Compliance into the Weeds http://compliancepodcastnetwork.net en What happens when two compliance aficionados get together to talk all things compliance, risk management and ERM? You get Tom Fox, the Voice of Compliance and Matt Kelly, the Coolest Guy in Compliance, going into the weeds of a topic each week. Each week, you can take a deep dive with two of the top writers, thinkers and prognosticators in compliance.  https://megaphone.imgix.net/podcasts/7a954b1a-d30e-11e8-87cc-2f03e1d4419c/image/50dc237c1b75e8920f563e030ffe58eb.png?ixlib=rails-4.3.1&max-w=3000&max-h=3000&fit=crop&auto=format,compress Compliance into the Weeds http://compliancepodcastnetwork.net no episodic complianceintotheweeds Tom Fox What happens when two compliance aficionados get together to talk all things compliance, risk management and ERM? You get Tom Fox, the Voice of Compliance and Matt Kelly, the Coolest Guy in Compliance, going into the weeds of a topic each week. Each week, you can take a deep dive with two of the top writers, thinkers and prognosticators in compliance.  What happens when two compliance aficionados get together to talk all things compliance, risk management and ERM? You get Tom Fox, the Voice of Compliance and Matt Kelly, the Coolest Guy in Compliance, going into the weeds of a topic each week. Each week, you can take a deep dive with two of the top writers, thinkers and prognosticators in compliance. 

]]> Tom Fox tfox@tfoxlaw.com Navigating DOJ's Evolving Self-Disclosure Strategies The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore the subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a recent Law360 post by Hui Chen on the evolving calculus for self-disclosure. Hui Chen’s insights into the Department of Justice’s (DOJ) evolving self-disclosure strategies are crucial for companies navigating the complexities of compliance in today’s uncertain regulatory environment. As a former DOJ compliance counsel and a Microsoft compliance officer, Chen emphasizes the challenges posed by a politicized, understaffed DOJ, urging companies to reassess their compliance programs amid shifting enforcement dynamics. Tom and Matt echo Chen’s concerns regarding the DOJ’s current state. Tom, acknowledging Chen’s expertise, highlights the impact of the department’s politicization and understaffing on the effectiveness of compliance efforts, while Matt underscores the importance of proactive self-disclosure despite uncertainties, stressing the potential risks of inaction under the current administration. Both agree that the fractured nature of the DOJ requires a reevaluation of traditional compliance and self-disclosure strategies. Key highlights: Navigating DOJ Self-Disclosure Strategies with Wei Chen Justice Department’s Impact on Corporate Prosecutions Mitigating Criminal Violations through Self-Disclosure Benefits of Self-Disclosure in Corporate Enforcement Resources: Hui Chen on Law360 (sub req’d) Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Apr 2026 05:00:00 -0000 full 464 Tom Fox Tom and Matt consider a recent piece by Hui Chen on assessing self-disclosure. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore the subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a recent Law360 post by Hui Chen on the evolving calculus for self-disclosure. Hui Chen’s insights into the Department of Justice’s (DOJ) evolving self-disclosure strategies are crucial for companies navigating the complexities of compliance in today’s uncertain regulatory environment. As a former DOJ compliance counsel and a Microsoft compliance officer, Chen emphasizes the challenges posed by a politicized, understaffed DOJ, urging companies to reassess their compliance programs amid shifting enforcement dynamics. Tom and Matt echo Chen’s concerns regarding the DOJ’s current state. Tom, acknowledging Chen’s expertise, highlights the impact of the department’s politicization and understaffing on the effectiveness of compliance efforts, while Matt underscores the importance of proactive self-disclosure despite uncertainties, stressing the potential risks of inaction under the current administration. Both agree that the fractured nature of the DOJ requires a reevaluation of traditional compliance and self-disclosure strategies. Key highlights: Navigating DOJ Self-Disclosure Strategies with Wei Chen Justice Department’s Impact on Corporate Prosecutions Mitigating Criminal Violations through Self-Disclosure Benefits of Self-Disclosure in Corporate Enforcement Resources: Hui Chen on Law360 (sub req’d) Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore the subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a recent Law360 post by Hui Chen on the evolving calculus for self-disclosure.

Hui Chen’s insights into the Department of Justice’s (DOJ) evolving self-disclosure strategies are crucial for companies navigating the complexities of compliance in today’s uncertain regulatory environment. As a former DOJ compliance counsel and a Microsoft compliance officer, Chen emphasizes the challenges posed by a politicized, understaffed DOJ, urging companies to reassess their compliance programs amid shifting enforcement dynamics. Tom and Matt echo Chen’s concerns regarding the DOJ’s current state. Tom, acknowledging Chen’s expertise, highlights the impact of the department’s politicization and understaffing on the effectiveness of compliance efforts, while Matt underscores the importance of proactive self-disclosure despite uncertainties, stressing the potential risks of inaction under the current administration. Both agree that the fractured nature of the DOJ requires a reevaluation of traditional compliance and self-disclosure strategies.

Key highlights:

  • Navigating DOJ Self-Disclosure Strategies with Wei Chen
  • Justice Department’s Impact on Corporate Prosecutions
  • Mitigating Criminal Violations through Self-Disclosure
  • Benefits of Self-Disclosure in Corporate Enforcement

Resources:

Hui Chen on Law360 (sub req’d)

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

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]]> 1397 no Banking Regulators Cut Model Risk Guidance: Implications for Compliance, Audit, and AML Oversight The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully, and looking for some hard-hitting insights on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss new Federal Reserve, FDIC, and OCC model risk management guidance issued late Friday, arguing it replaces detailed, bright-line expectations with thin, principles-based language. They contrast the prior OCC guidance (109 pages) with the new 12-page document, saying it describes model risk governance abstractly but offers little direction on what banks should do, leaving decisions about materiality and oversight to management. They highlight practical consequences for bank compliance and internal audit, including reduced leverage to insist on prudent governance, potential weakening of AML model oversight under the strict-liability Bank Secrecy Act, and the risk of more arbitrary enforcement amid reduced regulatory staffing. They also note that the guidance excludes AI models, with future AI guidance promised only through a later comment process. Key highlights: From 109 pages to 12 Principles vs specifics debate Internal audit sidelined Regulators and capacity cuts AI models left out  Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Apr 2026 04:00:00 -0000 full Tom Fox What does the FED and OCC say about Risk Management in 2026? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully, and looking for some hard-hitting insights on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss new Federal Reserve, FDIC, and OCC model risk management guidance issued late Friday, arguing it replaces detailed, bright-line expectations with thin, principles-based language. They contrast the prior OCC guidance (109 pages) with the new 12-page document, saying it describes model risk governance abstractly but offers little direction on what banks should do, leaving decisions about materiality and oversight to management. They highlight practical consequences for bank compliance and internal audit, including reduced leverage to insist on prudent governance, potential weakening of AML model oversight under the strict-liability Bank Secrecy Act, and the risk of more arbitrary enforcement amid reduced regulatory staffing. They also note that the guidance excludes AI models, with future AI guidance promised only through a later comment process. Key highlights: From 109 pages to 12 Principles vs specifics debate Internal audit sidelined Regulators and capacity cuts AI models left out  Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully, and looking for some hard-hitting insights on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss new Federal Reserve, FDIC, and OCC model risk management guidance issued late Friday, arguing it replaces detailed, bright-line expectations with thin, principles-based language.

They contrast the prior OCC guidance (109 pages) with the new 12-page document, saying it describes model risk governance abstractly but offers little direction on what banks should do, leaving decisions about materiality and oversight to management. They highlight practical consequences for bank compliance and internal audit, including reduced leverage to insist on prudent governance, potential weakening of AML model oversight under the strict-liability Bank Secrecy Act, and the risk of more arbitrary enforcement amid reduced regulatory staffing. They also note that the guidance excludes AI models, with future AI guidance promised only through a later comment process.

Key highlights:

  • From 109 pages to 12
  • Principles vs specifics debate
  • Internal audit sidelined
  • Regulators and capacity cuts
  • AI models left out 

Resources:

Matt on Radical Compliance

 Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

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]]> 1381 no Surveying Retaliation Against Compliance Officers The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a new anonymous Radical Compliance survey, launched with Case IQ and Compliance Week, to quantify retaliation against compliance officers who raise compliance concerns to senior management. The survey asks what misconduct was reported, who retaliated, what forms of retaliation took place, such as firing, demotion, harassment, budget cuts, blacklisting, and what actions followed. Matt also encourages responses even from those who have not experienced retaliation. Tom and Matt have previously discussed anecdotally but have not systematically studied, and plan to publish their findings and host a webinar later in the spring, likely in June. They also discuss potential structural protections informed by data, such as disclosure expectations around CCO departures (e.g., 8-K concepts) and contract/regulatory-approval models like those in India’s banking sector, and suggest that the findings could inform DOJ views on compliance autonomy and effective compliance programs. Key highlights: Survey Launch Explained Retaliation Questions Why This Study Matters Defining Prevalence Using Findings for Change Final Call to Participate Resources: Matt on Radical Compliance Survey on Retaliation Against Compliance Professionals Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Apr 2026 04:00:00 -0000 full 462 Tom Fox The Radical Compliance survey on retaliation against CCOs. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a new anonymous Radical Compliance survey, launched with Case IQ and Compliance Week, to quantify retaliation against compliance officers who raise compliance concerns to senior management. The survey asks what misconduct was reported, who retaliated, what forms of retaliation took place, such as firing, demotion, harassment, budget cuts, blacklisting, and what actions followed. Matt also encourages responses even from those who have not experienced retaliation. Tom and Matt have previously discussed anecdotally but have not systematically studied, and plan to publish their findings and host a webinar later in the spring, likely in June. They also discuss potential structural protections informed by data, such as disclosure expectations around CCO departures (e.g., 8-K concepts) and contract/regulatory-approval models like those in India’s banking sector, and suggest that the findings could inform DOJ views on compliance autonomy and effective compliance programs. Key highlights: Survey Launch Explained Retaliation Questions Why This Study Matters Defining Prevalence Using Findings for Change Final Call to Participate Resources: Matt on Radical Compliance Survey on Retaliation Against Compliance Professionals Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a new anonymous Radical Compliance survey, launched with Case IQ and Compliance Week, to quantify retaliation against compliance officers who raise compliance concerns to senior management.

The survey asks what misconduct was reported, who retaliated, what forms of retaliation took place, such as firing, demotion, harassment, budget cuts, blacklisting, and what actions followed. Matt also encourages responses even from those who have not experienced retaliation. Tom and Matt have previously discussed anecdotally but have not systematically studied, and plan to publish their findings and host a webinar later in the spring, likely in June. They also discuss potential structural protections informed by data, such as disclosure expectations around CCO departures (e.g., 8-K concepts) and contract/regulatory-approval models like those in India’s banking sector, and suggest that the findings could inform DOJ views on compliance autonomy and effective compliance programs.

Key highlights:

  • Survey Launch Explained
  • Retaliation Questions
  • Why This Study Matters
  • Defining Prevalence
  • Using Findings for Change
  • Final Call to Participate

Resources:

Matt on Radical Compliance

Survey on Retaliation Against Compliance Professionals

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

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]]> 1024 Duty Owed vs. Material Nonpublic Information: Prediction Markets and Compliance The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the prediction markets and what they mean for compliance.    Tom and Matt focus on the phrase “violation of a duty owed” by employees and notes that this standard appears significantly broader than traditional insider trading laws. They explain that insider trading law centers on the disclosure of material nonpublic information, whereas a “duty owed” framework emphasizes the underlying duty itself. Because “duty owed” could encompass many different types of obligations beyond material nonpublic information, the speaker highlights the potential compliance implications and expresses interest in exploring a related hypothetical scenario.  Resources  Tom   Instagram Facebook YouTube Twitter LinkedIn  A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Apr 2026 04:00:00 -0000 full 461 Tom Fox The prediction markets and compliance. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the prediction markets and what they mean for compliance.    Tom and Matt focus on the phrase “violation of a duty owed” by employees and notes that this standard appears significantly broader than traditional insider trading laws. They explain that insider trading law centers on the disclosure of material nonpublic information, whereas a “duty owed” framework emphasizes the underlying duty itself. Because “duty owed” could encompass many different types of obligations beyond material nonpublic information, the speaker highlights the potential compliance implications and expresses interest in exploring a related hypothetical scenario.  Resources  Tom   Instagram Facebook YouTube Twitter LinkedIn  A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the prediction markets and what they mean for compliance.   

Tom and Matt focus on the phrase “violation of a duty owed” by employees and notes that this standard appears significantly broader than traditional insider trading laws. They explain that insider trading law centers on the disclosure of material nonpublic information, whereas a “duty owed” framework emphasizes the underlying duty itself. Because “duty owed” could encompass many different types of obligations beyond material nonpublic information, the speaker highlights the potential compliance implications and expresses interest in exploring a related hypothetical scenario.

 Resources 

Tom  

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Facebook

YouTube

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LinkedIn

 A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence. 

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]]> 1470 no AI-Driven SOC Audits and the Growing Trust Gap The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss concerns that AI-driven automation may be weakening SOC 1 and SOC 2 audits used to assure vendor financial reporting controls and cybersecurity/privacy controls.   They focus on allegations by an anonymous whistleblower (“Deep Delver”) that tech startup Delve fabricates audit documentation with AI and relies on audit firms to rubber-stamp reports, claims Delve denies, potentially undermining trust in hundreds of SOC reports. Beyond Delve, they warn that startups are “fracturing” the traditional SOC audit model, driving timelines and costs from months and tens of thousands of dollars to days and a few thousand, encouraging check-the-box, low-quality audits, sometimes via little-known overseas firms. They note regulators are unlikely to intervene, leaving companies to reassess due diligence and the real assurance value of SOC reports.  Key Highlights  ·      Delve Whistleblower Claims ·      Red Flags in Audit Firms ·      How SOC Audits Work ·      Check the Box Trap ·      Regulatory Blind Spots ·      What Companies Should Do  Resources Delve accused of misleading customers with ‘fake compliance’ in YaHoo!Finance Delve response Promises of ‘fast and easy’ threaten SOC credibility in Journal of Accountancy  Tom   Instagram Facebook YouTube Twitter LinkedIn  A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Apr 2026 04:00:00 -0000 full 460 Tom Fox Wither SOC II audits? The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss concerns that AI-driven automation may be weakening SOC 1 and SOC 2 audits used to assure vendor financial reporting controls and cybersecurity/privacy controls.   They focus on allegations by an anonymous whistleblower (“Deep Delver”) that tech startup Delve fabricates audit documentation with AI and relies on audit firms to rubber-stamp reports, claims Delve denies, potentially undermining trust in hundreds of SOC reports. Beyond Delve, they warn that startups are “fracturing” the traditional SOC audit model, driving timelines and costs from months and tens of thousands of dollars to days and a few thousand, encouraging check-the-box, low-quality audits, sometimes via little-known overseas firms. They note regulators are unlikely to intervene, leaving companies to reassess due diligence and the real assurance value of SOC reports.  Key Highlights  ·      Delve Whistleblower Claims ·      Red Flags in Audit Firms ·      How SOC Audits Work ·      Check the Box Trap ·      Regulatory Blind Spots ·      What Companies Should Do  Resources Delve accused of misleading customers with ‘fake compliance’ in YaHoo!Finance Delve response Promises of ‘fast and easy’ threaten SOC credibility in Journal of Accountancy  Tom   Instagram Facebook YouTube Twitter LinkedIn  A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss concerns that AI-driven automation may be weakening SOC 1 and SOC 2 audits used to assure vendor financial reporting controls and cybersecurity/privacy controls.  

They focus on allegations by an anonymous whistleblower (“Deep Delver”) that tech startup Delve fabricates audit documentation with AI and relies on audit firms to rubber-stamp reports, claims Delve denies, potentially undermining trust in hundreds of SOC reports. Beyond Delve, they warn that startups are “fracturing” the traditional SOC audit model, driving timelines and costs from months and tens of thousands of dollars to days and a few thousand, encouraging check-the-box, low-quality audits, sometimes via little-known overseas firms. They note regulators are unlikely to intervene, leaving companies to reassess due diligence and the real assurance value of SOC reports. 

Key Highlights 

·      Delve Whistleblower Claims

·      Red Flags in Audit Firms

·      How SOC Audits Work

·      Check the Box Trap

·      Regulatory Blind Spots

·      What Companies Should Do

 Resources

Delve accused of misleading customers with ‘fake compliance’ in YaHoo!Finance

Delve response

Promises of ‘fast and easy’ threaten SOC credibility in Journal of Accountancy

 Tom  

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Facebook

YouTube

Twitter

LinkedIn

 A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence. 

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1391 no Balt and TradeStation: Lessons for the Compliance Professional The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the Declination awarded to Balt SAS and the OFAC enforcement action involving TradeStation.  First, they review a Corporate Enforcement Policy declination for French medical-equipment company BAL SAS and the company’s U.S. subsidiary after self-disclosing, cooperating and remediating misconduct involving a U.S. subsidiary executive and a Belgian consultant allegedly funneling about $600,000 in bribes to a French public hospital official using sham consulting agreements, invoices, and poor documentation; BAL disgorged about $1.21 million in profit on roughly $1.68 million in revenue and disclosed while its internal investigation was still ongoing, raising timing and high-margin red-flag issues. Second, they cover OFAC’s $1.1 million settlement with TradeStation for accidentally disabling sanctions-screening controls for nearly a year, enabling hundreds of transactions from Iran, Syria, and Crimea; despite having layered tools on paper, IT changes and lapsed subscriptions undermined those controls, underscoring the need for ongoing monitoring, testing, and auditing.  Key highlights: Balt FCPA Case Disclosure Timing Profit Margin Red Flags Controls and France Angle TradeStation Overview How Screening Failed Monitoring and Accountability Costs and OFAC Lessons Resources: Matt in ⁠Radical Compliance⁠ Tom in the ⁠FCPA Compliance Report⁠ Tom   ⁠Instagram⁠ ⁠Facebook⁠ ⁠YouTube⁠ ⁠Twitter⁠ ⁠LinkedIn⁠ A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Mar 2026 10:56:00 -0000 full 459 Tom Fox Tom and Matt look at the Balt declination and TradeStation enforcement action. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the Declination awarded to Balt SAS and the OFAC enforcement action involving TradeStation.  First, they review a Corporate Enforcement Policy declination for French medical-equipment company BAL SAS and the company’s U.S. subsidiary after self-disclosing, cooperating and remediating misconduct involving a U.S. subsidiary executive and a Belgian consultant allegedly funneling about $600,000 in bribes to a French public hospital official using sham consulting agreements, invoices, and poor documentation; BAL disgorged about $1.21 million in profit on roughly $1.68 million in revenue and disclosed while its internal investigation was still ongoing, raising timing and high-margin red-flag issues. Second, they cover OFAC’s $1.1 million settlement with TradeStation for accidentally disabling sanctions-screening controls for nearly a year, enabling hundreds of transactions from Iran, Syria, and Crimea; despite having layered tools on paper, IT changes and lapsed subscriptions undermined those controls, underscoring the need for ongoing monitoring, testing, and auditing.  Key highlights: Balt FCPA Case Disclosure Timing Profit Margin Red Flags Controls and France Angle TradeStation Overview How Screening Failed Monitoring and Accountability Costs and OFAC Lessons Resources: Matt in ⁠Radical Compliance⁠ Tom in the ⁠FCPA Compliance Report⁠ Tom   ⁠Instagram⁠ ⁠Facebook⁠ ⁠YouTube⁠ ⁠Twitter⁠ ⁠LinkedIn⁠ A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the Declination awarded to Balt SAS and the OFAC enforcement action involving TradeStation. 

