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Adventures in Compliance

Adventures in Compliance – Leadership Lessons from the Adventure of The Speckled Band

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” The appeared in the Strand Magazine from July 1891 to June 1892. Over 12 episodes, I will be reviewing each story and mine them for leadership, compliance and ethical lessons. In this episode, I consider “The Adventure of the Speckled Band” which was originally published in the Strand Magazine in February 1892 and was included in the collection of stories published as ‘The Adventures of Sherlock Holmes’.

Summary

The story begins with Miss Helen Stoner, a young woman obviously in distress, visiting Sherlock Holmes and Dr. Watson at 221B Baker Street. She is worried about her life, fearing that she might meet the same mysterious end that her twin sister, Julia, did two years prior. Julia’s dying words were about a “speckled band.”

Helen and Julia lived with their stepfather, Dr. Grimesby Roylott, the last survivor of a noble but financially ruined family, in Stoke Moran Manor in Surrey. Dr. Roylott is a doctor with a violent history and is known to keep exotic animals from India, such as a cheetah and a baboon, at their estate.

After hearing noises and seeing strange activities from her stepfather’s room, Helen suspects that her life is in danger, especially as she is now sleeping in the same room her sister did just before she died.

Sherlock Holmes and Dr. Watson travel to the Manor, examining the room where Julia died and the surrounding areas, including Dr. Roylott’s chamber. Holmes observes that the bed is clamped to the floor, a bell rope that doesn’t work, a vent that leads to Dr. Roylott’s room, and a saucer of milk. Putting the pieces together, he devises a plan to find out the truth.

Holmes and Watson camp out in Helen’s room that night, and they hear a low whistle and metallic noise. Suddenly, Holmes strikes out with his cane at the bell rope and a poisonous snake (the “speckled band”) drops onto the floor. Holmes forces the snake back through the vent, and it bites Dr. Roylott, who is found dead in his room.

In the end, Holmes explains how Dr. Roylott used the snake, trained to travel through the vent to the sound of a whistle, to kill Julia, and he had attempted the same with Helen. The motive was financial, as Dr. Roylott would have lost a significant amount of income from the girls’ mother’s estate if they married.

Leadership Lessons

1.         Attention to detail: Sherlock Holmes is known for his attention to detail, and this is evident in “The Adventure of the Speckled Band.” He solves the mystery by paying close attention to small details that others have overlooked. Leaders can learn from this by focusing on the details and not overlooking anything that could be important.

2.         Critical thinking: Holmes is a master of critical thinking, and this is demonstrated in the story as he analyzes the evidence and develops a theory to explain the mysterious events. Leaders can learn from this by developing their critical thinking skills and approaching challenges with a logical and analytical mindset.

3.         Empathy: Throughout the story, Holmes demonstrates a deep sense of empathy for the victim and her family, and he is determined to bring the culprit to justice. Leaders can learn from this by being empathetic and understanding towards their employees and by showing compassion for others.

4.         Adaptability: Holmes demonstrates his ability to adapt to changing circumstances and adjust his approach as needed. Leaders can learn from this by being flexible and open-minded, and by recognizing that there may be multiple solutions to a problem.

5.         Courage: Despite the danger involved, Holmes is determined to solve the case and bring the culprit to justice. Leaders can learn from this by being courageous and standing up for what is right, even in the face of challenges and obstacles.

6.         Communication skills: Throughout the story, Holmes effectively communicates with others, including Dr. John Watson and the victim’s family, to gather information and solve the case. Leaders can learn from this by developing their communication skills and being clear and concise in their interactions with others.

Resource

The New Annotated Sherlock Holmes

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Adventures in Compliance

Adventures in Compliance – Leadership Lessons from The Adventure of the Blue Carbuncle

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” The appeared in the Strand Magazine from July 1891 to June 1892. Over 12 episodes, I will be reviewing each story and mine them for leadership, compliance and ethical lessons. “The Adventure of the Blue Carbuncle” was first published in the Strand Magazine in January 1892 and is included in the collection ‘The Adventures of Sherlock Holmes’.

