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By Adam Turteltaub Virginia MacSuibhne is not your typical compliance officer. It’s not surprising then that this former global chief compliance at Agilent and Roche, who also has an Etsy shop selling irreverent, NSFW compliance merch, decided she wanted to do an atypical podcast. Rather than focusing on a brilliant idea she had or a huge success, she suggested we discuss the mistakes she has made. Each of them has an important lesson for others in compliance. Mistake #1: Do the code of conduct ...
By Adam Turteltaub A good, juicy case study is great for compliance training. An artfully created scenario can also be remarkably effective, especially for ethics training. What makes them so appealing, and how do you use them best? Colin May , Adjunct Professor at Stevenson University, explains that problem-based learning is very effective for adults both for knowledge transfer and retention. It also helps people apply what they have learned. Case studies, which are based on actual incidents, a...
By Adam Turteltaub There’s a lot of discussion about the relationship between compliance and the general counsel. Less words, though, have been dedicated to the important relationship between compliance and HR. Netherlands-based Asaf Shalev , Global Ethics, Risk & Compliance Lead for DLL rightly observes that maximizing synergy between the work of HR and compliance is a key for success of both the compliance program and the business. The departments share overlapping interests in a number of...
By Adam Turteltaub Stress can be a good thing. Burnout, though, is something altogether different and very real for compliance professionals. Sarah Hadden ( LinkedIn ), CEO and Publisher of Corporate Compliance Insights shares in this podcast the not always encouraging data on stress and burnout from their 2025 Compliance Officer Working Conditions, Stress & Mental Health survey. The research did reveal some very good news. Compliance officers are generally happy with their work. They have a...
By Adam Turteltaub There is a tendency to think of risk assessment as one thing and demonstrating the value of the compliance program as another. In this podcast, Catherine Bruno, Assistant Director Office of Integrity and Compliance (OIC) at the FBI shows that the risk assessment process can also be a great way to demonstrate the value of a strong compliance program. So how do they make that happen? First, the OIC ensures that individuals who are closer to the risk, the subject matter experts a...
By Adam Turteltaub The words “works council” inspires fear and dread in the hearts and minds of many who have never worked with them. They need not, says Lisanne Winde , attorney at law at Wybenga advocaten and Alain Lambert , regional ethics and compliance officer for Central Europe at WSP. In this podcast, they share how the works council can actually help compliance teams. These entities are not unions but are specific to the company. They can be helpful for facilitating communication with em...
By Adam Turteltaub An audit by a Unified Program Integrity Contractor auditor, better known as a UPIC audit, can be a very scary thing. Providers are often shocked and even indignant to receive a letter notifying them of the audit and alleging fraud. Jon Rawlson ( LinkedIn ), President & Founder of Armory Hill Advocates , reminds us that the audit was likely not triggered by an allegation but by an algorithm catching outlier events such as a provider processing claims outside of their normal...
By Adam Turteltaub As the sun set, the chief compliance officer stared out the window, wondering how she would communicate with her workforce in a way that they would understand. As much as she looked, the answer wasn’t outside in the skies turning from blue to black. She wasn’t finding it under the white LEDs in the ceiling above her desk, either. Feeling a bit desperate, and a little bit bored, she decided to walk the halls to see if perhaps the answers were there. She got all of ten feet befo...
By Adam Turteltaub In addition to releasing its General Compliance Program Guidance , the OIG at HHS announced plans to publish a series of Industry Segment-Specific Compliance Program Guidances (ICPG). The first of these, addressing nursing facilities, was released in November 2024. As CJ Wolf , Professor in healthcare Administration at BYU Idaho explains in this podcast, the first ICPG is instructive both for skilled nursing facilities (SNFs) and those looking to anticipate what will be coming...
By Adam Turteltaub Sevda Huseynova is the Ethics and Compliance Officer for SOCAR Midstream, a state-owned enterprise (SOE) in Azerbaijan. The company manages the oil and gas export pipelines of the country. If you think working for an SOE means you don’t have to worry about compliance, she warns you to think again. SOEs still faces risk in a wide range of areas including anticorruption, sanctions, third parties and more. Investors want to ensure that the company operates up to global standards,...
