Copyright © 2020, Guidepost Solutions LLC.

REMOTE…BUT NOT REMOVED – Webinar Series

Maintaining An Effective Compliance Program During The COVID-19 Pandemic

REMOTE – BUT NOT REMOVED

Julie Myers Wood Chief Executive Officer, Guidepost Solutions Former Head of Immigration and Customs Enforcement (ICE), DHS Held Significant Roles in Departments of Justice, Homeland Security,

Treasury, and Commerce, as well as at the White House

Megan Prendergast Millard Senior Managing Director, Guidepost Solutions Deputy Superintendent for Enforcement, NYDFS Office of General Counsel, NYDFS Assistant District Attorney, Brooklyn

Brief Bios

IMMEDIATE REALITIES FOR COMPLIANCE DEPARTMENTS

01Compliance departments are not revenue-generators and are likely already operating with leaner budgets prior to the COVID-19 pandemic

02The business side of the enterprise may at the same time be experiencing serious challenges during the COVIC-19 pandemic

03 While government, law enforcement and regulatory agencies have made statements that demonstrated a level of understanding, that does not equate to a complete “pass” when it comes to legal or regulatory requirements

04 Unfortunately, financial crime is in turn on the rise as fraudsters see this pandemic as another way to exploit people and companies when they are feeling vulnerable

REALITY

Given the foregoing, it is of paramount importance that your compliance program continues to function effectively during the pandemic

RUNNING AN EFFECTIVE COMPLIANCE PROGRAM

CommunicationsPeople PrioritiesOperations

PEOPLE: STAFFING

Contingency staffing plan in “overdrive”

Geographical considerations

Temporary realignment from business to compliance

New collaborative work environment

PEOPLE: TRAINING

Targeted online programs for compliance department employees

Consideration of timing and/or subject of mandatory, enterprise-wide compliance training modules

Compliance & Non-Compliance Employees

COMMUNICATION

Communication BY Executives

Tone-at-the-Top

Competing priorities for emergency/crisis messaging

Reminders to all employees for certain policies and procedures now tailored to working remote

Strike a balance – understanding the new normal but maintaining the emphasis on the need for compliance

Communication TO Executives

Compliance Operational Challenges

Competing priorities across enterprise Executives need to know the critical

elements of the compliance department are functioning (or not)

OPERATIONS

Usual, day-to-day responsibilities (e.g., I-9s, watchlist screening)

Expedited business hiring for new COVID-19 offerings

Down-time or delayed patches to platforms/tools supporting the compliance program

Essential vs non-essential compliance vendors

Audit rights and other key terms and conditions in vendor contracts

VENDORS:Third Party Relationships

ONBOARDING:New Employees

PRIORITIES

Strategic Initiatives: Long & Short-Term

Remediation of gaps identified during past risk assessments, audits, etc.

Awareness of budget cuts across entire enterprise Documentation of decisions to delay or cancel compliance initiatives

KEY TAKEAWAYS

What are the main risks for your company and how can you continue to control those risks during the COVID-19 pandemic:

What is the location of your operations?

What are the risks associated with the industry sector you are operating in?

What is the regulatory landscape you are operating in and what guidance have those regulators provided?

How do you monitor use of third-party vendors?

Do you engage in transactions with foreign governments and how has COVID-19 effected those transactions?

Copyright © 2020, Guidepost Solutions LLC.

REMOTE…BUT NOT REMOVED Webinar Series

Upcom ing top ics:• Risk Mitigation Strategies for Businesses Navigating the

CARES Act; April 28• How COVID-19 is Impacting the World of Privacy; May 12

To register for upcoming webinars and to view past recordings, visit:

guidepostsolutions.com/webinar

CONTACT

Megan Prendergast MillardSenior Managing Director, Financial & Regulatory Compliance Servicesmmillard@guidepostsolutions.com

Julie Myers WoodChief Executive Officerjwood@guidepostsolutions.com