By Adam Turteltaub

While Ericsson is best known for its mobile phones, the company’s reach in wireless is far greater. It is the creator of Bluetooth technology, owns patents on much of the critical IP that wireless systems depend on, and is active in more than 180 countries providing much of the hardware, and even cellphone towers, that enables all of us to talk, text, and surf the web wherever we are in the world.

Jan Sprafke, Chief Compliance Officer at Ericsson, explains in this podcast that with that global reach – including operations in approximately 100 high risk countries – also comes a large network of suppliers. To manage the potential compliance challenges that go along with it, the company uses a risk-based approach to supplier management

They assess the country risk, go to market approach and whether the supplier will be using subcontractors. Then they work closely with sourcing and other assurance functions on an ongoing basis.

The company’s supplier code of conduct is shared with their vendors. But, it is just the start. There is also training provided, supplier days, meetings with them to discuss FCPA, AML, health and safety and other topics. All of these efforts and more help suppliers understand what Ericsson’s expectations are, not just in principle but also in practice.

They even work with many of their contractors as they select their subcontractors.

The goal is to create an end-to-end framework for managing third party compliance risk.

Download the podcast (maybe even on your mobile device) to learn more.

Jan Sprafke on Supplier Compliance [Podcast]

By Adam Turteltaub

Julie Janeway (LinkedIn), General Counsel and principal owner, Principled  Healthcare Consulting will be speaking about internal and parallel investigations at the 2024 HCCA Compliance Institute. In this podcast she slices off a bit of that expertise.

A thorough investigation is needed, she advises whenever there is an issue that could require arbitration, a court case, administrative hearing, contractual dispute or reputational issues, whether by an employee, contractor or the organization itself. The same is true if there is a policy breach or alleged violation of the code of conduct.

So how best to do it? Have both an investigation plan and a preplan which designates who will be responsible for the investigation depending on what the issue is. For example, a privacy officer would likely play the lead role in a HIPAA breach allegation.

As for the plan itself, it should be thorough. The team executing it should include individuals with a wide range of skills and, she highly recommends it include an experienced investigations attorney.

What should you avoid? Several things, she cites, including retaliation, making the plan as you go along, letting supervisors or managers interview subordinates and not having insurance for when investigations happen.

The rules are largely the same with parallel investigations, which are required pursuant to statues that call for entities notified of an investigation by a governmental agency to conduct their own investigation. These absolutely must be done, or the organization may face sanctions. She highly recommends doing these investigation under attorney-client privilege.

Listen in to learn more about what to do and what not to do in an investigation. Then, don’t miss her session at the 2024 Compliance Institute, March 18-20 in Nashville.

Julie Janeway on Compliance Investigations [Podcast]

By Adam Turteltaub

In 1984 I went to my friend Chris’s wedding, and one of the other groomsmen, Drew Neisser (LinkedIn), his then boss, talked me into pursuing a career in advertising. Just a few months shy of 40 years later, I caught a video on LinkedIn of him with chief marketing officers discussing the struggles of managing remote workers. It didn’t matter that these were marketing people, the problems sounded just like we in compliance face.

So, I asked Drew, who is the founder of CMO Huddles and the author of the book Renegade Marketing:  12 Steps to Building Unbeatable B2B Brands, to sit down and do a podcast on the topic.

Drew points out that, despite workers being required to come into the office more often, there is still a cost to remote work. Churn is higher than before. Partners at law firms complain that their associates are years behind in their development, likely due to the inability to learn by osmosis.

So what do we do? He recommends that we recognize the present reality and look to hire self-starters. People who need a great deal of hand holding will not work out in a world where their managers are miles, if not hundreds of miles, away.

Second, make sure the team understands what the organization’s business is. Then, help them connect, intellectually and emotionally, with it. If they don’t, then it’s just another job to them.

Incorporate virtual bonding activities, but also try to get the team together in person. That effort creates culture and connection.

Looking outside your team, he recommends four tactics:

Meet, ideally in person. Get to know your colleagues, and understand their business priorities. Focus on helping them solve their problems.

Track all the people you want to meet and influence. Then, take active steps to connect with them and get to know them.

