How to navigate the busy intersection of ethics and compliance with good intentions and meaningful actions as the Compliance Office(r) is also at war. Due to the escalation and length of the aggression, we have a new critical role in complying with the business risks sanctions, safeguarding human rights, restoring an open, respectful, and sustainable society, stopping dictatorship, and supporting democracy and peace. The organisation’s role will significantly impact your customers, employees, and stakeholders:
- Strengthen the investigation processes to detect, evaluate, investigate, and close apparent or real cases of non-compliance. Regularly make the investigations’ efforts, numbers, and results visible to the organisation and stakeholders.
- Keep all information on investigations in compliance with the regulations of local jurisdictions for investigation processes and international rules.
- Identify and prevent transactions related to beneficial owners in Russia/Belarus, including politicians, oligarchs, elite-related people, and state-owned enterprises starting from oil and defence companies. Identify alternative suppliers from Russia, create exit plans as part of the boycotting efforts, and address discontinuity risks. Activate exit actions for subsidiaries operating in Russia/Belarus to address potential counter-measure scenarios
- Ensure sanction compliance with OFAC after the listing of VTB, Otkritie, Novikombank, and Sovcombank as Specially Designated Nationals and Sberbank, including subsidiaries https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220224
- Plan for the insolvency risks in transactions with Russian banks after the SWIFT ban and OFAC asset freeze. Reassess due diligence procedures and OFAC matches on third parties receiving new sanctions. https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1516prevent the investment in and the financing of companies related to Russia and its government to avoid reputational and economic losses, including subsidiaries and beneficial owners,
- Deal with the effect of export license cancellations and trade restrictions from Russian clients and suppliers, starting from direct technology exports. https://www.whitehouse.gov/briefing-room/statements-releases/2022/02/24/fact-sheet-joined-by-allies-and-partners-the-united-states-imposes-devastating-costs-on-russia/
- Address reputational losses by cancelling sponsorships, JV, partnerships, and agreements with Russian/Belarus companies
- Offer mental health, employment, and financial support to employees with families in Ukraine with a sensibility to employees in the Baltics, Poland, Romania, Slovakia, and Hungary. Raise awareness on the front-line staff to identify any business operation related to Russia
- Assess measures against Venezuela, Belarus, Armenia, and other dictatorships supporting Russia. Channel donations and practical help for the people affected by the invasion.
- Improve the efficiency of IT controls to prevent cyber-attacks from Russian/Belarus threat agents, starting from ransomware, phishing and distributed denial-of-services
- Suppose the corporate strategy contains words like ethics and integrity. In that case, the corporate duty is to raise the voice and advocate for stakeholders to take a clear and practical position to document the adopted corporate principles and values.
You get multiple guidance on the above issues from 20+ global experts that have hands-on experience at the following two conferences.
- The Global Corporate Governance Day on the 14th of September 2022will address Governance from multiple angles, including attitudes, values, beliefs, and goals, with particular good Governance characteristics to enhance the ethics and integrity in the organisation (Event details here, Agenda here, and Register here).
- At the annual global Corporate Culture Day on the 20th of October 2022, we follow up on the above issues and review and develop corporate culture issues that focus on Leadership: Metrics, Accountability, Transparency, and provide recommendations and reflections to address the corporate focus on; values, environment, recognition, awareness, engagement, and business disruptors challenges (Event details here, Agenda here, and Register here).