General
Internal Audit in Tumultuous Times
Good news for internal auditors who feel overwhelmed, under-resourced, and frustrated that not enough people at your organization value your opinion — you’re not alone. GRC software vendor AuditBoard published a report last week that surveyed more than 200 internal audit leaders around the world, and apparently those feelings of existential dislocation are par for…
Read MoreCorporate Compliance and ‘Cartel Risk’
Last week I moderated a webinar on Latin American drug cartels, and where “cartel risk” is or isn’t similar to the corruption risks that compliance teams have worried about for years. Perfect timing! That same week, the Justice Department settled an FCPA case where drug trafficking was one element of the story. Let’s review the…
Read MoreThoughts on Job-Seeking and Referrals
The other day I heard from a friend who has been a corporate auditor for many years. She recently landed a new job as head of internal audit at a respectable and stable company, presumably with a respectable and stable salary too. So I asked her: How’d you get that job, anyway? After all, I’ve…
Read MoreCompliance and Incentives, Part II
Today I want to return to the idea of effective incentives for corporate compliance. In a post on the subject last week, we explored some fundamentals of how to build an incentives program, but struggled with exactly how to tie executive compensation to compliance criteria. So for help, I turned to that fount of all…
Read MoreGetting Started on Compliance Incentives
Last week I had the privilege of moderating a webinar on how to structure and use incentives in an ethics and compliance program. This is good, because incentives are one of those ideas that we all know should be in your program somehow, but using them smartly and at scale is tricky. My notes are…
Read MoreAn Intriguing Whistleblower Award Case
We haven’t talked about whistleblower awards in a while, but a recent spat over one such award from the Securities and Exchange Commission might be worth our attention. It raises some interesting questions about whether the SEC’s whistleblower award policies might squelch employees’ incentives to first report misconduct concerns on internal hotlines. The SEC issued…
Read MoreImportance of ‘Feeling Heard,’ Yet Again
By now most people have heard that grand juries in Washington and Chicago are declining to indict people arrested for anti-ICE protests. The political subtext here is that juries in Democratic regions won’t indict people arrested by the Trump Administration. What does that tell us about the breakdown in cultural norms within large organizations? That…
Read MoreKeeping Humans in the AI Loop
I spent this week in Lithuania attending a conference for compliance officers in Eastern Europe, and this being Europe, of course that meant artificial intelligence and data privacy were all over the agenda. So it’s rather poetic that European regulators also just published fresh guidance on human oversight of automated decision-making systems. The guidance was…
Read MoreOct. 30: Compliance Career Forum
Readers of Radical Compliance know that we love to talk about the compliance job market around here. So I’m delighted to announce that we are co-hosting a virtual Compliance Officer Career day on Oct. 30, to discuss what the job market looks like for compliance officers these days and how you can keep positioning yourselves…
Read MoreAI and Policy Chatbots, Part II
Today I want to return to the idea of using an AI-driven chatbot as a compliance policy adviser for employees. On one hand, the potential gains for your compliance program are clear; but are we miscalculating some of the potential risks that AI chatbots might bring to your program too? This particular bee crept into…
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