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FCPA Compliance Report

Tom Fox has practiced law in Houston for 30 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
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Oct 29, 2018

In this podcast, we celebrate Doyle’s final novel, The Valley of Fear. This novel was written in 1914 and serialized in the Strand Magazinebetween 1914 and 1915. It was notable for two reasons. The first that it was at least inspired by events in America involving the Molly Maguires, the Pinkerton Agency and its undercover agent James McParland. It informs the topic of virtual teams. 

In this story, Holmes decodes a cipher from Professor Moriarty's organization for a person named Douglas in Birlstone. It is discovered that there is a corpse who was an assassin sent to kill Mr. Douglas. Douglas literally blew the head off of his American assassin and dressed the body as himself. Holmes intoned that a dumb-bell weighed down the killer's clothes in a moat. The assassin left a calling card, monikerred VV341, which was a code for the Vermissa Valley Lodge 341. This was a reference to undercover work that Douglas did years before for the Pinkerton Agency when he went undercover, first with Freemen in Chicago, then west to a desolate mountain coal mine area, to take down corrupt murderers who ran the Valley Freemen Lodge. Years later the US criminals enlisted Professor Moriarty to find Douglas. Holmes warns Douglas to flee England. But Moriarty prevails and the story ends with Mrs. Douglas wiring Holmes that her husband was lost overboard on his way to South Africa.

I thought about this final Holmes novel, with its multi-continent settings, in connection with an article in the Harvard Business Review, entitled “Managing Yourself Getting Virtual Teams Right”, by Keith Ferrazzi. It provided insight for any Chief Compliance Officer (CCO) or compliance practitioner to master this most valuable and necessary tool is a skill in the modern multi-national organization.

The Right Team

It all starts with the right people, the right size and the right roles. Your team, no larger than 10 should have “good communication skills, high emotional intelligence, an ability to work independently, and the resilience to recover from the snafus that inevitably arise. There are three groups.  The core consists of executives responsible for strategy. The operational group leads and makes decisions about day-to-day work but does not tackle the larger issues handled by the core. Finally the outer network consists of temporary or part-time members who are brought in for a particular stage of the project because of their specialized expertise. 

The Right Leadership

The group must have trust by getting to know each other as people, if only through the virtual format. Once trust is established the next step is foster open dialogue or. Finally, it is important to clarify goals and guidelines or “the importance of establishing a common purpose or vision, while also framing the work in terms of team members’ individual needs and ambitions. Explain to everyone why you are coming together and what benefits will result, and then keep reiterating the message.”

The Right Touchpoints

There are three key points at which the team should get together; kickoff, onboarding and milestones. Kickoff allows everyone to put a face with a name. Onboarding is when you bring a new person onto the virtual team. Finally, Ferrazzi says that even the most dedicated teams can lose momentum as team members begin to feel disconnected. To counter-act this, he suggests bringing the full team together at milestones.

The Right Technology

Some of the obvious is conference calling, direct calling and text messaging and virtual team rooms all which can make the virtual team experience work well. When data on employee resource use was made available, “a few interested parties self-organized into a virtual project team to create a system that documents individuals’ cost savings over time. As people began to compete for the biggest savings, the company benefited.”

The earliest virtual teams were formed to facilitate innovation among top experts around the world who didn’t have time to travel. However in today’s corporate environment, teams of physically dispersed employees are more often just a necessity of doing business. The compliance function will almost always be dispersed across a wide multi-national area. Some of the tips presented herein can help you run a more efficient organization while allowing greater flexibility going forward. 

If you are looking for the top compliance training class around, the Compliance Master Class. If you would like information please email at tfox@tfoxlaw.comand I can forward you the agenda. If you would to register, you can do so here.

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