Innovation in Compliance with Tom Fox

Welcome to the podcast series: In Conversation with K2 Intelligence FIN: Navigating an Increasingly Complex Sanctions Landscape. This series is sponsored by K2 Intelligence FIN. This week I will visit with  Adam Frey, Managing Director at Intelligence FIN and Eric Lorber, Vice President at Intelligence FIN. Over the week, we will review the current sanctions landscape, discuss how to build a sanctions compliance program, walk listeners through what happens when you discover a sanctions breach or potential breach, consider new sanctions exposure and conclude with a look in that veiled land of the future by considering issues on the horizon. In this Episode 3, I am joined by Eric Lorber On what to do if you have a sanctions violation or think you may have violated a sanctions program. Frey concluded by stating, “these are the types of sort proactive steps that I think OFAC and the regulatory authorities would really like to see. It is signaling is we are taking this seriously. It's very much a sort of a signal that we are on your side enforcement agencies and regulatory authorities.”Join us tomorrow where I am joined again by Eric Lorber to consider new sanction risk exposures for commercial corporations and in the shipping space. ResourcesFor more information on K2 Intelligence FIN's Sanctions Risk Advisory Services, click here.For more information on Navigating the Sanctions Minefield: What Every Global Business Should Know, click here.

Welcome to the podcast series: In Conversation with K2 Intelligence FIN: Navigating an Increasingly Complex Sanctions Landscape. This series is sponsored by K2 Intelligence FIN. This week I will visit with  Adam Frey, Managing Director at Intelligence FIN and Eric Lorber, Vice President at Intelligence FIN. Over the week, we will review the current sanctions landscape, discuss how to build a sanctions compliance program, walk listeners through what happens when you discover a sanctions breach or potential breach, consider new sanctions exposure and conclude with a look in that veiled land of the future by considering issues on the horizon. In this Episode 2, I am joined by Adam Frey to learn about how to build an effective sanctions compliance program. We conclude with a few thoughts on the constant pressure for cost-cutting in the compliance function, which has been made more acute during the time of Covid-19. Frey noted that it “ is a consistent pressure. But I think it's important to emphasize organizations really have to resist the urge to, to cut costs.” The reason is the cost of a compliance failure is so high and the regulators have said that all businesses must remain ever vigilant.  The idea of cutting corners now in an attempt to reduce costs could really end up adding costs down the line in terms of fines and penalties down the road. Please join us tomorrow where Eric Lorber returns to discuss the actions you should take if you have sanctions violation or even a potential. While it depends somewhat on the size of the organization.ResourcesFor more information on K2 Intelligence FIN's Sanctions Risk Advisory Services, click here.For more information on Navigating the Sanctions Minefield: What Every Global Business Should Know, click here.

Director of Advisory Services at SAI Global, James Green, is this week’s guest on the Innovation In Compliance podcast. James’ role involves helping clients manage atypical risk concerns or situations, including business continuity, vendor risk, pandemic, workplace violence, and active shooters. He chats with Tom Fox about his company’s 360° view of risk management and how to survive risks that you never saw coming.Compliance vs Operational Risk ManagementJames gives his perspective on the difference between compliance and operational risk management. Compliance, he says, is ensuring that you’re adhering to your own standards, policies and regulatory requirements. Operational risk management, on the other hand, is mitigating any risk to the company, no matter where it originates. Hurricane Harvey is a classic example of checking all the compliance and risk management boxes, but failing to mitigate the actual risk. Tom comments that compliance and risk management are much closer than just complementary: a combined approach helps a business create a more robust strategy for overall risk management. 360° View of Risk ManagementSAI Global advocates a 360° view of risk management; risk and compliance need to be seen holistically. “We believe a company needs to be assessing risk in totality wherever it comes from,” James says. “And it doesn't matter where it comes from, because the goal is to increase your organization's resilience, right. That is really the goal of all of our collective functions, is that when there's a bump in the night, we can manage through it successfully, legally, ethically, to the satisfaction of our stakeholders.”When Things Go Bump In The NightTom comments on SAI Global’s real-time risk management approach. He asks James how it allows an organization to be more agile and responsive to market conditions as they come up. James responds that while compliance and risk professionals are great at mitigating issues that just happened, they need to also be aware that there will always be unknown and unanticipated issues. “...The problem is in our world, there's always an unknown that's coming up. Right now we're living through COVID-19 which was unknown to a lot of us,” James points out. “There's always something that's gonna happen. There's always another bump in the night. So you can't be planning based on what happened in the past. You need to be agile. You need to be nimble.” He gives tips on how to determine if a risk is strategically acceptable, and the role risk management should play in the corporation. COVID-19 and Supply ChainThey originally saw COVID-19 as a supply chain issue, James says, and started advising their clients about it in January. It became much more than that, he remarks. “Supply chain really needs to be embedded in your risk model... because it can damage what your suppliers and vendors do, it can damage your brand to your customers.” He shares useful COVID-19 resources that his company has made freely available to the public.ResourcesSAIGlobal.comCOVID-19 ResourcesJames Green on LinkedIn | Twitter