Share something about yourself and encourage them to do the same. Get to know the person and stay in touch. For example, send them over articles you think they would find of interest based on what you learned about them.

Join formal and informal work groups. If there is a team forming to tackle a problem, be a part of it. But also look to book groups and other less structured ways to connect.

Throughout, he advises thinking of yourself as an impact player and a business leader.

Finally, he advises understanding how people want to communicate these days, and meet them there. The era of relying solely on email are done, especially for the younger generation.

Listen in for some very good insights for compliance officers from a career marketer.

Drew Neisser on Connecting in a Working Remote World [Podcast]

By Adam Turteltaub

Some people have a gift for invisibly attending a conference, and no one knows that they were even there. That’s great for a conference of spies, but most people at compliance conferences like to meet at least some of the other attendees.

For many, though, connecting with strangers is difficult, whether they know no one or they are shy about going beyond their usual circle of contacts.

So what do you do if you are one of them?

To find out we spoke with Richard Bistrong (LinkedIn), newsletter author and CEO Of Frontline Antibribery, who will be moderating a general session at the 2024 SCCE European Compliance & Ethics Institute in Amsterdam.

If you spot someone standing alone and looking a bit lost, he recommends you think like a host and invite them to join you. Even if you’re already talking with friends, he advises being a croissant and not a bagel: be sure there is an opening for others. Make the effort to catch them up with the conversation – “we were just discussing helplines”—and ask them to share their thoughts.

If you hesitate to join conversations because you don’t feel you are good at small talk, think of a few questions in advance to use as ice breakers. They don’t have to be traditional compliance-related questions. You could ask people about what excited them the most in the last year. Richard often uses Vertellis cards to start or help conversations.

For those at the conference with a friend or colleague, use the other person as your wingman or wingwoman. Tell them who you are interested in meeting and have them serve as a second set of eyes and ears.

Also, don’t forget about the SCCE & HCCA staff as a source of connection. See if they know someone it would be good for you to talk with.

Listen in to learn more, including how to follow up properly after the conference is over.

Then, be sure to say hello to Richard (and offer him a croissant) in Amsterdam at the 2024 SCCE European Compliance & Ethics Institute, March 18-20.

Richard Bistrong on Conference Networking [Podcast]

By Adam Turteltaub

Compliance programs have come far over the last few decades, but there is still more that they could do to elevate their performance. In this podcast, Alison Taylor, Clinical Associate Professor at NYU Stern School of Business and author of the book Higher Ground shares some intriguing and provocative ideas for improvement.

She is a strong believer in what she calls “firm foundations”. These foundations avoid having too many rules which can, inadvertently, have a negative impact, causing employees to abdicate responsibility for their action and grow overly reliant on following rules. Instead, she argues for simplifying and being attuned to human behavior and the role of incentives.

Be wary too, she advises, of mixed messages and potentially pernicious effects when it appears, whether true or not, that the rules for the rank and file do not apply to leadership. It degrades trust and the culture.

To get more employees to speak up when they see wrongdoing, she advises investing the time in understanding why they don’t raise their hands more.

When it comes to measuring the impact of the compliance program, she is a strong proponent of measuring the ethical culture. Do employees feel safe speaking up?  Whom do they speak to when there is a problem? Do they believe the whistleblower line is truly anonymous? Is leadership looking out for them?

The answers to these questions, and how they change over time, can illuminate how well the program is working.

Listen in to gain more insights, including how to build a common ethical foundation and the importance of adequate authority for the compliance and ethics program.

Alison Taylor on a Higher Ground for Compliance [Podcast]

By Adam Turteltaub

Clara Becerra Campos, Senior Compliance Analyst-Europe for TD SYNNEX, and Dr. Tobias Kruis, Head of Corporate Compliance, Giesecke+Devrient, will be addressing the new EU whistleblowing requirements at the 2024 SCCE European Compliance & Ethics Institute, which takes place in Amsterdam March 18-20.

In this podcast, they delve into the challenges posed by the directive, which significantly expands the number of EU-based and non-EU-based companies that must comply.

The directive not only provides protections for whistleblowers, they explain. It also establishes procedures and deadlines for handling reports. As significantly, it leaves the door open to variations among EU member states, which complicates the picture considerably.