First, they review a Corporate Enforcement Policy declination for French medical-equipment company BAL SAS and the company’s U.S. subsidiary after self-disclosing, cooperating and remediating misconduct involving a U.S. subsidiary executive and a Belgian consultant allegedly funneling about $600,000 in bribes to a French public hospital official using sham consulting agreements, invoices, and poor documentation; BAL disgorged about $1.21 million in profit on roughly $1.68 million in revenue and disclosed while its internal investigation was still ongoing, raising timing and high-margin red-flag issues.

Second, they cover OFAC’s $1.1 million settlement with TradeStation for accidentally disabling sanctions-screening controls for nearly a year, enabling hundreds of transactions from Iran, Syria, and Crimea; despite having layered tools on paper, IT changes and lapsed subscriptions undermined those controls, underscoring the need for ongoing monitoring, testing, and auditing.

 Key highlights:

  • Balt FCPA Case
  • Disclosure Timing
  • Profit Margin Red Flags
  • Controls and France Angle
  • TradeStation Overview
  • How Screening Failed
  • Monitoring and Accountability
  • Costs and OFAC Lessons

Resources:

Matt in ⁠Radical Compliance⁠

Tom in the ⁠FCPA Compliance Report⁠

Tom  

⁠Instagram⁠

⁠Facebook⁠

⁠YouTube⁠

⁠Twitter⁠

⁠LinkedIn⁠

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

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]]> 1620 no McKinsey’s Lilli AI Hack: What It Signals for AI Governance, Security and Disclosure The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look the recent hack of McKinsey’s AI tool Lilli.  Tom and Matt discuss a Financial Times report that a white-hat hacker, Paul Price of one-person firm Code Wall, exploited flaws in McKinsey’s internal AI tool “Lilli” to access millions of internal chat messages, view sensitive client-related file names, and see the model weights used to train the system; McKinsey patched the vulnerabilities after disclosure. They argue the incident highlights emerging AI risks beyond traditional cybersecurity, including AI agents autonomously scouting for targets, the possibility of attackers altering models to change outputs and create hard-to-detect “drift,” and confusion over who inside organizations owns AI security and governance. The episode also explores the messy, inconsistent disclosure landscape for AI-related incidents and urges compliance and GRC leaders to slow AI adoption, pressure-test systems, clarify accountability, ensure kill-switch/manual fallback capabilities, and consider reputational fallout.  Key Highlights  ·      McKinsey AI Hack Overview ·      Three Big Implications ·      Model Drift and Tampering ·      GRC Playbook for AI Risk ·      Accountability and Kill Switches  Resources Matt in Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn   A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Mar 2026 04:00:00 -0000 full 458 Tom Fox Tom and Matt look at the McKinsey AI hack. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look the recent hack of McKinsey’s AI tool Lilli.  Tom and Matt discuss a Financial Times report that a white-hat hacker, Paul Price of one-person firm Code Wall, exploited flaws in McKinsey’s internal AI tool “Lilli” to access millions of internal chat messages, view sensitive client-related file names, and see the model weights used to train the system; McKinsey patched the vulnerabilities after disclosure. They argue the incident highlights emerging AI risks beyond traditional cybersecurity, including AI agents autonomously scouting for targets, the possibility of attackers altering models to change outputs and create hard-to-detect “drift,” and confusion over who inside organizations owns AI security and governance. The episode also explores the messy, inconsistent disclosure landscape for AI-related incidents and urges compliance and GRC leaders to slow AI adoption, pressure-test systems, clarify accountability, ensure kill-switch/manual fallback capabilities, and consider reputational fallout.  Key Highlights  ·      McKinsey AI Hack Overview ·      Three Big Implications ·      Model Drift and Tampering ·      GRC Playbook for AI Risk ·      Accountability and Kill Switches  Resources Matt in Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn   A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look the recent hack of McKinsey’s AI tool Lilli. 

Tom and Matt discuss a Financial Times report that a white-hat hacker, Paul Price of one-person firm Code Wall, exploited flaws in McKinsey’s internal AI tool “Lilli” to access millions of internal chat messages, view sensitive client-related file names, and see the model weights used to train the system; McKinsey patched the vulnerabilities after disclosure. They argue the incident highlights emerging AI risks beyond traditional cybersecurity, including AI agents autonomously scouting for targets, the possibility of attackers altering models to change outputs and create hard-to-detect “drift,” and confusion over who inside organizations owns AI security and governance. The episode also explores the messy, inconsistent disclosure landscape for AI-related incidents and urges compliance and GRC leaders to slow AI adoption, pressure-test systems, clarify accountability, ensure kill-switch/manual fallback capabilities, and consider reputational fallout.

 Key Highlights 

·      McKinsey AI Hack Overview

·      Three Big Implications

·      Model Drift and Tampering

·      GRC Playbook for AI Risk

·      Accountability and Kill Switches

 Resources

Matt in Radical Compliance

 

Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

 

A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence. 

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]]> 1193 no Carrots and Sticks in Washington: Antitrust Whistleblowers and an FCPA SOL Extension The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look two recent developments sending a common message to compliance teams.   First, DOJ antitrust official Daniel Glad warns that a new Antitrust Whistleblower Awards program and increased pursuit of prison time for individuals compress companies’ timelines to investigate and self-disclose, because insiders may report first and cost those firms potential leniency. Second, Senate Democrats led by Elizabeth Warren propose the FCPA Reinforcement Act to extend the FCPA statute of limitations from five to 10 years for an eight-year window, aiming to preserve future enforcement capacity for misconduct occurring now. They connect these “sticks” with “carrots” such as fast declinations for self-disclosure, emphasizing the need for robust compliance programs, strong reporting culture, prompt investigations, and clear decisions on disclosure regardless of who controls Washington.  Key Highlights  ·      Two Washington Signals ·      Antitrust Whistleblower Push ·      FCPA Reinforcement Act ·      Carrots Sticks and Culture ·      Why Internal Reporting Matters ·      Self Disclosure Through Line  Resources Matt in Radical Compliance here and here  Tom   Instagram Facebook YouTube Twitter LinkedIn  A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Mar 2026 04:00:00 -0000 full 457 Tom Fox How the DOJ and Democratic Senators are upping the game for self-disclosure. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look two recent developments sending a common message to compliance teams.   First, DOJ antitrust official Daniel Glad warns that a new Antitrust Whistleblower Awards program and increased pursuit of prison time for individuals compress companies’ timelines to investigate and self-disclose, because insiders may report first and cost those firms potential leniency. Second, Senate Democrats led by Elizabeth Warren propose the FCPA Reinforcement Act to extend the FCPA statute of limitations from five to 10 years for an eight-year window, aiming to preserve future enforcement capacity for misconduct occurring now. They connect these “sticks” with “carrots” such as fast declinations for self-disclosure, emphasizing the need for robust compliance programs, strong reporting culture, prompt investigations, and clear decisions on disclosure regardless of who controls Washington.  Key Highlights  ·      Two Washington Signals ·      Antitrust Whistleblower Push ·      FCPA Reinforcement Act ·      Carrots Sticks and Culture ·      Why Internal Reporting Matters ·      Self Disclosure Through Line  Resources Matt in Radical Compliance here and here  Tom   Instagram Facebook YouTube Twitter LinkedIn  A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look two recent developments sending a common message to compliance teams.  

First, DOJ antitrust official Daniel Glad warns that a new Antitrust Whistleblower Awards program and increased pursuit of prison time for individuals compress companies’ timelines to investigate and self-disclose, because insiders may report first and cost those firms potential leniency. Second, Senate Democrats led by Elizabeth Warren propose the FCPA Reinforcement Act to extend the FCPA statute of limitations from five to 10 years for an eight-year window, aiming to preserve future enforcement capacity for misconduct occurring now. They connect these “sticks” with “carrots” such as fast declinations for self-disclosure, emphasizing the need for robust compliance programs, strong reporting culture, prompt investigations, and clear decisions on disclosure regardless of who controls Washington. 

Key Highlights 

·      Two Washington Signals

·      Antitrust Whistleblower Push

·      FCPA Reinforcement Act

·      Carrots Sticks and Culture

·      Why Internal Reporting Matters

·      Self Disclosure Through Line

 Resources

Matt in Radical Compliance here and here

 Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

 A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence. 

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]]> 1144 no SDNY’s New Declination Policy: Crime Categories, Cooperation, and Compliance Implications The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the recently announced new Southern District of New York standard for Declinations. They look at SDNY U.S. Attorney Jay Clayton’s newly released self-disclosure/cooperation/declination policy and its implications for corporate compliance. While the core elements, prompt voluntary disclosure, cooperation, remediation, and restitution, mirror existing DOJ expectations, they highlight a significant change: SDNY now treats “aggravated circumstances” as certain categories of crimes that are categorically ineligible for declinations, including foreign corruption/FCPA, sanctions evasion, terrorism, sex trafficking with minors, smuggling, drug cartels, and forced labor, rather than focusing on offense traits such as senior management involvement or recidivism. They note potential inconsistencies with DOJ’s corporate enforcement approach, uncertainty about disclosure timing despite references to promptness and pre-investigation disclosure, broad discretion in enforcement, and the risk of forum shopping. Key highlights: Why SDNY Declinations Matter Clayton Policy Key Changes Aggravated Circumstances Redefined FCPA Carve Out Confusion Timing and Disclosure Pressure Cooperation Restitution Disgorgement Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Mar 2026 05:00:00 -0000 full 456 Tom Fox Tom and Matt look at the new SDNY policy on declinations. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the recently announced new Southern District of New York standard for Declinations. They look at SDNY U.S. Attorney Jay Clayton’s newly released self-disclosure/cooperation/declination policy and its implications for corporate compliance. While the core elements, prompt voluntary disclosure, cooperation, remediation, and restitution, mirror existing DOJ expectations, they highlight a significant change: SDNY now treats “aggravated circumstances” as certain categories of crimes that are categorically ineligible for declinations, including foreign corruption/FCPA, sanctions evasion, terrorism, sex trafficking with minors, smuggling, drug cartels, and forced labor, rather than focusing on offense traits such as senior management involvement or recidivism. They note potential inconsistencies with DOJ’s corporate enforcement approach, uncertainty about disclosure timing despite references to promptness and pre-investigation disclosure, broad discretion in enforcement, and the risk of forum shopping. Key highlights: Why SDNY Declinations Matter Clayton Policy Key Changes Aggravated Circumstances Redefined FCPA Carve Out Confusion Timing and Disclosure Pressure Cooperation Restitution Disgorgement Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the recently announced new Southern District of New York standard for Declinations.

They look at SDNY U.S. Attorney Jay Clayton’s newly released self-disclosure/cooperation/declination policy and its implications for corporate compliance. While the core elements, prompt voluntary disclosure, cooperation, remediation, and restitution, mirror existing DOJ expectations, they highlight a significant change: SDNY now treats “aggravated circumstances” as certain categories of crimes that are categorically ineligible for declinations, including foreign corruption/FCPA, sanctions evasion, terrorism, sex trafficking with minors, smuggling, drug cartels, and forced labor, rather than focusing on offense traits such as senior management involvement or recidivism. They note potential inconsistencies with DOJ’s corporate enforcement approach, uncertainty about disclosure timing despite references to promptness and pre-investigation disclosure, broad discretion in enforcement, and the risk of forum shopping.

Key highlights:

  • Why SDNY Declinations Matter
  • Clayton Policy Key Changes
  • Aggravated Circumstances Redefined
  • FCPA Carve Out Confusion
  • Timing and Disclosure Pressure
  • Cooperation Restitution Disgorgement

Resources:

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

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]]> 1358 no FCPA Trial Rarity: Charles Hobson Convicted The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the recent conviction of Charles ‘Hunter” Hobson for FCPA violations. Former Corsa Coal senior sales executive Charles Hunter Hobson was found guilty in Pennsylvania of helping arrange roughly $4.8 million in bribes to officials tied to a state-owned Egyptian coal company, using an intermediary, to secure about $143 million in contracts. Also, Hobson allegedly pocketed about $200,000. Tom and Matt  Hobson’s unsuccessful “dog bite” defenses. They also discuss tensions between corporate and individual accountability, the practical reality that companies may cooperate and “turn on” individuals, and that individuals can also expose companies by cooperating with prosecutors. Finally, they speculate on why DOJ pursued trial amid shifting enforcement signals, referencing other recent FCPA matters (Millicom DPA, Smartmatic indictment) and past DOJ trial losses, and conclude that the best approach is to avoid bribery and avoid being the “last man standing.” Key highlights: Hobson Case Overview Dog Bite Defense Breakdown Payment Red Flags Declinations and Individual Risk Why Go to Trial? Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Feb 2026 05:00:00 -0000 full 454 Tom Fox Tom and Matt review the Hobson FCPA trial conviction. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the recent conviction of Charles ‘Hunter” Hobson for FCPA violations. Former Corsa Coal senior sales executive Charles Hunter Hobson was found guilty in Pennsylvania of helping arrange roughly $4.8 million in bribes to officials tied to a state-owned Egyptian coal company, using an intermediary, to secure about $143 million in contracts. Also, Hobson allegedly pocketed about $200,000. Tom and Matt  Hobson’s unsuccessful “dog bite” defenses. They also discuss tensions between corporate and individual accountability, the practical reality that companies may cooperate and “turn on” individuals, and that individuals can also expose companies by cooperating with prosecutors. Finally, they speculate on why DOJ pursued trial amid shifting enforcement signals, referencing other recent FCPA matters (Millicom DPA, Smartmatic indictment) and past DOJ trial losses, and conclude that the best approach is to avoid bribery and avoid being the “last man standing.” Key highlights: Hobson Case Overview Dog Bite Defense Breakdown Payment Red Flags Declinations and Individual Risk Why Go to Trial? Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the recent conviction of Charles ‘Hunter” Hobson for FCPA violations.

Former Corsa Coal senior sales executive Charles Hunter Hobson was found guilty in Pennsylvania of helping arrange roughly $4.8 million in bribes to officials tied to a state-owned Egyptian coal company, using an intermediary, to secure about $143 million in contracts. Also, Hobson allegedly pocketed about $200,000. Tom and Matt  Hobson’s unsuccessful “dog bite” defenses. They also discuss tensions between corporate and individual accountability, the practical reality that companies may cooperate and “turn on” individuals, and that individuals can also expose companies by cooperating with prosecutors. Finally, they speculate on why DOJ pursued trial amid shifting enforcement signals, referencing other recent FCPA matters (Millicom DPA, Smartmatic indictment) and past DOJ trial losses, and conclude that the best approach is to avoid bribery and avoid being the “last man standing.”

Key highlights:

  • Hobson Case Overview
  • Dog Bite Defense Breakdown
  • Payment Red Flags
  • Declinations and Individual Risk
  • Why Go to Trial?

Resources

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1452 no Truth Stranger the Fiction: Binance, Iran, Crypto and Compliance The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at recent reporting on Binance that raises questions about the effectiveness of its compliance program, monitorships, and executive attitudes toward compliance. They recap Binance’s 2023 resolution of U.S. criminal and civil matters involving money laundering and sanctions evasion. They discuss the Fortune article, which reported that Binance continued to route funds through its platform to the Iranian government in 2024 and into 2025. They highlight Mr. Zou’s public response on X, suggesting that if investigators found misconduct, it implied they failed to prevent it, which the hosts criticize as a misunderstanding that business units own risk and that compliance’s role is to provide systems, channels, oversight, and escalation rather than “prevent” all misconduct. Key highlights: Truth Stranger Than Fiction in Compliance Binance’s 2023 Guilty Plea, $4.3B Penalty & Two Monitorships Compliance Team Fallout: Investigators Fired & CCO on the Move ‘If You Found It, You Failed’: Why CEOs Misunderstand Compliance Iran as the Red Line: Plea Agreement Breach, Politics, and Corruption Risk Will Anyone Enforce This? Rule of Law Questions and What Comes Next Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Feb 2026 05:00:00 -0000 full 454 Tom Fox Tom and Matt look at Binance. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at recent reporting on Binance that raises questions about the effectiveness of its compliance program, monitorships, and executive attitudes toward compliance. They recap Binance’s 2023 resolution of U.S. criminal and civil matters involving money laundering and sanctions evasion. They discuss the Fortune article, which reported that Binance continued to route funds through its platform to the Iranian government in 2024 and into 2025. They highlight Mr. Zou’s public response on X, suggesting that if investigators found misconduct, it implied they failed to prevent it, which the hosts criticize as a misunderstanding that business units own risk and that compliance’s role is to provide systems, channels, oversight, and escalation rather than “prevent” all misconduct. Key highlights: Truth Stranger Than Fiction in Compliance Binance’s 2023 Guilty Plea, $4.3B Penalty & Two Monitorships Compliance Team Fallout: Investigators Fired & CCO on the Move ‘If You Found It, You Failed’: Why CEOs Misunderstand Compliance Iran as the Red Line: Plea Agreement Breach, Politics, and Corruption Risk Will Anyone Enforce This? Rule of Law Questions and What Comes Next Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at recent reporting on Binance that raises questions about the effectiveness of its compliance program, monitorships, and executive attitudes toward compliance.

They recap Binance’s 2023 resolution of U.S. criminal and civil matters involving money laundering and sanctions evasion. They discuss the Fortune article, which reported that Binance continued to route funds through its platform to the Iranian government in 2024 and into 2025. They highlight Mr. Zou’s public response on X, suggesting that if investigators found misconduct, it implied they failed to prevent it, which the hosts criticize as a misunderstanding that business units own risk and that compliance’s role is to provide systems, channels, oversight, and escalation rather than “prevent” all misconduct.

