Compliance Bricks and Mortar for January 31

These are some of the compliance-related stories that recently caught my attention.

Five Golden Rules of What Works – The Internal Marketing of Compliance by Tom Fox

I am attending the ACI Foreign Corrupt Practices Act (FCPA) Boot Camp in Houston. … One of the presentations was on how to tell your compliance story. It presented several interesting aspects of how to not only communicate your internal compliance story but how to also market compliance within your organization. Céline Gearson, Chief Ethics and Compliance Officer at Cameron International, had an interesting perspective on how she internally markets her compliance function. She termed these as “The Five Golden Rules of What Works”.

1. Socialize, Socialize, Socialize
2. Communicate metrics and near misses
3. Create engagement and excitement
4. Become a marketing guru and IT expert
5. Embed your initiatives into business processes

Did Dennis Rodman violate the FCPA? By Richard L. Cassin in the FCPA Blog

Among the more than $10,000 in gifts Dennis Rodman delivered to North Korea dictator Kim Jong Un in Pyongyang this month were “hundreds of dollars’ worth of Irish Jameson whiskey, European crystal, an Italian suit, a fur coat, and an English Mulberry handbag for Kim’s wife, Ri Sol-ju,” the Daily Beast said Friday. The U.S. government is now investigating whether Rodman violated the law against importing luxury goods into North Korea.

Keep emergency plans updated, or face disastrous consequences from regulators in Investment News

Financial advisory firms need to think seriously about disaster planning and should be conducting annual tests of their preparedness plans if they want to stay out of hot water with regulators. Each year, registered investment advisers need to document the testing of their continuity plan, as well as any updates to these plans, Les Abromovitz, a senior consultant at National Compliance Services Inc., said at a pre-conference session at TD Ameritrade Institutional’s national conference in Orlando on Wednesday.

SEC’s turf threatened, Commissioner Michael Piwowar says by Dina ElBoghdady in the Washington Post

In one of his first public speeches since joining the SEC in August, Republican Commissioner Michael Piwowar said that the Financial Stability Oversight Council is “reaching into the SEC’s realm” and posing “an existential threat” to the agency and other regulators. The council, also known as the FSOC, was charged by Congress with heading off risks to the financial system. It consists of regulators from the Federal Reserve, the Federal Deposit Insurance Corp. and others — including the SEC. Each of the top regulators on the council has a voting member, and for the SEC, that’s been the commission’s chairman.

Clifford Chance Adopts Continuous Improvement Program by Ron Friedmann in Prism Legal

This week Clifford Chance, one of the largest law firms in the world, published a white paper called Applying Continuous Improvement to high-end legal services.  I view it as a potential turning point in BigLaw. A few other law firms, especially Seyfarth Shaw with SeyfarthLean, have promoted process improvement, a sibling of continuous improvement.  But Clifford Chance is a Magic Circle with much bigger throw weight than most firms.

Facebook debunks Princeton study in Flowing Data

Researchers at Princeton released a study that said that Facebook was on the way out, based primarily on Google search data. Naturally, Facebook didn’t appreciate it much and followed up with their own “study” that debunks the Princeton analysis, blasted with a healthy dose of sarcasm. They also showed that Princeton is on their way to zero-enrollment.