Summary

The story begins on Boxing Day, when Holmes receives a peculiar old hat from Peterson, the commissionaire. The hat was found next to a Christmas goose, abandoned after its owner had a skirmish with some ruffians. Peterson also found a blue gem in the goose’s crop which turns out to be the “Blue Carbuncle,” a precious stone which was reported missing a few days earlier.

Intrigued by this series of events, Holmes and Watson embark on an investigative adventure. They start by tracing the goose back to a local poultry shop, which leads them to the supplier, who had given the goose as part of a group to a hotel. The hotel staff recognizes the goose and tells Holmes it was given to a Mr. Henry Baker.

When Henry Baker arrives to claim his hat and goose at Baker Street, Holmes realizes that Baker knows nothing about the Carbuncle. Further investigations lead Holmes to James Ryder, a hotel attendant, who confesses his crime after being confronted.

Ryder had persuaded a maid at the Countess of Morcar’s hotel to let him steal the Blue Carbuncle. Fearing detection, he had hidden the gem inside a goose at his sister’s poultry shop, but the bird had gotten mixed up with others, thus ending up with Baker.

At the end of the story, Holmes lets Ryder go, considering him a small, terrified man who will likely not survive a prison sentence. The Blue Carbuncle, a jewel of great value, is recovered, but the story concludes without stating whether it was returned to its rightful owner.

Leadership Lessons

  1. Attention to detail: Sherlock Holmes is known for his attention to detail, and this is evident in “The Adventure of the Blue Carbuncle.” He can solve the mystery by paying close attention to small details that others have overlooked. Leaders can learn from this by focusing on the details and not overlooking anything that could be important.
  2. Problem-solving skills: Holmes is a master of problem-solving, and this is demonstrated in the story as he unravels the mystery of the missing gemstone. Leaders can learn from this by developing their problem-solving skills and approaching challenges with a creative and analytical mindset.
  3. Teamwork: Although Holmes is the main detective in the story, he works with others, including Dr. John Watson, to solve the case. Leaders can learn from this by recognizing the importance of teamwork and building strong relationships with their colleagues.
  4. Adaptability: Throughout the story, Holmes demonstrates his ability to adapt to changing circumstances and adjust his approach as needed. Leaders can learn from this by being flexible and open-minded, and by recognizing that there may be multiple solutions to a problem.
  5. Honesty and integrity: Despite the temptation to keep the valuable gemstone for himself, Holmes returns it to its rightful owner, demonstrating his honesty and integrity. Leaders can learn from this by being honest and transparent in their dealings with others and by upholding their ethical principles.

Resource

The New Annotated Sherlock Holmes

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Adventures in Compliance

Adventures in Compliance – Compliance Lessons from The Man with the Twisted Lip

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” The appeared in the Strand Magazine from July 1891 to June 1892. Over 12 episodes, I will be reviewing each story and mine them for leadership, compliance and ethical lessons. In this episode, we consider “The Man with the Twisted Lip” which was originally published by the Strand Magazine in December 1891.  

Summary

The story begins when Watson, called out by a friend Mrs. St. Clair, finds himself in an opium den in the East End of London. While attempting to extract his friend, he encounters Sherlock Holmes in disguise. Holmes is there on a different case involving Neville St. Clair, Mrs. St. Clair’s husband, who was reported missing under mysterious circumstances.

Mrs. St. Clair had seen her husband at a second story window of the opium den, distressed and quickly pulled away from the window. When she rushed to find him, the only people in the room were the landlord and a dirty, disfigured beggar known as Hugh Boone. Despite Boone’s rough exterior, he is known for his eloquence and wit.

Despite no evidence of foul play or indication of St. Clair being there, Mrs. St. Clair insists her husband was in the room. Holmes takes up the case and starts investigating, finding St. Clair’s clothes in the room, but no sign of the man himself.

