エピソード

  • Day 9-Continuous Monitoring and Continuous Improvement
    2025/01/09
    Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will plan to join each day in January for this exploration of best practices in compliance. Continuous monitoring and improvement are essential elements in developing effective compliance programs, serving as a dynamic approach to addressing and adapting to evolving risks. This underscores the critical nature of these concepts, particularly highlighted in the 2023 update to the evaluation of corporate compliance programs and emphasizes the necessity for organizations to integrate real-time data and maintain comprehensive documentation in their decision-making processes. This approach not only ensures compliance but also fosters agility and resilience in navigating the complexities of modern business landscapes. Key Highlights · Understanding Changes in Company Risks · Continuous Monitoring and Improvement · External Information Sources for Compliance Resources Listeners to this podcast can receive a 20% discount to The Compliance Handbook, 5th edition by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
    続きを読む 一部表示
    8 分
  • Day 8- Building Effective Compliance Through Payroll
    2025/01/08
    Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will plan to join each day in January for this exploration of best practices in compliance. Operationalizing a compliance program through payroll is a vital component of a company's risk management strategy, serving as both a control mechanism and a crucial link to the broader compliance function. Payroll is instrumental in identifying potential red flags, such as offshore payments, which require meticulous documentation and enhanced internal controls to prevent compliance violations. Tom Fox, a noted expert in compliance, underscores the significant role payroll plays in fortifying compliance programs by aligning with FCPA requirements and preventing fraudulent activities. He advocates for the implementation of demonstrable controls like Approval Certification processes, segregation of duties, and regular review procedures to effectively mitigate compliance risks. According to Fox, by embedding robust controls within payroll operations, companies not only deter potential violations but also ensure compliance is woven into the organizational fabric, thus operationalizing their compliance programs seamlessly. Key Highlights ·  Payroll should be on the front lines of any attempt to prevent, detect, and then remediate anti-corruption compliance. · Key compliance program components for payroll. · Watch for Offshore payments. Resources Listeners to this podcast can receive a 20% discount to The Compliance Handbook, 5th edition by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
    続きを読む 一部表示
    9 分
  • Day 7- Argentieri on Clawbacks and Holdbacks
    2025/01/07
    Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will plan to join each day in January for this exploration of best practices in compliance. In this episode, we explore the critical insights from the DOJ Clawback Program for compliance professionals. It emphasizes integrating compliance into the compensation structure as an effective strategy to promote ethical behavior and prevent misconduct. We also delve into the significance of financial accountability, noting the DOJ's practice of reducing fines for firms that reclaim compensation from responsible employees. Finally, the episode highlights the necessity of continuously evaluating and enhancing compliance-linked compensation systems, urging companies to regularly assess their effectiveness, gather feedback, and make necessary adjustments. This iterative process reinforces the idea that compliance programs must be dynamic and proactive, rather than static operational checklists. Key Highlights · Integrating Compliance into Compensation · Financial Accountability Emphasis · DOJ's Commitment to Individual Accountability · Continuous Evaluation and Improvement Resources Listeners to this podcast can receive a 20% discount to The Compliance Handbook, 5th edition by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
    続きを読む 一部表示
    8 分
  • Day 6-M&A Safe Harbor Policy
    2025/01/06
    Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will plan to join each day in January for this exploration of best practices in compliance. In this episode, we delve into the Department of Justice's mergers and acquisitions (M&A) Safe Harbor Policy, as explained by Deputy Attorney General Lisa Monaco. This policy encourages companies to voluntarily self-disclose criminal conduct discovered during the acquisition process. If a company promptly discloses such misconduct, cooperates with the ensuing investigation, and engages in appropriate remediation, restitution, and disgorgement, it can receive a presumption of a criminal declination. Key deadlines include disclosing misconduct within six months of the closing date and fully remediating within one year. The DOJ aims to incentivize acquiring companies to perform robust pre- and post-acquisition due diligence and self-disclosure to mitigate risks and de-risk transactions effectively. Key Highlights · New DOJ Mergers and Acquisitions Safe Harbor Policy · Key Requirements and Deadlines · Historical Context and Clarifications Resources Listeners to this podcast can receive a 20% discount to The Compliance Handbook, 5th edition by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