Key highlights:

  • Truth Stranger Than Fiction in Compliance
  • Binance’s 2023 Guilty Plea, $4.3B Penalty & Two Monitorships
  • Compliance Team Fallout: Investigators Fired & CCO on the Move
  • ‘If You Found It, You Failed’: Why CEOs Misunderstand Compliance
  • Iran as the Red Line: Plea Agreement Breach, Politics, and Corruption Risk
  • Will Anyone Enforce This? Rule of Law Questions and What Comes Next

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1205 no NPAs, Escalation and Ethics in Competing The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at three recent stories to draw compliance lessons for the future. They discuss significant developments in compliance, focusing on Jay Clayton’s recent speech regarding FCPA enforcement and the implications for companies. They also analyze a case involving the termination of compliance officers at Scotiabank for failing to escalate concerns about insider trading. The conversation concludes with a reflection on athlete decision-making in the context of injuries and the lessons for corporate compliance practices. Key highlights: Jay Clayton’s Speech and White Collar Crime Prosecution Compliance Officers and Escalation Failures at Scotiabank Ethics in Sports: Decision-Making and Compliance Lessons Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Feb 2026 05:00:00 -0000 full Tom Fox Today, we consider self-disclosure, NPAs, terminated compliance officers, and Lindsey Vonn. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at three recent stories to draw compliance lessons for the future. They discuss significant developments in compliance, focusing on Jay Clayton’s recent speech regarding FCPA enforcement and the implications for companies. They also analyze a case involving the termination of compliance officers at Scotiabank for failing to escalate concerns about insider trading. The conversation concludes with a reflection on athlete decision-making in the context of injuries and the lessons for corporate compliance practices. Key highlights: Jay Clayton’s Speech and White Collar Crime Prosecution Compliance Officers and Escalation Failures at Scotiabank Ethics in Sports: Decision-Making and Compliance Lessons Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at three recent stories to draw compliance lessons for the future.

They discuss significant developments in compliance, focusing on Jay Clayton’s recent speech regarding FCPA enforcement and the implications for companies. They also analyze a case involving the termination of compliance officers at Scotiabank for failing to escalate concerns about insider trading. The conversation concludes with a reflection on athlete decision-making in the context of injuries and the lessons for corporate compliance practices.

Key highlights:

  • Jay Clayton’s Speech and White Collar Crime Prosecution
  • Compliance Officers and Escalation Failures at Scotiabank
  • Ethics in Sports: Decision-Making and Compliance Lessons

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

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]]> 1656 no The Reality of AI Adoption in Corporate Compliance The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly examine three recent surveys that examine the real-world impact of AI adoption in corporate environments. Recording from Alexandria, Virginia, where Matt is attending a conference on ethical governance of AI, Matt and Tom discuss the differing perceptions of AI’s benefits between senior executives and other employees. They explore findings from PWC, Section, and Workday surveys, uncovering a significant gap in AI’s perceived value. The discussion highlights the challenges of integrating AI, the significant rework required by employees, and the struggle to build trust in AI tools. They also debate whether enterprise-scale AI deployment or incremental, point-specific adoption is the best path forward. Key highlights: Conference on Ethical AI Governance Reality Checks on AI Adoption AI Rework and Employee Training Concerns Trust Issues with AI Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Feb 2026 05:00:00 -0000 full 452 Tom Fox Tom and Matt differ on AI adoption. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly examine three recent surveys that examine the real-world impact of AI adoption in corporate environments. Recording from Alexandria, Virginia, where Matt is attending a conference on ethical governance of AI, Matt and Tom discuss the differing perceptions of AI’s benefits between senior executives and other employees. They explore findings from PWC, Section, and Workday surveys, uncovering a significant gap in AI’s perceived value. The discussion highlights the challenges of integrating AI, the significant rework required by employees, and the struggle to build trust in AI tools. They also debate whether enterprise-scale AI deployment or incremental, point-specific adoption is the best path forward. Key highlights: Conference on Ethical AI Governance Reality Checks on AI Adoption AI Rework and Employee Training Concerns Trust Issues with AI Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly examine three recent surveys that examine the real-world impact of AI adoption in corporate environments.

Recording from Alexandria, Virginia, where Matt is attending a conference on ethical governance of AI, Matt and Tom discuss the differing perceptions of AI’s benefits between senior executives and other employees. They explore findings from PWC, Section, and Workday surveys, uncovering a significant gap in AI’s perceived value. The discussion highlights the challenges of integrating AI, the significant rework required by employees, and the struggle to build trust in AI tools. They also debate whether enterprise-scale AI deployment or incremental, point-specific adoption is the best path forward.

Key highlights:

  • Conference on Ethical AI Governance
  • Reality Checks on AI Adoption
  • AI Rework and Employee Training Concerns
  • Trust Issues with AI

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1663 no The Essence of Leadership and Why Donald Trump Is Not a Role Model The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of #ComplianceintotheWeeds, Tom Fox, and Matt Kelly look at the leadership failures from Donald Trump and his administration after the killing of Alex Pretti last weekend. This episode has significant editorial commentary. Matt and Tom critically examine the behavior and leadership failings of Donald Trump and his Administration in the wake of the shooting of Alex Pretti and argue that his approach is far from exemplary for CEOs or business leaders. The discussion highlights the essence of effective leadership as the ability to instill trust and direction, contrasting this with Trump's history of questionable business acumen and the allegations of his disastrous lying to the American people. The takeaway is that true leadership involves integrity, trustworthiness, and the ability to inspire and guide employees toward a common goal, traits that Trump is argued to lack.  Key highlights: Comparing CEOs to Donald Trump Crisis of hyper-transparency Corporate responses. Were they enough or a first step? Leadership and Trust Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Jan 2026 05:00:00 -0000 full 451 Tom Fox The crisis in Minnesota and leadership. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of #ComplianceintotheWeeds, Tom Fox, and Matt Kelly look at the leadership failures from Donald Trump and his administration after the killing of Alex Pretti last weekend. This episode has significant editorial commentary. Matt and Tom critically examine the behavior and leadership failings of Donald Trump and his Administration in the wake of the shooting of Alex Pretti and argue that his approach is far from exemplary for CEOs or business leaders. The discussion highlights the essence of effective leadership as the ability to instill trust and direction, contrasting this with Trump's history of questionable business acumen and the allegations of his disastrous lying to the American people. The takeaway is that true leadership involves integrity, trustworthiness, and the ability to inspire and guide employees toward a common goal, traits that Trump is argued to lack.  Key highlights: Comparing CEOs to Donald Trump Crisis of hyper-transparency Corporate responses. Were they enough or a first step? Leadership and Trust Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of #ComplianceintotheWeeds, Tom Fox, and Matt Kelly look at the leadership failures from Donald Trump and his administration after the killing of Alex Pretti last weekend. This episode has significant editorial commentary.

Matt and Tom critically examine the behavior and leadership failings of Donald Trump and his Administration in the wake of the shooting of Alex Pretti and argue that his approach is far from exemplary for CEOs or business leaders. The discussion highlights the essence of effective leadership as the ability to instill trust and direction, contrasting this with Trump's history of questionable business acumen and the allegations of his disastrous lying to the American people. The takeaway is that true leadership involves integrity, trustworthiness, and the ability to inspire and guide employees toward a common goal, traits that Trump is argued to lack. 

Key highlights:

  • Comparing CEOs to Donald Trump
  • Crisis of hyper-transparency
  • Corporate responses. Were they enough or a first step?
  • Leadership and Trust

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1580 yes Addressing Retaliation Against Compliance Officers: Strategies and Insights The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the challenges of retaliation against Chief Compliance Officers (CCOs). They highlight the need for ongoing communication between compliance officers and senior management, and share strategies for CCOs to mitigate personal risk. The discussion includes real-world examples, the role of senior management in fostering a compliant culture, and the importance of scenario planning and training to prepare for potential issues. The episode emphasizes proactive measures such as charm offensives and preemptive remediation plans to navigate and defuse potential retaliatory scenarios. Key highlights: Real-Life Examples of Retaliation Management’s Perception and Compliance Challenges Building Relationships with Senior Management Proactive Compliance Strategies to Prevent Retaliation Framing Compliance Training Like Cybersecurity Drills Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Jan 2026 05:00:00 -0000 full 450 Tom Fox A look at how to prevent retaliation against CCOs. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the challenges of retaliation against Chief Compliance Officers (CCOs). They highlight the need for ongoing communication between compliance officers and senior management, and share strategies for CCOs to mitigate personal risk. The discussion includes real-world examples, the role of senior management in fostering a compliant culture, and the importance of scenario planning and training to prepare for potential issues. The episode emphasizes proactive measures such as charm offensives and preemptive remediation plans to navigate and defuse potential retaliatory scenarios. Key highlights: Real-Life Examples of Retaliation Management’s Perception and Compliance Challenges Building Relationships with Senior Management Proactive Compliance Strategies to Prevent Retaliation Framing Compliance Training Like Cybersecurity Drills Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the challenges of retaliation against Chief Compliance Officers (CCOs).

They highlight the need for ongoing communication between compliance officers and senior management, and share strategies for CCOs to mitigate personal risk. The discussion includes real-world examples, the role of senior management in fostering a compliant culture, and the importance of scenario planning and training to prepare for potential issues. The episode emphasizes proactive measures such as charm offensives and preemptive remediation plans to navigate and defuse potential retaliatory scenarios.

Key highlights:

  • Real-Life Examples of Retaliation
  • Management’s Perception and Compliance Challenges
  • Building Relationships with Senior Management
  • Proactive Compliance Strategies to Prevent Retaliation
  • Framing Compliance Training Like Cybersecurity Drills

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1422 no The Department of Retribution The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the new DOJ AAG position which will report directly to the White House.    In this episode, Tom and Matt discuss the recent developments in the Department of Justice, particularly the establishment of a new Assistant Attorney General for fraud reporting directly to the White House. They explore the implications of this move, the regulatory chaos it may create, and the potential for politically motivated enforcement actions. The conversation emphasizes the uncertainty facing compliance professionals and the need for robust risk management strategies in light of these changes as well as the chaos capitalism the Administration has introduced into American business.  Key Highlights  ·      Introduction to the Department of Retribution ·      The New Assistant Attorney General for Fraud ·      Political Implications of Fraud Enforcement ·      Potential Targets of Enforcement ·      Navigating Chaos Capitalism ·      Risk Management Strategies for Compliance Professionals  Resources Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn   A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Jan 2026 05:00:00 -0000 full 449 Tom Fox What does the new DOJ AAG reporting to the White House mean for businesses. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the new DOJ AAG position which will report directly to the White House.    In this episode, Tom and Matt discuss the recent developments in the Department of Justice, particularly the establishment of a new Assistant Attorney General for fraud reporting directly to the White House. They explore the implications of this move, the regulatory chaos it may create, and the potential for politically motivated enforcement actions. The conversation emphasizes the uncertainty facing compliance professionals and the need for robust risk management strategies in light of these changes as well as the chaos capitalism the Administration has introduced into American business.  Key Highlights  ·      Introduction to the Department of Retribution ·      The New Assistant Attorney General for Fraud ·      Political Implications of Fraud Enforcement ·      Potential Targets of Enforcement ·      Navigating Chaos Capitalism ·      Risk Management Strategies for Compliance Professionals  Resources Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn   A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the new DOJ AAG position which will report directly to the White House. 

 

In this episode, Tom and Matt discuss the recent developments in the Department of Justice, particularly the establishment of a new Assistant Attorney General for fraud reporting directly to the White House. They explore the implications of this move, the regulatory chaos it may create, and the potential for politically motivated enforcement actions. The conversation emphasizes the uncertainty facing compliance professionals and the need for robust risk management strategies in light of these changes as well as the chaos capitalism the Administration has introduced into American business. 

Key Highlights 

·      Introduction to the Department of Retribution

·      The New Assistant Attorney General for Fraud

·      Political Implications of Fraud Enforcement

·      Potential Targets of Enforcement

·      Navigating Chaos Capitalism

·      Risk Management Strategies for Compliance Professionals

 Resources

Matt in Radical Compliance

Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

 

A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence. 

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]]> 1311 no Matt’s Key Compliance Issues and Trends to Watch in 2026 The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss key issues Matt is following in 2026. They look into anticipated FCPA enforcement actions against Chinese telecom giant ZTE and the controversial indictment of SmartMatic, raising concerns about possible politicization of compliance enforcement. The conversation also covers the potential impact on whistleblower cases if key Qui Tam lawsuits under the False Claims Act are invalidated, as well as the ongoing federal-state conflict over AI regulations. Additionally, they touch on the financial complexities and risks associated with AI funding deals, drawing parallels to past financial crises. Compliance officers are advised to prepare for an uncertain and challenging regulatory landscape in the year ahead. Key highlights: FCPA Enforcement in 2026 The Future of Qui Tam Lawsuits Federal Preemption of State AI Laws AI Accounting and Financial Risks Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 Jan 2026 05:00:00 -0000 full 448 Tom Fox Matt and Tom return to look into 2026. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss key issues Matt is following in 2026. They look into anticipated FCPA enforcement actions against Chinese telecom giant ZTE and the controversial indictment of SmartMatic, raising concerns about possible politicization of compliance enforcement. The conversation also covers the potential impact on whistleblower cases if key Qui Tam lawsuits under the False Claims Act are invalidated, as well as the ongoing federal-state conflict over AI regulations. Additionally, they touch on the financial complexities and risks associated with AI funding deals, drawing parallels to past financial crises. Compliance officers are advised to prepare for an uncertain and challenging regulatory landscape in the year ahead. Key highlights: FCPA Enforcement in 2026 The Future of Qui Tam Lawsuits Federal Preemption of State AI Laws AI Accounting and Financial Risks Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss key issues Matt is following in 2026.

They look into anticipated FCPA enforcement actions against Chinese telecom giant ZTE and the controversial indictment of SmartMatic, raising concerns about possible politicization of compliance enforcement. The conversation also covers the potential impact on whistleblower cases if key Qui Tam lawsuits under the False Claims Act are invalidated, as well as the ongoing federal-state conflict over AI regulations. Additionally, they touch on the financial complexities and risks associated with AI funding deals, drawing parallels to past financial crises. Compliance officers are advised to prepare for an uncertain and challenging regulatory landscape in the year ahead.

Key highlights:

  • FCPA Enforcement in 2026
  • The Future of Qui Tam Lawsuits
  • Federal Preemption of State AI Laws
  • AI Accounting and Financial Risks

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1948 no Special Holiday Episode: MGI’s Compliance Triumph in DOJ Tariff Evasion Case The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this final episode of Compliance into the Weeds for 2025, Tom Fox and Matt Kelly discuss an enforcement action by the Justice Department involving MGI International, a plastics manufacturer caught in a tariff evasion scheme orchestrated by its COO. The company avoided criminal prosecution by self-disclosing the misconduct, fully cooperating, and implementing compliance reforms, leading to a declination by the DOJ. We explore the case’s details, the role of independent internal investigations, and the implications for compliance policies under different administrations. Listeners are encouraged to consider the case as a roadmap for achieving favorable enforcement outcomes. Key highlights: Case Overview: MGI International’s Tariff Evasion Detailed Background of the Case Legal and Compliance Insights Analysis of DOJ’s Actions and Policies Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 31 Dec 2025 05:00:00 -0000 full 446 Tom Fox Tom and Matt close the year with a declination. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this final episode of Compliance into the Weeds for 2025, Tom Fox and Matt Kelly discuss an enforcement action by the Justice Department involving MGI International, a plastics manufacturer caught in a tariff evasion scheme orchestrated by its COO. The company avoided criminal prosecution by self-disclosing the misconduct, fully cooperating, and implementing compliance reforms, leading to a declination by the DOJ. We explore the case’s details, the role of independent internal investigations, and the implications for compliance policies under different administrations. Listeners are encouraged to consider the case as a roadmap for achieving favorable enforcement outcomes. Key highlights: Case Overview: MGI International’s Tariff Evasion Detailed Background of the Case Legal and Compliance Insights Analysis of DOJ’s Actions and Policies Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this final episode of Compliance into the Weeds for 2025, Tom Fox and Matt Kelly discuss an enforcement action by the Justice Department involving MGI International, a plastics manufacturer caught in a tariff evasion scheme orchestrated by its COO.

The company avoided criminal prosecution by self-disclosing the misconduct, fully cooperating, and implementing compliance reforms, leading to a declination by the DOJ. We explore the case’s details, the role of independent internal investigations, and the implications for compliance policies under different administrations. Listeners are encouraged to consider the case as a roadmap for achieving favorable enforcement outcomes.

Key highlights:

  • Case Overview: MGI International’s Tariff Evasion
  • Detailed Background of the Case
  • Legal and Compliance Insights
  • Analysis of DOJ’s Actions and Policies

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1293 no The DOJ's Inconsistent Stance on White Collar Crime and FCPA Enforcement The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the mixed and muddled messages coming out of the DOJ on FCPA and white collar enforcement.    We discuss recent signals from the DOJ suggesting a reinvigorated stance on corporate malfeasance, juxtaposed with actions like the pardoning of convicted offenders which muddle the overall message. The conversation covers Deputy Attorney General Todd Blanche's inflammatory speech on the seriousness of FCPA actions, the controversial pardons by President Trump, and the apparent selective enforcement against foreign versus U.S. companies. The episode examines the ramifications of these mixed signals for compliance professionals, companies, and whistleblowers, emphasizing the need for clearer guidance and consistency from the DOJ.  Key Highlights  ·      Mixed Messages from the Justice Department on FCPA and White Collar Enforcement ·      Deputy Attorney General's Angry Speech ·      Controversial Pardons and Their Implications ·      ZTE and FCPA Charges ·      Inconsistencies and Compliance Challenges ·      The Impact of Presidential Pardons on Compliance  Resources Matt in Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn  A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Dec 2025 05:00:00 -0000 full 445 Tom Fox Mixed and muddled messages from the DOJ on enforcement. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the mixed and muddled messages coming out of the DOJ on FCPA and white collar enforcement.    We discuss recent signals from the DOJ suggesting a reinvigorated stance on corporate malfeasance, juxtaposed with actions like the pardoning of convicted offenders which muddle the overall message. The conversation covers Deputy Attorney General Todd Blanche's inflammatory speech on the seriousness of FCPA actions, the controversial pardons by President Trump, and the apparent selective enforcement against foreign versus U.S. companies. The episode examines the ramifications of these mixed signals for compliance professionals, companies, and whistleblowers, emphasizing the need for clearer guidance and consistency from the DOJ.  Key Highlights  ·      Mixed Messages from the Justice Department on FCPA and White Collar Enforcement ·      Deputy Attorney General's Angry Speech ·      Controversial Pardons and Their Implications ·      ZTE and FCPA Charges ·      Inconsistencies and Compliance Challenges ·      The Impact of Presidential Pardons on Compliance  Resources Matt in Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn  A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the mixed and muddled messages coming out of the DOJ on FCPA and white collar enforcement. 

