This week’s guest is Lindsay Sweeney, Senior Manager of Communications at K2 Integrity, a risk, compliance, investigations, and monitoring firm. She graduated with degrees in journalism and history and was convinced that her career would be in either of those industries. However, she started working in a small shop whose clients were mostly associated with fintech; she would eventually join K2 Integrity. She joins Tom Fox to discuss how you can use social media and communications to drive home internal messages and get your message and brand out to your clients, customers, and the compliance community.  At K2 Within her first six months at K2 Integrity, the company expanded their presence in the media with a major financial crimes practice and merged with a financial integrity network in DC. From there, they kicked off a rebrand, which was both challenging and easier to do remotely due to the pandemic. She tells Tom, “It wasn't just a matter of changing our name in certain places,” she shares. “It was a matter of resetting how we think about ourselves and how we talk about ourselves, not just to clients, but also how we position ourselves internally.”  Surprise! Tom asks Lindsay what the biggest surprises she’s had were like. “I don't know if [it was] a big surprise or more like little surprises along the way, but I've come to realize one as a communicator there is no such thing as overcommunication,” she responds. “Keeping people in the loop is not just beneficial for making sure that everyone knows where the steps are along the way, but you're going to get a different perspective from someone… that's going to change the way you do things… maybe you'll find a new way to do something that you wouldn't have previously thought of.” The Evolution of Content Marketing Lindsay believes that personalization and targeted information in content marketing is going to become bigger; it was already in the works, but the pandemic has accelerated the process. Additionally, there will be increased focus on bite-sized content to accommodate the attention span of people at home. Resources Lindsay Sweeney on LinkedIn

Innovation in Compliance with Tom Fox

Social Media and Communications with Lindsay Sweeney

Amii Barnard-Bahn, C-Suite Coach and Consultant, is Tom Fox’s guest on this week’s episode of the Innovation in Compliance Podcast. She is a compliance professional, an author, and a key speaker. Amii joins Tom to talk about her new book, The PI Guidebook: How the Promotability Index® Can Help You Get Ahead in Your Career, and how leaders can create a healthier workplace environment for their employees. How The PI Guidebook Helps Workplace Cultures Amii is a firm believer in the concept of radical self-reliance, especially in your career. She is a big advocate for employees learning how to own their jobs and thinking of their responsibilities surrounding their careers differently. Amii has created a framework within the PI Guidebook that helps them with this, and she has divided the framework into five key elements: self-awareness, external awareness, strategic thinking, thought leadership, and executive presence. Becoming efficient in these disciplines will go a long way at keeping you from becoming expendable. "You do these things [and] you're going to keep your career title, would be the best in that role, and you'll always be needed," Amii tells Tom. Who Can Use This Guide? Amii's Guidebook is applicable to anyone who wishes to start the process of their own self-assessment. Use it for yourself to grow a leader mindset; it can also help individuals in nonprofits or governments understand their client's perspectives, as well as how companies and organizations work. Young people reading the Guidebook will find advice that Amii wishes she had when she was their age. One key piece of advice she shares is how important networking is to your professional relationships. "What matters is 'do you play nice with others'," she stresses. The Need for The PI Guidebook Amii is certified in a range of assessments, but she found over time that there wasn't any assessment on the market that put control in the individual person's hands regarding their own self-development. The assessments do not give companies any ability in helping their employees in an impactful way. She created the PI Guidebook to counteract that. "It's much more powerful if you can evoke people's self-inquiry and curiosity about their own development," she remarks. Her guidebook helps create a dialogue between employer and employee. The employee can self-assess and the employer can say what else the employee may need to work on. It builds a rapport between them.  Starting The Promotion Conversation Tom asks Amii to give tips on employees asking for promotions Amii advises never bringing up promotions when your manager is sharing your performance review. Picking a quiet time when they are relaxed or want to chat is better. It's especially important to give them a heads up that you wish to speak with them and what you wish to speak about. Talk about projects that you might be interested in working on and express a desire at wanting to take on new challenges within the organization.  Resources Amii Barnard-Bahn | LinkedIn | Twitter The PI Guidebook