    続きを読む 一部表示
    7 分
  • Day 5- Enhancing Compliance Through Automation
    2025/01/05
    Learn more about your ad choices. Visit megaphone.fm/adchoices
    続きを読む 一部表示
    6 分
  • Day 4- Building Effective Data Analytics Programs for Compliance
    2025/01/04
    Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will plan to join each day in January for this exploration of best practices in compliance. In today's business environment, compliance professionals leverage data analytics to adhere to regulatory requirements and ethical standards. This episode focuses on the importance of defining specific risks an organization wants to monitor, capturing relevant data creatively, and utilizing internal expertise to build effective data analytics programs. By starting small and focusing on one risk at a time, compliance officers can demonstrate their dedication to improving compliance despite limited resources. Additionally, a data-driven approach helps shift focus from individual policy violations to identifying systemic issues, enhancing overall organizational compliance. Key takeaways include understanding multiple factors in creating data-driven compliance programs, recognizing the value of shifting focus to systemic issues, and gradually building analytics capabilities. Key Highlights · Defining and Identifying Risks · Innovative Data Capture and Internal Collaboration · Demonstrating Value to Senior Management Resources Listeners to this podcast can receive a 20% discount to The Compliance Handbook, 5th edition by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
    続きを読む 一部表示
    7 分
  • Day 3- Key Updates in the ECCP: Messaging Apps, Internal Controls, and Compensation
    2025/01/03
    Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will plan to join each day in January for this exploration of best practices in compliance. In today's episode, we delve into the significant updates in the evaluation of corporate compliance programs, focusing on messaging apps, internal controls, and adequate compensation. The revised language in the ECCP highlights the DOJ's increased scrutiny on the use of messaging apps, emphasizing the need for tailored policies that align with a company's specific risks and business needs. We also discuss the critical importance of internal controls as minimum expectations set by the DOJ, and the necessity of continuous monitoring to manage these risks effectively. Lastly, we examine the newly added provisions related to adequate compensation, ensuring that compliance teams are empowered and protected against retaliation. The episode concludes by summarizing three key takeaways for compliance professionals: the growing importance of communications compliance, the need for robust and functional internal controls, and the imperative of adequately compensating compliance personnel. Key Highlights · Messaging Apps and Compliance · Internal Controls and Risk Management · Adequate Compensation for Compliance Teams Resources Listeners to this podcast can receive a 20% discount to The Compliance Handbook, 5th edition by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
    続きを読む 一部表示
    7 分
  • Day 2- 2024 ECCP on Incentives, Consequences, and Clawbacks
    2025/01/02
    Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will plan to join each day in January for this exploration of best practices in compliance. In this episode, we discuss how the Department of Justice (DOJ) has emphasized the importance of designing and implementing compliance-based compensation schemes. Financial incentives, such as deferred or escrowed compensation tied to conduct, play a critical role in fostering a culture of compliance. The episode also explores the necessary continuum of assessment, analysis, implementation, and monitoring that companies must follow for effective compliance incentive programs. Additionally, Tom covers the DOJ’s rigorous approach to consequence management, particularly concerning clawback provisions in executive contracts. The episode guides compliance professionals on the essential steps and analyses required to adhere to the enhanced DOJ expectations. Key takeaways include the importance of financial incentive analysis and the distinct yet related roles of clawbacks and consequence management within a compliance program. Key Highlights · Starting with Incentives and Consequences · Incentive Program Breakdown · Consequence Management Deep Dive Resources Listeners to this podcast can receive a 20% discount to The Compliance Handbook, 5th edition by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices
    続きを読む 一部表示
    8 分