Boone is arrested and put in a cell, where Holmes observes him closely. Eventually, Holmes discovers that Boone and Neville St. Clair are the same person. St. Clair, a respectable man with a previously high-paying job, had been leading a double life as the beggar Boone. He discovered that he could earn more money begging while disguised as the disfigured Boone, so he maintained this deception to support his family’s comfortable lifestyle.

St. Clair is extremely relieved to be found out, as he was tired of the lie but didn’t know how to get out of it without damaging his family’s reputation. In the end, it is decided that Boone’s ‘disappearance’ would be maintained to protect the family, and St. Clair vows to abandon his alter ego for good.

Compliance Lessons

1.     Honesty and Transparency: The character Neville St. Clair disguises himself and leads a dual life, which eventually leads to misunderstandings and a temporary downfall. In leadership, being open, transparent, and honest is crucial. Leaders who hide important facts or issues from their teams can create mistrust and a lack of confidence.

2.     Understand Different Perspectives: As a beggar, Neville St. Clair was able to understand a different section of society that he normally would not interact with. A good leader must strive to understand the different perspectives within their team, the broader organization, and the external market. This enhances decision-making and ensures that everyone feels heard and valued.

3.     Adaptability: Despite his odd choice, St. Clair displayed a high degree of adaptability by successfully leading a double life. In leadership, circumstances often change rapidly, and the ability to adapt quickly and effectively is vital. Good leaders can handle uncertainty, make necessary adjustments, and guide their teams through changes.

4.     The Importance of Brand: St. Clair manipulated his appearance to fit into different roles. While this is not advisable ethically, it does underscore the impact of a leader’s image on their followers. Leaders need to be mindful of how their behavior, attitude, and professionalism influence others.

5.     Resilience: Despite the hardships he encountered in his double life, St. Clair demonstrated resilience. Leaders often face challenges and obstacles. The ability to bounce back, remain positive, and continue moving forward is a key leadership trait.

6.     Integrity: The absence of integrity in St. Clair’s actions highlights the importance of this trait in leadership. Leaders must maintain high ethical standards and act in a way that is consistent with their words.

Resource

The New Annotated Sherlock Holmes

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Adventures in Compliance

Adventures in Compliance – Leadership Lessons from the Five Orange Pips

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” The appeared in the Strand Magazine from July 1891 to June 1892. Over 12 episodes, I will be reviewing each story and mine them for leadership, compliance and ethical lessons. In this episode, I consider “The Five Orange Pips” which was originally published on the Strand Magazine in November 1891 and is included in the collection of stories found in the book ‘The Adventures of Sherlock Holmes’.

Summary

The story begins when a young man named John Openshaw seeks Holmes’ help. John has received a mysterious letter from abroad containing five dried orange pips and the initials “K.K.K.”, along with a demand to “put the papers on the sundial”. Both his uncle, Elias, who lived in America for several years, and his father had previously received similar letters and subsequently died under suspicious circumstances.

Sherlock deduces that K.K.K. represents the Ku Klux Klan, a racist group from the United States, and the five orange pips are a death threat, previously sent to John’s relatives who had disobeyed the order to surrender certain papers. Elias Openshaw, John’s uncle, had made enemies during his time in the US due to his involvement with the group, and the papers likely hold some dangerous information about them.

Holmes advises John to return home, find the papers, and turn them over. Unfortunately, before this could happen, John is found dead, apparently drowned after falling into a small river.

Holmes sends a reply to the Klan’s address in America, mimicking their style by including five orange pips in the envelope. He suspects that the people responsible for John’s death were on a sailing ship called the Lone Star. While Holmes is unable to bring the criminals to justice directly, the Lone Star is reported to have been lost at sea in a storm, implying a form of poetic justice.

This story ends on a somber note, as it is one of the few cases that Holmes is unable to solve in time to prevent a tragic death. 