 

We discuss recent signals from the DOJ suggesting a reinvigorated stance on corporate malfeasance, juxtaposed with actions like the pardoning of convicted offenders which muddle the overall message. The conversation covers Deputy Attorney General Todd Blanche's inflammatory speech on the seriousness of FCPA actions, the controversial pardons by President Trump, and the apparent selective enforcement against foreign versus U.S. companies. The episode examines the ramifications of these mixed signals for compliance professionals, companies, and whistleblowers, emphasizing the need for clearer guidance and consistency from the DOJ.

 Key Highlights 

·      Mixed Messages from the Justice Department on FCPA and White Collar Enforcement

·      Deputy Attorney General's Angry Speech

·      Controversial Pardons and Their Implications

·      ZTE and FCPA Charges

·      Inconsistencies and Compliance Challenges

·      The Impact of Presidential Pardons on Compliance

 Resources

Matt in Radical Compliance

 Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

 A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence. 

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]]> 1375 no Live from the Floor of ACI The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss their initial reflections on the first day of the recently concluded ACI-FCPA and Global Anti-Corruption Conference. Key points include the current state of FCPA enforcement, the impact of reduced DOJ manpower, and the continued importance of robust compliance. Despite claims about ramping up enforcement, the number of staff dedicated to FCPA cases has been significantly reduced. They also touch on the DOJ’s focus on comprehensive white-collar crime enforcement, including healthcare fraud and cartel-related activities. Additionally, they discuss Severin Wirz’s new book, Bribery Beyond Borders, on the historical context of FCPA enforcement. Key highlights: FCPA Enforcement Realities White Collar Crime and DOJ Priorities Cartels and Corruption Whistleblower Program Insights Book Signing and Historical Context Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Dec 2025 05:00:00 -0000 full 444 Tom Fox Tom and Matt from ACI-FCPA and the Global Anti-Corruption Conference. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss their initial reflections on the first day of the recently concluded ACI-FCPA and Global Anti-Corruption Conference. Key points include the current state of FCPA enforcement, the impact of reduced DOJ manpower, and the continued importance of robust compliance. Despite claims about ramping up enforcement, the number of staff dedicated to FCPA cases has been significantly reduced. They also touch on the DOJ’s focus on comprehensive white-collar crime enforcement, including healthcare fraud and cartel-related activities. Additionally, they discuss Severin Wirz’s new book, Bribery Beyond Borders, on the historical context of FCPA enforcement. Key highlights: FCPA Enforcement Realities White Collar Crime and DOJ Priorities Cartels and Corruption Whistleblower Program Insights Book Signing and Historical Context Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss their initial reflections on the first day of the recently concluded ACI-FCPA and Global Anti-Corruption Conference.

Key points include the current state of FCPA enforcement, the impact of reduced DOJ manpower, and the continued importance of robust compliance. Despite claims about ramping up enforcement, the number of staff dedicated to FCPA cases has been significantly reduced. They also touch on the DOJ’s focus on comprehensive white-collar crime enforcement, including healthcare fraud and cartel-related activities. Additionally, they discuss Severin Wirz’s new book, Bribery Beyond Borders, on the historical context of FCPA enforcement.

Key highlights:

  • FCPA Enforcement Realities
  • White Collar Crime and DOJ Priorities
  • Cartels and Corruption
  • Whistleblower Program Insights
  • Book Signing and Historical Context

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

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]]> 1223 no Understanding SFO Guidance and Compliance Program Assessments The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recently released Serious Fraud Office (SFO) guidance on compliance programs. Tom and Matt highlight the SFO's lack of specific directives and contrast them with more detailed guidance from the United States. The conversation focuses on the ambiguity organizations face in understanding what the SFO looks for in assessing compliance programs and underscores the need for a more holistic, tailored approach to individual circumstances. Key highlights: Introduction to SFO Guidance Comparing SFO Guidance with US Standards Uncertainty in SFO's Expectations Holistic Assessment by SFO Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Dec 2025 05:00:00 -0000 full 443 Tom Fox A look a the new SFO Guidance on compliance programs. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recently released Serious Fraud Office (SFO) guidance on compliance programs. Tom and Matt highlight the SFO's lack of specific directives and contrast them with more detailed guidance from the United States. The conversation focuses on the ambiguity organizations face in understanding what the SFO looks for in assessing compliance programs and underscores the need for a more holistic, tailored approach to individual circumstances. Key highlights: Introduction to SFO Guidance Comparing SFO Guidance with US Standards Uncertainty in SFO's Expectations Holistic Assessment by SFO Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recently released Serious Fraud Office (SFO) guidance on compliance programs.

Tom and Matt highlight the SFO's lack of specific directives and contrast them with more detailed guidance from the United States. The conversation focuses on the ambiguity organizations face in understanding what the SFO looks for in assessing compliance programs and underscores the need for a more holistic, tailored approach to individual circumstances.

Key highlights:

  • Introduction to SFO Guidance
  • Comparing SFO Guidance with US Standards
  • Uncertainty in SFO's Expectations
  • Holistic Assessment by SFO

Resources:

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1186 no Uncovering FCPA Violations: Millicom's Complex Case Involving Drug Cartel Funds The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the intricate details of a recent FCPA  enforcement action against Millicom Cellular, a Luxembourg-based telecommunications company with operations in Guatemala. The discussion uncovers how Millicom's joint venture, Comunicaciones Celulares (CommCell), became embroiled in bribery and corruption involving duffel bags of drug cartel cash used to pay off Guatemalan officials. Despite the DOJ’s earlier pause on FCPA enforcement, the emergence of narco-trafficking aspects led to a reopened investigation and significant penalties for Millicom. Key points include the case timeline, the lack of Millicom's operational control and visibility, and the broader implications for due diligence in joint ventures and cross-border operations in high-risk regions. Key highlights: Details of the FCPA Enforcement Action Millicom’s Joint Venture in Guatemala Self-Disclosure and DOJ’s Response Timeline of Events and Corruption Details Drug Trafficking and Bribery Connections Implications and Compliance Lessons Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Nov 2025 05:00:00 -0000 full 442 Tom Fox The Millicom Cellular FCPA Enforcement Action The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the intricate details of a recent FCPA  enforcement action against Millicom Cellular, a Luxembourg-based telecommunications company with operations in Guatemala. The discussion uncovers how Millicom's joint venture, Comunicaciones Celulares (CommCell), became embroiled in bribery and corruption involving duffel bags of drug cartel cash used to pay off Guatemalan officials. Despite the DOJ’s earlier pause on FCPA enforcement, the emergence of narco-trafficking aspects led to a reopened investigation and significant penalties for Millicom. Key points include the case timeline, the lack of Millicom's operational control and visibility, and the broader implications for due diligence in joint ventures and cross-border operations in high-risk regions. Key highlights: Details of the FCPA Enforcement Action Millicom’s Joint Venture in Guatemala Self-Disclosure and DOJ’s Response Timeline of Events and Corruption Details Drug Trafficking and Bribery Connections Implications and Compliance Lessons Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the intricate details of a recent FCPA  enforcement action against Millicom Cellular, a Luxembourg-based telecommunications company with operations in Guatemala.

The discussion uncovers how Millicom's joint venture, Comunicaciones Celulares (CommCell), became embroiled in bribery and corruption involving duffel bags of drug cartel cash used to pay off Guatemalan officials. Despite the DOJ’s earlier pause on FCPA enforcement, the emergence of narco-trafficking aspects led to a reopened investigation and significant penalties for Millicom. Key points include the case timeline, the lack of Millicom's operational control and visibility, and the broader implications for due diligence in joint ventures and cross-border operations in high-risk regions.

Key highlights:

  • Details of the FCPA Enforcement Action
  • Millicom’s Joint Venture in Guatemala
  • Self-Disclosure and DOJ’s Response
  • Timeline of Events and Corruption Details
  • Drug Trafficking and Bribery Connections
  • Implications and Compliance Lessons

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1418 no The Atlanta Hawks Scandal: Lessons in Financial Misconduct The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the basics of fraud prevention with headlines torn from the NBA and a FinServ enforcement action.  The embezzlement scandal at the Atlanta Hawks has drawn attention to critical weaknesses in corporate governance and internal control systems, serving as a cautionary tale for organizations everywhere. They view the scandal as a glaring example of the consequences of neglecting internal controls and the segregation of duties, where an executive, Leslie Jones, exploited their finance role to embezzle funds for personal indulgences. His experience underscores the value of routine audits, which, despite their perceived monotony, are essential for uncovering fraud. Meanwhile, Matt is equally concerned, focusing on the need for robust internal controls and the principle of least privilege, warning against granting excessive access to employees to prevent misuse of power and safeguard organizational integrity.  Key Highlights  ·      Lessons from Atlanta Hawks Fraud Case ·      Least Privilege Access for Preventing Financial Fraud ·      Financial Data Examination for Fraud Detection ·      Executives' Lavish Misconduct: Lessons in Ethics  Resources Matt in Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn   A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Nov 2025 05:00:00 -0000 full 441 Tom Fox How the basics guard against fraud abuse. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the basics of fraud prevention with headlines torn from the NBA and a FinServ enforcement action.  The embezzlement scandal at the Atlanta Hawks has drawn attention to critical weaknesses in corporate governance and internal control systems, serving as a cautionary tale for organizations everywhere. They view the scandal as a glaring example of the consequences of neglecting internal controls and the segregation of duties, where an executive, Leslie Jones, exploited their finance role to embezzle funds for personal indulgences. His experience underscores the value of routine audits, which, despite their perceived monotony, are essential for uncovering fraud. Meanwhile, Matt is equally concerned, focusing on the need for robust internal controls and the principle of least privilege, warning against granting excessive access to employees to prevent misuse of power and safeguard organizational integrity.  Key Highlights  ·      Lessons from Atlanta Hawks Fraud Case ·      Least Privilege Access for Preventing Financial Fraud ·      Financial Data Examination for Fraud Detection ·      Executives' Lavish Misconduct: Lessons in Ethics  Resources Matt in Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn   A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the basics of fraud prevention with headlines torn from the NBA and a FinServ enforcement action. 

The embezzlement scandal at the Atlanta Hawks has drawn attention to critical weaknesses in corporate governance and internal control systems, serving as a cautionary tale for organizations everywhere. They view the scandal as a glaring example of the consequences of neglecting internal controls and the segregation of duties, where an executive, Leslie Jones, exploited their finance role to embezzle funds for personal indulgences. His experience underscores the value of routine audits, which, despite their perceived monotony, are essential for uncovering fraud. Meanwhile, Matt is equally concerned, focusing on the need for robust internal controls and the principle of least privilege, warning against granting excessive access to employees to prevent misuse of power and safeguard organizational integrity. 

Key Highlights 

·      Lessons from Atlanta Hawks Fraud Case

·      Least Privilege Access for Preventing Financial Fraud

·      Financial Data Examination for Fraud Detection

·      Executives' Lavish Misconduct: Lessons in Ethics 

Resources

Matt in Radical Compliance

 

Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

 

A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence. 

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1540 no Incentives in Compliance: Structuring Effective Compensation Plans The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the intricacies of integrating incentives into corporate compliance programs. Matt shares insights from a recent webinar and blog posts, discussing how companies can encourage ethical behavior through executive compensation plans, performance bonuses, and other incentive schemes. The conversation explores the Justice Department’s guidelines on executive compensation, the intricacies of designing these programs to align with industry-specific risks, and the implications for various levels of management. They also examine the challenges of establishing meaningful compliance metrics and striking a balance between compliance incentives and overall business objectives across multiple sectors. Key highlights: The Role of Incentives in Compliance Programs Structuring Executive Compensation for Compliance Challenges and Nuances in Incentive Programs Incentives for Different Business Models Compensation Types and Ethical Behavior Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been honored with a Davey, Communicator, and W3 Award, all for excellence in podcasting. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Nov 2025 05:00:00 -0000 full 440 Tom Fox How to create monetary incentives for compliance. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the intricacies of integrating incentives into corporate compliance programs. Matt shares insights from a recent webinar and blog posts, discussing how companies can encourage ethical behavior through executive compensation plans, performance bonuses, and other incentive schemes. The conversation explores the Justice Department’s guidelines on executive compensation, the intricacies of designing these programs to align with industry-specific risks, and the implications for various levels of management. They also examine the challenges of establishing meaningful compliance metrics and striking a balance between compliance incentives and overall business objectives across multiple sectors. Key highlights: The Role of Incentives in Compliance Programs Structuring Executive Compensation for Compliance Challenges and Nuances in Incentive Programs Incentives for Different Business Models Compensation Types and Ethical Behavior Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been honored with a Davey, Communicator, and W3 Award, all for excellence in podcasting. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the intricacies of integrating incentives into corporate compliance programs.

Matt shares insights from a recent webinar and blog posts, discussing how companies can encourage ethical behavior through executive compensation plans, performance bonuses, and other incentive schemes. The conversation explores the Justice Department’s guidelines on executive compensation, the intricacies of designing these programs to align with industry-specific risks, and the implications for various levels of management. They also examine the challenges of establishing meaningful compliance metrics and striking a balance between compliance incentives and overall business objectives across multiple sectors.

Key highlights:

  • The Role of Incentives in Compliance Programs
  • Structuring Executive Compensation for Compliance
  • Challenges and Nuances in Incentive Programs
  • Incentives for Different Business Models
  • Compensation Types and Ethical Behavior

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been honored with a Davey, Communicator, and W3 Award, all for excellence in podcasting.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1446 no The NBA Betting Scandal - Lessons for the Compliance Professional The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the unfolding NBA betting scandal and explore what it all might mean for the compliance professional.  Their discussion covers the allegations and implications involving high-profile NBA figures, including Terry Rozier, Damon Jones, and Chauncey Billups. They explore the role of material non-public information, the importance of risk assessment, the effectiveness of current compliance measures, and the crucial role of data analytics in detecting fraudulent activities. Insights into sports betting, preventive controls, and the ethical challenges faced by professional athletes are also discussed, drawing parallels for corporate compliance professionals.  Key highlights: NBA Betting Scandal Overview Historical Context and Data Analytics Conflict of Interest and Risk Assessment Investigation and Compliance Strategies  Resources: Tom is writing a multipart series on the scandal on the ⁠FCPA Compliance and Ethics blog.⁠ Tom   ⁠Instagram⁠ ⁠Facebook⁠ ⁠YouTube⁠ ⁠Twitter⁠ ⁠LinkedIn⁠ A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the ⁠Top 25 Regulatory Compliance Podcasts⁠ , a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Oct 2025 04:00:00 -0000 full Tom Fox Tom and Matt mine the NBA betting scandal. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the unfolding NBA betting scandal and explore what it all might mean for the compliance professional.  Their discussion covers the allegations and implications involving high-profile NBA figures, including Terry Rozier, Damon Jones, and Chauncey Billups. They explore the role of material non-public information, the importance of risk assessment, the effectiveness of current compliance measures, and the crucial role of data analytics in detecting fraudulent activities. Insights into sports betting, preventive controls, and the ethical challenges faced by professional athletes are also discussed, drawing parallels for corporate compliance professionals.  Key highlights: NBA Betting Scandal Overview Historical Context and Data Analytics Conflict of Interest and Risk Assessment Investigation and Compliance Strategies  Resources: Tom is writing a multipart series on the scandal on the ⁠FCPA Compliance and Ethics blog.⁠ Tom   ⁠Instagram⁠ ⁠Facebook⁠ ⁠YouTube⁠ ⁠Twitter⁠ ⁠LinkedIn⁠ A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the ⁠Top 25 Regulatory Compliance Podcasts⁠ , a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the unfolding NBA betting scandal and explore what it all might mean for the compliance professional. 

Their discussion covers the allegations and implications involving high-profile NBA figures, including Terry Rozier, Damon Jones, and Chauncey Billups. They explore the role of material non-public information, the importance of risk assessment, the effectiveness of current compliance measures, and the crucial role of data analytics in detecting fraudulent activities. Insights into sports betting, preventive controls, and the ethical challenges faced by professional athletes are also discussed, drawing parallels for corporate compliance professionals.

 Key highlights:

  • NBA Betting Scandal Overview
  • Historical Context and Data Analytics
  • Conflict of Interest and Risk Assessment
  • Investigation and Compliance Strategies

 Resources:

Tom is writing a multipart series on the scandal on the ⁠FCPA Compliance and Ethics blog.⁠

Tom  

⁠Instagram⁠

⁠Facebook⁠

⁠YouTube⁠

⁠Twitter⁠

⁠LinkedIn⁠

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the ⁠Top 25 Regulatory Compliance Podcasts⁠ , a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. 

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1898 no The End of Self-Disclosure? The Criminal Indictment of Smartmatic The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the rare occurrence of a company, Smartmatic, being added to an existing indictment for FCPA violations. They explore the unusual circumstances surrounding this case, including the political sensitivity of Smartmatic, its ongoing litigation with Fox News, and the potential implications for corporate voluntary self-disclosure under the current administration. They delve into the changes in DOJ criteria for FCPA prosecutions and raise concerns about selective prosecution and the broader impact on compliance strategies. Key highlights: Overview of Smart Medic Indictment Political Context and Conspiracy Theories Implications for Compliance and Self-Disclosure Concerns About Selective Prosecution Resources: Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Oct 2025 04:00:00 -0000 full 438 Tom Fox A new calculus for self-disclosure? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the rare occurrence of a company, Smartmatic, being added to an existing indictment for FCPA violations. They explore the unusual circumstances surrounding this case, including the political sensitivity of Smartmatic, its ongoing litigation with Fox News, and the potential implications for corporate voluntary self-disclosure under the current administration. They delve into the changes in DOJ criteria for FCPA prosecutions and raise concerns about selective prosecution and the broader impact on compliance strategies. Key highlights: Overview of Smart Medic Indictment Political Context and Conspiracy Theories Implications for Compliance and Self-Disclosure Concerns About Selective Prosecution Resources: Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the rare occurrence of a company, Smartmatic, being added to an existing indictment for FCPA violations.

They explore the unusual circumstances surrounding this case, including the political sensitivity of Smartmatic, its ongoing litigation with Fox News, and the potential implications for corporate voluntary self-disclosure under the current administration. They delve into the changes in DOJ criteria for FCPA prosecutions and raise concerns about selective prosecution and the broader impact on compliance strategies.

