Can Driverless Compliance Programs Be Effective? One CECO's Perspective on AI
Our building blocks are: leadership, risk assessment, standards, training, awareness and monitoring. How a company executes these building blocks is the complicated part.
May 01, 2018 at 04:31 PM
6 minute read
I've worked at Walmart for nearly six years now. Every day I'm impressed by the people on my team and the leadership at the company. They challenge me to do my best every day. When I thought about this article, I thought about those people and how important they are to the company. Walmart has always been a company focused on people—whether it's delivering everyday low cost to our customers, or recognizing the great people we have working in our stores around the globe.
People at Walmart make the difference. Our people are guided and driven by our values—integrity being a key value for our over 2.3 million associates. When I think about artificial intelligence (AI), I am proud of the ways we are currently leveraging AI to have a better understanding of how our data works together and am excited about the opportunities to leverage AI in the future. However, it is important to remember, it will always be our people that make our company successful.
We think about our compliance program framework in terms of people, processes and systems. We built our program using “building blocks” that are mapped to different regulatory processes. Many companies go through the same exercise of regulatory mapping, but we tried to make our building blocks simple in the hope that our program efforts will be sustainable and easier to embed in the business. Our building blocks are: leadership, risk assessment, standards/controls, training, awareness, and monitoring/audit/response.
These building blocks address: (1) designing and defining our compliance goals; (2) formulating rules, principles, and assessing the risk; (3) implementing the program/rules and principles; and (4) monitoring and remediating identified violations.
This is all in the regulatory guidance and fairly straightforward, but how a company executes these building blocks effectively is more complex.
Design is important. If you get the design right, it makes everything else easier. So, when we plan our long-term strategy, we think about the business strategy. I've done that throughout my career, whether working in oilfield services in Africa or retail in Bentonville. What works for one company may not work for another. Thinking about people, process and systems has helped us ensure that our program efforts are in sync with the business strategy.
Five years ago, when I started in retail, I drew a series of circles—thinking about program maturity—using this framework. Inside the circles were three slices of a pie that represented people, process and systems.
I think about that systems piece of the pie when I think about artificial intelligence. As our program has matured, so has our use of technology. We now have a system to document and track thousands of licenses internationally in real time. We have a tool that uses spatial analytics to display data feeds from several different platforms in an interactive map. We have systems for training and monitoring. These tools help us automate processes, add speed, and eliminate repetitive, low-value activities, but they still rely on human judgment and design.
Working in over 60 countries in seven different industries, I have learned that design can be 80 percent of the problem or 80 percent of the solution. The design of a program varies depending upon the culture of the company, the values, the ways of doing business, the history of the company, the demographics, and the background of the employees that work in it.
Our technology piece of the pie has grown, but in my mind, people will always be there. One of my friends was telling me about this show on HBO called Westworld where robots seem to have a mind of their own and make decisions.
I think of artificial intelligence similarly to how my friend described that show. That would be one end of the spectrum—computers functioning with little human input (or in some cases on the show, no human input). For compliance, people are important, and our ethics program is a big part of our compliance culture. Somewhere in the middle of the artificial intelligence spectrum (where, on the one end, is a simple tool, and on the other end is Westworld) is where some of the tools that we use in our e-commerce compliance fall, such as image recognition for screening items. However, those tools rely on people to set up the rules and tell the computer what is permitted and what is not.
At the end of the day, for compliance, people and judgment are always part of the circle. I cannot imagine an effective program without human observation, study and analysis of how a company and its employees work together.
Can artificial intelligence help us identify symptoms of things that may not work well? The answer is yes. The companies of the future are going to be organized differently, and the fluidity of their structures will be paramount. As leaders in compliance, we have to ensure that we keep placing design as a relevant part of the agenda, using technology but not eliminating the value that great talent brings to the table.
Daniel Trujillo is the Senior Vice President and Chief Ethics & Compliance Officer for Walmart International. He joined Walmart in 2012, leading a rapidly expanding division that spans over 27 countries outside the United States. In his role, Daniel supports over 750,000 Walmart International employees with an organization that includes over 1,700 ethics and compliance professionals spread across the world, managing 14 different subject matters. Originally from Argentina, Daniel speaks five languages and has worked in over 60 countries on five continents—addressing compliance areas ranging from anti-corruption to trade. Before joining Walmart, he served as Deputy General Counsel and Director of Compliance at Schlumberger Ltd.—a global supplier of technology, integrated project management, and information solutions for customers working in the oil and gas industry. He previously worked at Cargill and Impregilo S.p.A.
Daniel graduated from the University of Buenos Aires Law School and went on to complete a Master of Business Administration (MBA) at Salvador University (Argentina) and Deusto (Spain), as well as a Master of International Commercial Law (LLM) at University of California, Davis.
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