Section 2

Building Your Foundation

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Implement What You Know with Confidence

Discover action-based tools that provide simple steps for program improvement or robust plans for new ways of doing business. 

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Your ethics and compliance program is an ecosystem of moving parts. New laws and regulations, new lines of business, new geographies, mergers and acquisitions become part of a growing enterprise that your compliance ecosystem must support. 

Effective compliance programs are able to deftly navigate these complexities because they have built strong foundations that were developed with the nature of the compliance industry in mind.

This section will give you the expert advice and programmatic best practices to ensure the first steps you take to develop your program are in the right direction. Or if your program is more mature, these resources and insights will give you the necessary guidance to course correct and improve your program’s foundation at whichever stage it is in. 

 

How to Survive a Friday Afternoon Cyber Threat

Chapter 1 of The Worst-Case Scenario Survival Guide for Compliance Professionals

Seventy-five percent of cyber crime is reported as fraud on Friday afternoons.* Let’s let that sink in a bit – a single day of the week – a favorite for many – is host to three-quarters of cyber crime reports. Who would have thought? No one … except for wrongdoers. Learn how to survive with Tom Fox.

 

Tom Fox 06/01/2017

Chapter 1 of The Worst-Case Scenario Survival Guide for Compliance Professionals

Seventy-five percent of cyber crime is reported as fraud on Friday afternoons.* Let’s let that sink in a bit – a single day of the week – a favorite for many – is host to three-quarters of cyber crime reports. Who would have thought? No one … except for wrongdoers. Learn how to survive with Tom Fox.

 

 

4. Determine if Anything Smells Fishy

There are a lot of physical, digital and human resources that go into processing a money transfer. With all these touchpoints, fraud can tuck itself neatly into nooks we would have never suspected to be tampered with.

According to a report reviewed by The Wall Street Journal, the morning after the theft, “… the senior official in charge of the server room … was concerned when a printer connected to the terminal couldn’t print out the interbank messages received during the night.”

 

5. Be Prepared

As with every compliance program, the key to success starts with assessing the risks of your organization. Many compliance practitioners understand this from the anti-corruption compliance perspective. Yet have you considered your risks from the AML perspective? Do you even have a corporate AML policy in place? Have you trained the appropriate employees on it? Do those employees know which countries have Thursday and Friday as their weekend so that if a request for payment comes in late Wednesday afternoon a confirmation may not be available until the next Monday? All of these issues must be considered.

 

6. Become Your Own Worst Enemy

We usually do not know what’s wrong with our processes until someone points them out. Make sure you are that someone, rather than a nefarious actor. Test for weaknesses in your risk management process intensively and regularly so that you are confident in your system at all times of every day of the week.

 

* Solicitors Regulation Authority (2016). IT Security: Keeping Information and Money Safe

**  Wall Street Journal (2016). From the Fed to the Philippines: Bangladesh’s Stolen-Money Trail.

Illustration by Dex Novak

Comments

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It never occurred to me to question the day and time a message came in. I think at this point any request to click a link (unsolicited) or to send money (for any reason) should be viewed with scrutiny. There are many ways to conduct business. Go specifically to the requester's business online presence and determine if the request was authentic.

0 Responses
June 2, 2017, 10:23 a.m. Andrea Ihara Andrea Ihara

Excellent article!

0 Responses
June 2, 2017, 7:51 a.m. Arelis Ludovic Arelis Ludovic