So what should you do? If your organization does not have a whistleblower line already in place they recommend you:

 	Implement an internal reporting channel
 	Be sure it’s aligned with legal and data privacy
 	Consider who will manage the system and conduct the investigations
 	Ensure confidentiality
 	Communicate with your workforce

For those with a helpline already they recommend starting with a gap analysis to determine if your existing efforts are meeting the new requirements.

Listen in to learn more, then join them in Amsterdam at the 2024 SCCE European Compliance & Ethics Institute.

Tobias Kruis and Clara Becerra Campos on the EU Whistleblower Requirements [Podcast]

By Adam Turteltaub

At the 2024 SCCE European Compliance & Ethics Institute, Segev Shani, Chief Compliance & Regulatory Officer at Neopharm Group will be leading the session “Corporate Use of Third-Party Artificial Intelligence (AI) Tools.”

In this podcast he shares that a great deal of risk comes from the headlong pursuit of AI technology. Businesses believe that if they are not using Ai that they will be left behind, but the adoption rate is not being matched with a complete understanding of what AI is.

To manage this issue, he recommends creating an AI governance model that balances the risks and rewards. It can help employees and managers understand the risks, including inaccuracy, bias and both misuse and improper use of intellectual property. And, of course, there can be substantial privacy risks as well.

Listen in as he discusses proper governance, the need for training and the importance of integrating AI governance into business processes.

Then plan on joining us in Amsterdam, 18-20 March, at the 2024 SCCE European Compliance & Ethics Institute.

Segev Shani on AI Risk [Podcast]

By Adam Turteltaub

A good employee survey on compliance and ethics can yield a wealth of data on how your program is and isn’t working, where the risks are, and how to move forward. The challenge is getting the survey right and getting employees to respond.

Klaus Moosmayer, Member of the Executive Committee and Chief Ethics, Risk and Compliance Officer at Novartis, shares in this podcast that the compliance team has just completed the second round of their survey. The goal was to get first-hand data from as many employees globally as they could about any unethical behavior they perceive around them and how it is acted on.

The survey was developed with substantial help from behavioral scientists, who created a questionnaire that captured where the company is now but also enabled them to dig deeper into key issues. For example, in the first round of the survey the Novartis team discovered that approximately 80% of employees go first to their leaders and managers when seeing unethical behavior. In the second survey they focused on what the leaders are doing with those reports.

To encourage responses from employees, they invested the time in preparing the workforce and setting the context that the survey is a part of a broader effort to strengthen company culture.

The messaging behind the survey was both local and global, with company presidents underscoring the importance of the study.

After the first survey was completed, they made the effort to showcase how the data was used and what would be changing at Novartis as a result. That helped earn higher participation rates for the second survey.

How does the data get used? The aggregated data helps inform leadership and enabled conversations as high as the board level.

The data is also incorporated into the company’s integrated digital ethics, risk and compliance platform.

Country managers are shown their data and told how it compared to other regions, which, of course, indicates how well they are or aren’t doing versus their peers. Local leaders are then encouraged to use the data to have roundtables, town halls and other meetings to understand why their scores are what they are.

Listen in to learn what made the Novartis survey so successful and how to improve your own.

Klaus Moosmayer on the Novartis Employee Survey [Podcast]

By Adam Turteltaub

When it comes to AI, there is little agreement. Some see great potential, while others see great nightmares. Some see opportunities, and many see nothing but risks. In the EU, though, there is agreement on one thing, a new EU AI Law. In December 2023 the EU Parliament and Council agreed to  a bill “…to ensure AI in Europe is safe, respects fundamental rights and democracy, while businesses can thrive and expand.”

Longtime compliance professional Letitia Adu-Ampoma (LinkedIn) explains that while the law won’t fully come into force for two years or more, it’s time for compliance teams to start paying attention and preparing.

The act is a part of the EU digital strategy, which is very focused on human-centric legislation. Its goal is to keep positive the impact of AI on people and society.

The approach it takes is risk-based, categorizing AI systems based on the level of risk: unacceptable (and prohibited), high risk, minimal risk and no risk. The act is very specific in how it defines which AI systems fall into each category. The unacceptable risk category, for example, includes social credit scoring, emotional recognition and behavioral manipulation.

