The top compliance roundtable podcast is back with a wrap up with a review of the first year of the Trump Administration and its impact on the compliance profession. Stayed tuned to the end for riffs and rants in this edition.
For Matt Kelly’s musings on Jay Clayton, the PCAOB, government rule-making and the SOX compliance debate, see the following:
8 Compliance Events to Watch in 2018
Clayton, Congress Talk Cybersecurity
The Private Market Stresses Driving SOX Compliance Debate
Framing the Arguments Over SOX Compliance
Treasury Report Eyes SOX Compliance
Regulatory Czar Eyes Agency Guidance
For Mike Volkov’s excellent 3-part podcast series on the Mueller investigation and related blog posts, see the following:
Obstruction of Justice-A Primer
Understanding Special Counsel Mueller’s Authorization
Perspective on the Russian Investigation — The Michael Flynn Plea Agreement (Part II of III)
For the Cordery Compliance client alerts see the following:
EU Conflict Minerals and Metals Regime
Disruptive Technology Start-Ups & The Need For Legal Compliance
New Schrems Case Poses a Threat to International Data Flows?
For Jay Rosen’s post on the new FCPA Corporate Enforcement Policy see the following:
The members of the Everything Compliance panel include:
In this episode, podcast favorite James Koukios returns to discuss highlights from international anti-corruption efforts, enforcement actions and developments highlighted in Morrison and Foerster’s December report. We highlight five developments:
For more information read the full Morrison & Foerster white paper Top Ten International Anti-Corruption Developments for December 2017
In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week.
In this episode I visit with Carlos Ayres, partner at Medea, Ayres and Sarubbi in Sao Paulo. We visit on the past year in anti-corruption enforcement in Brazil and where it may lead in 2018. Carlos discusses the continued fallout from the Odebrecht corruption scandal, across the continent of Latin America with the new anti-corruption laws being implemented in Argentina, Peru and Chile. We also discuss what US and UK companies need to do if they are doing business in those countries to protect themselves.
For more on Carlos Ayres and his firm Meada, Ayres and Sarubbi, check out their website by clicking here.
In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week.
In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week, including:
In this episode Matt Kelly and myself take a deep dive into the weeds of the recent remarks by Neomi Rao, head of the Office for Information and Regulatory Affairs (OIRA), the Administration’s top regulatory review office outlining ambitious plans for more deregulation in 2018 — including efforts to sweep independent federal agencies into her purview and to crack down on the “sub-regulatory” guidance that corporate compliance professionals consume all the time. The talk was given before the Brookings Institute and she touted the 2 for 1 kill order for new regulations the Administration heralded last year and claimed that over 1500 planned regulations had been pulled from review.
For the compliance practitioner, this may all be much ado about nothing or more simply Rao and the Administration is simply Waiting for Godot to arrive as both the SEC and regulations relevant to military, national security, or foreign policy are exempt. New regulations required by statute are exempt.is exempt from the guillotine of which Rao speaks. However, it does cause one to ponder if the 2012 FCPA Guidance and 2017 Evaluation of Corporate Compliance Programs would have been released under this new system of hari-kari.
Matt and I explore the differences be proposing to repeal two rules but not actually repeal them as those proposed repeals must go through the usual public comment and review process. We also discuss how the Administration approach hurts businesses by removing a source of practical guidance from the general public. Think about how the business community clamored prior to 2012 for specific guidance from both the SEC and Justice Department on what constituted a best practices compliance program. Finally, we consider if there is a positive effect at all for business and the American public not be given guidance by the government.
For more information see Matt Kelly’s post Regulatory Czar Eyes Agency Guidance
In this special Supplemental edition Jay Rosen reports on Friday’s SCCE Southern California Regional Compliance and Ethics Conference. The topics he highlights are:
In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week.
In this episode Matt Kelly and I take a deep dive into the absolutely stunning indictment of five former partners or employees of KPMG and one former employee at the Public Company Oversight Accounting Board (PCAOB). Last spring, KPMG dismissed the following: David Middendorf, KPMG’s then-national managing partner for audit quality and professional practice, Thomas Whittle, KPMG’s then-national partner-in-charge for inspections and David Britt, KPMG’s banking and capital markets group for lured the following former professionals from the PCAOB: Brian Sweet, Cynthia Holder and Jeffrey Wada, all certified public accountants with promises of jobs at the accounting firm in exchange for stolen information. Sweet did not make the cut was not hired.
