There have been some great and interesting blog posts about the coronavirus in our community over the past several weeks. Mike Volkov appealed for real leadership in this time of crisis, Matt Kelly has been pondering what we need to be thinking about now, down the road and in the future about COVID-19 and Harry Cassin has kept the FCPA Blog as the compliance community’s bulletin board for all things coronavirus—compliance related.

As the Voice of Compliance and founder of the only podcast network dedicated to compliance, I decided that one of the things I could do was to start a podcast dedicated to compliance, the compliance practitioner and compliance profession in the time of coronavirus. So today, I want to introduce Compliance and Coronavirus-Clarity and Sanity for the Compliance Professional as the latest offering on the Compliance Podcast Network. I will be posting each new podcast three times per week at 9 AM CST on Tuesday, Wednesday and Thursday of each week for the foreseeable future. This new series is sponsored by SAI Global.

In this first week I am dropping the following episodes:

Sean Freidlin on Successfully Working from Home

For my inaugural episode I speak with Sean Freidlin, Director of Product Marketing at SAI Global. Sean is a long-time work from home employee and he recently posted an article on how to successfully work from home. He shares some of the strategies he has learned over the years.

Joanne Taylor on Financial Crimes Compliance During Coronavirus

In this episode, I speak with Joanne Taylor, Managing Director at K2 Intelligence Financial Information Network. Joanne has worked as a Solicitor, in the financial and financial services industries. She now assists companies with financial crimes compliance and investigations. We visit on how and why companies must keep their financial services compliance robust during this time of the coronavirus health crisis.

Matt Kelly on the Downslope Risk of the Coronavirus Curve

In this episode, I am joined by Matt Kelly, the coolest guy in compliance, who is maintaining his coolness during the coronavirus crisis. Matt is also the founder of Radical Compliance. He talks about the downslope of the coronavirus curve.

Over the next several weeks, I will be considering Supply Chain, FCPA enforcement, legal issues such as force majeure, the SEC’s role and a wider variety of issues related to coronavirus and COVID-19. If you have a topic you would like explored please let me know. If you have written anything on the topic, come on the podcast and talk about it. Check out these first three episodes and please help me to get the word out about this most significant addition to the Compliance Podcast Network.

A special THANK YOU to SAI Global for sponsoring this series. 

Name any catastrophic corporate compliance failure and every root cause analysis will show there were silos which compliance could not break through. In the Boeing 737 Max design failure there was the siloed nature of the entire design, creation, training, regulatory and implementation team for the safety feature, the failed Maneuvering Characteristics Augmentation System (MCAS). At Wells Fargo, it was the siloed nature of the commercial banking group from other corporate disciplines such as legal, internal audit, human resources and even the Board of Directors. The over-riding theme was the number of compliance miss-steps that led to these disasters. While the siloed nature of these organizations processes led to a literal number of very small steps which contributed to the final disaster, it demonstrated to me even more clearly why compliance must not only have a seat the table but also be embedded throughout your organization.

Three Key Takeaways:

  1. Every major corporate scandal involves silos.
  2. Compliance should rotate senior leadership through its function.
  3. A CCO must be curious.

One thing is certain going into 2020 and beyond is that technology that will improve the efficiency of compliance and will assist in the operationalization of compliance into fabric of every business which embraces it. I would posit that the compliance professional who incorporates the techniques they advocate into their organization’s compliance program will not only move their compliance program forward but also make their company run more efficiently and, at the end of the day, more profitably.

AI is a step which weds the human interaction and experiences with the data which is available to every company – its own internal information which is most generally sitting in siloed verticals and not being used. This data can provide the foundation for business research and risk-forecasting models and AI. When you couple this data with the insights into what humans do well or poorly; you can pair the best of these two seemingly disparate incongruities. Moreover, when a compliance function embraces the use of AI and embraces this human and technological approach for forecasting and risk assessments and then keeps improving their risk management techniques, it will create a sustainable strategic business, compliance and intelligence advantage over its competition.

Three Key Takeaways:

  1. Use the big data in your own organization.
  2. Break down silos to get the data.
  3. Using the data in your own organization will drive greater business efficiency and greater profitability.

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the Compliance Podcast Network to explore these issues. Today’s episode asks has your compliance training has been Conrona-Cancelled? We provide some things you can create to supplement your routine training and communication.

Some of the highlights include:

  • Create a virtual ‘Ethics and Compliance Live Show’ – a fun and entertaining way to communicate compliance topics.
  • What might a show consist of?
    • An original song;
    • An Opening Monologue;
    • A Top Ten list
    • An original skit around compliance;
    • Visit with the CCO about the skit;
    • Virtual Q&A; and
    • Closing compliance tune.
  • How about a Colbert-style show?
  • A Johnny Carson-style show?
  • A David Letterman-style show?
  • Always remember, you are only limited by your imagination.
  • Maintain Fun – Variety and Surprise. Novelty breads engagement. Need to constantly switch it up. Try lots of little things.
  • What are some of the additional pluses during this current time?
    • These formats are powerful mediums that can be digested in small increments when working remotely.
    • You can still make a personal connection.
    • You can still educate and make the training/communication interesting.
    • It can all be digested on the employees time.

Ronnie Feldman

Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)

Learnings & Entertainments (Website)

60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.

Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.

Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.

Design thinking is another innovation which can help the CCO move forward in a cutting-edge manner to make a compliance program not only more robust but also operationalize it into the fabric of the company. Such a mechanism would help to drive compliance into the operational nature of a company.

This design thinking protocol can help to create a more effective ethics and compliance training model by using employees to provide the initial input to improve its effectiveness and relevance to the front-line employees. The compliance team then implements several proposed solutions until the most operative one or ones becomes apparent. These are then rolled out companywide for better and more effective compliance training. As the entire process is documented, when the regulators, such as the DOJ or SEC, come knocking, you will have the ability to not only explain your training but also demonstrate its effectiveness.

Three key takeaways:

  1. Design thinking concepts are not simply for product innovation but for culture innovation.
  2. Design thinking works around the users’ needs rather internal operating efficiencies. For a compliance program, this means employees, third-parties and customers.
  3. Design thinking works to improve your compliance regime by building from the ground up rather than a legalistic top-down approach.