By Adam Turteltaub KISS takes on a new meaning in this podcast: Keep it Streamlined & Strategic. Keeping it streamlined and strategic is also the topic of a session at the 2025 HCCA Compliance Institute that will be led by Krista Muszak , Senior Manager, Process Optimization at Pfizer and Angela Smart , Senior Compliance and Ethics Partner, Intermountain Healthcare. Specifically. they’ll be applying this new take on KISS to the topic of program effectiveness. So how does it work? How do we k...
By Adam Turteltaub Business people are given all kinds of goals for revenues, profitability, efficiency and more. For compliance, though, not so often. Many organizations struggle with how to set compliance goals, or even if they should set them. Madrid-based, Juan Ignacio Paillás , Head of Global Compliance Business Sectors for Merck KGaA, Darmstadt, Germany, explains how it should be done. First, he advises, understand the context in which you are working, particularly about how your organizat...
By Adam Turteltaub Healthcare is often rife with fraud, and organizations struggle to prevent it. To gain a different perspective on how to prevent wrongdoing, we spoke with Alec Burlakoff , a convicted fraudster from Insys Pharmaceuticals who now leads Limitless! Consulting . To prevent fraud, he recommends seriously looking at the incentives program in your organization, especially if there are individuals whose commissions may make up more than half of their compensation. Such high rates of r...
By Adam Turteltaub Are your helpline calls being responded to properly? Are the investigations proceeding expeditiously and properly? To find out, it’s good to do an audit periodically. Before you can begin, though, you need to determine if there is enough available data for an audit, cautions Juliette Gust, President of Ethics Suite , and author of the chapter “Auditing the Confidential Reporting Hotline and Case Management Program Effectives” in the new edition of The Complete Compliance and E...
By Adam Turteltaub Think you don’t have to worry about the SEC because you’re at a private company or a non-profit? Think again says, Kevin Muhlendorf , attorney at Wiley Rein. You may still end up in the Commission’s crosshairs. He warns that the SEC’s power of investigations expands far and wide, and just being a supplier to a publicly-traded company may lead them to focus on your business. If a private company is acquired by a public one or makes even a non-public offering, there is risk of f...
By Adam Turteltaub Business transformations can be times both of risk and opportunity for compliance programs. Employees, struggling to understand the changes around them and feeling stressed, may opt to do the wrong or at least ill-advised things. By the same token, transformations provide an opportunity for compliance teams to change their roles within the organization and redefine the value that they bring. Jill Swain , Global Ethics Manager and Dawn Wood , Engagement, Training and Programme ...
By Adam Turteltaub Oh, Artificial Intelligence. So much promise, and so much risk. What’s a compliance and ethics professional to do? Start by listening to this podcast about the chapter “Managing the Ethics and Compliance Risks of Artificial Intelligence” in the 2025 edition of The Complete Compliance & Ethics Manual . We spoke with the article’s co-authors, Gwen Hassan (chief compliance officer at Unisys), Dr. Anthony J. Rhem (CEO and principal consultant at A.J. Rhem & Associates), an...
By Adam Turteltaub Sometimes you make a few technical changes to a compliance program because a law or regulation has changed. Autoliv didn’t want to do that and just meet technical requirement of the EU Whistleblower Directive . They wanted to use it as an opportunity to assess what they were doing to encourage employee reporting, whether it was working, and to improve support for people speaking up. Erica Wikman , Vice President, Corporate Compliance, Autoliv and David Barr ( LinkedIn ), co-fo...
By Adam Turteltaub So the IT folk can’t wait for your business people to delete those old documents, meantime, the business people want to hold onto them because they never know when they might need that info again. Then, all of a sudden there’s a legal issue and a hold is in place. Instantly the game changes. Chris Kruse , Executive Vice President & Advisor at CasePoint explains that when a legal hold is placed several things need to happen: Employees with relevant need to be identified The...
By Adam Turteltaub You do all that work but how do you know you’re being successful? It’s not like people come running in the door and say, “Hey, guess what bad thing I almost did.” The compliance team at the National Security Agency (NSA) had that same challenge. In this podcast, Natalie Knowles, Director of Compliance, and Zack Conyne, Manager, first provide an overview of the NSA. As they explain it has two primary missions: cybersecurity and signals intelligence. Every employee there annuall...