Apparently these three were offered jobs if they provided KPMG with information on the PCAOB’s planned reviews of certain KMPG audits of specific public companies. The six were charged with conspiracy and wire fraud, alleging they repeatedly used stolen confidential regulator information to subvert KPMG’s regulatory inspection process. Even more troubling is the report that Middendorf, Whittle and Britt pressured Holder and Wada to continue providing the information or their jobs were in jeopardy.
All of these six are now facing criminal indictments. We explore what all of this might mean for KPMG, the PCAOB and the SEC. Can KPMG audits be trusted going forward? What type of culture existed that allowed this type of behavior to occur and continue for over two years before it was internally reported. Who else at KPMG knew or should have known about this conduct? What audits are now suspect? What happens if KPMG is found guilty at trial or accepts a guilty plea? Can it continue to perform audits?
Turning to the PCAOB, does it have a revolving door problem? Should it prevent its professionals from going to auditors? How does it assure such confidential information does not walk about the door? For SEC, what is the appropriate sanction against KPMG given the senior partner involvement? Is the SEC investigating other audit firms?
For more reading see Matt Kelly’s blog post Six Charged in PCAOB Inspections Leak
For additional reading see Francine McKenna’s article in MarketWatch KPMG indictment suggests many who weren’t charged knew regulator data was stolen
In this episode I visit with Damon Brenner, partner at Control Risks on the 2018 Control Risk Map. He details some of the company’s findings in the document entitled RiskMap 2018. Jonathan Wood, Director at Control Risks will present to the Greater Houston Business and Ethics Roundtable on the Risk Map this coming Thursday, 25th January, from 8-10 AM at the offices of Marathon Oil, here in Houston. For more information click here.
It is one of the definitive forecast of political and security risk across the globe in the coming year. The top five listed risks for 2018 were:
Each of these areas has full reports dedicated to them and available for download. Further, the Risk Map is broken down by region. The main map covers the countries of the world and provides regional nuance within and across national borders. The Maritime, Kidnap and Travel Risk maps give further insights into Control Risks areas of specialist expertise. In short all of this information is available for any compliance professional for use in helping to assess your annual risks going forward. It is a visual, data and information feast for anyone interested in global risk, in a wide variety of areas.
If you are in the Houston area, the Greater Houston Business and Ethics Roundtable (GHBER) is privileged to have Control Risks present its 2018 Risk Map at our first meeting of the year, this coming Thursday, 25th January, from 8-10 AM at the offices of Marathon Oil, here in Houston. Our presenter will be Control Risks Director, Jonathan Wood, the author of the White Paper on the Number 1 listed risk of the Global Powder Keg, including North Korea. Wood leads Control Risks’ Global Issues practice, on global political, operational, security and integrity risks to multinational organizations in the oil and gas, mining, insurance, financial services, retail, construction and technology sectors. His subject matter expertise encompasses geopolitics, global governance, economic development and transnational security issues. He leads Control Risks’ analysis of transnational terrorism, single-issue direct action, and geopolitics. In short, Wood knows his stuff and he can further educate all who attend the GHBER meeting.
If you are in Houston, I hope you can join us. The information Control Risks makes available is worth it. For more information on the GHBER meetings, featuring Jonathan Wood of Control Risks, go the GBHER website.
In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week.
In this episode, the top compliance roundtable podcast is back with a look at some of the top FCPA, compliance and data privacy/data security issues from 2017 and how they inform what will be the top such issues in 2018.
For Jay Rosen’s post on the new FCPA Corporate Enforcement Policy, see the following:
For Cordery Compliance’s posts touching on these cases, see the following:
Client Alert: Morrisons Data Breach Litigation Succeeds
Client Alert: Carphone Warehouse fined under data breach
For Matt Kelly’s post on this topic, see the following:
Microchip Meltdowns and Vendor Risk
For Tom Fox’s post on the continued internationalization of anti-bribery/anti-corruption enforcement, see the following:
DOJ-Aggressive International Anti-Corruption Enforcement to Continue
Rants follow at the end.