Leadership Lessons 

1.         Be proactive: Holmes was proactive in investigating the case of the five orange pips, even when there was limited information available. Leaders should also be proactive and take the initiative to solve problems and achieve their goals.

2.         Persevere: Holmes persevered in his investigation of the case, even when the trail seemed to have gone cold. Leaders should also persevere and not give up in the face of challenges or obstacles.

3.         Stay focused: Holmes stayed focused on his investigation and did not let distractions or other cases interfere with his work. Leaders should also stay focused on their goals and avoid being sidetracked by distractions.

4.         Use creative thinking: Holmes used his creative thinking and innovative approaches to solve the case of the five orange pips. Leaders should also encourage and embrace creative thinking, as it can lead to new solutions and breakthroughs.

5.         Be vigilant: Holmes was vigilant and kept a watchful eye for any clues or developments in the case of the five orange pips. Leaders should also be vigilant and keep a watchful eye for any opportunities or threats that may impact their organization.

Resources

The New Annotated Sherlock Holmes

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Adventures in Compliance – Compliance Lessons from the Boscombe Valley Mystery

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” The appeared in the Strand Magazine from July 1891 to June 1892. Over 12 episodes, I will be reviewing each story and mine them for leadership, compliance and ethical lessons. “The Boscombe Valley Mystery” was first published in the Strand Magazine in October 1891 and is included in the collection in the book ‘The Adventures of Sherlock Holmes’.

Summary

In this tale, Holmes and his companion Dr. Watson journey to Boscombe Valley in Herefordshire to investigate the murder of Charles McCarthy. Local law enforcement believes the man’s son, James McCarthy, is responsible for the crime as he was found near the crime scene with a distraught demeanor, and a heated argument between him and his father was witnessed earlier.

Despite the seeming clarity of the case, the younger McCarthy’s childhood sweetheart, Alice Turner, firmly believes in his innocence and urges Holmes to uncover the truth. Holmes, known for his keen observation and logical deduction, notices several key details that others have overlooked.

Holmes discovers a clue in the form of a dying message left by the elder McCarthy, consisting of the words “rat” and “a dying man”. Holmes deduces that the message actually refers to “Ballarat”, an Australian town, and “a dying woman”, which was misheard by the elder McCarthy in his weakened state.

Upon further investigation, Holmes finds out that both McCarthys and Turner’s father were involved in a shared past in Australia, specifically in the town of Ballarat. Turner’s father and McCarthy had been involved in a criminal enterprise, and Turner’s father owed McCarthy a debt of gratitude.

In the end, Holmes uncovers that it was Turner’s father who committed the murder, to protect Alice from being forcibly married to James McCarthy due to the elder McCarthy’s insistence. Turner’s father was the “dying woman”, his health already deteriorating due to a terminal illness.

Holmes lets Turner’s father confess his crime to the local police, who in turn, due to Turner’s illness and the extenuating circumstances, choose not to arrest him. James McCarthy is then released, cleared of the charges, and the case is concluded.

Compliance Lessons

1.         Importance of Complete Investigations: In the story, the local police are quick to arrest James McCarthy based on circumstantial evidence, not conducting a comprehensive investigation. In a compliance setting, it’s crucial to conduct thorough investigations before drawing conclusions. Rushing may lead to wrong decisions, causing reputational damage and legal consequences.

2.         Avoiding Assumptions and Bias: The police assume that because James McCarthy was found near his father’s dead body, he must be the killer. Assumptions and biases can lead to serious compliance violations. It’s crucial to base decisions on factual evidence and avoid personal prejudices.

3.         Consistency in Applying Rules and Regulations: Holmes shows consistency in his approach to solving mysteries, irrespective of who is involved. This is an important lesson for compliance – rules and regulations must be consistently applied regardless of the person or situation involved.