By Adam Turteltaub When we last spoke with Tyler Shultz back in 2020, he discussed his experience at Theranos as both an employee and a whistleblower. Four years later, the case is in the rearview mirror, the former CEO is in prison, he founded two startups of his own, and he now speaks to corporations about cultivating courageous work cultures With the benefit of some time and distance, he shares in this podcast his experiences and what he has learned, particularly about corporate culture. The ...
By Adam Turteltaub Few things hold more promise, or cause more stress for compliance professionals, than AI. What is it? How does it work? And does anyone know how to keep it from showing so much bias? David Silva , Chief Compliance Officer at Collaborative Imaging, will be addressing the topic of “Healthcare, Artificial Intelligence, and Compliance” at the 2025 HCCA Compliance Institute , which will takes place April 28-May 1 in Las Vegas. To get some of his insights now, we sat down for this p...
By Adam Turteltaub Chart auditing may not be the sexiest part of healthcare compliance, but it plays an important role in discouraging Medicare fraud and catching problems early. Madhavi Perumpalath , Director-Physician Practice Compliance at Northeast Georgia Health System and Alka Kumar , Compliance Director and Privacy Officer at Resolve Pain Solutions, explain that CMS provides good guidance to healthcare providers, such as diagnosis and procedure codes that are appropriate to bill for. Take...
By Adam Turteltaub With value-based care growing, what role does compliance play? To find out we spoke with Carolyn Barton , Vice President, West Regional Compliance Officer at Kaiser Permanente. She explains that at Kaiser they define value-based care as a healthcare delivery and financing model that improves health outcome and increases access to affordable care in the community through evidence-based care, a commitment to equity and simplicity and aligned incentives. Doctors and health plans,...
By Adam Turteltaub No one would dispute that stress and compliance go hand in hand, but Scot Eibel ( LinkedIn ), a former chief compliance officer and currently leading Eibel Coaching and Compliance Consulting , warns that doesn’t mean it has to get out of control. There are steps we can all take to manage our stress levels. One stressor to watch for is over vigilance. While we all need to be vigilant, assessing risk and watching out for threats, it needs to be tempered. Resist the temptation, h...
By Adam Turteltaub Benjamin Christenson, Trial Attorney and Special Assistant to the Director for Criminal Enforcement at the US Department of Justice Antitrust Division, joins us for this podcast in which he sheds light on the their document, Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (ECCP). First issued in 2019, the ECCP was updated in 2024 to reflect changes in business, the law and technology, as well as what the Antitrust Division had learned over the ...
By Adam Turteltaub Want to improve your code of conduct? Don’t miss the session: Cornering the Code: A Multi-Disciplinary Approach Toward a Better Code of Ethics at the 2025 SCCE European Compliance & Ethics Institute . In this podcast Matej Drascek , Head of Internal Audit at LON d.d. and Ursula Schmidt of Schmidt Advisory recommend starting with the right language. Research has shown, they explain, that people react more strongly to words like “we” and “our”, which can convey a stronger se...
Kasturi Venkatesh discusses "Ethics in Action," highlighting key issues in tackling personal conflicts of interest, from employees' fear of reporting to complex situations in limited talent pools. She stresses the importance of nuanced understanding, proactive communication, and an approachable ethics team. The conversation also delves into essential tools for evaluating and mitigating conflicts, including understanding risk, clarifying roles, and developing flexible, clearly defined mitigation plans with proper oversight.
By Adam Turteltaub On November 6, 2024, the U.K.’s Home Office issued Economic Crime and Corporate Transparency Act 2023: Guidance to organisations on the offence of failure to prevent fraud (the Guidance). It comes out of the Economic Crime and Corporate Transparency Act (ECCTA), which establishes that a corporation can be held criminally liable for failing to prevent fraud committed by any “associated person” for the benefit of the company. This “associated person” can be an employee or even a...
By Adam Turteltaub Auditing and monitoring of the compliance program is pretty standard these days. Entain’s Karen Nightingale , Group Director of Ethics & Compliance and Jonathan Fox , Group Head of Ethics & Compliance Programmes , make the case in this podcast for going to the next level and actively testing your program. The two will also be addressing the topic at the 2025 SCCE European Compliance & Ethics Institute , which will take place in Lisbon, 10-12 March. Doing so, they s...