The members of the Everything Compliance panel include:
In this episode Matt Kelly and I take deep dive into the issue of non-GAAP metrics and its implications. We were inspired an article in this quarter's MIT Sloan Management Review entitled, "The Pitfalls of Non-GAAP Metrics" by H. David Sherman and S. David Young. It is fascinating review of this topic, which as the authors note "Lurking within the financial statements and communications of public companies is a troubling trend. Alternative metrics, once used sparingly, have become increasingly ubiquitous and more detached from reality."
In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week. Jonathan Marks joins us to discuss his new Board and Fraud blog.
In this episode, Matt Kelly and I take a look at some of the more intriguing issues in compliance and ethics, FCPA and greater GRC issues in the new year of 2018.
For more on these topics see Matt Kelly’s blog post “Eight Compliance Events to Watch in 2018”
In this episode, I visit with SCCE incoming President Gerry Zack about his new role with the organization. Some of our topics include: his new role with the SCCE, why he took on the challenge of running the world’s largest compliance professionals’ organization; some of his initial observations of SCCE; where the organization will be headed in 2018 and ways for a compliance professional to become involved in SCCE going forward.
In Part II of a two-part series, the top compliance roundtable podcast is back with a review of the new Justice Department’s FCPA Corporate Enforcement Policy.
For Jonathan Armstrong’s posts touching on these issues, see the following:
For some of Cordery Compliance’s writings on these topics, please see:
Rolls-Royce case sends a strong signal
Cease Processing Data Judgment
Mike, Jay and Jonathan are back with rants which follow the discussions.
The members of the Everything Compliance panel include:
In Part II, the top compliance roundtable podcast reviews the new DOJ FCPA Corporate Enforcement Policy.
In this episode, I visit with Keith Read, Advisor to Convercent and Angus Robertson, Senior Vice President for Convercent on some of the key trends they observed in the marketplace in 2017, from the vendor perspective. I found this an interesting perspective as both of these gents spend quite a bit of time listening to compliance practitioner on what their needs are for their organizations. Some of the key trends they observed included:
Data Privacy
A hugely increased focus on data privacy, partly driven by GDPR and partly driven by the increasing size and global reach of our customer base.
Whistle-blowing & Social Media
A genuine recognition of the importance of effective whistle-blowing programs, given that social media now means that people are far more prepared to speak out if they are not happy to speak up. This also brings with it the need for active retaliation prevention, not just a passive ‘shelf’ policy.
Global legislation around ABC
Increasing global compliance-related legislation – new and updated laws such as Sapin II, the UK’s Criminal Finances Act, the Brazilian Clean Companies Act, all utilize similar approaches to the enforcement of anticorruption legislation. This makes developing and implementing a common response strategy can be far more effective, and less costly; moreover, drawing disparate sources of data together - often for the first time - can be eye-opening.
Big Data and Analytics
Companies are focused more than ever on data, reporting and benchmarking. How do I as an ethics and compliance leader get the data I need to understand the health of my organization and the effectiveness of my program? How do I show how well I’m performing and the business value?
Delineation of Compliance vs. Ethics
Consumers and employees focused more on ethics causes organizations to shift. This is especially true in B2C and industries led by technology or the shared economy.
Employee engagement and nudge programs
Providing the just-in-time information that is context aware relative to business process and communication, so that employees can make the right decision at the right time to support their company values.
The FCPA Compliance Report is proud to have Convercent sponsor this episode. Convercent works to drive ethics to the center of business through Enterprise Ethics & Compliance Software
that invites users to share, listen and learn to help build a more ethical corporate culture. For more information go to Convercent.com.
Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, including:
Welcome to the Part V and our final entry of this five-part podcast series Jay Rosen and I produced in honor of the latest Star Wars movie The Last Jedi. Each day over this week, Jay and I reviewed a In this final entry, we consider Rogue One and the myth of the rogue employee.
Today we consider the only stand-alone entry in the Star War series, Rogue One. This movie tells the tale of the spies who stole the schematics from the original Death Star and transmitted it to Princess Leia and thereby the Rebel Alliance. Rogue One is the first film in the Star Wars Anthology series, a series of stand-alone spin-off films in the Star Wars franchise. It is not clear where the name of the movie came from; although my personal nomination is that in the attack led by Luke on the original Death Star, his squadron was Rogue Two so the movie title is a tribute to those Rebel Alliance X-wing fighters and their pilots.