The Promotability Index with Amii Barnard-Bahn

Debbie Mrzaek, President of The Sales Company, is Tom Fox’s guest on this week’s episode of the Innovation in Compliance Podcast. She has spent her career helping individuals and companies around the world as a sales consultant helping them develop good customer relationships. Debbie joins Tom to talk about sales processes and what compliance professionals can learn from sales personnel.   Active Listening and Communication: The Key To Success in Sales Active listening is the key to success in sales, as the sales process is all about communication. Knowing when to speak and when to be quiet is vital, Debbie stresses: “If you’re talking more than 60% of the time, shut up. You’re not learning anything; you’re not getting any new information.” Learning to ask open-ended questions and allowing the other person to do most of the talking will go a long way. Anyone can learn the skills of a salesman, and you don’t have to be extroverted or a social butterfly to be successful in sales. All you need to do is be able to carry conversations and have genuine care for your clients.   A Proper Sales Forecast A proper sales forecast isn’t one that’s done only once a year, but rather every day. Done this way, it drives the sales process further and also improves time management. Sales professionals can see at any point where they did well or where they went wrong. “Tackling the numbers, really understanding what they are, keeping up with them every single day, and knowing where you stand...and where you have shortcomings [can help immensely],” Debbie says. Tom adds that assessing your risk, and assessing them annually, as well as monitoring them and then adjusting your risk strategy where needed is also important.    Relationships are Key The traditional sales model has the sales professional go out and acquire the potential client then turn them over to the inside sales customer. This approach, Debbie remarks, has its flaws because the relationship the sales professional built with the client ends up being tossed over to a stranger. Relationships are a key part about sales. “We want to establish relationships where people can come back to us again and again,” Debbie says. She talks about the third sales model which she calls the flexible sales process. In this model, the sales professional acquires the client but gets to maintain the relationship whilst working closely with the inside customer service people. Everyone in the sales department is working together as opposed to individual silos with poor communication.   Improving Your Sales Model For individuals established in business, improving the sales model will follow the lines of assessing what’s already been done in the sales department. It involves asking yourself questions like how long it took to close an opportunity with a client and whether or not that client has bought from you more than once. Sales personnel can then use that information when they’re forecasting what they want to do in the future. Tom remarks that these concepts are applicable for in-house compliance professionals as well.   The Impact of COVID-19 and What’s Next The pandemic has impacted the approach to sales, Debbie tells Tom. Going forward, people will decide how they want to connect and communicate with sales professionals, whether in-person, virtually, or a hybrid of both. Debbie stresses that sales professionals have to have conversations with each prospect about this because they need to know what their clients want. Sales in the future will continue to see more innovation with respect to technology and the availability of data. Salespeople are going to learn how to use data like AI. She also believes that these kinds of technologies will be more user-friendly in the coming years.   *Check out Smarsh Advance, which will be held on November 9th. For information or to register, click here.*   Resources Debbie Mrazek | LinkedIn | Twitter The Sales Company  

