Compliance should build contingency plans, prepare for any regulatory shift

Key themes and takeaways from the London Directors Group

Discussion notes from our 18th stop on the Tech Talk World Tour


  • 42 registrations
  • Including: Apollo Education, BT Group, Guy Carpenter, LendInvest, OneFamily, Pearson plc, pWc, Turner Broadcasting, WorldPay, World Remit, Western Union, Royal Mail, AKJ Associates and Diageo
  • Hosted at London’s ME Hotel

First a short story….
The morning of our 18th Tech Talk, CEO Patrick Quinlan ripped his suit pants leaving the hotel the morning of the event. Being an efficient packer and world traveler, his suitcase was lean, with a single spare pair of casual jeans, causing him to visit the nearest department store en route to his morning meeting.

He ran into the store, found appropriate pants, changed into them and realized at the checkout the security tag was still embedded into the waistline. Conscious of time, he paid for the pants, received a receipt and told the cashier to plug their ears. Out the door, he told them he will get the security tag off in Denver, some 4,698 miles away.

Holding the receipt up to show a packed room Tuesday night in London of compliance and ethics professionals that he did indeed pay for the pants he was wearing in front of them, also showing he still had the security tag affixed to the pants — became the leading metaphor for this regional event.

Compliance moves you in a thousand unexpected directions – the outcome depends on due diligence, risk assessment and the ability to continue to move forward knowing you did the right thing.

On the heels of our exciting announcement last week of our first international office in London, this regional event meant something a bit different for us. Proudly able to call this city a second home, this gathering brought together some of our local clients like Western Union, Pearson and World Remit and shared common challenges and frustrations faced in today’s regulatory landscape from a compliance and ethics perspective.

Watch the video above to listen to CEO Patrick Quinlan’s Keynote session along with the expert panel discussion with compliance professionals from Western Union and Pearson plc. 


It was difficult not to discuss the outcome of US Presidential election the night of this event, given that from the tube to the office, President-elect Donald J. Trump took center to most conversations throughout the day. It caused the group to reflect on potential changes that may impact the industry.

A few things that will be changing under the Trump Administration:

  • The policy environment will go through swift changes.
  • The regulatory landscape has been identified has one of our four core areas for the incoming Administration and Congress.

A recent article in the New York Times outlines the ways the Trump Administration may impact the industry and shows what we as a software provider emphasize our product’s usefulness around the globe to meet the changing standards of on the FCPA, trade sanctions and oversight of the financial services market.

From the article:
“If there are budget cuts, one area that is likely to continue to thrive is the enforcement of the Foreign Corrupt Practices Act, which prohibits paying bribes to foreign officials to win business in their countries. The Justice Department depends in large part on companies to self-report violations of this law and conduct internal investigations to determine the scope of the misconduct.

The roots of the government’s crackdown on overseas corruption can be traced to the administration of George W. Bush, and it was continued aggressively by President Obama. Many of the cases involve foreign companies that have paid millions of dollars in fines, and they are a way to show the public that global enterprises are being overseen to ensure compliance with American law.”

Questions that shaped the conversation given the parallels that can be drawn with the recent passing of the June 2016 Brexit vote, or the UK’s withdrawal from the European Union and it’s impact on the compliance and ethics space included:

  1. Did the Brexit vote create new challenges for your compliance team to get executive attention to get a normal cadence with executives — did the oxygen get sucked out of the room with that unintended surprise?
  2. How will you identify global risks in your organization in light of the recent news? How do companies identify risks in the wake of Brexit?

Opportunities that exist today for technology and for valued partnerships like we have with our current clients and with potential European-based clients are un-phased by the change, a strong message that Quinlan emphasized throughout the event.

Compliance is not an easy job and we exist to help make it easier. Building innovative technology to help insert compliance into the enterprise of companies in any industry, our global presence and the team we have in place today is situated for a mutually beneficial relationship around the globe.


The Corporate Shield developed by Managing Director Keith Read.

Hands-on session led by Managing Director Keith Read
Many organizations have invested heavily in their anti-bribery and corruption (AB&C) programs, and for good reasons. Due to increasing globalization of business, the cultural intricacies and nuances can be a beast to manage and identifying looming risks let alone better managing them. In light of legislations developing such as the UK Bribery Act (UKBA), Foreign Corrupt Practices Act (FCPA) and similar statues that despite detail differentials have similar core requirements.

It can be argued the situation is different when it comes to Conflicts of Interest. Some countries, such as the US, adopt a rules-based approach to COI. Other countries, like the UK, take a principles-based approach, take no specific approach or a by-product approach of other legislation.

Whatever the approach, the direct legislative drive for a Conflicts of Interest program is variable, with the consequence that organizations often expose themselves to completely unnecessary risk by failing to realize the benefits of an effective Conflicts of Interest program. Without question, this is a crucial element of an overall compliance program and when properly joined-up with other compliance activities, represents an effective compliance ‘Corporate Shield’. There is an invariable a link between COI and corruption in all of its types. However good an organization’s AB&C program may be, with a comparable COI program, the organization will, undoubtedly, be exposed, which can be directly or indirectly link to bribery as a conflict consequence.


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December 6: PHOENIX