As long as 24 years ago, Lynn S. Paine wrote about the myth of the rogue employee in the Harvard Business Review (HBR), in an article entitled “Managing for Organizational Integrity”. In this article she wrote, “executives are quick to describe any wrongdoing as an isolated incident, the work of a rogue employee. The thought that the company could bear any responsibility for an individual’s misdeeds never enters their minds. Ethics, after all, has nothing to do with management. In fact, ethics has everything to do with management.” How prescient she was in her article.
For it is management who sets the tone throughout the organization, whether that is something along the lines of a wink and a nod towards ethics and compliance or the more ubiquitous miss your numbers for two quarters and you will be history, Paine noted, “More typically, unethical business practice involves the tacit, if not explicit, cooperation of others and reflects the values, attitudes, beliefs, language, and behavioral patterns that define an organization’s operating culture. Ethics, then, is as much an organizational as a personal issue.”
However, a company’s responsibility is more than simply to set the right tone then sit back and do nothing. The drafters of the Foreign Corrupt Practices Act (FCPA) recognized this when they included the requirement for internal controls to be included in the law. For, as Paine said, “Managers who fail to provide proper leadership and to institute systems that facilitate ethical conduct share responsibility with those who conceive, execute, and knowingly benefit from corporate misdeeds.”
Yet the myth of the rogue employee is more than a simple myth. It is also a dangerous myth. It is dangerous because it excuses negligent or intentional corporate behavior. Mike Volkov, in a blog post entitled “The Myth of the Rogue Employee”, noted that illegal conduct such as that under the FCPA does not occur “in a vacuum.” He explained “There are other employees with whom the person interacts, there are financial controls in place to protect against such misconduct, there are reporting mechanisms for employees to report suspicious activity, and there is likely to be someone in the organization who is close enough to the bad actor, or responsible for the conduct of the bad actor, and who suspected or should have suspected that the actor was engaged in misconduct.” Moreover, the more sophisticated the scheme, the more actors are involved and the more controls are overridden or disregarded as he explained, “As the misconduct becomes more complicated, like in the case of bribery or antitrust violations, where such schemes require additional actors or raise red flags or where others are in a position to know or suspect that misconduct may have occurred”.
The three basic tenets of a best practices compliance program are to prevent, detect and remedy. By claiming employees who engage in bribery and corruption have ‘gone rogue’; companies are attempting to divest themselves of responsibility for actions from which they benefit, particularly if the bribery and corruption generated business sales and revenue.
We hope you have enjoyed our five-part podcast series on the intersection of Star Wars and compliance as much as we enjoyed producing it. Always remember the storytelling component of compliance. Reciting rules, regulations, policies and procedures is the way to engage effectively in compliance.
May the podcast be with you this holiday season.
Welcome to the Day 4 of the five-day podcast series Jay Rosen and I are producing in honor of the latest Star Wars movie The Last Jedi. Each day over this week, Jay and I will review a Star Wars movie and discuss it from the compliance perspective. Today, we consider Episode VII, The Force Awakens and disruption in compliance.
The full series schedule is:
Monday, December 18, Part I- IV-a New Hope and risk.
Tuesday, December 19, Part II- V-The Empire Strikes Back and due diligence.
Wednesday, December 20, Part III- VI-Return of the Jedi and effective training.
Thursday, December 21, Part IV- VII-The Force Awakens and disruptive innovation in compliance.
Friday, December 22, Part V-Rogue One and the myth of the rogue employee.
Today I consider the first ‘new’ Star Wars movie entry, Episode VII – The Force Awakens. I say it is a new Star Wars movie as it was the first one not created by LucasFilms, as George Lucas had sold his company to Disney, which produced the 2016 entry into the Star Wars oeuvre. It was directed by JJ Abrams and told the story of the Star Wars universe some 30 years after the destruction of the last Death Star. It is this disruptive nature of the Star Wars franchise that I will focus on today as it relates to disruption innovation in compliance.
The film introduced several new characters: Rey, Finn and Poe Dameron, Kylo Ren and the First Order, a successor to the Galactic Empire. The film was largely one giant search for Luke Skywalker who had gone into isolation after his failure to re-establish the Jedi order. In addition to introducing the new characters, we are reunited with Han, Chewbacca and Princess Leia, who is now General Leia Organa. The First Order has developed new weapon, Starkiller, a deliciously worthy successor to the Death Star; the Rebel Alliance majorly disrupts the weapon and the First Order by destroying it, in the film’s climactic battle.