Welcome to this special podcast series; In Conversation with K2 Intelligence FIN: Navigating an Increasingly Complex Sanctions Landscape. This series is sponsored by K2 Intelligence FIN. This week I will visit with Adam Frey, Managing Director at Intelligence FIN and Eric Lorber, Vice President at Intelligence FIN.Over the week, we will review the current sanctions landscape, discuss how to build a sanctions compliance program, walk listeners through what happens when you discover a sanctions breach or potential breach, consider new sanctions exposure and conclude with a look in that veiled land of the future by considering issues on the horizon. In this Episode 1, I am joined by Eric Lorber to review the current sanctions landscape.The bottom line is that sanctions are here to stay and every business needs to understand their impact to your company. Please join us tomorrow where we discuss building a sanctions compliance program with Adam Frey. ResourcesFor more information on K2 Intelligence FIN's Sanctions Risk Advisory Services, click here.For more information on Navigating the Sanctions Minefield: What Every Global Business Should Know, click here.

Melissa Koch is the CEO of InFront Compliance, an online assessment and reporting tool for highly regulated industries. She is a business, technology and data lawyer by trade, with over 20 years experience. As such, she has been at the forefront of the changing landscape of compliance. She chats with Tom Fox about how her company helps its clients navigate the intersection of law, technology and compliance.The Intersection of Law, Technology and Compliance“It’s always at the intersection that I think the most interesting things happen,” Melissa tells Tom. When you view compliance as an ecosystem - the intersection of law, technology and compliance as a unified field - you are able to see how they all work together to create an environment of collaboration and communication. Collaborative vendor risk management in particular, she explains, views compliance as an ecosystem with many stakeholders. It’s a way to facilitate lines of transparency between these stakeholders to enable reliability and consistency and to help define your company’s overall compliance posture. “And the foundation is really about communication and making sure you know who’s involved, what they’re doing, and having those sight lines and having that visibility to make much more informed decisions… on how to manage the compliance landscape.” Embracing Data In Real Time Vendor ManagementTom asks how data fits into the collaborative ecosystem. Melissa responds that InFront Compliance embraces data because you can’t get the transparency to make better decisions without it. InFront creates and curates libraries of assessments for organizations in highly regulated industries such as financial services. Ensuring that their businesses stay compliant in a fast changing regulatory landscape, is one way InFront serves their clients. They also foster a “continuous culture of compliance” so their clients can see where they have gaps and close them before they become a problem.Building ResilienceA business is resilient if it’s able to bounce back quickly after an event that impacts its operations. Melissa remarks that resilience, policy development and change management all work together to make sure that your organization can effectively navigate any sudden and/or unforeseen changes. One way your company can build resilience is to adopt a dynamic and practical approach to policy development, Melissa says. “For those organizations that are adaptable and fluid in their ability to navigate change, are policies that live and breathe with the organization. So they are created specifically for that organization and how that organization does business. But they also have built into the policy regular review periods... It makes sure that everything is accurate and reflective of how that organization does business and when it's not, then it changes... Those policies are there to help support the organization when there's been a stress event for the organization.” ResourcesInFrontCompliance.comEmail: melissa@infrontcompliance.com

Dan Wager heads Financial Crime Compliance Strategies at LexisNexis Risk Solutions. His global team focuses on identifying market opportunities, merger acquisition opportunities, regulatory developments, and product development in the areas of anti-bribery, anti-corruption, money laundering, sanctions screening, and sanctions enforcement. He joins Tom Fox on this week's show to chat about the key findings of LexisNexis' report, The True Cost of Financial Crimes, and its implications for compliance professionals.Understanding Financial Crime"One of the things I'm trying to do," Tom tells Dan, "is bring people like yourself on the podcast to really help the anti-corruption compliance specialist who's in the commercial corporation understand financial crimes." Dan comments that LexisNexis has been doing this report for five years but at the regional level. This report, by contrast, is a global roll-up overview, where they are bringing the regional studies together into a global view, to see the true cost as well as challenges and trends facing the industry.Key InsightsDan and Tom discuss the key findings from the report, including: The true cost of compliance globally is in excess of $180 billion a year. Each region has its own compliance risks and issues. Non-bank payment providers pose various compliance challenges, in particular for clearing banks. The increasing compliance burden has an adverse impact on attracting and retaining talent. The proper use of the right technologies can assist in offsetting costs and making better compliance decisions. A Layered Approach to Compliance Using a layered approach helps a compliance professional think through the risk management of their compliance program, recognizing that implementing financial crime compliance initiatives can provide broader benefits to their business. Dan explains that the layered approach to compliance starts at the front gate, and it involves using technology to determine whether the person or proposed action poses a compliance risk. "The layered approach means before you spend something on someone or give money to someone or buy something from someone you should have vetted them," he points out. Tom asks about page 45 of the report. Dan says that it's about using the right technology for your business' needs. That is what will reduce labor cost, he points out. "It doesn't mean that you can hire cheaper labor. It means you have fewer people to accomplish the same compliance because you're automating and accomplishing through technology much of the rote work."ResourcesLexisNexis Risk SolutionsStudy: The True Cost of Financial Crimes