Creators and users of high risk AI will be required to register the system in a public record. They will also need to conduct an impact assessment and be transparent.

Transparency will also be critical for generative AI. Providers will need to disclose the content generated and ensure that the models are not designed to create illegal content. There will also need to be governance in place to protect against copyright violations.

So what should compliance teams do now? Letitia recommends reading the guidance and to start preparing the business unit for what is to come.

Listening to the podcast would be good, too.



NOTE: This podcast was recorded in January 2024. The final version of the EU AI Act is yet to be released - a final EU parliament debate on the text will take place before its release. In the meantime, some 'unofficial' pre-final versions of the text have been leaked online in advance of this debate. The final EU definition of AI and key timescales for enforcement mentioned in the podcast are based on proposals made public. Listeners should look out for the final position which will be detailed in the EU AI Act when it is officially published in the next few weeks.

Letitia Adu-Ampoma on the EU Artificial Intelligence Act [Podcast]

By Adam Turteltaub

Having a compliance champions or ambassadors program can be a great boon for the compliance program, if you keep the champions engaged. Unfortunately, that doesn’t always happen. If not managed properly your champions may end up sleep walking through the job.

In this podcast, Matt Silverman, author of the book The Champions Network and Global Trade Director and Senior Counsel at Viavi lays out several strategies for maintaining the involvement and commitment of your champions network.

To ensure engagement, he recommends remembering that the people who decided to be champions did so for a reason. It may be for a wage stipend or for altruistic reasons.  Tapping into that motivation is essential.

On an ongoing basis it’s important that they see the impact of their work on the organization and their own career. That means sharing outcomes, as best you can, and providing them with access to development opportunities. These could be specific to deepening compliance expertise or as broad as developing business and soft skills. Whichever you choose, it is a way for them to see what’s in it for them.

Give them an opportunity, as well, to be recognized for their work, whether that’s an official recognition by the CEO or an opportunity to interact with leadership. Remember, appreciation can be a powerful reward.

And, of course, make sure there is actual work that they need to do as a part of being a champion. Having the title alone is not enough.

Listen in to more about how to create engaged compliance champions.

Matt Silverman on Keeping Compliance Champions Engaged [Podcast]

By Adam Turteltaub

Mergers and acquisitions create stress, opportunity and risk both for the organization and the compliance team. In this podcast, Sergio Leal, who until recently was head of M&A compliance at Ericsson along with Jan Sprafke, the company’s chief compliance officer, share their advice for compliance professionals in the midst of a transaction.

They stress that the compliance team needs to be involved during the entire lifecycle, from target identification to due diligence to post-acquisition integration. This will help the organization avoid unanticipated liabilities and risks.

To ensure success the compliance team needs to be embedded in the M&A team. Meet with the stakeholders regularly to ensure you are aligned with their processes. When you do, remember that compliance is just one piece of a very complex puzzle.

Be prepared to move quickly. The DOJ amnesty program for issues discovered in an acquisition has a rapidly ticking clock.

At the start of an acquisition or merger, they recommend focusing on three areas:

 	The ultimate beneficial owner
 	The operations of the business
 	The already existing compliance program, if any, and internal controls

Be especially vigilant if the acquired entity had some government ownership or government contracts. And, be very diligent if there is not a compliance program already in place.

Listen in to learn more about how to be an integral part of mitigating the risks of mergers and acquisitions.

Sergio Leal and Jan Sprafke on M&A Compliance Due Diligence [Podcast]

By Adam Turteltaub

To quote CMS, “The Open Payments program is a national disclosure program that promotes a more transparent and accountable health care system. Open Payments houses a publicly accessible database of payments that reporting entities, including drug and medical device companies, make to covered recipients like physicians.”

For this transparency to work, though, it’s important for the data to actually be used. Kelly Cooper (LinkedIn), Compliance Specialist at UF Health Shands Compliance Services, reports that too often it isn’t. There is a downward trend of providers reviewing the data collected, she reports, due to lack of awareness of the program and why it matters.

That needs to change. Physicians and the hospitals that employ them are now required to post a notice for patients about the Open Payment system and how to access it. This will likely lead to more questions from patients and the need for providers to monitor the data more closely.