One of the key things the Department of Justice (DOJ) has communicated over the past few months is the importance of doing compliance rather than having a paper compliance program in place. In releasing the new Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy, the DOJ emphasized the clear delineation of factors they will consider in determining if a company has an operationalized best practices compliance program in place in the context of a FCPA enforcement action. All of this has required disruptive innovation in compliance beyond the simple paper compliance program which until recently was seen as the norm.
Compliance is a process. Compliance programs should evolve as business risks change. Just as disruptive innovation tends to focus on process, your compliance program should focus on your overall business process to be successful.
Compliance 3.0 is very different from compliance programs of the past decade. Compliance is moving from a solutions shop where all compliance functions are centered in the legal or compliance department to a process function where the front-line business team can use technology and other tools to operationalize compliance. The 2017 Evaluation of Corporate Compliance Programs focused on how well a company operationalizes compliance into the business functions. The authors point to new business models as disruptive and I think this concept translates into how compliance can be burned into the DNA of an organization rather than simply sitting in the corporate office in the US.
Not all disruptive innovations succeed as disruption is only one step in both the creative and growth process. The key concept is what former SCCE President Roy Snell says are the three goals of any compliance program; to prevent, find and fix issues. This is how compliance differs from legal, whose job is to protect the company; from compliance whose mission is to monitor, obtain the data and then use the data as a feedback loop back into the company.
As many compliance practitioners are lawyers, we are naturally reticent to embrace such change, however I think the pronouncements of the DOJ throughout the year have made even clearer the need for continued evolution of anti-corruption compliance going forward. In The Force Awakens, there were numerous disruptions. We saw the death of one of the most beloved characters in the series, Han Solo, the growing awareness by Rey of her powers and the return of Luke Skywalker. It totally disrupted the First Order and destroyed its most lethal weapon.
Join us tomorrow where we consider Rogue One and the myth of the rogue employee.
May the podcast be with you this holiday season.
In Part I of a two-part series, the top compliance roundtable podcast is back with a review of the new Justice Department’s FCPA Corporate Enforcement Policy.
For Mike Volkov’s post on the new FCPA Corporate Enforcement Policy, see the following:
Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy
For Matt Kelly’s post on the new FCPA Corporate Enforcement Policy, see the following:
DOJ Expands FCPA Pilot Program
The gang is back with rants which follow the discussions.
The members of the Everything Compliance panel include:
Welcome to the Day 3 of the five-day podcast series Jay Rosen and I are producing in honor of the latest Star Wars movie The Last Jedi. Each day over this week, Jay and I will review a Star Wars movie and discuss it from the compliance perspective. Today, we consider Episode VI, Return of the Jedi and effective training.
The full series schedule is:
Monday, December 18, Part I- IV-a New Hope and risk.
Tuesday, December 19, Part II- V-The Empire Strikes Back and due diligence.
Wednesday, December 20, Part III- VI-Return of the Jedi and effective training.
Thursday, December 21, Part IV- VII-The Force Awakens and disruptive innovation in compliance.
Friday, December 22, Part V-Rogue One and the myth of the rogue employee.
In this final movie from the original three, the good guys win in the end after overcoming incredible odds. Many fans and critics panned it for including the incredibly cute and furry Ewoks on the moon named Endor as a part of the storyline. Many thought one very tall Wookie was enough cuteness for the series. This movie’s big reveal was that Luke and Princess Leia were twins and that she was now free to unabashedly pursue bad boy Han Solo. While Episode VI was the lowest grossing film of the original three, coming in at only $572MM worldwide, it was still a great ride and visually stunning. George Lucas’ in-house organ, Industrial Light & Magic (ILM), certainly earned their title for their special effects in the movie. The Sarlacc battle sequence was great, the speeder bike chase on the Endor moon was way cool and the space battle between Rebel and Imperial pilots was a great ride.
I have adapted an approach from Joel Smith on his Inhouse Owl website to help determine compliance training effectiveness.
1.What you want to measure. Before you ever train an employee, you should have a goal in mind. What actions do you want employees to take? What risks do you want them to avoid? In compliance, you want them to avoid non-ethical and non-compliant actions that would lead to compliance violations. The goal is to train employees to follow your Code of Conduct and your compliance program policies and procedures so you avoid liability related to actions.
