- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Kyle Brasseur2023-05-01T16:22:00
Any compliance officer will tell you the best way to assess the risk of a certain matter is to think about it from a regulatory perspective.
“‘What would the Department of Justice think if we did this? Would this violate any laws or restrictions?’” If the answers to these questions aren’t clear, it’s often advised to err on the side of caution.
Seagate did not when it decided in 2020 to continue selling hard disk drives to Chinese telecommunications giant Huawei after the latter had certain export restrictions placed on it by the Commerce Department. The data storage company was fined $300 million—the largest stand-alone administrative penalty in the history of the Bureau of Industry and Security (BIS)—for this miscalculation.
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A new strike force co-led by the Department of Justice and Commerce Department made an impact when charges against a former Apple engineer for theft and attempted theft of trade secrets were included as part of its first enforcement actions.
Seagate will pay the largest stand-alone administrative penalty in the history of the Commerce Department’s Bureau of Industry and Security for violating export control restrictions against Chinese telecommunications giant Huawei.
When making anti-regulatory decisions, a board is expressing its real risk appetite. This can be frustrating, even bewildering, for compliance professionals, especially when rules are clear and explicit in their expectations.
Top-of-mind issues addressed at Compliance Week’s Third-Party Risk Management & Oversight Summit, held June 3-4 in Atlanta, included safe deployment of artificial intelligence, assessing vendor viability and sustainability, understanding the role of procurement in risk ranking, the intersection (or lack thereof) between data privacy and cybersecurity, and many others.
Anne Morriss, co-author of “Move Fast and Fix Things,” advises compliance officers to tap into curiosity, communicativeness, and comfort with discomfort to build organizational trust, fast.
Regulators and government agencies often speak to the value of empowered corporate compliance programs to advancing their mission. Why not practice what they preach by empowering compliance among their own ranks?