What Compliance Can Learn From Sales with Debbie Mrazek

Tom Fox welcomes back Alexander Dill on this week’s episode of the Innovation in Compliance Podcast. Alexander is a lecturer at UCLA, as well as an author and advisor, specializing in financial regulation, risk management, and compliance. Alexander and Tom talk about anti-money laundering and the key problems compliance professionals encounter. The Importance of Compliance Ratings Compliance Systems Compliance rating systems were created to measure accuracy and integrity. After the events of Enron and WorldCom, there was a general criticism of credit rating agencies. Moody's Investors Service, where Alexander spent a considerable amount of time working, got a great deal of that criticism due to the organization's poor ratings performance and its lack of fraud rating. Moody's wanted to continue to self-regulate as opposed to being regulated by the global regulators, and so the creation of these compliance systems helped with that. Alexander explains that the initial work that was done with respect to the ratings systems, helped lay the foundation for compliance when it became heavily regulated after the financial crisis of Dodd Frank. The Compliance Regulators Tom asks Alexander to explain the different types of regulators and what OFAC is. The main regulator for compliance is FinCen, which is the Financial Crimes Enforcement Network. FinCen is the primary rule making authority but delegates supervisory and examination authority to other agencies. Alexander goes on to list the other regulatory agencies. The regulatory agencies overlap, however the conflict that arises is that their objectives often do not align. "Banking agencies are focused on safety and soundness, and the law enforcement authorities spearheaded by FinCen focus on the law enforcement objective, so those don't always come together in a uniform manner," Alexander remarks.  The Role of Corporate Governance and Risk Management The main role of corporate governance in anti-money laundering is to maximize shareholder welfare. Corporate governance systems are designed to protect franchise value. The systems cover all material risks that arise from conflicts of interest within agencies. Risk management is important to anti-money laundering as it is a component of corporate governance. Alexander stresses that the risk management function should fit into the corporate governance framework to be effective. COVID-19 and Beyond The pandemic has impacted the field of anti-money laundering and compliance in many ways, but perhaps the most notable way is that it enhanced fraudulent schemes. With a great deal of the world's population migrating online, it opened up the pathway for various cyber attacks and cyber related crimes. COVID-19 unfortunately created various opportunities for people to exploit online platforms. Alexander hoped that in the future the Anti-Money Laundering Act that was introduced last year 2020, will begin to bear fruit and that red tech innovation and machine learning will help to curb these issues.  Resources Alexander Dill | LinkedIn | Twitter Check out Professor Dill's book, Anti-Money Laundering Regulation and Compliance here.    Texas Tax rate at 80% of 8.25%

Money Laundering Regulation and Compliance with Alexander Dill

Cecilia Akuffo is Tom Fox’s guest on this week’s episode of the Innovation in Compliance Podcast. Cecilia is a Talent Acquisition Partner who has extensive experience in management, interviewing, recruiting, and social media. Cecilia works in the higher education industry as a Tech Recruiter. She joins Tom to talk about her career, workplace dignity, and what she is looking forward to in the future. Setting The Tone in Talent Acquisition Talent acquisition communications training is crucial in the compliance context because that's where it all starts, Cecilia points out. The first time you look at someone's resume, or the first time you have an interaction with them in the talent acquisition process, you can start to convey your company's values, culture, and expectations. Doing recruiting right sets the tone at the beginning for how you expect individuals to comply within your organization.  The Evolution of Talent Acquisition The main evolution in the world of talent acquisition is that it is its own entity within organizations. In the past, recruitment was not seen as much of a big priority, and companies did not actively invest in that part of their organization. Now, talent acquisition has multiple departments, and companies have recognized the need to focus on getting talent for their organizations. Workplace Dignity  Tom asks Cecilia to talk about her podcast, and why workplace fairness and dignity is important. Cecilia explains that she wanted to highlight companies that normalized their employees coming to work in exchange for a paycheck, but not accepting abuse as part of the package. The companies that perform the best are the ones where the employees feel that the executives reflect the values that they expect of their workers. When fairness is emphasized, a healthy work environment is established. Diversity and Inclusion Along with an emphasis on dignity and fairness, companies need to have diversity and inclusion. Diversity is being invited, and inclusion is valuing whatever contribution you have to offer. "Inclusion is not just having people at a certain level speak… It's also inviting other voices, including those that may not have the same kind of power," Cecilia says. Give everyone an opportunity to have their voice and contribution be seen and heard. What's Next Tom asks Cecilia what is her vision for the podcast network and for talent acquisition. "The most important thing driving me is related to workplace fairness and dignity," she begins. There are many podcasts that focus on diversity and inclusion but not enough that focus on what is truly happening in the working world. Cecilia wants to focus on workplace dignity to bring more attention to the issue.   Resources Cecilia Akuffo | LinkedIn | Twitter Workplace Fairness and Dignity Texas Tax rate at 80% of 8.25%