2. What is employee engagement? The next step is to get a sense of whether employees feel that the training you provided is relevant and targeted to their job. If it’s not targeted, employees will likely not be committed to changing risky behavior. You can get data on employee engagement through a quick post-training survey, which will help you isolate and qualify the training benefit.
3. Did employees actually learn anything? A critical part of any employee training is the assessment. If you want to understand the “benefit” of training employees, you must know whether they actually learned anything during training. You can collect this data in a number of ways, but for compliance training, the best way is to measure pre-and post-training understanding over time. Basically, each time you train an employee, measure comprehension both before and after training.
4. Are employees applying your training? You need to conduct a survey to determine employee application and their implementation of the training topics. To do so, you must conduct employee surveys to understand whether they ceased engaging in certain risky behaviors or better yet understand how to conduct themselves in certain risky situations. These surveys can provide a good sense of whether the training has been effective.
Join us tomorrow where we consider The Force Awakens and disruptive innovation in compliance.
May the podcast be with you this holiday season.
Welcome to the Day 2 of a five-day podcast series Jay Rosen and I are producing in honor of the latest Star Wars movie The Last Jedi. Each day over this week, Jay and I will review a Star Wars movie and discuss it from the compliance perspective. Today, we consider Episode V, The Empire Strikes Back and due diligence.
The full series schedule is:
Monday, December 18, Part I- IV-a New Hope and risk.
Tuesday, December 19, Part II- V-The Empire Strikes Back and due diligence.
Wednesday, December 20, Part III- VI-Return of the Jedi and effective training.
Thursday, December 21, Part IV- VII-The Force Awakens and disruptive innovation in compliance.
Friday, December 22, Part V-Rogue One and the myth of the rogue employee.
This movie is my personal favorite of the initial trilogy. During the climactic battle between Luke Skywalker and Darth Vader, there is the BIG REVEAL where Vadar utters the immortal line, “I AM YOUR FATHER”. In the context of knowing who you are doing business with under the Foreign Corrupt Practices Act or UK Bribery Act. I once heard a company President say he did not need to perform due diligence because he looked a man in the eyes and that was enough to know if he was honest. (I should add, this company President also evaluated the strength of a handshake as an additional level of due diligence.) Hopefully we have moved past this level of sophistication for due diligence and its evaluation thereof.
There are three levels of due diligence and you must make a determination which is appropriate for the entity or person you are investigating. If a red flag appears it must be cleared or a risk management strategy articulated to allow moving forward.
Level I
First level due diligence typically consists of checking individual names and company names through several hundred Global Watch lists comprised of anti-money laundering (AML), anti-bribery, sanctions lists, coupled with other financial corruption and criminal databases. Level I due diligence addresses such basic issues as whether the third party actually exists, the identities of management, officers, directors and shareholders and whether such persons are on regulators’ watch lists. It can also provide some basic information on whether there are politically exposed persons (PEPs) involved in the third party. Finally, if there are any media reports linking the company to corruption.
Level II
Level II due diligence encompasses supplementing Level I due diligence with a deeper screening of international media, typically the major newspapers and periodicals from all countries plus detailed Internet searches. Such inquiries will often reveal other forms of corruption-related information and may expose undisclosed or hidden information about the company, the third party’s key executives and associated parties. Level II can give you information on adverse litigation, any bankruptcy proceedings, overt signs of financial difficulty. More generally it will also provide local online information such as corporate filings, regulatory filings, lawsuits and locally archived materials. You also be able to determine if there were any in-country investigations or sanctions from regulatory entities.
Level III
This level is the deep dive. It will require an in-country ‘boots-on-the-ground’ investigation and is designed to supply your company “with a comprehensive analysis of all available public records data supplemented with detailed field intelligence to identify known and more importantly unknown conditions. Seasoned investigators who know the local language and are familiar with local politics bring an extra layer of depth assessment to an in-country investigation.
Now imagine if Luke had performed a more robust level of due diligence on Darth Vadar? Would he have been able to find out Darth Vadar was his father? Perhaps not but then again, we might not have heard that seminal line “I AM YOUR FATHER”.
Join us tomorrow where we consider Return of the Jedi and effective training.
May the podcast be with you this holiday season.