When’s the last time you heard the question, “Do we really need a corporate code of conduct?” asked in your company, if ever? And do you react with surprise or even a bit of annoyance as you read it here, thinking it’s stupid to even ask such a thing in 2014? Perhaps it is. Whether […]
Carole Switzer
Posted inRisk Management
Playing the Game of Risk in Workplace Education
In his acclaimed book, “A Theory of Fun for Game Design,” Raph Koster says: “Fun from games arises out of mastery. It arises out of comprehension. It is the act of solving puzzles that makes games fun. In other words, with games, learning is the drug.” Koster, a gaming industry thought leader, is focused on […]
Posted inUncategorized
Retuning Compliance
We hear a lot about the challenges of compliance in today’s business environment. In articles and speeches every day, experts talk about voluminous requirements, complex and conflicting obligations, fast-paced change, and lack of information—and we nod our heads in agreement and commiserate with each other about how hard our jobs are. We’ve been dancing to […]
Posted inInternal Controls
The Battle to Balance Vigilance and Suspicion
While they would never utter the words “Why bother?” aloud, and even suggesting they might think it is bound to be controversial, frustrated financial services professionals can be excused if they occasionally feel this phrase forming in their minds when thinking about their role in the ongoing battle against money laundering. After all, the magnitude […]
Posted inUncategorized
The Fine Art of Knowing Your Customer
Who knew that the art of anti-money laundering (AML) compliance had so much in common with the science of spotting fake paintings? Art forgery, which the FBI has estimated generates more than $6 billion annually, represents a big and decidedly criminal business. This is the case despite the fact that fine arts sleuths can borrow […]
Posted inFrom the Archive
Analyze This: The Value of Business Risk Assessments
Therapy is difficult to define and relatively easy to avoid. That’s a problem when it comes to creating and sustaining an effective anti-money laundering (AML) capability with a robust business risk-management program at its core. Just ask companies whose AML programs remain in need of serious treatment. Or ask a comedian. “I’ve been in therapy,” […]
Posted inUncategorized
The Complex Mechanics of Money Laundering
In Hollywood, money launderers tend to operate in an audience-friendly way; viewers can easily peer into their clever but not overly complex schemes. In Steven Spielberg’s movie “Catch Me if You Can,” we watch raptly as Leonardo DiCaprio’s phony pilot launders his ill-gotten gains by swiping a Pan Am logo from a toy model, affixing […]
Posted inFrom the Archive
Preventing Retaliation Starts With Promoting a ‘Speak-Up’ Culture
What’s the first thing that comes to mind when I say retaliation? If you’re like most governance, risk management, and compliance (GRC) managers—and like most people, period—your brain probably churned out “whistleblower,” “fired,” or maybe even “corporate scandal.” If so, you would fail this word association quiz (and you would be in good company). It […]
Posted inAnti-Bribery
Brad Pitt: The New Anti-Corruption Compliance Officer
Anti-corruption compliance efforts are rarely, if ever, as easy as a-b-c. However, these endeavors would be much easier and more effective if more companies understood—and deployed—their ABCs. “ABC” refers to anti-bribery and corruption analytics, which are statistical techniques that comb through massive amounts of data and sniff out unusual patterns, questionable transactions, and compliance risks […]
Posted inAnti-Bribery
Finding the Corruption Needle in the Haystack
Beryl Markham was a 20th Century female adventurer and one of the first pilots to fly solo and non-stop across the Atlantic (she did it from east to west against prevailing winds). Markham also knew how to turn a phrase. “The way to find a needle in a haystack,” she once said, “is to sit […]