So what should compliance teams do? She recommends looking at training, awareness and policies. In addition, be sure that the profiles of covered individuals are correct and up to date.

And, be prepared to navigate the dispute process. It can be a long one, but there are shortcuts.

Finally, she urges compliance teams to use the data to get a better handle on staffing, credentialing, what the payment trends are and any red flags.

Listen in to learn more about what the Open Payments program is and how your compliance team should be working with it.

 

Kelly Cooper on Open Payments [Podcast]

By Adam Turteltaub

The 2024 CMS Medicare Physician Fee Schedule extends no less than ten different pandemic flexibilities related to telehealth. In this podcast, Randi Seigel, partner and Jared Augenstein, managing director, at Manatt take us through all of them, including in-person visit requirements, audio-only services, physician supervision and opioid treatment.

They also address:

 	Changes in the structure of the telehealth services list
 	Changes to payment by place of services
 	Remote psychological and therapeutic monitoring
 	Enrollment and revocation
 	A new opportunity for payments for social needs of Medicare beneficiaries

Listen in to learn more about what’s new, what’s the same, and what will sunset at the end of 2024.

Randi Seigel and Jared Augenstein on the CMS 2024 Medicare Physician Fee Schedule [Podcast]

By Adam Turteltaub

Effective investigative interviews are both important and sensitive. To get some pointers about how to conduct them properly, we turn in this podcast to Wendy Evans, Senior Corporate Ethics Investigator at Lockheed Martin. Wendy is also an instructor for the SCCE Fundamentals of Compliance Investigations workshops.

She recommends starting by doing your homework. Before you talk with anyone, whether a possible witness or the subject, get all the information you can from the reporter. Then, review it to see if it includes the what, where, when, why and who. If you don’t have all that information, take the time to find it since it can identify what the potential motivation behind the incident was.

With that information in hand, check your case management system to see if any of the parties were involved in previous reports. Follow that by notifying HR and the subject’s manager that you will be conducting an interview. They may have important insight.

Think through what other evidence you may need for the investigation, including expense and audit reports.

If you are going to conduct the interview remotely, she offers four pieces of advice:

 	Be sure to schedule it appropriately. Sending a meeting request on a Friday for a Monday meeting can create an entire weekend of unnecessary stress for the individual.
 	Mark the meeting request as private so you, and they, don’t have to worry about others seeing it.
 	Ensure that the person has video and a private place to talk.
 	Always include your phone number in case a technology glitch gets in the way.

At the time of the interview, don’t just jump into the questions. Take time to build some rapport. This will help reduce the stress level.

Then, when you start asking questions, begin with broad ones -- “tell me about your work” or “what were your last three business trips?” --  that aren’t simple yes or no. Then, over time, move in to more narrow, specific questions.

When it’s time to get to the hard questions, help the subject prepare themselves psychology. Preface then by saying something along the lines of, “I have to ask you a tough question.”

When concluding the interview, ask: Is there anything else I should know but didn’t ask you? That can prompt the sharing of additional information.

Finally, be sure to thank them for their time and cooperation. Be sure to also reiterate what the investigation process is and what they can expect next.

Listen in to learn more, and, maybe, join her at an upcoming Fundamentals of Compliance Investigations workshop.

Wendy Evans on Investigative Interviewing [Podcast]

By Adam Turteltaub

Matt Kelly (LinkedIn), Editor and CEO at Radical Compliance is a close watcher of all things compliance, and in this podcast he shares his take on both the top stories of 2023 and what he sees in the cards for 2024.

FCPA

On the Foreign Corrupt Practices Act front, he noted a change in enforcement. While the volume of resolutions declined on the DOJ side, the SEC has remained very active.

Perhaps most notably, the Albermarle case had an interesting twist. The way the company did business was changed dramatically as a part of the settlement, he reports, with a restructuring of its overseas sales and the end of the use of third parties. He speculates this may be the start of a new trend in which monetary penalties are accompanied by required changes to the way companies do business.

Also of note in FCPA was the announcement by Lisa Monaco at the SCCE Compliance &amp; Ethics Institute of a leniency policy in mergers and acquisitions. Because of the relatively short timeline for finding and disclosing problems, there is a strong incentive for organizations to involve the compliance team early and deeply in these transactions.