Talent Acquisition and Workplace Dignity with Cecilia Akuffo

Welcome to this special podcast series, Integrity Matters: Culture, Training and Compliance, sponsored by K2 Integrity. This week I visit with Koby Bambilia, Managing Director, and Tina Rampino, Associate Managing Director. Over the series we have broken down corporate culture, compliance training and communications. Topics included breaking down the big picture on culture, espresso shots of training, skills development and regulatory changes, tailored and risked based training and operational aspects of training. In this concluding Part 5, I am joined again by Tina Rampino who reviews key operational aspects of training, including budget, delivery and more. We began with a discussion of one of the most critical issues around compliance training, but one I believe does not get nearly enough discussion in the compliance community, that being the issue of budgeting. During times of economic stress compliance training budgets are often tightened. Rampino believes this approach needs to be avoided. The reason is straight forward, “investing in training and professional development for employees can save money in the long-run, both operationally and when it comes to regulatory requirements. An institution’s greatest asset is their employees and especially when you’re entrusting them to protect your institution from risk.” This means that if you are providing employees with ongoing training to assist them to continuously refine their knowledge and skills; it will also keep them engaged and incentivized to take compliance more seriously. Moreover, as Rampino noted, “developing and retaining employees is beneficial to financial institutions in the long-run and demonstrates sustainability within the compliance program.” Instead of cutting back on training budgets in general, institutions should assess the training needs as they align with the greatest risk and find ways to deliver the most targeted and relevant training across the enterprise. Rampino advocates several different styles of compliance training. These include, having a “balance of online/in-person training; including independent or self-guided training; as well as hands on training with an instructor.” We concluded with Rampino’s thoughts on regulatory expectations around compliance training. She believes, “Regulators are more interested than ever in seeing that an institution is investing in a sustainable, scalable, and dynamic training program. They want to know that an institution understands their risks and that it demonstrates that with the training that is provided to their employees. Regulators are expecting more targeted and role-based training offerings and that the content is evolving as the risks evolve.” K2 Integrity has developed an online training platform and resource center, Dedicated Online Financial Integrity Network (DOLFIN), to help clients with their training requirements and provide more diverse options for training content and modalities. Find out more about DOLFIN here. For more information on K2 Integrity click here. Texas Tax rate at 80% of 8.25%

Integrity Matters: Culture, Training and Compliance - Part 5: Operational Aspects of Training

Welcome to this special podcast series, Integrity Matters: Culture, Training and Compliance, sponsored by K2 Integrity. This week I visit with Koby Bambilia, Managing Director, and Tina Rampino, Associate Managing Director. Over this series, we will break down corporate culture, compliance training and communications. Topics include breaking down the big picture on culture, espresso shots of training, skills development and regulatory changes, tailored and risked based training and operational aspects of training. In Part 2, I am joined by Tina Rampino who discusses ‘espresso shots’ of training to help facilitate attainable training demands. Texas Tax rate at 80% of 8.25%

Integrity Matters: Culture, Training and Compliance - Part 2: Espresso Shots of Training

Welcome to this special podcast series, Integrity Matters: Culture, Training and Compliance, sponsored by K2 Integrity. This week I visit with Koby Bambilia, Managing Director, and Tina Rampino, Associate Managing Director. Over the series, we break down corporate culture, compliance training and communications. Topics include breaking down the big picture on culture, espresso shots of training, skills development and regulatory changes, tailored and risked based training and operational aspects of training. In Part 4, I am joined by Koby Bambilia to discuss why tailored and risked based training is so critical now. In this episode we went into the weeds of specific tailored and risk-based training. Getting ahead of regulators and ensuring your institution has skills-based trainings is critical. But more than this, regulators now want to see specific risk-based training, tailored to individual needs. This approach is not limited to financial institution regulators but the US Department of Justice (DOJ), Securities and Exchange Commission (SEC), FinCEN, Office of Foreign Asset Control (OFAC) also favor this approach. I asked Bambilia if he could provide some examples from the world of financial institutions and financial services firms. Initially, he noted that an institution cannot have a blanket training without follow-up trainings on specific job functions. Some of the different needs for different employee classifications include bank tellers, who need to know more about cash transactions and regulatory requirements, such as Currency Transaction Report (CTR) and pouch activities. This is obviously different from private wealth managers. Employees in trade finance departments need to know more than others on sanctions and embargoes. Moving on to third party relationships, correspondent banking departments need to know, for example, the red flags for nested accounts. Private bankers, who are covered under the Foreign Account Tax Compliance Act (FATCA), must be trained on the law so they can be more vigilant and aware for detecting tax evasions. The key is that each group requires its unique training and since every institution has a different set of risks, institutions should understand that one form of training cannot fit all situations. Tailored training is a key element and, as Bambilia noted, “a universal one, regardless of the institution’s size, risks, and resources. The example of the examiner saying training is like a burger…demonstrates the need to assure proper and tailored training throughout the institution.” The bottom line is that there is no one training model which will fit all your employees. Bambilia concluded that it “may feel like a heavy lift up front, it can pay its dividends - not just from a compliance perspective but also from an angle of operational efficiencies - you are assuring that your operation and IT staff know what to do going forward. If they know what to do - that will save a lot of pain and effort on their side, but also for you as a compliance officer.” K2 Integrity has developed an online training platform and resource center, Dedicated Online Financial Integrity Network (DOLFIN), to help clients with their training requirements and provide more diverse options for training content and modalities. Find out more about DOLFIN here. For more information on K2 Integrity click here. Texas Tax rate at 80% of 8.25%

