Hi everyone,
It's been a while, but for a reason.
Find out that very reason below (🥁), but also:
- 👮♂️"Why I did not go to jail": Marc Andreessen describes the importance of having a good compliance advisor
- 🎁 Surprise link "The paradox of secrecy"!
👮♂️ "Why I did not go to jail"
In an old blog post (February 2014 but which came to my attention via Benjamin White), the all-start Silicon Valley investor & entrepreneur Marc Andreessen describes how easily you can violate the law without knowing it. Even more: credible persons and firms explicitly approved the transaction or structure.
But he didn't violate the law thanks to his trusted General Counsel, Jordan Breslow.
It's a great story that underlines the importance of all compliance professionals.
At the same time, I believe every compliance professional can fall victim to confirmation bias:
"If X approved this transaction and X is very credible, this must be OK!
We shouldn't train only our colleagues to stay critical when screening transactions, we should also train ourselves to stay critical all the time.
We're all human after all.
🎁 Surprise link
Why?
Without disclosing too much, it's a great analogy of when it's okay to break the rules (and when probably it's not okay).
🥁 The reason: busy
I finetuned my gamified compliance workshop to make it fit for Sanctions training and awareness.
And this is what companies are saying:
"This what we have been looking for."
Simple & clear. Quoi!
My main conclusion from these conversations: all companies have screening procedures in place to be compliant with Sanctions regulations, but what they neglect to do is to raise awareness.
They didn't focus on the human factor. Their colleagues. They gave them a check-the-box exercise and thought the compliance work was done.
But since the war against Ukraine and the sanctions against the Russian Federation, the sanctions compliance game has changed.
Never has there been such a hard restriction between two intertwined economies. The consequence is that there are many circumvention methods to which Western companies can fall victim.
With the workshops, we are working to improve the human factor and awareness at companies. Because all tools & procedures fall short of the complexity of supply chains and circumvention methods.
Thanks for reading!
Jochen