Have I really not written anything since July 18th? You’re probably sitting there by your RSS reader saying, “he never calls, he never writes….”
I’ve been travelling a lot, which is one reason, and I’ve been head-down on a couple of work projects.
So let me just refer you to an excellent post by Michael Volkov. I say excellent not just because he refers to me in the title, and not just because he has a picture of me at the top of the post, but because he’s absolutely right.
I write and speak a lot on control convergence—the idea that the silos of compliance controls should be merged since we’re all looking for the same or very similar data. OFAC compliance and FCPA/UKBA compliance is a no-brainer in my opinion for this kind of approach. Same with anti-money laundering. If your company has an FIU (mainly in banks and other financial institutions), and your FCPA/UKBA compliance team hasn’t tapped into that resource, you need a new FCPA/UKBA compliance team. Remember, AML compliance is older, more structured, more mature, and has better resources. If you need an AML compliance program, you need a good one, and you need it badly. Companies can spend upwards of $100 million on AML programs. Is there anyone out there who has spent that kind of money on FCPA/UKBA compliance? I don’t think so. Maybe Siemens, but most of their money was spent on internal investigations, not the compliance program per se.
So…go read Mr. Volkov’s post, and I promise new posts more regularly.