Integrity Matters: Culture, Training and Compliance – Part 4: Tailored and Risked Based Training

Welcome to this special podcast series, Integrity Matters: Culture, Training and Compliance, sponsored by K2 Integrity. This week I visit with Koby Bambilia, Managing Director, and Tina Rampino, Associate Managing Director. Over this series, we are breaking down corporate culture, compliance training and communications by discussing topics such as breaking down the big picture on culture, espresso shots of training, skills development and regulatory changes, tailored and risked based training and operational aspects of training. In Part 3, I am joined by Koby Bambilia to discuss the intersection of meeting compliance skill development and regulatory requirements. Texas Tax rate at 80% of 8.25%

Integrity Matters: Culture, Training and Compliance – Part 3: Skills Development and Meeting Regulatory Needs

Peter Baumann is Tom Fox’s guest on this week’s episode of the Innovation in Compliance Podcast. He is the founder of ActiveNav, a company that helps its customers reduce data risk, make better management decisions and comply with privacy regulations. He has been in the information governance field for 30 years both as a publisher and as a content creator. Peter joins Tom to talk about how the disciplines of information governance, and the data industry, relate to a variety of compliance issues. How Information Governance Has Changed The most significant change in information governance, Peter tells Tom, has been its explosion of growth. Companies used to only operate from a singular network, and via a single machine. There was well managed control, and no-one else was able to have access to the information filtered through those single networks and machines. That is no longer the case. With the rise of the internet and connecting corporate networks with each other, the control has collapsed and sensitive data has become more accessible. Being Compliant Through Data Retention Policies Peter iterates that companies need to have a map of their data and what's actually in it. "Until you get there, you're always gonna fall short of meeting any of these privacy regulations because you can't actually say what you've got, where it is, and whether you should have it," he adds. Companies need a top and bottom approach to their data mapping, which lets companies know how to approach these issues strategically. Peter also stresses that senior management need to treat their data as if it's the best asset in their organizations. "Only when those things become a kind of de facto position will organizations start to manage and govern their data appropriately," he tells Tom. Unstructured Data & Eradicating Dark Data Peter explains that unstructured data is data that sits outside of a database environment. The very idea of a database is based on the concept of structure, so any data existing outside of it is unstructured. To get rid of dark data, companies need to have an understanding of what data they have, its nature, size, and where it is stored. That is the first step. The second step is minimization, that is, doing a system cleanup of redundant files or records that are beyond their natural retention policies. The final step would then be to find your sensitive data, understand what it is, then either encrypt or delete it, or move it somewhere else. This will get you to your government's baseline.  The Impact of COVID-19 & Looking To The Future The pandemic has changed how companies approach data as content has become more fragmented now. "The biggest change I'd say, is the shift in both commercial, private, and government towards more collaborative based tools," Peter remarks. He gives the examples of Microsoft Teams and Slack. The downside of these tools however, is that they don't have the appropriate mechanisms built into their platforms to ensure that they are complying with governance. With respect to the future, companies should expect to see penalties and fines start to drift down to mid-market and eventually smaller businesses. "Ignorance and the lack of policy systems and preemptive planning won't be tolerated as an excuse by the courts," Peter warns. The tools and the experience are out there to ensure that companies are aware of what data they have so they will be expected to comply with regulations and face the consequences if they don't. Resources Peter Baumann | LinkedIn | Twitter ActiveNav Texas Tax rate at 80% of 8.25%

