General
Glencore, Part III: Third-Party Agents
Today we have another exploration of Glencore’s recent compliance progress report, this time looking at how the trading giant handles third-party risk management. Glencore’s report does offer extensive detail into how it runs its compliance program and third-party risk drives everyone nuts, so let’s see what lessons we can learn. For those unfamiliar with the…
Read MoreTroubling New Data on AI Risks
Today I want to go back to artificial intelligence and some of the policy management and corporate culture challenges that the technology keeps posing. KPMG recently released a wide-ranging survey of how people view and use AI, with statistics that could cast a long shadow over your own AI compliance efforts. Let’s take a look.…
Read MoreTalking Tariffs and Compliance
Today we have another Radical Compliance podcast interview, this time talking about the compliance implications of the Trump Administration’s proposed tariffs regime — although the more you consider tariffs and President Trump’s erratic approach to them, the more you realize that their implications will spill far beyond the compliance function. To help me unpack all…
Read MoreGlencore, Part II: Risk Assessments
Today I want to return to Glencore and the ethics and compliance progress report the company released a few weeks ago. Specifically, how did Glencore overhaul that part of the compliance program that drives so many people to exasperation — the risk assessment process? For those who didn’t see our previous post on Glencore’s compliance…
Read MoreOn Vacation This Week
Thank you for visiting, dear readers, but Radical Compliance is taking some much-needed vacation this week. We likely won’t have any updates to the website, and no newsletter on Friday, April 25. You can always send us tips at [email protected]. Otherwise, behave yourselves and we’ll be back as usual on Monday, April 28.
Read MoreDiving Into Glencore Compliance Report
Commodities trading giant Glencore published an in-depth look at its ethics and compliance function this week, part of the company’s penance for a corporate corruption scandal it settled in 2022. Anyone wanting a glimpse into how global businesses might structure their compliance operations, especially when recovering from a misconduct scandal, look no further. As you…
Read MoreThat New York Action Against Block
Last week New York state regulators sanctioned online payments giant Block for persistent shortcomings in the anti-money laundering compliance program for Cash App, the popular digital wallet owned by Block. Even for folks not in financial services or subject to New York state regulation, this case offers important lessons about modern compliance risks that any…
Read MoreThe Unsexy Keys to Data Analytics
Compliance officers need a strong data analytics capability for their programs to succeed, so today I want to talk about the nitty-gritty “infrastructure issues” you need to resolve with the rest of the enterprise if you want to get that capability where it needs to be. This has been on my mind since I moderated…
Read MoreOn Navigating Global Legal Tensions
One big challenge for compliance officers is how to manage your program at a global level, when so often that means juggling multiple legal jurisdictions with conflicting standards for corporate behavior. So when I had the chance recently to moderate a webinar on that very subject, I took lots of notes. I pass them along…
Read MoreMore on CCOs and Law Degrees
My phone rang the other day. At the other end of the line was a source who had to remain anonymous. Why? “Because I’m a compliance officer with a law degree, calling to explain why it’s so useful to have a law degree,” he said. “If my name gets out, the compliance officers without law…
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