Beyond the Checkbox (Ep. 1): What the Justice Department Wants for Due Diligence Programs
Episode Summary
In this episode of "Beyond the Checkbox," host Matt Kelly and guest Maria D’Avanzo dive deep into the ever-evolving world of corporate compliance and anti-corruption. D’Avenzo, a seasoned compliance professional and partner at Feinberg, D’Avanzo & Gasbarro, shares her extensive experience in building effective compliance programs tailored to organizational needs. The discussion focuses on the importance of understanding and managing third-party risks, particularly within large, global enterprises.
Maria emphasizes the role of leadership in shaping a proactive compliance culture. She recounts her experiences at Cushman & Wakefield, highlighting how leadership's involvement (or lack thereof) can significantly influence compliance efforts. Under supportive leadership, she could enhance the firm's ethics and compliance, transforming its approach from mere box-checking to active, ongoing engagement.
The conversation also explores practical strategies for ensuring compliance programs meet the Department of Justice's expectations. Maria outlines key elements like risk assessment, tiered due diligence, and continuous monitoring. These insights are invaluable for compliance officers aiming to navigate the complexities of modern corporate environments effectively.
Key Insights
Leadership Determines Compliance Culture
Maria D'Avanzo highlights the critical role of leadership in shaping an organization's compliance culture. She contrasts her experiences under two different CEOs at Cushman & Wakefield. The first CEO's limited involvement led to a "box-checking" compliance approach, whereas the subsequent CEO, from Goldman Sachs, significantly elevated the compliance function, emphasizing ethics and initiating more hands-on management practices. This change facilitated a more ethical culture and improved compliance oversight, demonstrating how leadership commitment can profoundly impact corporate compliance effectiveness.
Compliance is a People-Centric Role
Maria D'Avanzo argues that successful compliance requires strong interpersonal skills, moving beyond legal or procedural expertise. She shares insights from her travels to company sites across the globe, where informal interactions, such as having coffee with colleagues, played a crucial role in building trust and understanding operational challenges. These experiences illustrate that personalizing the role of compliance officers and building relationships within the organization are essential for fostering a culture of transparency and ethical behavior.
Risk-Based Compliance is Key to DOJ Expectations
According to Maria D'Avanzo, the Department of Justice does not seek a uniform compliance program but expects a risk-based approach tailored to each organization's unique challenges. She details how Cushman & Wakefield managed their due diligence by categorizing third parties by risk levels and adapting their scrutiny accordingly. This method ensured that resources were allocated efficiently, addressing the highest risks with more intensive investigations and maintaining lighter oversight where appropriate. This strategy aligns with DOJ's directives, emphasizing the importance of flexibility and responsiveness in compliance practices.
Beyond the Checkbox (Ep. 1): What the Justice Department Wants for Due Diligence Programs
Episode Summary
In this episode of "Beyond the Checkbox," host Matt Kelly and guest Maria D’Avanzo dive deep into the ever-evolving world of corporate compliance and anti-corruption. D’Avenzo, a seasoned compliance professional and partner at Feinberg, D’Avanzo & Gasbarro, shares her extensive experience in building effective compliance programs tailored to organizational needs. The discussion focuses on the importance of understanding and managing third-party risks, particularly within large, global enterprises.
Maria emphasizes the role of leadership in shaping a proactive compliance culture. She recounts her experiences at Cushman & Wakefield, highlighting how leadership's involvement (or lack thereof) can significantly influence compliance efforts. Under supportive leadership, she could enhance the firm's ethics and compliance, transforming its approach from mere box-checking to active, ongoing engagement.
The conversation also explores practical strategies for ensuring compliance programs meet the Department of Justice's expectations. Maria outlines key elements like risk assessment, tiered due diligence, and continuous monitoring. These insights are invaluable for compliance officers aiming to navigate the complexities of modern corporate environments effectively.
Key Insights
Leadership Determines Compliance Culture
Maria D'Avanzo highlights the critical role of leadership in shaping an organization's compliance culture. She contrasts her experiences under two different CEOs at Cushman & Wakefield. The first CEO's limited involvement led to a "box-checking" compliance approach, whereas the subsequent CEO, from Goldman Sachs, significantly elevated the compliance function, emphasizing ethics and initiating more hands-on management practices. This change facilitated a more ethical culture and improved compliance oversight, demonstrating how leadership commitment can profoundly impact corporate compliance effectiveness.
Compliance is a People-Centric Role
Maria D'Avanzo argues that successful compliance requires strong interpersonal skills, moving beyond legal or procedural expertise. She shares insights from her travels to company sites across the globe, where informal interactions, such as having coffee with colleagues, played a crucial role in building trust and understanding operational challenges. These experiences illustrate that personalizing the role of compliance officers and building relationships within the organization are essential for fostering a culture of transparency and ethical behavior.
Risk-Based Compliance is Key to DOJ Expectations
According to Maria D'Avanzo, the Department of Justice does not seek a uniform compliance program but expects a risk-based approach tailored to each organization's unique challenges. She details how Cushman & Wakefield managed their due diligence by categorizing third parties by risk levels and adapting their scrutiny accordingly. This method ensured that resources were allocated efficiently, addressing the highest risks with more intensive investigations and maintaining lighter oversight where appropriate. This strategy aligns with DOJ's directives, emphasizing the importance of flexibility and responsiveness in compliance practices.
