USAA, Part III: Better Risk Assessments 

USAA

Today we have one more look at that enforcement action banking regulators took against USAA last month, over the bank’s slow pace of compliance improvements. We’ve already reviewed changes to board oversight and compliance staffing levels that USAA needs to make. Next up: risk assessments.  Again, a quick recap. FinCEN and the Office of the…

Read More

A Difficult Picture for Anti-Fraud Today

fraud

The Association of Certified Fraud Examiners is holding its 2021 conference this week (virtually), and to that end the ACFE also just published its latest survey on anti-fraud budgets, resources, and challenges.  Suffice to say, anti-fraud and internal audit teams have had a busy year. More than half of all survey respondents said they’ve found…

Read More

Enterprise Risks: The Pandemic, and Beyond

risk

Surprising exactly no one, the top worries this year among corporate leaders are the pandemic and its economic consequences. So says Protiviti’s annual report on top enterprise risks, although the report does also flag a few other concerns that corporate audit and risk managers may want to consider. The top risk for 2021, according to…

Read More

Another Lesson From Boeing: Silos

boeing

Boeing’s missteps with the 737 Max jet offer many powerful lessons for corporate compliance, audit, and risk executives. Our latest lesson comes from an in-depth article in the New York Times, examining the decisions Boeing made about the jet’s design and subsequent pilot training, and the terrible consequences that followed. Every compliance and audit professional…

Read More

Shameless Self-Promotion: Anti-Fraud Triangle Paper

anti-fraud triangle

As devout Radical Compliance readers might already know, from time to time I have written about something I call the Anti-Fraud Triangle—a method of assessing misconduct risk in your organization, based on the Fraud Triangle that auditors have used for decades to understand fraud risk. Well, I just published a longer white paper on the…

Read More

Do We Have a Problem With Compliance Risk Assessments?

risk

This week I dove into PwC’s annual State of Compliance Report, reading the report itself and eavesdropping on a webcast with the PwC compliance gurus who wrote it. The study has plenty of data worth reading, and one conclusion from that data jumped out at me immediately. We have some disconcerting patterns emerging in how…

Read More