Tag: Sherlock Holmes

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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.
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Adventures in Compliance

The Three Garridebs and Objective Discipline

We are back with another five episodes of Adventures in Compliance to consider the next five stories from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s offering, I consider The Three Garridebs. From this story the need for objective discipline in a variety of areas in any best practices compliance program.

Compliance Takeaways
  1. That objectivity in disciple is called the Fair Process Doctrine. As you incorporate the Fair Process Doctrine in your compliance program, there are three key areas to focus on.
  2. Administration of discipline.Discipline must not only be administered fairly but it must be administered uniformly across the company for the violation of any compliance policy.
  3. Employee promotions.If your company is seen to advance and only reward employees who achieve their numbers by whatever means necessary, other employees will certainly take note and it will be understood what management evaluates and rewards employees on.
  4. Internal investigations. Simply put, if your employees do not believe that the investigation is fair and impartial, then it is not fair and impartial.
  5. An often-overlooked role of any Chief Compliance Officer (CCO) or compliance professional is to help provide employees with procedural fairness. If your compliance function is seen to be fair in the way it treats employees, in areas as varied as financial incentives, to promotions, to uniform discipline meted out across the globe; employees are more likely to inform the compliance department when something goes array. If employees believe they will be treated fairly, it will go a long way to more fully operationalizing your compliance program.
Join us tomorrow as we consider The Problem of Thor Bridge.
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Adventures in Compliance

The Sussex Vampire and Root Cause Analysis

We conclude our week of Sherlock Holmes-themed podcasts today. Over this week’s blog posts, I have been exploring the first five stories from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s concluding offering, I consider The Adventure of the Sussex Vampire and it informs a root cause analysis in any best practices compliance program. The concludes my initial exploration of The Casebook of Sherlock Holmes and its intersection with compliance and leadership. I hope you have enjoyed listening to it as much as I did researching and brining it to you. But do not worry as I will continue my exploration of the entire Holmes oeuvre in later podcast series.

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Adventures in Compliance

The Three Gables and Institutional Justice

We are back with fan favorite Sherlock Holmes week. In this week’s special series of podcasts, I will focus on the first five from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s offer, I consider The Adventure of the Three Gable and how institutional justice in any best practices compliance program. Join us tomorrow where we conclude our week of stories from The Casebook of Sherlock Holmes by looking at the The Adventures of the Sussex Vampire and how it informs root cause analysis.

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Adventures in Compliance

The Marazin Stone and Storytelling in Compliance

We are back with fan favorite Sherlock Holmes week. In this week’s blog posts, I will focus on the first five stories from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s offering, I consider The Adventure of the Marazin Stone and how it informs storytelling in compliance. Join us tomorrow as we continue our week of stories from The Casebook of Sherlock Holmes by looking at the The Adventure of the Three Gables and institutional justice.

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Adventures in Compliance

The Blanched Soldier and Learning to Ask for Help

We are back with fan favorite Sherlock Holmes week. In this week’s blog posts, I will focus on the first five stories from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s offering, I consider The Adventure of the Blanched Soldier and learning to ask for help. Join us tomorrow as we continue our week of stories from The Casebook of Sherlock Holmes by looking at the The Adventure of the Marazin Stone and storytelling in compliance.