SEC Cybersecurity Rules

The July SEC rules on disclosures of cyber incidents require firms to disclose an incident within four days. Companies will need to describe the nature, timing and material consequences. That will increase the importance of thorough and prompt cyber materiality assessments, as well as both quantitative and qualitative impacts.

Greenhouse Gas Disclosures

The SEC’s proposed rule on greenhouse gas disclosures is now the longest and most commented rule in history. It also has not been finalized while, in the meantime, both California and Europe have passed their own laws.

The rule is likely to be very complex and impose a significant burden on companies.

Healthcare

The biggest news he saw in 2023 was the new General Compliance Program Guidance issued by the Office of Inspector General at HHS. The document makes it clear that it expects a fully independent compliance program. As the document states:

The compliance officer should:

 	report either to the CEO with direct and independent access to the board or to the board directly;
 	have sufficient stature within the entity to interact as an equal of other senior leaders of the entity;
 	demonstrate unimpeachable integrity, good judgment, assertiveness, an approachable demeanor, and the ability to elicit the respect and trust of entity employees; and
 	have sufficient funding, resources, and staff to operate a compliance program capable of identifying, preventing, mitigating, and remediating the entity’s compliance risks.

The Future

Looking to the future he asks if others will be as supportive as the OIG at HHS.

He also points to other things to watch such as the Foreign Extortion Prevention Act, the PCAOB’s extremely controversial NOCLAR proposal and SEC v. Govil, which could eliminate disgorgement in many cases.

Li

Matt Kelly on the Top Compliance Stories from 2023 [Podcast]

By Adam Turteltaub

We all want the compliance team to be approachable. It would be ideal if, when people thought of compliance, they had positive, maybe even warm and fuzzy, associations in their mind.

But, how do we get there? For BroadPath, a friendly blue koala was the answer.



In this podcast, Jaime Watkins, the compliance officer there, explains that she drew inspiration from the Basic Compliance & Ethics Academy and an exercise that called for creating a compliance mascot. Back at the office she created a contest among employees to create a mascot as a part of the company’s celebration of their compliance and ethics week. A winner was selected, and, with the help of the marketing team, the blue koala was born.

Since then, the furry critter has been a regular part of their training, newsletter and is used everywhere that they can, even sometimes straying to the activities of other groups in the company.

The impact of the koala has been enormous. People enjoy seeing variations of how it is dressed up for holidays and it even plays a role in regular compliance trivia contests.

Listen in to learn more about how a mascot could help your compliance efforts.

Jaime Watkins on Creating a Compliance Mascot [Podcast]

By Adam Turteltaub

Decades ago, while at a bit of a career crossroads, I was thinking of making a dramatic change and moving halfway around the world. I was talking it through with a friend who said that one day he asked himself whether he wanted to have a successful career or an interesting one. He realized that interesting was more important to him. That decision led him from Missouri to New York to Hong Kong, Singapore and Thailand, where he ended up enjoying great success.

Ricardo Weffer, Group Ethics and Compliance Head of Al Dahra, has had a similar career journey that ranged from Venezuela to Dubai with countless points in between.

In this podcast he shares his almost two decades of work in compliance and anticorruption in Latin America, the Middle East, Sub-Saharan Africa, Central Europe and Asia. A lawyer by training, he has worked in energy, banking, tobacco, logistics and agriculture.

Despite all this variety, both in geography and industry, he shares that there are professional commonalities wherever he has gone. These include great compliance and business leaders who stand for what is right and are willing to fight for it. He has also found, happily, that, no matter what the industry, companies are mostly made up of real, hard-working, well-intentioned people driven by values who want to do the right thing.

What wisdom does he have for those thinking of having a global career?  He offers three pieces of advice:

 	Be adventurous and open to new experiences.
 	Be willing to be taught.
 	Enjoy it. Working and living abroad can be tough, but the rewards are worth it.

Listen in to learn more, including some inspiring words about the impact of compliance professionals.

Ricardo Weffer on a Global Career in Compliance [Podcast]

By Adam Turteltaub

Compliance professionals can face a lot of resistance in the course of their work: leaders who don’t have the time, budget limits, managerial indifference, and even outright hostility. But, sometimes the impediments are inside us.

