31 Days to a More Effective Compliance Program

Shawn Rogers, Senior Director, Global Training & Awareness, Walmart has developed ten design objectives for establishing your compliance program training design objectives. You should consider doing the same for your organization. It may well be that your organization may value other objectives. What the government has told us since the original FCPA Resource Guide back in 2012 is that it expects...

How can you begin to think through a best practices compliance training program? I put that question to Shawn Rogers, Senior Director, Global Training & Awareness, Walmart. Rogers advised that you ‘envision’ what your training would like as a first step. He stated, “A common mistake is jumping right to the question is which courses you want and how to deploy them. However, there are several things...

One of the ways that CCOs and compliance practitioners can better use 360-degrees of communication is through Twitter. In a  MIT Sloan Management Review article, entitled “How Twitter Users Can Generate Better Ideas”, authors Salvatore Parise, Eoin Whelan and Steve Todd found “employees with a diverse Twitter network – one that exposes them to people and ideas they don’t already know – tend to gen...

Other than the skill of listening, asking questions is about as important to the compliance practitioner as any other that can be employed. Yet, equally critical is to ask the right question, which is an issue explored Brian Grazer and Charles Fishman in their book, entitled “A Curious Mind: The Secret to a Bigger Life”.  Grazer is a well-known and successful Hollywood director who has directed su...

A 360-degree approach to communications entails looking at all forms of interactions as a way to interconnect. This means both verbal and non-verbal and in clues and hints. This concept can be particularly helpful in relating to and with cultures outside the U.S. as one of the most critical issues to a compliance function is breaking through a company’s internal cultural boundaries. In a  Harvard...

What if you could multiply the impact and effectiveness of your compliance program throughout your company? That would be a great boon to any compliance practitioner and compliance program. It is also something that is very possible by considering a 360-degree view of communications in compliance using multipliers.  Liz Wiseman is the co-author with Greg McKeown of “Multipliers: How the Best Leade...

Such small gestures can make a difference. I recently read a biography of Dale Carnegie by Steven Watts, entitled “Self-Help Messiah: Dale Carnegie and Success in Modern America”, penned by Ian Frazier. Carnegie is of course well known for his seminal work “How to Win Friends and Influence People” first published in 1936. I was somewhat surprised to learn that the text was largely drawn up as tran...

Our next lesson on compliance communications comes from best-selling authors James Patterson and David Baldacci and it about your brand. I had always thought of your brand as the image customers have of your business. It should be strategic and intentional. For a corporate compliance function, it might mean something along the lines of doing business ethically and in compliance. It could mean crea...

How often have you thought about the role of communications in your entire hotline reporting system? I do not mean posters giving the hotline number, promising anonymity and non-retaliation. I mean using compliance communications to create a social environment where employees feel comfortable speaking up to ask questions and report concerns and they know the options for doing that.  Why do many co...

The 360-degree approach to compliance works with all the stakeholders in a compliance program, even the “Document, Document, and Document” stakeholders; i.e., the regulators. By using innovative techniques, one law firm came up with mechanism to present verifiable evidence to regulators, using the basic techniques of social media in operationalizing compliance as a solution to a difficult complian...

One of the more difficult things to predict in the mergers and acquisition context is how the cultures of the two entities will merge. Further, while many mergers claim to be a ‘merger of equals’ the reality is far different as there is always one corporate winner that continues to exist and one corporate loser that simply ceases to exist. This is true across industries and countries; witness the...

Why do people share information? The answer to that question has important implications for every compliance practitioner and compliance program. Sharing is a primary method to communicate and connect. In any far-flung international corporation, this is always a challenge, particularly for disciplines which can be viewed as home office overhead at best; the Land of No at worst. Work to hone your m...

I am a huge fan of using social media in your compliance function. But how can you get your arms around how to structure such a program for your company? After acknowledging that social media focuses on the social aspects of the communication, the most important thing to remember is that communication in social media is two-way; both inbound and outbound. It helps to bring your employee base toget...

How does one company and one CCO actively use social media to make the company’s compliance culture more effective? The company was Dun & Bradstreet, Inc. (D&B) and its then CCO, Louis Sapirman, who discussed D&B’s integration of social media into compliance with me. These tools can go a long way towards enhancing your compliance program going forward. Recall the declination to prosecute that Morg...

What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the message of compliance going forward. Many of the applications that we use in our personal communication are free or available at very low cost. So why not...

In this month's offering of 31 Days to a More Effective Compliance Program, you will learn about training and communication techniques that the CCO can use to provide not only a well-rounded role as a CCO but also facilitate a much more holistic approach to compliance in your organization. Best of all the techniques, discussed are largely available to you at little to no cost. There are things tha...

The 2020 Update provided clear-cut criteria regarding effective compliance investigations. Sean Freidlin, host of the Compliance Book Club podcast believes that many compliance teams are failing to promptly substantiate a majority of the reports they investigate, due in part to their inability to quickly and easily find the evidence they need, especially in relation to harassment and misconduct ca...

The 2020 Update not only continued to emphasize the importance of monitoring and testing the effectiveness of a compliance program, but it spoke more about a Chief Compliance Officer (CCO) and compliance function utilizing data to engage in both continuous monitoring and continuous improvement. The DOJ for some time now has stressed the importance of leveraging data in order to have objective evid...

The 2020 Update emphasized the need for the corporate compliance function to ensure both consistency and fairness not only in monitoring investigations but also in monitoring the resulting discipline. One of the ways the 2020 Update emphasized this was through tracking the investigations and the discipline that may come out of any investigation. One of the challenges companies have is facts and ci...

Going into the 2020s and beyond, a corporate compliance function needs to be an integral part of your corporate business strategy going forward. One of the key reasons is the ever-important debate of compliance as a cost center will become more critical going forward in this decade. Obviously if compliance programs are not effective, enforcement actions will continue to be extremely costly. Over l...

Measuring the effectiveness of your compliance program will be one of the key criteria going forward. One of the mechanisms to do so is through Key Performance Indicators (KPIs). KPIs are a critical component in showing compliance program success or failure, if you have been working towards your stated goals and for reporting success. And while specific requirements for this kind of reporting have...

Disconnectedness compliance comes from the fact there is not one system which connects the disparate strands of the compliance discipline. In the view of Thomas Sehested, GAN Integrity founder and its former Chief Executive Officer connected compliance “enables a CCO and all those people in the organization working with compliance, to have one central place, a one system of record for everything t...

The DOJ and SEC have both made it clear that they expect companies to be more robust in their use of data analytics in compliance programs. This means using data to not only detect and prevent illegal conduct but also in the remediation prong of any best practices compliance program as well through continuous improvement. In 2019, former Deputy Assistant Attorney General Matthew Miner said in a sp...

Yesterday we considered the compliance professional in the 2020s and beyond. Today we look at the Compliance Function. The Coronavirus pandemic has accelerated change in compliance that have been percolating for the last few years. Indeed, I believe that in as short a time as 5 years, 2020 will be seen as an inflection point in compliance; IE., the Year When Everything Changed. There are four majo...

What should compliance practitioners do to move themselves forward professionally in the 2020s and beyond? Ton consider this question, I drew inspiration from the Financial Times (FT) piece, entitled “Work in the 2020s: 5 essential skills to succeed”, by Lyndsey Jones. In this article Jones laid out five areas where workers need to have skills that will keep abreast of the ever-evolving marketplac...