Key highlights:

  • Overview of Smart Medic Indictment
  • Political Context and Conspiracy Theories
  • Implications for Compliance and Self-Disclosure
  • Concerns About Selective Prosecution

Resources:

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Award, all for podcast excellence.

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]]> 1436 no Navigating Effective Human Oversight for ADS/ADMT in AI Compliance The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully, and looking for some hard-hitting insights on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Matt’s recent experience at a compliance conference in Lithuania and engage in a thorough discussion about effective human oversight in AI systems. They examine the recent guidance from the European Data Protection Supervisor (EDPS) on maintaining human oversight of automated decision-making processes, relating it to similar regulatory requirements in California. The conversation explores the implications for corporate compliance, IT, and audit professionals, highlighting the challenge of balancing AI efficiency with the need for effective human intervention to mitigate risks and ensure regulatory compliance. Key highlights: Matt’s Experience in Lithuania AI Regulation in the EU and CCPA Amendments re: ADS and ADMT Effective Human Oversight in AI Systems Challenges in AI Control Design The Role of Compliance and Audit in AI Oversight Resources: Matt on Radical Compliance Tom with a 5-Part podcast series on the CCPA Amendments on ADS/ADMT with Alyssa DeSimone on Life with GDPR Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Oct 2025 04:00:00 -0000 full 437 Tom Fox The regulatory requirement for the human in the loop. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully, and looking for some hard-hitting insights on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Matt’s recent experience at a compliance conference in Lithuania and engage in a thorough discussion about effective human oversight in AI systems. They examine the recent guidance from the European Data Protection Supervisor (EDPS) on maintaining human oversight of automated decision-making processes, relating it to similar regulatory requirements in California. The conversation explores the implications for corporate compliance, IT, and audit professionals, highlighting the challenge of balancing AI efficiency with the need for effective human intervention to mitigate risks and ensure regulatory compliance. Key highlights: Matt’s Experience in Lithuania AI Regulation in the EU and CCPA Amendments re: ADS and ADMT Effective Human Oversight in AI Systems Challenges in AI Control Design The Role of Compliance and Audit in AI Oversight Resources: Matt on Radical Compliance Tom with a 5-Part podcast series on the CCPA Amendments on ADS/ADMT with Alyssa DeSimone on Life with GDPR Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully, and looking for some hard-hitting insights on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Matt’s recent experience at a compliance conference in Lithuania and engage in a thorough discussion about effective human oversight in AI systems.

They examine the recent guidance from the European Data Protection Supervisor (EDPS) on maintaining human oversight of automated decision-making processes, relating it to similar regulatory requirements in California. The conversation explores the implications for corporate compliance, IT, and audit professionals, highlighting the challenge of balancing AI efficiency with the need for effective human intervention to mitigate risks and ensure regulatory compliance.

Key highlights:

  • Matt’s Experience in Lithuania
  • AI Regulation in the EU and CCPA Amendments re: ADS and ADMT
  • Effective Human Oversight in AI Systems
  • Challenges in AI Control Design
  • The Role of Compliance and Audit in AI Oversight

Resources:

Matt on Radical Compliance

Tom with a 5-Part podcast series on the CCPA Amendments on ADS/ADMT with Alyssa DeSimone on Life with GDPR

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence.

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]]> 1543 no Chatbots and Interplay of Multiple Compliance Systems The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the implications of artificial intelligence, specifically the use of chatbots in compliance programs. Matt joins from Vilnius, Lithuania, where he is set to address a gathering of Baltic and Eastern European compliance professionals. The discussion centers on AI chatbots used for policy guidance, specifically addressing the ethical concerns and potential risks associated with tracking individual employee inquiries, as well as the possibility of violating whistleblower protection laws. Tom and Matt emphasize the importance of robust IT general controls and corporate culture in managing these new AI-powered compliance tools. They also address how regulators, like the Department of Justice, may evaluate the effectiveness of AI in compliance programs going forward. Key highlights: Exploring AI in Compliance Chatbot Concerns and Whistleblower Anonymity User Experience vs. Compliance Function Experience Regulatory Expectations and Future of AI in Compliance Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Oct 2025 04:00:00 -0000 full 436 Tom Fox Are chatbots a problem for compliance? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the implications of artificial intelligence, specifically the use of chatbots in compliance programs. Matt joins from Vilnius, Lithuania, where he is set to address a gathering of Baltic and Eastern European compliance professionals. The discussion centers on AI chatbots used for policy guidance, specifically addressing the ethical concerns and potential risks associated with tracking individual employee inquiries, as well as the possibility of violating whistleblower protection laws. Tom and Matt emphasize the importance of robust IT general controls and corporate culture in managing these new AI-powered compliance tools. They also address how regulators, like the Department of Justice, may evaluate the effectiveness of AI in compliance programs going forward. Key highlights: Exploring AI in Compliance Chatbot Concerns and Whistleblower Anonymity User Experience vs. Compliance Function Experience Regulatory Expectations and Future of AI in Compliance Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the implications of artificial intelligence, specifically the use of chatbots in compliance programs.

Matt joins from Vilnius, Lithuania, where he is set to address a gathering of Baltic and Eastern European compliance professionals. The discussion centers on AI chatbots used for policy guidance, specifically addressing the ethical concerns and potential risks associated with tracking individual employee inquiries, as well as the possibility of violating whistleblower protection laws. Tom and Matt emphasize the importance of robust IT general controls and corporate culture in managing these new AI-powered compliance tools. They also address how regulators, like the Department of Justice, may evaluate the effectiveness of AI in compliance programs going forward.

Key highlights:

  • Exploring AI in Compliance
  • Chatbot Concerns and Whistleblower Anonymity
  • User Experience vs. Compliance Function Experience
  • Regulatory Expectations and Future of AI in Compliance

Resources:

Matt on Radical Compliance 

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1237 no Amplified Risks: Navigating Corporate Challenges in the Age of Social Media The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the bot attack on Cracker Barrel during its abortive name change imbroglio. They explore the notion that social media risk is not a new concept, but rather an amplifier of existing risks for companies. It discusses the heightened potential for misinformation about a company’s values and how social media platforms have magnified this risk. Regulatory measures and accountability issues are addressed, with a nod to the role of prominent figures like Elon Musk. The episode underscores the inevitable, albeit unfair, reality of managing these amplified risks in today’s digital landscape. Key highlights: Introduction to Social Media Risks Amplification of Existing Risks Challenges in Managing Misconceptions The Unavoidable Reality of Social Media Accountability Resources: Matt on Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been honored with a Davey, Communicator, and W3 Award for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Oct 2025 04:00:00 -0000 full 435 Tom Fox Tom Fox and Matt Kelly analyze the bot attack on Cracker Barrel amid its unsuccessful attempt to change its name. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the bot attack on Cracker Barrel during its abortive name change imbroglio. They explore the notion that social media risk is not a new concept, but rather an amplifier of existing risks for companies. It discusses the heightened potential for misinformation about a company’s values and how social media platforms have magnified this risk. Regulatory measures and accountability issues are addressed, with a nod to the role of prominent figures like Elon Musk. The episode underscores the inevitable, albeit unfair, reality of managing these amplified risks in today’s digital landscape. Key highlights: Introduction to Social Media Risks Amplification of Existing Risks Challenges in Managing Misconceptions The Unavoidable Reality of Social Media Accountability Resources: Matt on Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been honored with a Davey, Communicator, and W3 Award for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the bot attack on Cracker Barrel during its abortive name change imbroglio.

They explore the notion that social media risk is not a new concept, but rather an amplifier of existing risks for companies. It discusses the heightened potential for misinformation about a company’s values and how social media platforms have magnified this risk. Regulatory measures and accountability issues are addressed, with a nod to the role of prominent figures like Elon Musk. The episode underscores the inevitable, albeit unfair, reality of managing these amplified risks in today’s digital landscape.

Key highlights:

  • Introduction to Social Media Risks
  • Amplification of Existing Risks
  • Challenges in Managing Misconceptions
  • The Unavoidable Reality of Social Media Accountability

Resources:

Matt on Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been honored with a Davey, Communicator, and W3 Award for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1427 no Navigating H-1B Visa Reforms & Corporate Compliance Challenges The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the Trump administration’s recent H-1B visa reforms and their implications for corporate compliance officers. Highlighting the sudden and arbitrary policy changes, they discuss the potential chaos and confusion that businesses reliant on H-1B visas may face. They explore the economic ramifications, the threat of increased corporate costs, and the embedded risks of corruption. The episode highlights the broader issue of regulatory unpredictability under the Trump administration and offers compliance professionals guidance on coping strategies in this volatile environment. Key highlights: H-1B Visas: Current Headlines Understanding H-1B Visas Trump Administration’s New H-1B Visa Policy Policy Clarifications and Implications Potential for Corruption Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Sep 2025 04:00:00 -0000 full 434 Tom Fox A new H1B Visa program. What does it mean for compliance? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the Trump administration’s recent H-1B visa reforms and their implications for corporate compliance officers. Highlighting the sudden and arbitrary policy changes, they discuss the potential chaos and confusion that businesses reliant on H-1B visas may face. They explore the economic ramifications, the threat of increased corporate costs, and the embedded risks of corruption. The episode highlights the broader issue of regulatory unpredictability under the Trump administration and offers compliance professionals guidance on coping strategies in this volatile environment. Key highlights: H-1B Visas: Current Headlines Understanding H-1B Visas Trump Administration’s New H-1B Visa Policy Policy Clarifications and Implications Potential for Corruption Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the Trump administration’s recent H-1B visa reforms and their implications for corporate compliance officers.

Highlighting the sudden and arbitrary policy changes, they discuss the potential chaos and confusion that businesses reliant on H-1B visas may face. They explore the economic ramifications, the threat of increased corporate costs, and the embedded risks of corruption. The episode highlights the broader issue of regulatory unpredictability under the Trump administration and offers compliance professionals guidance on coping strategies in this volatile environment.

Key highlights:

  • H-1B Visas: Current Headlines
  • Understanding H-1B Visas
  • Trump Administration’s New H-1B Visa Policy
  • Policy Clarifications and Implications
  • Potential for Corruption

Resources:

Matt on Radical Compliance 

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.

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]]> 1217 no SCCE Compliance and Ethics Institute Report Key highlights: The SCCE conference was well-attended with over 1300 participants. The absence of key representatives from the Trump administration was notable. Innovative presentations offered fresh perspectives on compliance topics. Compliance professionals must adapt policies to effectively support AI tools. Leadership changes at SCCE signal a new direction for the organization. Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 18 Sep 2025 04:00:00 -0000 full 433 Tom Fox Matt reports on his assessment of SCCE's CEI. Key highlights: The SCCE conference was well-attended with over 1300 participants. The absence of key representatives from the Trump administration was notable. Innovative presentations offered fresh perspectives on compliance topics. Compliance professionals must adapt policies to effectively support AI tools. Leadership changes at SCCE signal a new direction for the organization. Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Key highlights:

  • The SCCE conference was well-attended with over 1300 participants.
  • The absence of key representatives from the Trump administration was notable.
  • Innovative presentations offered fresh perspectives on compliance topics.
  • Compliance professionals must adapt policies to effectively support AI tools.
  • Leadership changes at SCCE signal a new direction for the organization.

Resources:

Matt on Radical Compliance 

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1073 no Checking in on Codes of Conduct The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly review a recent report from LRN on the state of Codes of Conduct. This episode explores the multifaceted use of a corporate code of conduct, discussing its role as both a defensive and offensive tool. Tom and Matt emphasize the importance of managers talking about the code and view it as a substantive part of senior management’s dialogue on corporate culture. The conversation underscores the code’s utility in various contexts and advocates for its broader adoption within the organization. Key highlights: Code as a Tool The Role of Managers in Code Discussion Senior Managers and Corporate Culture Versatility of the Code Resources: Matt on Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Sep 2025 04:00:00 -0000 full 432 Tom Fox What is the state of your Code of Conduct? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly review a recent report from LRN on the state of Codes of Conduct. This episode explores the multifaceted use of a corporate code of conduct, discussing its role as both a defensive and offensive tool. Tom and Matt emphasize the importance of managers talking about the code and view it as a substantive part of senior management’s dialogue on corporate culture. The conversation underscores the code’s utility in various contexts and advocates for its broader adoption within the organization. Key highlights: Code as a Tool The Role of Managers in Code Discussion Senior Managers and Corporate Culture Versatility of the Code Resources: Matt on Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly review a recent report from LRN on the state of Codes of Conduct.

This episode explores the multifaceted use of a corporate code of conduct, discussing its role as both a defensive and offensive tool. Tom and Matt emphasize the importance of managers talking about the code and view it as a substantive part of senior management’s dialogue on corporate culture. The conversation underscores the code’s utility in various contexts and advocates for its broader adoption within the organization.

Key highlights:

  • Code as a Tool
  • The Role of Managers in Code Discussion
  • Senior Managers and Corporate Culture
  • Versatility of the Code

Resources:

Matt on Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1300 no Fracht - The Bonkers Sanctions Case The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss a recent OFAC enforcement action against a Swiss-domiciled freight forwarding company, Fracht. The case stands out for its complexity, involving a single, high-value transaction that exposed the company to significant sanctions risk through dealings with both Venezuelan and Iranian entities. Tom and Matt break down the compliance failures, the role of senior management, and the extensive remediation steps taken post-incident. This episode offers actionable lessons for compliance professionals on supply chain due diligence, the importance of compliance involvement in urgent deals, and the consequences of sidelining compliance functions. Key highlights: OFAC Enforcement Details Anatomy of the Transaction Third- and Fourth-Party Risks Senior Management Involvement Compliance Failures & Supply Chain Visibility Remediation & Consequence Management Key Takeaways for Compliance Professionals: Always involve compliance in high-value, urgent transactions. Ensure robust due diligence for all counterparties, including third- and fourth-party risks. Senior management must be accountable for compliance failures. Remediation should include policy updates, staff training, and ongoing oversight. Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Sep 2025 04:00:00 -0000 full 431 Tom Fox Why day and time are key compliance red flags. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss a recent OFAC enforcement action against a Swiss-domiciled freight forwarding company, Fracht. The case stands out for its complexity, involving a single, high-value transaction that exposed the company to significant sanctions risk through dealings with both Venezuelan and Iranian entities. Tom and Matt break down the compliance failures, the role of senior management, and the extensive remediation steps taken post-incident. This episode offers actionable lessons for compliance professionals on supply chain due diligence, the importance of compliance involvement in urgent deals, and the consequences of sidelining compliance functions. Key highlights: OFAC Enforcement Details Anatomy of the Transaction Third- and Fourth-Party Risks Senior Management Involvement Compliance Failures & Supply Chain Visibility Remediation & Consequence Management Key Takeaways for Compliance Professionals: Always involve compliance in high-value, urgent transactions. Ensure robust due diligence for all counterparties, including third- and fourth-party risks. Senior management must be accountable for compliance failures. Remediation should include policy updates, staff training, and ongoing oversight. Resources: Matt on Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss a recent OFAC enforcement action against a Swiss-domiciled freight forwarding company, Fracht.

The case stands out for its complexity, involving a single, high-value transaction that exposed the company to significant sanctions risk through dealings with both Venezuelan and Iranian entities. Tom and Matt break down the compliance failures, the role of senior management, and the extensive remediation steps taken post-incident. This episode offers actionable lessons for compliance professionals on supply chain due diligence, the importance of compliance involvement in urgent deals, and the consequences of sidelining compliance functions.

Key highlights:

  • OFAC Enforcement Details
  • Anatomy of the Transaction
  • Third- and Fourth-Party Risks
  • Senior Management Involvement
  • Compliance Failures & Supply Chain Visibility
  • Remediation & Consequence Management

Key Takeaways for Compliance Professionals:

  • Always involve compliance in high-value, urgent transactions.
  • Ensure robust due diligence for all counterparties, including third- and fourth-party risks.
  • Senior management must be accountable for compliance failures.
  • Remediation should include policy updates, staff training, and ongoing oversight.

Resources:

Matt on Radical Compliance 

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1497 no Examining the Impact of Reducing Middle Management on Corporate Culture The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the implications of reducing the number of middle managers in corporate America. Kelly’s blog post, inspired by a Wall Street Journal article, serves as the foundation for a broader discussion on how the reduction of managers impacts corporate culture, employee dynamics, and compliance programs. They explore the reasons behind this trend, such as the desire for agility or cost-cutting, and its effects on communication, institutional knowledge, and the role of compliance officers. They also explore potential solutions, including the use of AI, enhanced training, and adaptive compliance strategies, to mitigate the risks associated with fewer middle managers. Key highlights: Corporate America’s Managerial Shift Implications for Corporate Culture AI and Compliance Solutions Institutional Knowledge and Risks Compliance Takeaways and Final Thoughts Resources: Matt on Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Sep 2025 04:00:00 -0000 full 430 Tom Fox How will the culling of middle managers impact compliance? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the implications of reducing the number of middle managers in corporate America. Kelly’s blog post, inspired by a Wall Street Journal article, serves as the foundation for a broader discussion on how the reduction of managers impacts corporate culture, employee dynamics, and compliance programs. They explore the reasons behind this trend, such as the desire for agility or cost-cutting, and its effects on communication, institutional knowledge, and the role of compliance officers. They also explore potential solutions, including the use of AI, enhanced training, and adaptive compliance strategies, to mitigate the risks associated with fewer middle managers. Key highlights: Corporate America’s Managerial Shift Implications for Corporate Culture AI and Compliance Solutions Institutional Knowledge and Risks Compliance Takeaways and Final Thoughts Resources: Matt on Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the implications of reducing the number of middle managers in corporate America.

Kelly’s blog post, inspired by a Wall Street Journal article, serves as the foundation for a broader discussion on how the reduction of managers impacts corporate culture, employee dynamics, and compliance programs. They explore the reasons behind this trend, such as the desire for agility or cost-cutting, and its effects on communication, institutional knowledge, and the role of compliance officers. They also explore potential solutions, including the use of AI, enhanced training, and adaptive compliance strategies, to mitigate the risks associated with fewer middle managers.