Tom Fox chats with President and founder of Simple SEO Group, Brendan Egan, in this week's show. Brendan is a podcast host as well as a contributing author to Entrepreneur Magazine. His recent article entitled Marketing Dos and Don'ts During A Crisis is the focus of discussion on this week's episode of Innovation In Compliance. Marketing During A Crisis"Your marketing is really what's going to drive your business and drive your revenue and determine whether or not you're successful," Brendan tells Tom. In day to day business, and especially during a crisis, you need to look at marketing based on your short-, medium- and long-term objectives. Brendan points out that you shouldn't make any knee-jerk decisions that would impact your long-term growth or integrity. Instead, make short-term alterations to your marketing during a crisis that demonstrates how you're supporting and looking out for your customers. Your medium and long-term plans will most likely be unaffected, Brendan says.Why Lawyers Need To ListenLegal and compliance practitioners need to understand the importance of marketing, especially in these times. Brendan remarks that marketing is a grey area with a lot of overlap: marketing can overlap into a company's culture, into the legal space, and even the compliance department. The most successful businesses take a company-wide approach to marketing. In addition, companies need to be fluid in order to respond proactively to a changing world. Tom comments that Simple SEO Group's time horizon approach allows them and their clients to respond to ever-changing information in a productive manner.Marketing Is EssentialTom asks, "How are you helping corporations think through how they can effectively market in an economic dislocation?" Brendan responds that he started Simple SEO Group during a recession, so he is well versed in helping businesses make money in spite of the economic downturn. "During a recession, marketing becomes that much more important," he says. "It almost becomes… an essential service." More and more companies are turning to digital marketing because their usual marketing channels are drying up, he says. Survival is a matter of being open to new marketing opportunities, especially online, so you can continue to grow during COVID-19 and beyond.ResourcesSimpleSEOGroup.comBrendanEgan.comArticle: Marketing Dos and Don'ts During a CrisisBook: 101 Tips From The Marketing Masters

Tom Fox met Mary Ann Faremouth at the National Speakers Association’s (NSA) Winter Conference. He was immediately enthralled with her passion for recruiting. Mary Ann is the founder and CEO of Faremouth & Company, a national recruiting and consulting firm. She also networks with a consortium of recruiters, sharing jobs and helping candidates. Mary Ann describes herself as a “holistic recruiter”: she looks at the whole person when placing candidates, as she believes this more human approach works best for these times. She chats with Tom about her book, Revolutionary Recruiting, and shares practical advice for job seekers as well as employers.The Faremouth MethodTom asks Mary Ann to describe the Faremouth Method. She explains that it is the 5-step process she uses to place candidates. These 5 steps are: Know yourself: do an inventory of your skills and talents. Ask better questions. Step out of your comfort zone. Take the time to do it right. Be a hunter. She says, “The Faremouth Method helps me really identify who that person is right now, what their purpose is, what their passions are, and that helps me align them with a position that's gonna fit that.”A Win-Win Approach“...if we take the time to understand what their [candidates’] passions are, what their skills are, what their transferable skills are, we can place them in positions where the retention rate is a lot higher. Candidates are happier because they're feeling a sense of purpose. The clients are happier because people aren't leaving, and so it's a win-win for everyone.” Mary Ann and Tom discuss why her holistic approach makes good business sense. Tom comments that Mary Ann brings not only her professionalism to the table, but also candidates and clients trust her advice. She responds that her motto is ‘Integrity Personified’, and that doing the right thing for everyone is one of her key values but it is also just good business. “If I make a good match, everybody's happy,” she points out. “Then guess what happens? That client’s gonna send me his vendors, that applicant’s gonna send me his friends.”Key Mistakes Employers MakeRevolutionary times such as these, require a revolutionary approach to recruiting, Mary Ann argues. In the new normal, both job seekers and employers have to be willing to think outside the box. Tom asks Mary Ann to outline the key mistakes employers make when they’re looking to hire a new employee. She responds that employers often have unreasonable demands and expectations. Going forward, they have to look realistically at the job and its requirements, and look for a candidate with those transferable skills, Mary Ann says. She shares some insights about the post-COVID job market. Another mistake employers make is that they don’t ask the right questions during interviews. She advocates asking more hypothetical questions so that employers can gauge the potential employee’s problem solving skills, and if they have the right mindset to be part of the team. Mary Ann then shares some insightful and practical advice for listeners to prepare themselves for the future. Life is ultimately about relationships, she remarks. Ask yourself, What can I do in service of others? “Maybe this is the time for us to look at these worst of times being the best of times for us to improve and to learn what our skill set might be that we can refine to help make a contribution to the greater good,” Mary Ann comments.ResourcesFaremouth.comRevolutionary Recruiting book on Amazon | Barnes and NobleUSA Daily TimesThe Price of Business podcast