Information Governance and The Data Industry with Peter Baumann

Welcome to this special podcast series, Integrity Matters: Culture, Training and Compliance, sponsored by K2 Integrity. This week I visit with Koby Bambilia, Managing Director, and Tina Rampino, Associate Managing Director. Over the series, we will break down corporate culture, compliance training and communications. Topics include breaking down the big picture on culture, espresso shots of training, skills development and regulatory changes, tailored and risked based training and operational aspects of training. In Part 1, I am joined by Tina Rampino who breaks down the big picture on culture. We began with the basics: that a culture of Compliance is the foundation of an organization’s compliance program. Rampino said it is a measure of how well employees feel empowered to identify, mitigate, and escalate risk within their institution. An institution’s compliance culture is set by an institution’s Board and Executive Leadership team. Their messaging should be continuously reinforced in an institution’s risk appetite statement, policies, training and enterprise-wide communications. A strong compliance culture should be evident at all levels of the financial institution and across all three lines of defense. Rampino detailed some key questions to ask, such as “What is the tone that is set from the most senior levels of the organization? Are employees motivated by doing any and all business no matter the risk? Are they empowered to act with integrity and choose the right business that aligns with their compliance culture?” She went on to relate, “Many institutions have built training and communications programs to help employees understand what the “right business means” – reinforcing an institution’s risk appetite statement, incorporating policies and procedures, and training on red flags and high-risk issues.” She concluded, “A culture of compliance should empower employees, not just in the second line of defense but in all areas of the institution – to think about the risks being presented through their customers, transactions, and products and services and how they can do their part in mitigating risk to the institution.” An effective compliance training program can help to ensure that an institution is regularly addressing new issues and emerging risks. It also helps to ensure that employees have the right knowledge and skills necessary to perform their roles, so they understand the risks within the institution and their business area as well as the consequences of non-compliance. Rampino detailed some of the areas your organization should focus on with the following questions, “Do our training programs match the risks of our institution, and the variety of functions within it?”; “Do our employees have the right experience and training to do their jobs?” and “Are we regularly addressing new issues and ensuring our programs help our teams deal with emerging risks?” In terms of an effective communications program, institutions should ensure robust and recurring communication. “One and done” is not an effective way to deliver communications or develop an organizational culture. A robust program issues clear messages in a recurring fashion. Rampino concluded with some key takeaways on communications. First, institutions that want to create a culture of compliance should issue policy alerts and remind staff of changes. Second, information should then be easily accessible and readily available for employees. Finally, town halls, quarterly newsletters, and even short video messages explaining changes can be effective ways to ensure that all staff members understand what they must do to support the institution’s focus on compliance. For more information, go to K2 Integrity. Texas Tax rate at 80% of 8.25%

Integrity Matters: Culture, Training and Compliance - Part 1: Culture of Compliance