In this podcast, Kristy Grant-Hart, CEO of Spark Compliance Consulting and author of the new book Your Year as a Wildly Effective Compliance Officer, points out that sometimes we get in our own way. It’s just easier for us to see what the external blocks are than it is to see those we create for ourselves.

Overcome them, she argues by trusting your own value. Ask for what you want, and don’t trust that others will see the need. And, when you do ask, be sure to make clear what value the compliance program provides.

She also cautions against falling into Imposter Syndrome and feeling as if you don’t belong in the room. Sitting there quietly doesn’t help, in fact it hurts by giving others the impression that you and the compliance team are not adding value. Instead, speak up at every meeting so that you can be perceived as a contributor.

On the personal level, set goals for yourself. Pick an area to deepen your expertise and another to grow personally, such as in speaking publicly or improving your productivity. Also, look to growing your network. Plan on attending in-person meetings and then follow up with the people you meet there. Don’t just make them another entry in your Outlook contact list.

When it comes to those external barriers, she advises not taking push back personally because most often it isn’t personal. People have other commitments.

In fact, look at why they are pushing back and evaluate if the criticism is fair. If it is, then adjust your efforts. If it isn’t, let it go. Not everyone is going to get along with you.

Finally, she discusses how to ensure you don’t let work take over your life. Reserve time for family, friends and your passions, and keep those commitments. When it comes to after-hours emails and texts, don’t answer them if you don’t have to, or if you do, send a delayed respond. That way people learn you won’t be responding 24/7/365.

Be considerate, too. If you think of something in the evening and want to get a note out that isn’t urgent, be sure to let the recipient know they don’t need to respond right away.

Listen in to learn more about how to clear your internal path and become your own best ally in compliance.

Kristy Grant-Hart on internal Barriers to Success [Podcast]

By Adam Turteltaub

We are starting a new year of Compliance Perspectives podcasts by going back to basics with an episode designed for those who are charged with starting a compliance program. While the conversation is directed to this audience, there are some good reminders even for established programs.

Providing guidance are Pam Cleveland, Compliance Officer – Medicare Advantage for UCLA Health FPG and Megan Grifa, Senior Director, Compliance at Sidecar Health.

So, if you are charged with launching a program, where do you begin? They advise starting by taking the time to develop a work plan that outlines your compliance program elements. Look to see what the regulatory requirements are for the business you are in and make a catalog of them. That, in turn, will help you set the objectives of your program.

Next, take the time to tailor those requirements to the unique aspects of your organization. To do so, first spend time with operations to understand their level of knowledge, processes, resources and documentation. That will help you prioritize what needs to be done.

Take the time also to gain the support of leadership. They may need education in everything from what a compliance program is to the specific requirements of your situation. One very effective technique is bringing them examples of non-compliance in your industry and the consequences of it.

On an ongoing basis, follow the seven elements of a compliance program and make sure that you prepare your colleagues for the fact that changes happen. Law and regulations evolve, and the compliance program must do the same. It will help things go a bit smoother when you have to institute a new direction.

Listen in to learn more about the essential steps for starting a compliance program.

Pam Cleveland and Megan Grifa on Starting a Compliance Program [Podcast]

By Adam Turteltaub

When compliance professionals discuss AI most of the conversation tends to focus on the risk.  Frank Orlowski (LinkedIn), Founder and President of Ation Advisory Group, though, is far from all gloom and doom on the topic. In fact, he believes AI can be an asset to compliance programs.

AI, he explains, can be of great value for compliance any place where there are large amounts of transactions that need to be monitored and checked. Two notable examples are travel & entertainment and accounts payable/vendors. AI is very useful for identifying outlier transactions that could be a sign of trouble.

In manufacturing, it can be very helpful in monitoring materials being used. AI can also be helpful, he believes, in ESG efforts.

But, there are limits. AI is not ready for handling contracts, he argues. It is also chronically deficient when it comes to addressing the gray areas of ethics and fairness. There it’s important for compliance teams to work with the business unit closely to ensure decisions are adequately documented and AI does not make decisions that would be regrettable from an ethics perspective.

Listen in to learn more about how AI could help your compliance efforts.

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