Key highlights:

  • Corporate America’s Managerial Shift
  • Implications for Corporate Culture
  • AI and Compliance Solutions
  • Institutional Knowledge and Risks
  • Compliance Takeaways and Final Thoughts

Resources:

Matt on Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1430 no Unpacking the University of Michigan Football Scandal: Compliance and Consequences The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the recent University of Michigan football scandal. They draw parallels to the infamous 2017 Houston Astros sign-stealing incident and examine the numerous compliance failures within Michigan’s football program. Highlighted issues include impermissible scouting, leadership failures by Jim Harbaugh, marginalization of the compliance function, and the NCAA’s ineffective enforcement. The conversation highlights crucial lessons for corporate compliance, emphasizing the importance of documentation, intern training, cooperation in investigations, and maintaining robust enforcement actions. Key highlights: Michigan Football Scandal Overview Impermissible Scouting and Violations Leadership Failures and Compliance Issues NCAA’s Toothless Enforcement Comparisons to Corporate Compliance Lessons for Compliance Officers Ed. Note: Tom Fox has written a 5-part blog post series on the UM Cheating Scandal. It will be posted each day this week. You can view the full series on his blog, the FCPA Compliance and Ethics Blog. Resources : Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 Aug 2025 04:00:00 -0000 full 429 Tom Fox Tom and Matt take on the UM football cheating scandal. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the recent University of Michigan football scandal. They draw parallels to the infamous 2017 Houston Astros sign-stealing incident and examine the numerous compliance failures within Michigan’s football program. Highlighted issues include impermissible scouting, leadership failures by Jim Harbaugh, marginalization of the compliance function, and the NCAA’s ineffective enforcement. The conversation highlights crucial lessons for corporate compliance, emphasizing the importance of documentation, intern training, cooperation in investigations, and maintaining robust enforcement actions. Key highlights: Michigan Football Scandal Overview Impermissible Scouting and Violations Leadership Failures and Compliance Issues NCAA’s Toothless Enforcement Comparisons to Corporate Compliance Lessons for Compliance Officers Ed. Note: Tom Fox has written a 5-part blog post series on the UM Cheating Scandal. It will be posted each day this week. You can view the full series on his blog, the FCPA Compliance and Ethics Blog. Resources : Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the recent University of Michigan football scandal.

They draw parallels to the infamous 2017 Houston Astros sign-stealing incident and examine the numerous compliance failures within Michigan’s football program. Highlighted issues include impermissible scouting, leadership failures by Jim Harbaugh, marginalization of the compliance function, and the NCAA’s ineffective enforcement. The conversation highlights crucial lessons for corporate compliance, emphasizing the importance of documentation, intern training, cooperation in investigations, and maintaining robust enforcement actions.

Key highlights:

  • Michigan Football Scandal Overview
  • Impermissible Scouting and Violations
  • Leadership Failures and Compliance Issues
  • NCAA’s Toothless Enforcement
  • Comparisons to Corporate Compliance
  • Lessons for Compliance Officers

Ed. Note: Tom Fox has written a 5-part blog post series on the UM Cheating Scandal. It will be posted each day this week. You can view the full series on his blog, the FCPA Compliance and Ethics Blog.

Resources :

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1642 no The Dark Side of AI in Employee Training The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss emerging concerns surrounding AI, particularly ChatGPT, in the realm of employee training. Their discussion centers on the potential use of AI, specifically ChatGPT’s newest ‘Agent Mode’, to administer compliance training courses on behalf of employees, which could potentially enable them to cheat. They debate the implications of this capability, touching on the historical context of cheating, the effectiveness of current training methods, and the need for new internal controls and strategies to adapt to these technological advancements. They also contemplate the future of training, potentially evolving into AI-driven bots that provide on-the-spot, micro-learning modules. The episode encourages compliance officers to thoroughly vet their training vendors to ensure measures are in place to prevent AI-enabled cheating. Key highlights: The Dark Side of AI in Compliance Training AI’s Impact on Employee Training AI’s Role in Training and Compliance Future of AI in Corporate Training Challenges and Considerations Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Aug 2025 04:00:00 -0000 full 428 Tom Fox Will AI invalidate compliance training effectiveness? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss emerging concerns surrounding AI, particularly ChatGPT, in the realm of employee training. Their discussion centers on the potential use of AI, specifically ChatGPT’s newest ‘Agent Mode’, to administer compliance training courses on behalf of employees, which could potentially enable them to cheat. They debate the implications of this capability, touching on the historical context of cheating, the effectiveness of current training methods, and the need for new internal controls and strategies to adapt to these technological advancements. They also contemplate the future of training, potentially evolving into AI-driven bots that provide on-the-spot, micro-learning modules. The episode encourages compliance officers to thoroughly vet their training vendors to ensure measures are in place to prevent AI-enabled cheating. Key highlights: The Dark Side of AI in Compliance Training AI’s Impact on Employee Training AI’s Role in Training and Compliance Future of AI in Corporate Training Challenges and Considerations Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss emerging concerns surrounding AI, particularly ChatGPT, in the realm of employee training.

Their discussion centers on the potential use of AI, specifically ChatGPT’s newest ‘Agent Mode’, to administer compliance training courses on behalf of employees, which could potentially enable them to cheat. They debate the implications of this capability, touching on the historical context of cheating, the effectiveness of current training methods, and the need for new internal controls and strategies to adapt to these technological advancements. They also contemplate the future of training, potentially evolving into AI-driven bots that provide on-the-spot, micro-learning modules. The episode encourages compliance officers to thoroughly vet their training vendors to ensure measures are in place to prevent AI-enabled cheating.

Key highlights:

  • The Dark Side of AI in Compliance Training
  • AI’s Impact on Employee Training
  • AI’s Role in Training and Compliance
  • Future of AI in Corporate Training
  • Challenges and Considerations

Resources:

Matt Kelly in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1630 no Two Cyber Security Cases for the Compliance Professional The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss recent enforcement actions under the False Claims Act (FCA) related to cybersecurity failures by government contractors. They analyze two significant cases: Illumina, a medical device maker, and Aero Turbine, a contractor for the US Air Force. The conversation highlights the importance of ‘security by design’ in product development and the growing scrutiny on compliance practices, especially for smaller companies. The discussion emphasizes the need for robust cybersecurity measures and the challenges faced by organizations in meeting regulatory requirements. Key highlights: False Claims Act Cases Overview Illumina Case Analysis Aero Turbine Case Insights Compliance Challenges for Smaller Companies Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Aug 2025 04:00:00 -0000 full 426 Tom Fox A look at 3 cyber security enforcement actions. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss recent enforcement actions under the False Claims Act (FCA) related to cybersecurity failures by government contractors. They analyze two significant cases: Illumina, a medical device maker, and Aero Turbine, a contractor for the US Air Force. The conversation highlights the importance of ‘security by design’ in product development and the growing scrutiny on compliance practices, especially for smaller companies. The discussion emphasizes the need for robust cybersecurity measures and the challenges faced by organizations in meeting regulatory requirements. Key highlights: False Claims Act Cases Overview Illumina Case Analysis Aero Turbine Case Insights Compliance Challenges for Smaller Companies Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss recent enforcement actions under the False Claims Act (FCA) related to cybersecurity failures by government contractors.

They analyze two significant cases: Illumina, a medical device maker, and Aero Turbine, a contractor for the US Air Force. The conversation highlights the importance of ‘security by design’ in product development and the growing scrutiny on compliance practices, especially for smaller companies. The discussion emphasizes the need for robust cybersecurity measures and the challenges faced by organizations in meeting regulatory requirements.

Key highlights:

  • False Claims Act Cases Overview
  • Illumina Case Analysis
  • Aero Turbine Case Insights
  • Compliance Challenges for Smaller Companies

Resources:

Matt Kelly in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1679 A Deep Dive into Cadence Design Systems' Export Control Violations The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent enforcement action against Cadence Design Systems for export control violations. They explore the company’s illegal sales of sensitive technology to a Chinese university connected to the Chinese military, resulting in $140 million in penalties and a three-year probation. The conversation delves into topics like weak subsidiary governance, challenges in monitoring Chinese subsidiaries, and the complexities of conducting investigations in China. They also reflect on the broader implications for U.S. companies operating in China and the intractable risks involved. Key highlights: Cadence Design Systems Case Overview Subsidiary Governance Issues Details of the Misconduct Resolution and Penalties Challenges in Compliance and Monitoring Complexities of Doing Business in China Resources Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Aug 2025 04:00:00 -0000 full 426 Tom Fox A deep dive into the Cadence enforcement action. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent enforcement action against Cadence Design Systems for export control violations. They explore the company’s illegal sales of sensitive technology to a Chinese university connected to the Chinese military, resulting in $140 million in penalties and a three-year probation. The conversation delves into topics like weak subsidiary governance, challenges in monitoring Chinese subsidiaries, and the complexities of conducting investigations in China. They also reflect on the broader implications for U.S. companies operating in China and the intractable risks involved. Key highlights: Cadence Design Systems Case Overview Subsidiary Governance Issues Details of the Misconduct Resolution and Penalties Challenges in Compliance and Monitoring Complexities of Doing Business in China Resources Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent enforcement action against Cadence Design Systems for export control violations.

They explore the company’s illegal sales of sensitive technology to a Chinese university connected to the Chinese military, resulting in $140 million in penalties and a three-year probation. The conversation delves into topics like weak subsidiary governance, challenges in monitoring Chinese subsidiaries, and the complexities of conducting investigations in China. They also reflect on the broader implications for U.S. companies operating in China and the intractable risks involved.

Key highlights:

  • Cadence Design Systems Case Overview
  • Subsidiary Governance Issues
  • Details of the Misconduct
  • Resolution and Penalties
  • Challenges in Compliance and Monitoring
  • Complexities of Doing Business in China

Resources

Matt Kelly in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator, and W3 Awards for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1397 no Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss two recent OFAC enforcement actions involving Harman International and Interactive Brokers and the lessons they provide for compliance professionals. Tom and Matt delve into the facts of both cases, finding under-resourced sanctions compliance programs in both companies. They highlight key issues, including inadequate personnel, misconfigured compliance tools, and a failure to conduct proper risk assessments. Despite self-disclosure and cooperation, both companies faced significant fines and were required to implement extensive remediation measures. The discussion highlights the growing importance of robust sanctions compliance programs in mitigating risks and preventing enforcement actions. Key highlights: Sanctions Enforcement Cases Overview Harman International’s Compliance Failures Interactive Brokers’ Compliance Issues Lessons and Final Thoughts Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Jul 2025 04:00:00 -0000 full 425 Tom Fox Lessons from recent OFAC enforcement actions. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss two recent OFAC enforcement actions involving Harman International and Interactive Brokers and the lessons they provide for compliance professionals. Tom and Matt delve into the facts of both cases, finding under-resourced sanctions compliance programs in both companies. They highlight key issues, including inadequate personnel, misconfigured compliance tools, and a failure to conduct proper risk assessments. Despite self-disclosure and cooperation, both companies faced significant fines and were required to implement extensive remediation measures. The discussion highlights the growing importance of robust sanctions compliance programs in mitigating risks and preventing enforcement actions. Key highlights: Sanctions Enforcement Cases Overview Harman International’s Compliance Failures Interactive Brokers’ Compliance Issues Lessons and Final Thoughts Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss two recent OFAC enforcement actions involving Harman International and Interactive Brokers and the lessons they provide for compliance professionals.

Tom and Matt delve into the facts of both cases, finding under-resourced sanctions compliance programs in both companies. They highlight key issues, including inadequate personnel, misconfigured compliance tools, and a failure to conduct proper risk assessments. Despite self-disclosure and cooperation, both companies faced significant fines and were required to implement extensive remediation measures. The discussion highlights the growing importance of robust sanctions compliance programs in mitigating risks and preventing enforcement actions.

Key highlights:

  • Sanctions Enforcement Cases Overview
  • Harman International’s Compliance Failures
  • Interactive Brokers’ Compliance Issues
  • Lessons and Final Thoughts

Resources:

Matt Kelly in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1583 Agentic Misalignment and AI Ethics: Analyzing AI Behavior Under Pressure The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a recent Anthropic report that highlights “agentic misalignment in AI systems.” The discussion addresses the unsettling, independent, and unethical behaviors exhibited by AI systems in extreme scenarios. The conversation explores the implications for corporate risk management, AI governance, and compliance, drawing parallels between AI behavior and human behavior using concepts such as the fraud triangle. The episode also explores how traditional anti-fraud mechanisms may be adapted for monitoring AI agents while reflecting on lessons from science fiction portrayals of AI ethics and risks. Key highlights: AI’s Unethical Behaviors Comparing AI to Human Behavior Fraud Triangle, the Anti-Fraud Triangle, and AI Science Fiction Parallels Resources: Matt Kelly in Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Jul 2025 10:31:00 -0000 full 424 Tom Fox What happens when you AI agent blackmails your CFO for funding? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a recent Anthropic report that highlights “agentic misalignment in AI systems.” The discussion addresses the unsettling, independent, and unethical behaviors exhibited by AI systems in extreme scenarios. The conversation explores the implications for corporate risk management, AI governance, and compliance, drawing parallels between AI behavior and human behavior using concepts such as the fraud triangle. The episode also explores how traditional anti-fraud mechanisms may be adapted for monitoring AI agents while reflecting on lessons from science fiction portrayals of AI ethics and risks. Key highlights: AI’s Unethical Behaviors Comparing AI to Human Behavior Fraud Triangle, the Anti-Fraud Triangle, and AI Science Fiction Parallels Resources: Matt Kelly in Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a recent Anthropic report that highlights “agentic misalignment in AI systems.”

The discussion addresses the unsettling, independent, and unethical behaviors exhibited by AI systems in extreme scenarios. The conversation explores the implications for corporate risk management, AI governance, and compliance, drawing parallels between AI behavior and human behavior using concepts such as the fraud triangle. The episode also explores how traditional anti-fraud mechanisms may be adapted for monitoring AI agents while reflecting on lessons from science fiction portrayals of AI ethics and risks.

Key highlights:

  • AI’s Unethical Behaviors
  • Comparing AI to Human Behavior
  • Fraud Triangle, the Anti-Fraud Triangle, and AI
  • Science Fiction Parallels

Resources:

Matt Kelly in Radical Compliance 

Tom

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A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.

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]]> 1714 no Boeing’s New Safety Initiatives and Compliance Reforms The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Boeing’s recent safety initiatives and reforms, as outlined in their annual aerospace safety report. They explore Boeing’s efforts to improve its speak-up culture, internal reporting systems, and the introduction of an expansive Safety Champions Program. The episode explores the procedural changes Boeing has implemented, including the handling of third-party reports and increased transparency for employees. Additionally, they examine the challenges and necessities of manager training in fostering an ethical corporate culture. The conversation concludes with insights on the recent Federal District Court hearing regarding Boeing’s non-prosecution agreement and the implications for transparency and accountability. Key highlights: Speak Up Culture Enhancements Ambassador Program Expansion Manager Training and Corporate Culture Court Hearing on Boeing’s Non-Prosecution Agreement Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 03 Jul 2025 18:26:00 -0000 Tom Fox and Matt Kelly discuss Boeing's safety initiatives and reforms in their annual Aerospace Safety Report. full 423 Tom Fox The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Boeing’s recent safety initiatives and reforms, as outlined in their annual aerospace safety report. They explore Boeing’s efforts to improve its speak-up culture, internal reporting systems, and the introduction of an expansive Safety Champions Program. The episode explores the procedural changes Boeing has implemented, including the handling of third-party reports and increased transparency for employees. Additionally, they examine the challenges and necessities of manager training in fostering an ethical corporate culture. The conversation concludes with insights on the recent Federal District Court hearing regarding Boeing’s non-prosecution agreement and the implications for transparency and accountability. Key highlights: Speak Up Culture Enhancements Ambassador Program Expansion Manager Training and Corporate Culture Court Hearing on Boeing’s Non-Prosecution Agreement Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Boeing’s recent safety initiatives and reforms, as outlined in their annual aerospace safety report.

They explore Boeing’s efforts to improve its speak-up culture, internal reporting systems, and the introduction of an expansive Safety Champions Program. The episode explores the procedural changes Boeing has implemented, including the handling of third-party reports and increased transparency for employees. Additionally, they examine the challenges and necessities of manager training in fostering an ethical corporate culture. The conversation concludes with insights on the recent Federal District Court hearing regarding Boeing’s non-prosecution agreement and the implications for transparency and accountability.

Key highlights:

  • Speak Up Culture Enhancements
  • Ambassador Program Expansion
  • Manager Training and Corporate Culture
  • Court Hearing on Boeing’s Non-Prosecution Agreement

Resources:

Matt Kelly in Radical Compliance

Tom

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A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast.

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]]> 1260 no The COSO Governance Framework The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recently released COSO Corporate Governance Framework. Tom and Matt take a deep dive into the new COSO Corporate Governance Framework draft. They discuss the importance of public comment on the draft, which is open until July 11, and explore the framework’s six key components. The framework aims to provide discipline in achieving good governance within organizations, covering areas such as strategy, culture, human resources, and resilience. Kelly highlights the significance of culture in compliance and the role of information quality in the future, providing practical tips on implementing and testing the framework. The episode highlights the importance of this framework for various stakeholders, encouraging practitioners to review and provide feedback on the draft. Key highlights: Overview of COSO’s Draft Corporate Governance Framework The Six Objectives of the Framework Importance of Culture in Compliance Principles and Points of Focus Resilience in Corporate Governance Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Jun 2025 04:00:00 -0000 full 422 Tom Fox Tom Fox and Matt Kelly unpack the COSO Corporate Governance Framework. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recently released COSO Corporate Governance Framework. Tom and Matt take a deep dive into the new COSO Corporate Governance Framework draft. They discuss the importance of public comment on the draft, which is open until July 11, and explore the framework’s six key components. The framework aims to provide discipline in achieving good governance within organizations, covering areas such as strategy, culture, human resources, and resilience. Kelly highlights the significance of culture in compliance and the role of information quality in the future, providing practical tips on implementing and testing the framework. The episode highlights the importance of this framework for various stakeholders, encouraging practitioners to review and provide feedback on the draft. Key highlights: Overview of COSO’s Draft Corporate Governance Framework The Six Objectives of the Framework Importance of Culture in Compliance Principles and Points of Focus Resilience in Corporate Governance Resources: Matt Kelly in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recently released COSO Corporate Governance Framework.

Tom and Matt take a deep dive into the new COSO Corporate Governance Framework draft. They discuss the importance of public comment on the draft, which is open until July 11, and explore the framework’s six key components. The framework aims to provide discipline in achieving good governance within organizations, covering areas such as strategy, culture, human resources, and resilience. Kelly highlights the significance of culture in compliance and the role of information quality in the future, providing practical tips on implementing and testing the framework. The episode highlights the importance of this framework for various stakeholders, encouraging practitioners to review and provide feedback on the draft.

Key highlights:

  • Overview of COSO’s Draft Corporate Governance Framework
  • The Six Objectives of the Framework
  • Importance of Culture in Compliance
  • Principles and Points of Focus
  • Resilience in Corporate Governance

Resources:

Matt Kelly in Radical Compliance

Tom

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LinkedIn

A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast.