John Lee Dumas, host of the award-winning podcast Entrepreneurs on Fire, joins Tom Fox on the last installment of Looking Back at 9/11 to commemorate the 20th anniversary of the 9/11 attack. He tells Tom how his life changed in that pivotal moment, and the big lessons he learned.  A Time of War John tells Tom that he was in his final year at Providence College, and in the ROTC cadets, on 9/11. When he saw the towers fall, he knew at once that it would change the trajectory of his career. He and his roommate looked at each other and they knew “that our next four years of active duty army experience went from being in the peacetime army to looking like we were going to war.” Within hours they were called to active duty: “We just became officers in the US army during a time of war,” John recalls. Leadership Lessons from the Army Tom asks John what leadership lessons he learned from his time in the army. John outlines three major takeaways that his time in combat taught him: To learn from those who went before. “I learned right at the beginning, I needed to stand upon the shoulders of giants,” he remarks. A good decision now is better than a great decision later. Action is everything. Make the best decision you can with the information you have, take action, then adjust if you need to when you know more. If you discover later on that you made a wrong decision, cut your losses and move on. Don’t compound that mistake by staying in a bad place, John advises. “I kept being willing to pull back and say let's try again, until I finally made a great decision. It took six years to make my first great decision, but that great decision has led to the last 10 years of living the exact life that I want to live.” What Americans Should Remember John wants Americans to appreciate their freedom, because it was hard won. He tells listeners, “So few people have ever experienced what true lawlessness is. And until you’ve experienced that, it's hard to really appreciate what we do have here. But you know, this is a great country and it is the home of the free because of the brave. And I hope that's just something that we will always remember.” Resources John Lee Dumas: Entrepreneurs on Fire | Twitter Texas Tax rate at 80% of 8.25%

Looking Back at 9/11: John Lee Dumas - “I Knew I Was Going to War”

Scott Moritz is Tom Fox’s guest on this episode of Looking Back at 9/11. Scott is the Senior Managing Director at FTI Consulting Risk and Investigations, assisting clients and their outside counsel in managing their response to white collar crime, misconduct and bribery incidents. He is also the host of the podcast series, Fraud Eats Strategy. Scott joins Tom to talk about how the events of 9/11 impacted the FBI. How 9/11 Changed The FBI: Structural and Cultural Ambidexterity 9/11 fundamentally changed the FBI overnight. Scott remarks that for a long time after 9/11, the FBI was primarily focused on the attack on the Trade Center. That was the Bureau’s main investigation, and it was being worked on by all the FBI field offices, and virtually every foreign attache office in the world. Many scholars, through various organizational studies and surveys, assumed that the FBI would have created simultaneous frontline structures and processes to balance their two competing missions: national security and law enforcement. The scholars also posited that perhaps the FBI would engage in cultural ambidexterity, which would be to refuse to take on the mission of national security altogether. The FBI did something altogether unexpected and tackled both.  The Benefit of One Agency “There was this rapid emergence of two clear, but distinct, identities, and eventually, you know, one new unified identity FBI, but some changes where, terrorism cases were centralized at headquarters...This was a big departure from the way that the FBI normally operated,” Scott tells Tom. By staying as a single agency, the FBI had better access to local law enforcement agencies and could take better advantage of defendants with information that could advance the national security mission. A Shift In The Private Sector Tom asks Scott to talk about any changes in the private sector he was personally involved in. The major change in the private sector post-9/11, especially with respect to financial institutions, was the induction of the Patriot Act which also paved the way for other significant changes. Financial Institutions and broker dealers had to harden the security of buildings and supply chains across the country’s infrastructure. There was also the explosion of no fly lists, watch lists and terrorist watch lists. Banks, building owners and brokerage companies had to navigate these systems often, and quickly. Scott was very involved in helping these institutions in their anti money laundering obligations, as well as their security obligations.  Looking To The Future Tom asks Scott to share some reflections on 9/11, and for the future. Scott remarks that post-9/11, the country was more united and people were more compassionate to one another. The best of humanity in forms of kindness and outpouring of love was seen not just from Americans to each other, but from the rest of the world to America. He hopes that someday he can see that kind of love and unity again.  Resources Scott Moritz | LinkedIn | Twitter Fraud Eats Strategy Texas Tax rate at 80% of 8.25%