This week's guest on the Innovation In Compliance podcast is Amy Hilbert of Casepoint. She joined Casepoint to help build out their services for federal, state and local, and international government agencies, and to help ensure that the company had the right people, processes and contracting methods in place. She chats with Tom Fox about Casepoint's services, and what they can do for compliance professionals.Products and ServicesAmy describes Casepoint as a legal technology platform, whose first component is e-discovery. Their clients use them "to help work through large volumes of data so they can narrow down to key pieces they need, either for a FOIA request, for an investigation, for certifications… or to actually go to litigation," Amy says. Moving Government To The CloudTom asks Amy to describe the unique requirements government agencies must face as they move to the cloud. Amy responds that every organization, including the government, has to look at their risk posture before moving to the cloud. Since the government's mandate is to protect the data of its citizens, they have to adopt more stringent policies and procedures. Amy points out, "Anything that goes into the cloud has to be FedRAMP certified."Project Management As The KeyAmy and Tom discuss why Casepoint was able to secure an exclusive contract with the SEC. "They [the SEC] went to great extents to make sure that they were really picking a solid solution based on the functionality and capabilities of the company," Amy says. "I think the key for Casepoint was our ability to handle some of those complex data types that we received." Tom remarks that Casepoint is not simply a technological platform and solution, but project management is also a key part of the company. Amy agrees that Casepoint's project managers are a key part of the company's success: they ensure that clients leverage the technology in the best way possible to get the most efficiency in their workflow.How Compliance Professionals Can BenefitTwo case studies illustrating how Casepoint helped clients are shared. She points out that maintaining metadata is the key to data analysis. Tom comments that the case studies emphasize for him the services component as well as the workflow process, which would enable the user to "quickly and efficiently be able to use the data that you've been able to synthesize for them… Oftentimes in a corporation, compliance practitioners who are lawyers may not understand or be able to pull as quickly other types of information. So having that sort of in-house expertise ... seems critical to me," Tom says.ResourcesCasepoint.com

In this five-part podcast series, sponsored by K2 Intelligence FIN, we have considered defining and building effective compliance programs. I have been joined in this series by Michelle Goodsir, a Managing Director at K2 Intelligence, and Gail Fuller, Financial Integrity Network (FIN) Vice President. Michelle has 25 years of financial crime compliance experience which includes fraud risk management, anti-bribery and corruption, corporate security and investigations, sanctions, and Anti-Money Laundering (AML) program experience working within the financial services industry and the US government. Gail focuses on developing, refining, and implementing FIN’s quantitative and qualitative risk rating tools. She leads engagements focused on helping FIN’s jurisdictional and private sector clients understand their exposure to financial crime risk and develop and implement strategies to mitigate their risks.Over this series we have considered key challenges in compliance, why compliance needs a seat at the table, how to do compliance on a budget; training and culture and what is on the horizon. In our conclusion, Part 5, I visit with Gail Fuller as we look into that veiled land of the future and view what’s on the horizon for compliance. Highlights include: What are regulators looking for when it comes to compliance? Regulators are looking for professionals to be proactive and creative problems solvers.  If compliance was an area that was previously not sufficiently funded, what are three things people need to do now if things are cut even further? Reinforce your commitment to compliance; rethink geographic distribution of your compliance team; and think through technology investments. Thinking about this whole series, we talked about a lot of tips… what are the areas you’d suggest our listeners focus on as they look to rebuild or enhance their programs? Be sure to communication your compliance priorities clearly, leverage personnel to more fully operationalize compliance and then harness and pursue technologies. ResourcesK2 Intelligence financial crimes risk & compliance page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance K2 Intelligence AML page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-money-laundering-complianceK2 Intelligence Anti-corruption page: https://www.k2intelligence.com/en/services/our-practices/financial-crimes-risk-and-compliance/anti-corruptionK2 Intelligence DOLFIN: https://www.finintegrity.com/dolfin.html