4.         Maintaining Confidentiality: Throughout the story, Sherlock Holmes maintains the confidentiality of his clients and their sensitive information. In compliance, safeguarding confidential information is paramount.

5.         Truth and Transparency: The story ends with the revelation of the truth, which is initially overlooked by those in charge of the investigation. This highlights the importance of transparency in all dealings and the pursuit of truth, even when it’s uncomfortable. Compliance programs should prioritize transparency and encourage the disclosure of truth.

6.         Adherence to Ethical Standards: Sherlock Holmes, even though he’s not a police officer, maintains high ethical standards while conducting his investigations. This is a crucial lesson for individuals in the compliance field. They should adhere to the highest ethical standards, regardless of their position or situation.

7.         Accountability and Justice: At the end of the story, the real killer is identified, and even though he escapes the traditional legal punishment due to his death, there’s a sense of justice served. In compliance, holding people accountable for their actions and ensuring justice is important.

Resources

The New Annotated Sherlock Holmes

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Adventures in Compliance – Lessons from A Case of Identity

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” They appeared in the Strand Magazine from July 1891 to June 1892. Over the 12 episodes, I will be reviewing each story and mine them for leadership, compliance, and ethical lessons. “A Case of Identity” was published in the Strand Magazine in August 1891 and is the third story in the collection of “The Adventures of Sherlock Holmes”.

Summary

In this case, Mary Sutherland, a typist, approaches Holmes for help after her fiancé, Mr. Hosmer Angel, mysteriously disappears on the day they were to be married. Holmes agrees to take the case. Sutherland gives Holmes a few letters written by Angel, and Holmes quickly observes that they were written on a typewriter, odd for a personal letter. Also, the writing style was similar to the letters of her stepfather, James Windibank.

As Holmes investigates, he deduces that Hosmer Angel does not exist and is, in fact, an alternate identity created by Mary’s stepfather, James Windibank. The motive for this strange charade was financial. Mary’s stepfather didn’t want to lose the income he gained from her, as her late mother left her a significant annual income which would be redirected upon her marriage.

The stepfather, who was young enough to pass as a man of Mary’s age, concocted the alternate identity to court Mary and then conveniently disappear to maintain control over Mary’s income. Holmes, however, decides not to reveal the truth to Mary to save her from further heartbreak. He suggests that Angel was a scoundrel who did not deserve her, leaving her to hope that Angel might return one day.

Compliance Lessons

1.         Empathy: Holmes was able to solve the case of identity by putting himself in the shoes of the victim and understanding her perspective. Leaders should also have empathy and be able to understand the perspectives of their colleagues, employees, or customers.

2.         Observation: Holmes used his powers of observation to gather information and uncover the truth behind the case of identity. Leaders should also be observant and pay attention to the details, as they can provide valuable insights.

3.         Problem-solving skills: Holmes used his problem-solving skills to solve the case and bring justice to the victim. Leaders should also be effective problem-solvers and should be able to find creative solutions to challenges.

4.         Communication skills: Holmes communicated effectively with the victim and the other characters in the story, and he was able to get the information he needed to solve the case. Leaders should also have strong communication skills, as they are crucial for building relationships and achieving success.

5.         Respect for the law: Throughout the story, Holmes showed respect for the law and acted within the bounds of the legal system. Leaders should also respect the law and act ethically, as they set an example for others and maintain the integrity of their organization.

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The New Annotated Sherlock Holmes

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Adventures in Compliance – Leadership Lessons from The Red-Headed League

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” The appeared in the Strand Magazine from July 1891 to June 1892. Over the 12 episodes, I will be reviewing each story and mine them for leadership, compliance and ethical lessons. “The Red-Headed League” was published in Strand Magazine in July 1891.

Summary

The story revolves around a peculiar organization called the Red-Headed League, which captivates the attention of Holmes and his assistant, Dr. John Watson.Jabez Wilson, a red-headed pawnbroker, seeks the help of Holmes after his temporary job with the Red-Headed League abruptly ends. Wilson had been enticed by an advertisement offering well-paid work exclusively to red-headed men. Curious about the strange circumstances, Holmes agrees to investigate.