Looking Back at 9/11: Scott Moritz - It Changed Overnight

Eric Feldman is Tom Fox’s guest on this episode of Looking Back at 9/11. Eric is the Senior Vice President and Managing Director at Affiliated Monitors, a company that deals with monitoring large and small companies in the government contracting, construction, engineering, manufacturing, and financial services. He also conducts assessments of corporate ethics and compliance programs across many countries. Eric joins Tom to talk about the impact the events of 9/11 had on the role of Inspector General. The Impact of 9/11 on The IG's Role Eric explains to Tom that 9/11 was the most informative time of his career, and the careers of many other Inspector Generals. It was a refocusing moment for everyone. Eric got to work within the oversight function, but as part of the mission he was overseeing. "That focus on mission was it for me," he tells Tom. Eric expresses that understanding the mission helped make him a better Inspector General. IGs all over the world became more concerned with looking at the broader picture of how funds were being used at their agencies to fight the war on terror, instead of the minutiae of looking at time and attendance reporting. The Importance of The IG Now Tom asks Eric to elaborate on how the IG's role rose in prominence post-9/11. Eric explains that government IGs became "part of the team" in different ways. There is more collaboration now across the agencies that IGs oversee. There is also independence: Eric expresses that there must be a balance between collaboration and independence. IGs are especially important as they ensure that the dollars being spent on the war and mission are being spent properly. A Wake Up Call of Unity Eric reflects that 9/11 was a wake-up call for the United States. The country came together, and there was a level of unity and patriotism, as well as a sense of duty that overtook politics. Eric hopes that the people can return to that unity without another catastrophe.  Resources Eric Feldman | LinkedIn | Twitter Affiliated Monitors Texas Tax rate at 80% of 8.25%

Looking Back at 9/11: Eric Feldman - A Wake Up Call

Alex Dill is Tom Fox’s guest on this episode of the Looking Back at 9/11 Series. Alex is a scholar and professor specializing in financial regulation, risk management and compliance. He also has corporate experience in ​​the ethics of business practices in finance, bankruptcy, bond covenants, and debt markets. He joins Tom to talk about The Patriot Act’s impact on responding to terrorist threats. How 9/11 Changed AML Before 9/11, AML regulations were very lax and backward looking. The focus was on prosecuting crimes that were already committed, and prosecuting money laundering, more so than the financing of terrorism. Banks weren’t engaging in meaningful customer due diligence as they felt the process invasive. After 9/11, this all changed. Law enforcement agencies and financial institutions revamped their policies and procedures to take a more preventive approach to AML and financing of terrorism. This led to The Patriot Act. The Financial Response Tom asks Alex if he saw a similar regulatory response with non-financial institutions with respect to Patriot Act AML procedures post-9/11. “There was a huge amount of rulemaking that had to be done,” Alex responds. He adds that public companies adopted customer due diligence, and that it was applied more broadly to different sectors, but with a risk-based approach. Companies now had to file suspicious activity reports, not just banks. Customer identification was also introduced. “The Patriot Act sought to encourage cooperation among law enforcement agencies, and among the financial institutions themselves to share information and obtain information from foreign law enforcement authorities,” Alex tells Tom. The Challenge With The Patriot Act  Alex explains to Tom that there are challenges with the Patriot Act. A major challenge is detecting the financing that goes into these attacks. Funds that finance these actions are sourced from both legal and illegal means, and that is a major issue. The transaction amount can be small, and this might pose a risk to some compliance officers.  Technology in Anti-Terrorism Alex remarks that technology is very important moving forward in the fight against terrorism, as it has changed the way we function in our world. The downside of technology is that it has also helped create some of the compliance issues we have today. Social media platforms have helped to create polarization in the society, and programs like cryptocurrency have been used by criminals for money laundering, and financing terrorism. However, Alex ends with a positive note stating that the AML act of 2020 has been doing the work to help curb these issues. Resources Alex Dill | LinkedIn | Twitter Texas Tax rate at 80% of 8.25%

Looking back at 9/11: Alex Dill - Patriot Act: The AML Response to Terrorist Threats

Innovation in compliance brings you interviews with industry leading experts who are changing the way practitioners approach compliance. Host Tom Fox, the Compliance Evangelist and Voice of Compliance is driving the conversation about compliance into the 2020s and beyond with his focus on innovations for the compliance practitioner and the compliance profession. If you want to learn how to bring business solutions to compliance problems to more fully operationalize compliance, this is the podcast for you.

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Innovation in Compliance with Tom Fox

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