Pesky little emails

Hard to believe that people are still tripping over emails.

“Emails Raise Doubts on FBI Plan,” The Wall Street Journal, November 3, 2018 A3.  Emails surface contradicting White House claims that moving the FBI from Pennsylvania Avenue in Washington D.C.  (as proposed by the prior administration) would cost more than leaving it where it is (down the street from the Department of Justice and across the street from the Trump Hotel).

Perhaps there were “soft costs” involved in the move than weren’t considered, or there were other reasons for not moving the FBI from its current location, notwithstanding the higher cost.  But it is embarrassing when emails coming to a different conclusion are discovered.

How transparent is your decision-making process?  Do you allow for some contrary information in your final decision?  Is that proactive information management of negative information?  Do you have a policy or a procedure on this?  Should you?

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Filed under Controls, Duty, Governance, Government, Information, Internal controls, Oversight, To report

Tracking

“Technology Puts Pinch on Oil Smuggling,” The Wall Street Journal, November 2, 2018 B6.  Smugglers of Iranian crude will be challenged by satellites and big data.

Smugglers had in the past “hid” their ships, but that will now be harder.  Certain companies find a business opportunity in helping to track these vessels.

What controls do you need to have in place to make sure your policies are followed?  How have people tried to avoid your controls?  How did you/will you respond?  Is there a market opportunity for others to help you enforce compliance by collecting other information?

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Filed under Analytics, Collection, Compliance (General), Controls, Governance, Information, Oversight, Third parties, Use, Value

Better than nothing?

Have you ever misused your company credit card?  How about used a company asset for your personal business?

“Gulfport CEO Exits Following Review,” The Wall Street Journal, November 2, 2018 B2.  CEO resigns after investigation into his use of his company credit card (he had paid the charges back, eventually, without interest) and the company plane.

On departure, he gets $400,000 and 6 months of health care coverage.  I don’t know whether that’s better than nothing.

The ground troops learn from their “betters.”  Seeing the CEO get canned for policy violations firms up the perception of the seriousness with which the company treats violations of policy or procedure.  More so than a ground troop getting canned.

Does your company publicize these stories?

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Filed under Compliance, Controls, Corporation, Duty, Employees, Governance, Internal controls, Oversight, Policy, Protect assets

Information economy

“Alternative Data Is Valued on Wall Street,”The Wall Street Journal, November 2, 2018 B1.  Companies mine different types of available information to help traders.

Is information is worth so much, won’t someone start a business to provide it?  Apparently.  What should you be monitoring to understand how your customers make their purchasing decisions, or what your competitors are doing?

Drones looking at parking lots and where are the iPhones coming from and going to and how many construction permits were issued?  What’s your metric?  How do you measure it?

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Filed under Access, Analytics, Collection, Data quality, Definition, Information, Use, Value

Taking ownership

What’s the most effective way to let management know there’s a sexual harassment problem in your workplace?  Who owns the culture at your company?

“Google Workers Walk Out In Protest,” The Wall Street Journal, November 2, 2018 B1.  Thousands walked out in protest.

Certainly, a different vector for applying pressure; perhaps better than coming from the investors.  If there’s something wrong with your company’s culture, can you take action?  Is this limited to sexual harassment?  Is this evidence of harassment in any of the pending actions?

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Filed under Controls, Culture, Governance, Oversight, Ownership

Fraud at the top

“Former Goldman Bankers Charged,” The Wall Street Journal, November 2, 2018 A1. “Two senior … bankers allegedly paid bribes and stole and laundered money … [in] one of the biggest financial frauds in history.”

What does it say when two of your 435 partners and one of your managing directors commits a fraud?  Failures in systems/controls?  Bad culture?  Do you have a “cowboy atmosphere” in Asia?  Poor training?  Are these rogue employees?  What’s the impact on your reputation?  What was the tone at the top?

This is primarily a Governance point.  How will the new CEO handle?

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Filed under Compliance, Compliance (General), Controls, Corporation, Culture, Directors, Duty, Duty of Care, Employees, Governance, Oversight, Policy, Supervision, Who is in charge?

Cheaters

“Market Cheats Get Caught More Often,” The Wall Street Journal, November 1, 2018 B10.  Traders manipulating prices by spoofing real futures trades are getting caught and prosecuted for criminal violations.  Exchanges cooperating with enforcement authorities.

If accurate information is worth X, what is inaccurate information worth?  It depends, whether you are buying or selling based on it.

So, this is both Information (information includes both accurate and inaccurate information) and Governance (manipulating market trades with false information is a crime that the CFTC and DOJ prosecute).

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Filed under Accuracy, Compliance, Compliance (General), Controls, Corporation, Data quality, Definition, Duty, Duty of Care, Employees, Governance, Information, Oversight