Upon examining the case, Holmes discovers that the Red-Headed League is a clever ruse devised by a criminal mastermind named John Clay. Clay, aided by his accomplice, Vincent Spaulding, a disguised assistant at Wilson’s pawnshop, had lured Wilson away from his shop to create a distraction.

Meanwhile, Clay planned to tunnel into the bank vault located next to the pawnshop to carry out a major robbery. However, Holmes foils the plan just in time, capturing Clay and preventing the theft. Holmes reveals the intricate details behind the crime and the motives of the criminals.

“The Red-Headed League” showcases Holmes’ exceptional deductive reasoning and his ability to solve seemingly complex mysteries by observing small details. The story also highlights the cleverness and audacity of criminals who employ elaborate schemes to carry out their illegal activities.

Leadership Lessons

1.         Pay attention to details: In the story, Sherlock Holmes was able to solve the case by paying close attention to small details, such as the unusual requirement of red hair for the members of the Red-Headed League. Leaders should also be detail-oriented and not overlook anything that seems insignificant, as it may hold valuable information.

2.         Be skeptical: Holmes was skeptical of the League from the start and investigated further, even when others didn’t see any reason to be concerned. Leaders should also be skeptical of seemingly too good to be true opportunities and should do their due diligence to verify their legitimacy.

3.         Think outside the box: Holmes used his unique and innovative thinking to solve the case and uncover the true motives of the criminals behind the League. Leaders should also encourage creative thinking and be open to new ideas and approaches to problem-solving.

4.         Work with a team: Holmes worked with Dr. John Watson to solve the case, and their teamwork allowed them to uncover the truth faster. Leaders should also value the importance of teamwork and collaboration and should foster a positive and supportive working environment.

5.         Trust your instincts: Holmes trusted his instincts and followed his gut feelings, even when the evidence didn’t seem to support his conclusions. Leaders should also trust their instincts and be confident in their decisions, if they are based on sound reasoning and evidence.

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Adventures in Compliance – Leadership Lessons from A Scandal in Bohemia

Welcome to a review of all the Sherlock Holmes stories which are collected in the work, “The Adventures of Sherlock Holmes.” They appeared in the Strand Magazine from July 1891 to June 1892. Over the next 12 episodes, I will be reviewing each story and mine them for leadership, compliance, and ethical lessons. We begin with “A Scandal in Bohemia” in which the author Arthur Conan Doyle, introduced his famous detective character, Sherlock Holmes. The story” was published in July 1891 and introduced the character of Irene Adler, a woman who is remembered as “The Woman” in Holmes’s life.

Summary

The story starts with Dr. Watson visiting Sherlock Holmes only to find him engaged in a case. A masked man, later revealed to be the King of Bohemia, approaches Holmes. The king is about to be married to a Scandinavian princess but fears that a past liaison with an American opera singer named Irene Adler could jeopardize his upcoming marriage.

The scandal revolves around a photograph showing the King and Adler together, which the King believes Adler might use to cause a scandal. Despite the King’s attempts to retrieve the photograph, Adler refuses to hand it over. He hires Holmes to obtain the photograph without causing any scandal or alerting Adler.

Holmes, with his astute observational and deductive abilities, impersonates a groom to gain information and then a clergyman to gain access to Adler’s home. However, his plan to trick Adler into revealing the photo’s location is foiled when a warning is raised about a fire, and Adler, in her concern, unwittingly reveals where the photograph is hidden.

Holmes returns the next day to retrieve the photograph but finds that Adler, suspecting foul play, has fled with her new husband, Godfrey Norton, leaving behind a letter for Holmes and a photograph of herself. The letter reveals that she saw through Holmes’s disguise and tricked him but assures the King she won’t use the photograph for blackmail since she is happy in her new life.