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]]> 1501 no Changes in FCPA Enforcement The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent memorandum from the Deputy Attorney General regarding the investigation and enforcement of the FCPA. The memo follows President Trump’s executive order pausing FCPA enforcement for six months. The hosts evaluate the potential impacts on compliance programs, with a possible shift to targeting foreign companies that harm US business interests and national security. They also explore the role of the Foreign Extortion Prevention Act and speculate on how the SEC might integrate these changes into its enforcement practices. Key highlights: Initial Reactions to the FCPA Memo Implications for Anti-Corruption Compliance Focus on Foreign Companies and National Security Skepticism and Potential Bias in Enforcement Strategic National Interests and Enforcement Considerations for Compliance Officers Resources: Memo on Guidelines for Investigation and Enforcement of the FCPA Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Jun 2025 04:00:00 -0000 full 421 Tom Fox What do changes in FCPA mean for you? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent memorandum from the Deputy Attorney General regarding the investigation and enforcement of the FCPA. The memo follows President Trump’s executive order pausing FCPA enforcement for six months. The hosts evaluate the potential impacts on compliance programs, with a possible shift to targeting foreign companies that harm US business interests and national security. They also explore the role of the Foreign Extortion Prevention Act and speculate on how the SEC might integrate these changes into its enforcement practices. Key highlights: Initial Reactions to the FCPA Memo Implications for Anti-Corruption Compliance Focus on Foreign Companies and National Security Skepticism and Potential Bias in Enforcement Strategic National Interests and Enforcement Considerations for Compliance Officers Resources: Memo on Guidelines for Investigation and Enforcement of the FCPA Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent memorandum from the Deputy Attorney General regarding the investigation and enforcement of the FCPA.

The memo follows President Trump’s executive order pausing FCPA enforcement for six months. The hosts evaluate the potential impacts on compliance programs, with a possible shift to targeting foreign companies that harm US business interests and national security. They also explore the role of the Foreign Extortion Prevention Act and speculate on how the SEC might integrate these changes into its enforcement practices.

Key highlights:

  • Initial Reactions to the FCPA Memo
  • Implications for Anti-Corruption Compliance
  • Focus on Foreign Companies and National Security
  • Skepticism and Potential Bias in Enforcement
  • Strategic National Interests and Enforcement
  • Considerations for Compliance Officers

Resources:

Memo on Guidelines for Investigation and Enforcement of the FCPA

Tom

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A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1402 no Autonomous AI Whistleblowing Misconduct The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly consider what happens when AI turns whistleblower. The advent of AI technologies, such as Claude Opus 4, has sparked debates over the potential for AI systems to autonomously report misconduct, presenting new ethical and operational challenges within AI governance. Tom Fox views AI whistleblowing with caution, questioning the feasibility of implementing effective governance rules and the complexities involved in distinguishing between AI-generated reports and those of human whistleblowers. His concerns are shaped by the legal and ethical implications of AI’s autonomous actions, highlighting a pressing need for clearer regulations. Similarly, Matt Kelly is concerned about the ethical nuances, emphasizing the difficulty AI might face in understanding corporate ethics and compliance culture without human oversight, and underscores the urgent need for regulatory frameworks to keep pace with the advancements in AI. Fox and Kelly’s perspectives converge on the necessity for robust oversight mechanisms and strategic planning to manage the compliance challenges posed by AI in whistleblowing scenarios. Key highlights: Autonomous AI Reporting Misconduct to Authorities Navigating AI Ethics for Regulatory Compliance Distinguishing AI Reporting in Whistleblower Cases Navigating AI Challenges in Compliance Programs Resources: Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Jun 2025 04:00:00 -0000 full 420 Tom Fox What happens when AI blows the whistle? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly consider what happens when AI turns whistleblower. The advent of AI technologies, such as Claude Opus 4, has sparked debates over the potential for AI systems to autonomously report misconduct, presenting new ethical and operational challenges within AI governance. Tom Fox views AI whistleblowing with caution, questioning the feasibility of implementing effective governance rules and the complexities involved in distinguishing between AI-generated reports and those of human whistleblowers. His concerns are shaped by the legal and ethical implications of AI’s autonomous actions, highlighting a pressing need for clearer regulations. Similarly, Matt Kelly is concerned about the ethical nuances, emphasizing the difficulty AI might face in understanding corporate ethics and compliance culture without human oversight, and underscores the urgent need for regulatory frameworks to keep pace with the advancements in AI. Fox and Kelly’s perspectives converge on the necessity for robust oversight mechanisms and strategic planning to manage the compliance challenges posed by AI in whistleblowing scenarios. Key highlights: Autonomous AI Reporting Misconduct to Authorities Navigating AI Ethics for Regulatory Compliance Distinguishing AI Reporting in Whistleblower Cases Navigating AI Challenges in Compliance Programs Resources: Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly consider what happens when AI turns whistleblower.

The advent of AI technologies, such as Claude Opus 4, has sparked debates over the potential for AI systems to autonomously report misconduct, presenting new ethical and operational challenges within AI governance. Tom Fox views AI whistleblowing with caution, questioning the feasibility of implementing effective governance rules and the complexities involved in distinguishing between AI-generated reports and those of human whistleblowers. His concerns are shaped by the legal and ethical implications of AI’s autonomous actions, highlighting a pressing need for clearer regulations. Similarly, Matt Kelly is concerned about the ethical nuances, emphasizing the difficulty AI might face in understanding corporate ethics and compliance culture without human oversight, and underscores the urgent need for regulatory frameworks to keep pace with the advancements in AI. Fox and Kelly’s perspectives converge on the necessity for robust oversight mechanisms and strategic planning to manage the compliance challenges posed by AI in whistleblowing scenarios.

Key highlights:

  • Autonomous AI Reporting Misconduct to Authorities
  • Navigating AI Ethics for Regulatory Compliance
  • Distinguishing AI Reporting in Whistleblower Cases
  • Navigating AI Challenges in Compliance Programs

Resources:

Radical Compliance

Tom

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]]> 1577 no Boeing, a NPA and the End of Monitors The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully and seeking insightful perspectives on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the Department of Justice’s recent proposal to grant Boeing a non-prosecution agreement. This decision stems from the 737 MAX crashes in the late 2010s that killed 346 people. They cover the history of Boeing’s settlements, the details and leniency of the new agreement, the role and scope of the independent compliance consultant, and the implications for corporate compliance and the victims’ families. The discussion highlights the potential end of compliance monitors and the broader impacts on corporate accountability. Key highlights: DOJ’s Non-Prosecution Agreement with Boeing Changes in the Settlement Agreement Role and Scope of the Independent Compliance Consultant Implications for Compliance Monitorships Boeing’s Whistleblower Program and Compliance Efforts Judicial and Victims’ Family Reactions Resources: Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 May 2025 04:00:00 -0000 full 419 Tom Fox Does the Boeing NPA portend the end of monitors? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully and seeking insightful perspectives on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the Department of Justice’s recent proposal to grant Boeing a non-prosecution agreement. This decision stems from the 737 MAX crashes in the late 2010s that killed 346 people. They cover the history of Boeing’s settlements, the details and leniency of the new agreement, the role and scope of the independent compliance consultant, and the implications for corporate compliance and the victims’ families. The discussion highlights the potential end of compliance monitors and the broader impacts on corporate accountability. Key highlights: DOJ’s Non-Prosecution Agreement with Boeing Changes in the Settlement Agreement Role and Scope of the Independent Compliance Consultant Implications for Compliance Monitorships Boeing’s Whistleblower Program and Compliance Efforts Judicial and Victims’ Family Reactions Resources: Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully and seeking insightful perspectives on compliance. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the Department of Justice’s recent proposal to grant Boeing a non-prosecution agreement.

This decision stems from the 737 MAX crashes in the late 2010s that killed 346 people. They cover the history of Boeing’s settlements, the details and leniency of the new agreement, the role and scope of the independent compliance consultant, and the implications for corporate compliance and the victims’ families. The discussion highlights the potential end of compliance monitors and the broader impacts on corporate accountability.

Key highlights:

  • DOJ’s Non-Prosecution Agreement with Boeing
  • Changes in the Settlement Agreement
  • Role and Scope of the Independent Compliance Consultant
  • Implications for Compliance Monitorships
  • Boeing’s Whistleblower Program and Compliance Efforts
  • Judicial and Victims’ Family Reactions

Resources:

Radical Compliance

 Tom

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A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1546 no Of Wal-Mart, Tariffs and Stakeholder Capitalism The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this episode of Compliance into the Weeds, Tom Fox and Matt Kelly deeply dive into a recent tweet by President Donald Trump targeting Walmart and their announced intention to raise prices based on increased tariff costs. The discussion explores the implications of Trump’s demand that Walmart absorb tariff costs instead of passing them on to consumers. It examines the broader implications for stakeholder capitalism, the role of presidential influence on corporate governance, and the complexities of risk management in an unpredictable political climate. The episode also touches on ESG issues and the delicate balance companies must strike in navigating these challenges. Key highlights: Trump’s Tweet and Walmart’s Dilemma Stakeholder Capitalism vs. Shareholder Primacy Corporate Governance and Presidential Influence Legal Implications and Corporate Compensation Risk Management in Unpredictable Times Resources: Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 May 2025 04:00:00 -0000 full 418 Tom Fox Will a tweet lead to more stakeholder capitalism? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this episode of Compliance into the Weeds, Tom Fox and Matt Kelly deeply dive into a recent tweet by President Donald Trump targeting Walmart and their announced intention to raise prices based on increased tariff costs. The discussion explores the implications of Trump’s demand that Walmart absorb tariff costs instead of passing them on to consumers. It examines the broader implications for stakeholder capitalism, the role of presidential influence on corporate governance, and the complexities of risk management in an unpredictable political climate. The episode also touches on ESG issues and the delicate balance companies must strike in navigating these challenges. Key highlights: Trump’s Tweet and Walmart’s Dilemma Stakeholder Capitalism vs. Shareholder Primacy Corporate Governance and Presidential Influence Legal Implications and Corporate Compensation Risk Management in Unpredictable Times Resources: Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this episode of Compliance into the Weeds, Tom Fox and Matt Kelly deeply dive into a recent tweet by President Donald Trump targeting Walmart and their announced intention to raise prices based on increased tariff costs.

The discussion explores the implications of Trump’s demand that Walmart absorb tariff costs instead of passing them on to consumers. It examines the broader implications for stakeholder capitalism, the role of presidential influence on corporate governance, and the complexities of risk management in an unpredictable political climate. The episode also touches on ESG issues and the delicate balance companies must strike in navigating these challenges.

Key highlights:

  • Trump’s Tweet and Walmart’s Dilemma
  • Stakeholder Capitalism vs. Shareholder Primacy
  • Corporate Governance and Presidential Influence
  • Legal Implications and Corporate Compensation
  • Risk Management in Unpredictable Times

Resources:

Radical Compliance

Tom

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LinkedIn

A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1281 no Leaving on a (Qatari) Jet Plane The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this Compliance into the Weeds episode, Tom Fox and Matt Kelly deeply dive into the potential gift of a luxury Qatari jetliner to President Trump. We discuss the launch of Trump’s meme coins and the Qatari government’s allegedly planned $400 million plane donation to Trump. The conversation examines the compliance and corruption risks these actions pose for U.S. and international businesses. Kelly emphasizes how these incidents challenge ethical standards and underscore the importance for companies to address new forms of corruption proactively within their anti-corruption programs. Key highlights: Trump’s Alleged Corruption: An Overview The Meme Coins Controversy The Qatari Plane Donation Compliance and Integrity in the Face of Corruption Resources: Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 May 2025 04:00:00 -0000 full 417 Tom Fox Matt and Tom look at the current corruption issues swirling around the President. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this Compliance into the Weeds episode, Tom Fox and Matt Kelly deeply dive into the potential gift of a luxury Qatari jetliner to President Trump. We discuss the launch of Trump’s meme coins and the Qatari government’s allegedly planned $400 million plane donation to Trump. The conversation examines the compliance and corruption risks these actions pose for U.S. and international businesses. Kelly emphasizes how these incidents challenge ethical standards and underscore the importance for companies to address new forms of corruption proactively within their anti-corruption programs. Key highlights: Trump’s Alleged Corruption: An Overview The Meme Coins Controversy The Qatari Plane Donation Compliance and Integrity in the Face of Corruption Resources: Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! With a nod to Peter, Paul, Mary, and John Denver, in this Compliance into the Weeds episode, Tom Fox and Matt Kelly deeply dive into the potential gift of a luxury Qatari jetliner to President Trump.

We discuss the launch of Trump’s meme coins and the Qatari government’s allegedly planned $400 million plane donation to Trump. The conversation examines the compliance and corruption risks these actions pose for U.S. and international businesses. Kelly emphasizes how these incidents challenge ethical standards and underscore the importance for companies to address new forms of corruption proactively within their anti-corruption programs.

Key highlights:

  • Trump’s Alleged Corruption: An Overview
  • The Meme Coins Controversy
  • The Qatari Plane Donation
  • Compliance and Integrity in the Face of Corruption

Resources:

Tom

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Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1632 no USRA Declination Case Study: Self-Disclosure Best Practices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the declination recently given by the DOJ to the Universities Space Research Association (USRA). In this episode, Tom and Matt dive deeply into a recent decline issued by the Department of Justice (DOJ) to the University Space Research Association (USRA). The discussion focuses on the organization’s exemplary behavior in self-disclosure and cooperation during an investigation into an employee’s misconduct. This misconduct included unauthorized export of software to Beijing University. The hosts highlight the case as a textbook example of effective compliance practices, self-reporting, and cooperation with regulators. They also explore the DOJ’s guidelines on self-disclosure and the importance of internal controls in high-risk areas. Key highlights: Case Overview: USRA Declination DOJ Press Release Insights Details of the Misconduct USRA’s Response and Cooperation Resources: DOJ Press Release on Universities Space Research Association Declination Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 May 2025 04:00:00 -0000 full Tom Fox Tom Fox and Matt Kelly explore the recent declination given by the DOJ to the USRA. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the declination recently given by the DOJ to the Universities Space Research Association (USRA). In this episode, Tom and Matt dive deeply into a recent decline issued by the Department of Justice (DOJ) to the University Space Research Association (USRA). The discussion focuses on the organization’s exemplary behavior in self-disclosure and cooperation during an investigation into an employee’s misconduct. This misconduct included unauthorized export of software to Beijing University. The hosts highlight the case as a textbook example of effective compliance practices, self-reporting, and cooperation with regulators. They also explore the DOJ’s guidelines on self-disclosure and the importance of internal controls in high-risk areas. Key highlights: Case Overview: USRA Declination DOJ Press Release Insights Details of the Misconduct USRA’s Response and Cooperation Resources: DOJ Press Release on Universities Space Research Association Declination Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the declination recently given by the DOJ to the Universities Space Research Association (USRA).

In this episode, Tom and Matt dive deeply into a recent decline issued by the Department of Justice (DOJ) to the University Space Research Association (USRA). The discussion focuses on the organization’s exemplary behavior in self-disclosure and cooperation during an investigation into an employee’s misconduct. This misconduct included unauthorized export of software to Beijing University. The hosts highlight the case as a textbook example of effective compliance practices, self-reporting, and cooperation with regulators. They also explore the DOJ’s guidelines on self-disclosure and the importance of internal controls in high-risk areas.

Key highlights:

  • Case Overview: USRA Declination
  • DOJ Press Release Insights
  • Details of the Misconduct
  • USRA’s Response and Cooperation

Resources:

DOJ Press Release on Universities Space Research Association Declination

Tom

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Facebook

YouTube

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LinkedIn

Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1113 no Settlement of OCC Charges for Wells Fargo Internal Auditors The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the settlement of charges by the OCC with two former top audit executives at Wells Fargo for their oversight failures during the bank’s fake accounts scandal. The Wells Fargo banking scandal is a cautionary tale of unchecked corporate misconduct and the critical role of auditor accountability. This scandal, which erupted due to Wells Fargo’s creation of fake accounts driven by unrealistic sales targets, exposed the bank’s dysfunctional corporate culture and raised questions about the efficacy of internal audits and the broader implications of regulatory actions. They discuss the scandal as emblematic of the broader issues stemming from repealing the Glass-Steagall Act, which blurs the lines between investment and consumer banking, fostering an environment where misconduct could thrive. Kelly points to the enormity of banks’ post-Glass-Steagall repeal as a breeding ground for potential misconduct and highlights the negligence of Wells Fargo’s leadership in failing to curb unethical practices. Both Fox and Kelly underscore the necessity for a comprehensive reevaluation of compliance and audit roles to prevent future scandals of this magnitude. Key highlights: Settlement of OCC Charges in Wells Fargo Impact of Regulatory Actions on Auditors Unethical Sales Goals Impacting Corporate Culture Glass Steagall Act Repeal: Wells Fargo Impact Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Fri, 02 May 2025 04:00:00 -0000 full 415 Tom Fox Tom Fox and Matt Kelly deeply dive into the OCC's settlement with former Wells Fargo audit executives for their oversight failures during the fake accounts scandal. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the settlement of charges by the OCC with two former top audit executives at Wells Fargo for their oversight failures during the bank’s fake accounts scandal. The Wells Fargo banking scandal is a cautionary tale of unchecked corporate misconduct and the critical role of auditor accountability. This scandal, which erupted due to Wells Fargo’s creation of fake accounts driven by unrealistic sales targets, exposed the bank’s dysfunctional corporate culture and raised questions about the efficacy of internal audits and the broader implications of regulatory actions. They discuss the scandal as emblematic of the broader issues stemming from repealing the Glass-Steagall Act, which blurs the lines between investment and consumer banking, fostering an environment where misconduct could thrive. Kelly points to the enormity of banks’ post-Glass-Steagall repeal as a breeding ground for potential misconduct and highlights the negligence of Wells Fargo’s leadership in failing to curb unethical practices. Both Fox and Kelly underscore the necessity for a comprehensive reevaluation of compliance and audit roles to prevent future scandals of this magnitude. Key highlights: Settlement of OCC Charges in Wells Fargo Impact of Regulatory Actions on Auditors Unethical Sales Goals Impacting Corporate Culture Glass Steagall Act Repeal: Wells Fargo Impact Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the settlement of charges by the OCC with two former top audit executives at Wells Fargo for their oversight failures during the bank’s fake accounts scandal.

