel risk, operational risk, cyber risk, structural risk, and external conditions assessed together, not in silos. Compliance professionals should take note. If your risk assessment is static, annual, and checklist-driven, you are already behind.

An additional framework compliance professionals should consider integrating into this approach is Threat and Hazard Identification and Risk Assessment (THIRA). While THIRA originated in the public sector and homeland security context, its core discipline translates directly to corporate compliance and enterprise risk management. THIRA forces organizations to first identify credible threats and hazards, assess their likelihood and impact, and only then evaluate existing capabilities and gaps. The discipline prevents the most common compliance failure: designing controls around assumed risks rather than actual ones.

A THIRA has three key steps:

  • Identify Threats and Hazards: Identify the threats and hazards that could impact them. These can include natural disasters such as hurricanes and earthquakes, technological hazards such as power outages, and human-caused events such as terrorism.
  • Assess Impacts: Once threats and hazards are identified, assess the potential impacts of these events. This involves understanding how these threats could affect people, property, and the environment.
  • Determine Capabilities: Based on the assessed impacts, determine the capabilities they need to address these threats and hazards. This includes identifying gaps in current capabilities and planning for resource allocation and training.

Used properly, THIRA complements a compliance risk assessment by grounding it in real-world scenarios, stress-testing assumptions, and aligning resources to consequence rather than convenience. In practice, compliance teams can use THIRA-style analysis to model disruptive events, validate whether policies and response plans would function under pressure, and ensure that authority, communications, and escalation protocols actually work in dynamic conditions. Like Duncan’s threat hub, THIRA is most effective when it is iterative, cross-functional, and embedded into daily decision-making rather than treated as a one-time exercise.

Continuous Monitoring Is Not a Buzzword in a Crisis Zone

In compliance circles, we often talk about continuous monitoring and continuous improvement. In high-risk environments, Duncan explains, these are not aspirational concepts. They are daily survival requirements. Threats change by the hour. Routes become unsafe. Infrastructure fails. Information degrades. Misinformation spreads intentionally. As Duncan makes clear, relying on sanitized reports or publicly available data alone is insufficient, particularly in places like Venezuela, where reliable information can be scarce and manipulated.

For compliance professionals, the parallel is obvious. If your organization relies solely on lagging indicators, static dashboards, or once-a-year training, you are operating on yesterday’s intelligence. A mature compliance program must be dynamic, responsive, and empowered to change course quickly.

Authority Matters More Than Policy

One of the most underappreciated insights in the discussion is the emphasis on delegated authority. Duncan is blunt: security teams must be empowered to make changes on the fly. Operations teams often resist this because they have a plan for the day. But rigid plans fail in dynamic environments. Compliance professionals should see themselves clearly in this description. How often does compliance identify a risk, only to be overruled by operational convenience? How often does policy exist without authority to enforce or adapt it?

This is not merely an execution issue. It is a governance failure. If compliance, security, or risk professionals lack real authority, then the program exists in name only.

Boards Are Often the Weakest Link

Perhaps the most candid portion of the conversation is Duncan’s discussion of boards of directors. Boards understand that risk exists, but they often do not understand their lane. Worse, they sometimes overstep based on assumptions rather than expertise, thereby influencing the organization’s security and risk culture to its detriment. This should resonate deeply with compliance professionals. Many compliance failures originate at the policy level. Boards check in periodically, hear a summary, and move on. They rarely engage with the complexity of the operating environment or the second- and third-order consequences of their decisions.

Duncan advocates for an ongoing relationship with boards or policy groups, not episodic briefings. Education is continuous. Risk is dynamic. Governance must keep pace. For compliance officers, this reinforces a critical point: board engagement is not about presentations. It is about sustained dialogue, shared understanding, and clearly articulated risk tolerance.

Culture Is Defined by Accepted Loss

One of the most insightful compliance lessons emerges from Duncan’s discussion of risk acceptance, particularly in the energy sector. Every organization accepts some level of loss. The problem arises when that acceptance is implicit, unexamined, or outdated. Compliance professionals should recognize this immediately. Risk tolerance that is not written down, debated, and revisited becomes invisible policy. It shapes behavior without accountability.

Duncan’s approach is instructive. He pushes organizations to explicitly articulate acceptable loss, document it, and use it as a guideline. When conditions change, that tolerance must be reassessed at the policy level. This is exactly how compliance culture should function. Silence is not neutrality. It is permission.

Security Is Not Just Physical: Insider Threats and Human Risk

If compliance professionals think security stops at the perimeter, Duncan quickly disabuses them of that notion. Insider threats loom large. Alcoholism, substance abuse, personal stressors, and poor life choices can all create vulnerabilities. So can espionage, coercion, and cultural dysfunction.

This is compliance territory. Training that treats employees like mushrooms kept in the dark will fail. Effective programs connect behavior to consequences: personal, professional, financial, and reputational. Duncan’s emphasis on “wholesome” training aligns with modern compliance expectations. Employees must understand not just what is prohibited, but why it matters, how it affects the organization, and how it exposes them personally.

Partnering with Locals: A Lesson in Third-Party Risk

One of the most counterintuitive lessons for many executives is the need to partner with local communities, vendors, and even security forces. Cutting locals out of economic participation breeds sabotage and resentment. Compliance professionals should immediately recognize the parallel to third-party risk management. Isolation does not reduce risk. Engagement does. Oversight, contracts, inspections, and partnerships create shared incentives and stability.

Whether it is food supply, logistics, or perimeter security, Duncan emphasizes layered controls and local investment. This is not unlike building a resilient third-party ecosystem rather than relying on transactional relationships.

The Threat Hub: A Compliance Blueprint

Perhaps the most transferable concept for compliance professionals is the “threat hub.” Duncan describes a cross-functional, daily forum where representatives from legal, finance, operations, security, and other functions review threats, vulnerabilities, and operational changes. This is what an effective compliance program should look like. Not a standalone department issuing policies, but an integrated function embedded across the organization, sharing intelligence, and adapting in real time.

Finally, Duncan issues a challenge that every compliance officer should take seriously: crisis exercises will break you. They expose gaps in policy, logistics, communications, authority, and preparedness that no binder ever reveals. Compliance professionals often assume crisis plans are adequate because they exist. Duncan’s experience says otherwise. Without realistic testing, organizations are unprepared when it matters most.

Final Thoughts

This conversation makes clear that security, compliance, and risk are not separate disciplines. They are different lenses on the same problem: how organizations survive and succeed in uncertain environments.

For compliance professionals, the takeaway is simple but uncomfortable. Static programs fail. Assumptions kill preparedness—authority matters. Culture is shaped by what leaders tolerate. And boards must be educated partners, not distant overseers. In high-threat environments, failure is immediate and unforgiving. In corporate compliance, it is slower, but no less certain.

The choice, as always, is whether to learn before the crisis or after it.

Join us tomorrow for Part 5 as we conclude our series by looking at AML risks associated with returning to Venezuela.