Jose Tabuena

As compliance programs must deal with growing amounts of data, they need tools to help separate true risks from background noise. Jose Tabuena examines.

How can internal audit support disruptive opportunities while monitoring for emerging risks coming from the Internet of Things? Columnist Jose Tabuena discusses these challenges.

The time to discover when your data breach incident response plan actually works is not in the middle of data breach. Jose Tabuena offers some insights on how to make sure that the incident response plan in place is actually up to the task.

The Department of Justice is poised to consider benchmarking as a criteria for determining how far certain companies have failed to enact adequate internal controls against wrongdoing. But what are the benchmarks for benchmarking itself? Jose Tabuena reports.

Jose Tabuena explores how companies and, specifically, chief compliance officers can demonstrate the effectiveness of their compliance programs and be seen as creditworthy in the eyes of the U.S. Sentencing Guidelines.

As regulators such as FINRA increasingly view culture as a factor when determining wrongdoing and punishment, building a strong culture is taking center stage. Jose Tabuena reports.

Image: Inside, CW columnist Jose Tabuena examines the power of data analytics and predictive models to assess compliance effectiveness and encourage employees toward acting responsibly, thereby ensuring an ethical workplace. But, Tabuena advises, keep in mind that predictive models only yield benefits if used appropriately.

Do compliance programs make a difference? Post-mortem reviews of compliance failures typically raise the question as to whether the cause of the failure is due to a rogue bad actor or a failure in controls. It may be both; a lack of compliance controls allowed or even enabled the rogue employee to engage in the misconduct as part of a culture that lacked transparency, accountability, and a tradition of speaking up.

Board audit committees and compliance professionals should review new compliance guidance provided in a recent speech by assistant attorney general Leslie Caldwell, chief of the U.S. Department of Justice’s Criminal Division. Along with the DoJ’s appointment of a “compliance counsel” this guidance presented so-called “metrics” to apply when evaluating programs for effectiveness. Columnist Jose Tabuena clarifies the misconceptions surrounding compliance program evaluation and measurement, and how internal audit can help make such reviews more robust.