Impressed by Adler’s intelligence and wit, Holmes keeps the photograph of her as a memento, and from then on, refers to Irene Adler as “the woman,” a figure who, in his eyes, epitomizes the strengths and intellect of her gender. The King relieved about the resolution, offers a reward, but Holmes rejects it, asking only for the photograph of Adler.

Leadership Lessons

  1. Adapt to changing circumstances: In the story, Sherlock Holmes was faced with a new and challenging case, and he adapted his strategies and methods to solve it effectively. Leaders should also be flexible and able to adapt to changing circumstances, whether in the workplace or their personal lives.
  2. Be strategic: Holmes used his strategic thinking to outmaneuver his opponent, the King of Bohemia, and solve the case. Leaders should also have a strategic mindset and think ahead to anticipate challenges and opportunities.
  3. Keep your word: In the story, Holmes kept his promise to the King of Bohemia, even when it was difficult, and he did not reveal the King’s secrets. Leaders should also be honest and trustworthy and keep their promises, as their reputation is one of their most valuable assets.
  4.  Use your strengths: Holmes used his exceptional deductive skills and attention to detail to solve the case, and he relied on his strengths to succeed. Leaders should also identify their strengths and use them to achieve their goals.
  5. Maintain professionalism: Throughout the story, Holmes maintained his professionalism, even in the face of personal challenges, and he did not let his emotions interfere with his work. Leaders should also maintain their professionalism, even in difficult situations, and they should strive to remain calm and level-headed.

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The New Annotated Sherlock Holmes

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The Creeping Man and Risk Management by the Board

We are back with another podcast on Adventures in Compliance, where we consider the intersection of Sherlock Holmes and Compliance. Today, I visit The Adventure of the Creeping Man. From this story we take the Holmes utterance to Watson “Come at once if convenient—if inconvenient come all the same”. This informs today’s discussion how Boards of Directors can be more involved in compliance through more effective oversight of risk management.
Compliance Takeaways

  1. What is the role of a company’s Board in a compliance program?
  2. A Board should not engage in management but should engage in oversight of the Chief Compliance Officer. The Board does this through asking hard questions, particularly around risk assessment, risk identification and risk management.
  3. What are 6 principles for Board oversight of compliance?
  4. Define the Board’s role.

A.Foster a culture of compliance risk management.
B. Incorporate risk management directly into a compliance strategy.
C. Define the company’s appetite for risk around compliance.
D. Execute the compliance risk management process.
E. Benchmark and evaluate the compliance process.
5. CCO reporting to the Audit/Compliance Committee must be structured carefully to promote ethics and compliance. Here are five best practices to help guide the reporting.
a. Quarterly reports.
b. Executive session.
c. Sitting in on other reports.
d. Informal relationship.
e. Annual report to full board.
Join us tomorrow as we mine the story of The Lion’s Mane for its compliance lessons.

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Adventures in Compliance

The Problem of Thor Bridge and Monitoring Controls

We are back with another series of Adventures in Compliance podcasts. This week I am exploring stories from The Casebook of Sherlock Holmes. In this week’s second offering, I consider The Problem of Thor Bridge. From this story we take the Holmes utterance “We must look for consistency. Where there is want of it, we must suspect deception”. This informs our discussion on monitoring controls.

Compliance Takeaways
  1. How do you determine that want of consistency? Monitoring controls is one key.
  2. Consider the fifth and final Objective from the COSO 2013 Internal Control Framework is Monitoring Activitiesas a guide.
  3. Further consider Principles 16 & 17 of the COSO Framework.
  4. Monitoring Activities should bring together your entire compliance program and give you a sense of whether it is running properly.
  5. Both ongoing monitoring and auditing are tools the CCO and compliance practitioner should use in support of this objective.
  6. The most important item to note is that all the controls need to be sustainable.
Join us tomorrow as we consider The Adventure of the Creeping Man.