The Wells Fargo banking scandal is a cautionary tale of unchecked corporate misconduct and the critical role of auditor accountability. This scandal, which erupted due to Wells Fargo’s creation of fake accounts driven by unrealistic sales targets, exposed the bank’s dysfunctional corporate culture and raised questions about the efficacy of internal audits and the broader implications of regulatory actions. They discuss the scandal as emblematic of the broader issues stemming from repealing the Glass-Steagall Act, which blurs the lines between investment and consumer banking, fostering an environment where misconduct could thrive. Kelly points to the enormity of banks’ post-Glass-Steagall repeal as a breeding ground for potential misconduct and highlights the negligence of Wells Fargo’s leadership in failing to curb unethical practices. Both Fox and Kelly underscore the necessity for a comprehensive reevaluation of compliance and audit roles to prevent future scandals of this magnitude.

Key highlights:

  • Settlement of OCC Charges in Wells Fargo
  • Impact of Regulatory Actions on Auditors
  • Unethical Sales Goals Impacting Corporate Culture
  • Glass Steagall Act Repeal: Wells Fargo Impact

Resources:

Matt in Radical Compliance

Tom

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Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1257 no The Uncertain Future of Compliance Monitors under the Trump Administration The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the future role of compliance monitors in the corporate world under the Trump administration. Despite the potential for changes, federal prosecutors are expected to continue using compliance monitors as a critical tool. However, the criteria for assigning these monitors may become more limited. The episode critically examines the trustworthiness of statements from the Trump administration and its Justice Department, emphasizing the uncertainty facing corporations and compliance professionals moving forward. Key highlights: Trump Administration’s Stance on Monitors Criteria for Assigning Monitors Skepticism Towards Statements Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Apr 2025 05:00:00 -0000 full 414 Tom Fox Tom Fox and Matt Kelly explore the future role of compliance monitors in the corporate world under the Trump administration. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the future role of compliance monitors in the corporate world under the Trump administration. Despite the potential for changes, federal prosecutors are expected to continue using compliance monitors as a critical tool. However, the criteria for assigning these monitors may become more limited. The episode critically examines the trustworthiness of statements from the Trump administration and its Justice Department, emphasizing the uncertainty facing corporations and compliance professionals moving forward. Key highlights: Trump Administration’s Stance on Monitors Criteria for Assigning Monitors Skepticism Towards Statements Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the future role of compliance monitors in the corporate world under the Trump administration.

Despite the potential for changes, federal prosecutors are expected to continue using compliance monitors as a critical tool. However, the criteria for assigning these monitors may become more limited. The episode critically examines the trustworthiness of statements from the Trump administration and its Justice Department, emphasizing the uncertainty facing corporations and compliance professionals moving forward.

Key highlights:

  • Trump Administration’s Stance on Monitors
  • Criteria for Assigning Monitors
  • Skepticism Towards Statements

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1311 no Unsexy Keys to Data Analytics for Compliance Programs The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the critical yet often overlooked aspects of data analytics. They discuss Matt’s recent blog post on the ‘Unsexy Keys to Data Analytics,’ emphasizing the importance of foundational infrastructure over flashy visualizations. The conversation covers the need for robust data validation, the cooperation between compliance, business units, and IT departments, and the challenges faced by compliance officers in smaller companies. Highlights include real-world examples, the role of data governance, and how to align compliance risk management with corporate objectives amid ever-changing business landscapes. Key highlights: The Importance of Data Infrastructure Compliance vs. Enterprise Data Analytics Collaboration Across Departments Data Governance and Change Management Aligning Compliance with Corporate Risk Management Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Apr 2025 05:00:00 -0000 full 413 Tom Fox Tom Fox and Matt Kelly explore critical yet often overlooked aspects of data analytics. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the critical yet often overlooked aspects of data analytics. They discuss Matt’s recent blog post on the ‘Unsexy Keys to Data Analytics,’ emphasizing the importance of foundational infrastructure over flashy visualizations. The conversation covers the need for robust data validation, the cooperation between compliance, business units, and IT departments, and the challenges faced by compliance officers in smaller companies. Highlights include real-world examples, the role of data governance, and how to align compliance risk management with corporate objectives amid ever-changing business landscapes. Key highlights: The Importance of Data Infrastructure Compliance vs. Enterprise Data Analytics Collaboration Across Departments Data Governance and Change Management Aligning Compliance with Corporate Risk Management Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the critical yet often overlooked aspects of data analytics.

They discuss Matt’s recent blog post on the ‘Unsexy Keys to Data Analytics,’ emphasizing the importance of foundational infrastructure over flashy visualizations. The conversation covers the need for robust data validation, the cooperation between compliance, business units, and IT departments, and the challenges faced by compliance officers in smaller companies. Highlights include real-world examples, the role of data governance, and how to align compliance risk management with corporate objectives amid ever-changing business landscapes.

Key highlights:

  • The Importance of Data Infrastructure
  • Compliance vs. Enterprise Data Analytics
  • Collaboration Across Departments
  • Data Governance and Change Management
  • Aligning Compliance with Corporate Risk Management

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1379 no The Role of Compliance Going Forward The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the intricate future of corporate compliance amidst changes brought by the presidential executive order suspending FCPA investigation and enforcement. Matt shares insights from a recent Compliance Week event in Boston, highlighting concerns among compliance professionals about the potential obsolescence of their roles. The discussion covers two primary scenarios: regulatory relaxation, making dedicated compliance roles redundant, and technological advancements, particularly AI, potentially replacing human compliance officers. However, both agree on the enduring importance of robust compliance functions integrated within corporate structures, emphasizing the strategic value of compliance in risk management and business operations. They explore the dual excitement and anxiety surrounding AI’s role in compliance. Matt and Tom caution against shortsighted management decisions to decentralize compliance functions and highlight how AI can be harnessed to enhance rather than replace human oversight. They argue for proactive measures from compliance officers to demonstrate their value and leverage AI to improve compliance programs. As Matt eloquently puts it, this is a challenging yet opportune time for compliance professionals to up their game and secure their vital role in ensuring corporate integrity and efficiency. Key highlights: The Future of Compliance Post-Executive Order The Role of Technology in Compliance AI’s Impact on Compliance Officers Strategic Imperatives for Compliance Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Hui Chen A Pause in FCPA Enforcement: Crisis or Opportunity Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Apr 2025 05:00:00 -0000 full 412 Tom Fox Tom Fox and Matt Kelly explore the future of corporate compliance amid the suspension of FCPA investigation and enforcement by the presidential executive order. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the intricate future of corporate compliance amidst changes brought by the presidential executive order suspending FCPA investigation and enforcement. Matt shares insights from a recent Compliance Week event in Boston, highlighting concerns among compliance professionals about the potential obsolescence of their roles. The discussion covers two primary scenarios: regulatory relaxation, making dedicated compliance roles redundant, and technological advancements, particularly AI, potentially replacing human compliance officers. However, both agree on the enduring importance of robust compliance functions integrated within corporate structures, emphasizing the strategic value of compliance in risk management and business operations. They explore the dual excitement and anxiety surrounding AI’s role in compliance. Matt and Tom caution against shortsighted management decisions to decentralize compliance functions and highlight how AI can be harnessed to enhance rather than replace human oversight. They argue for proactive measures from compliance officers to demonstrate their value and leverage AI to improve compliance programs. As Matt eloquently puts it, this is a challenging yet opportune time for compliance professionals to up their game and secure their vital role in ensuring corporate integrity and efficiency. Key highlights: The Future of Compliance Post-Executive Order The Role of Technology in Compliance AI’s Impact on Compliance Officers Strategic Imperatives for Compliance Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Hui Chen A Pause in FCPA Enforcement: Crisis or Opportunity Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly take a deep dive into the intricate future of corporate compliance amidst changes brought by the presidential executive order suspending FCPA investigation and enforcement.

Matt shares insights from a recent Compliance Week event in Boston, highlighting concerns among compliance professionals about the potential obsolescence of their roles. The discussion covers two primary scenarios: regulatory relaxation, making dedicated compliance roles redundant, and technological advancements, particularly AI, potentially replacing human compliance officers. However, both agree on the enduring importance of robust compliance functions integrated within corporate structures, emphasizing the strategic value of compliance in risk management and business operations.

They explore the dual excitement and anxiety surrounding AI’s role in compliance. Matt and Tom caution against shortsighted management decisions to decentralize compliance functions and highlight how AI can be harnessed to enhance rather than replace human oversight. They argue for proactive measures from compliance officers to demonstrate their value and leverage AI to improve compliance programs. As Matt eloquently puts it, this is a challenging yet opportune time for compliance professionals to up their game and secure their vital role in ensuring corporate integrity and efficiency.

Key highlights:

  • The Future of Compliance Post-Executive Order
  • The Role of Technology in Compliance
  • AI’s Impact on Compliance Officers
  • Strategic Imperatives for Compliance

Resources:

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Hui Chen A Pause in FCPA Enforcement: Crisis or Opportunity

Tom

Instagram

Facebook

YouTube

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LinkedIn

Compliance into the Weeds was recently honored as one of a Top 25 Regulatory Compliance Podcast

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1354 no Global Anti-Corruption Leadership The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly are joined by Mary Inman, a founding partner at Whistleblower Partners. Matt, Tom, and Mary reflect on the global response to anti-corruption measures following an executive order issued by former President Trump. The conversation highlights webinars conducted in early 2025 that addressed concerns over who would enforce anti-corruption laws worldwide if the United States stepped back. The sentiment among countries like Brazil, Hong Kong, Singapore, England, and France was clear; they were ready to take on the mantle themselves. Mary reports on her conversations with the SFO in London about instituting a whistleblower program and similar initiatives in the United Kingdom at His Majesty’s Revenue and Customs and the Financial Conduct Authority. Key highlights: Global Anti-Corruption Sentiment Post-Trump’s Executive Order Encouraging International Enforcement Evidence of Global Enforcement Actions Whistleblower Incentives in the UK Global Leadership in Anti-Corruption Resources: Mary Inman on LinkedIn Whistleblower Partners Matt in Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Mar 2025 05:00:00 -0000 Global Anti-Corruption Leadership full 411 Tom Fox Matt, Tom, and Mary reflect on the global response to anti-corruption measures following Trump's executive order. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly are joined by Mary Inman, a founding partner at Whistleblower Partners. Matt, Tom, and Mary reflect on the global response to anti-corruption measures following an executive order issued by former President Trump. The conversation highlights webinars conducted in early 2025 that addressed concerns over who would enforce anti-corruption laws worldwide if the United States stepped back. The sentiment among countries like Brazil, Hong Kong, Singapore, England, and France was clear; they were ready to take on the mantle themselves. Mary reports on her conversations with the SFO in London about instituting a whistleblower program and similar initiatives in the United Kingdom at His Majesty’s Revenue and Customs and the Financial Conduct Authority. Key highlights: Global Anti-Corruption Sentiment Post-Trump’s Executive Order Encouraging International Enforcement Evidence of Global Enforcement Actions Whistleblower Incentives in the UK Global Leadership in Anti-Corruption Resources: Mary Inman on LinkedIn Whistleblower Partners Matt in Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly are joined by Mary Inman, a founding partner at Whistleblower Partners.

Matt, Tom, and Mary reflect on the global response to anti-corruption measures following an executive order issued by former President Trump. The conversation highlights webinars conducted in early 2025 that addressed concerns over who would enforce anti-corruption laws worldwide if the United States stepped back. The sentiment among countries like Brazil, Hong Kong, Singapore, England, and France was clear; they were ready to take on the mantle themselves.

Mary reports on her conversations with the SFO in London about instituting a whistleblower program and similar initiatives in the United Kingdom at His Majesty’s Revenue and Customs and the Financial Conduct Authority.

Key highlights:

  • Global Anti-Corruption Sentiment Post-Trump’s Executive Order
  • Encouraging International Enforcement
  • Evidence of Global Enforcement Actions
  • Whistleblower Incentives in the UK
  • Global Leadership in Anti-Corruption

Resources:

Mary Inman on LinkedIn

Whistleblower Partners

Matt in Radical Compliance 

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1843 no A Deep Dive into Employee Leaks and Corporate Culture The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the issues surrounding employee leaks of confidential information, drawing on insights from a recent SCCE Europe event. They also consider the motivations behind such leaks, including dissatisfaction with corporate culture and ineffective internal reporting channels, exemplified by the recent leaks at Facebook. The episode reviews measures compliance officers can take to prevent leaks, such as implementing tight access controls, encryption, and improving communication during investigations. Practical tips for reducing leaks and the importance of trust in internal reporting are also highlighted. Key highlights: Discussion on Employee Leaks Facebook’s Toxic Culture (or not) and Leaks Addressing Internal Speak-Up Culture Practical Tips to Prevent Leaks Modern Communication Challenges Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Mar 2025 05:00:00 -0000 A Deep Dive into Employee Leaks and Corporate Culture full 410 Tom Fox Tom and Matt discuss the issue of employee leaks of confidential information, based on insights from a recent SCCE Europe event. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the issues surrounding employee leaks of confidential information, drawing on insights from a recent SCCE Europe event. They also consider the motivations behind such leaks, including dissatisfaction with corporate culture and ineffective internal reporting channels, exemplified by the recent leaks at Facebook. The episode reviews measures compliance officers can take to prevent leaks, such as implementing tight access controls, encryption, and improving communication during investigations. Practical tips for reducing leaks and the importance of trust in internal reporting are also highlighted. Key highlights: Discussion on Employee Leaks Facebook’s Toxic Culture (or not) and Leaks Addressing Internal Speak-Up Culture Practical Tips to Prevent Leaks Modern Communication Challenges Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the issues surrounding employee leaks of confidential information, drawing on insights from a recent SCCE Europe event.

They also consider the motivations behind such leaks, including dissatisfaction with corporate culture and ineffective internal reporting channels, exemplified by the recent leaks at Facebook. The episode reviews measures compliance officers can take to prevent leaks, such as implementing tight access controls, encryption, and improving communication during investigations. Practical tips for reducing leaks and the importance of trust in internal reporting are also highlighted.

Key highlights:

  • Discussion on Employee Leaks
  • Facebook’s Toxic Culture (or not) and Leaks
  • Addressing Internal Speak-Up Culture
  • Practical Tips to Prevent Leaks
  • Modern Communication Challenges

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1439 no More Compliance Challenges in the Trump Era The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss additional compliance issues raised by the current administration. The first involves the Trump Administration investigating environmental groups receiving EPA grants. While both believe the investigations are politically motivated, they highlight the need for a robust compliance program, documentation of that program in practice, and transparency with stakeholders. The second example is the Democratic Republic of Congo’s offer to the Trump administration for mineral extraction rights, raising concerns about navigating FCPA compliance amid high corruption risks. The episode underscores the importance of robust compliance capabilities to handle unpredictable regulatory environments and emerging risks. Key highlights: Compliance Issues under the Trump Administration Environmental Groups Under Investigation The Democratic Republic of the Congo Deal Compliance is the Answer Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Mar 2025 05:00:00 -0000 More Compliance Challenges in the Trump Era full Tom Fox Tom Fox and Matt Kelly discuss additional compliance issues brought up by the current administration in this episode. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss additional compliance issues raised by the current administration. The first involves the Trump Administration investigating environmental groups receiving EPA grants. While both believe the investigations are politically motivated, they highlight the need for a robust compliance program, documentation of that program in practice, and transparency with stakeholders. The second example is the Democratic Republic of Congo’s offer to the Trump administration for mineral extraction rights, raising concerns about navigating FCPA compliance amid high corruption risks. The episode underscores the importance of robust compliance capabilities to handle unpredictable regulatory environments and emerging risks. Key highlights: Compliance Issues under the Trump Administration Environmental Groups Under Investigation The Democratic Republic of the Congo Deal Compliance is the Answer Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss additional compliance issues raised by the current administration.

The first involves the Trump Administration investigating environmental groups receiving EPA grants. While both believe the investigations are politically motivated, they highlight the need for a robust compliance program, documentation of that program in practice, and transparency with stakeholders. The second example is the Democratic Republic of Congo’s offer to the Trump administration for mineral extraction rights, raising concerns about navigating FCPA compliance amid high corruption risks. The episode underscores the importance of robust compliance capabilities to handle unpredictable regulatory environments and emerging risks.

Key highlights:

  • Compliance Issues under the Trump Administration
  • Environmental Groups Under Investigation
  • The Democratic Republic of the Congo Deal
  • Compliance is the Answer

Resources

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1877 no Compliance – Who Are We? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly discuss a recent conference Matt attended that delved into compliance and the compliance profession in the Age of Trump II. Their discussion highlighted insights from a recent compliance panel hosted by Suffolk University Law School, featuring experts from large tech companies, a multi-state credit union, and a partner from a private law firm. The consensus among these experts is that despite the change in administration, the fundamental responsibilities and importance of compliance remain largely unchanged for organizations. Compliance is now deeply embedded in business operations, key in managing vendor risk, ensuring data protection, and upholding ethical standards. Matt emphasizes that compliance capabilities are vital when dealing with other companies, whether they are customers or vendors. The conversation explores the convergence of vendor risk management and ethics & compliance programs and examines how organizations can sustain their integrity and manage emerging risks. Matt and Tom touch on the potential impact of new regulations, the importance of internal stakeholders in the compliance process, and the necessity of maintaining a robust risk management framework in an ever-changing regulatory environment. This episode provides valuable insights for compliance officers navigating the complexities of the modern corporate landscape. Key highlights: Compliance in the Trump Administration Vendor Risk Management Impact of Tariffs on Compliance Who Are We as a Company? Managing Regulatory Uncertainty Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Mar 2025 06:00:00 -0000 full Tom Fox Tom and Matt explore the question of 'Who Are We?' as a compliance profession. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly discuss a recent conference Matt attended that delved into compliance and the compliance profession in the Age of Trump II. Their discussion highlighted insights from a recent compliance panel hosted by Suffolk University Law School, featuring experts from large tech companies, a multi-state credit union, and a partner from a private law firm. The consensus among these experts is that despite the change in administration, the fundamental responsibilities and importance of compliance remain largely unchanged for organizations. Compliance is now deeply embedded in business operations, key in managing vendor risk, ensuring data protection, and upholding ethical standards. Matt emphasizes that compliance capabilities are vital when dealing with other companies, whether they are customers or vendors. The conversation explores the convergence of vendor risk management and ethics & compliance programs and examines how organizations can sustain their integrity and manage emerging risks. Matt and Tom touch on the potential impact of new regulations, the importance of internal stakeholders in the compliance process, and the necessity of maintaining a robust risk management framework in an ever-changing regulatory environment. This episode provides valuable insights for compliance officers navigating the complexities of the modern corporate landscape. Key highlights: Compliance in the Trump Administration Vendor Risk Management Impact of Tariffs on Compliance Who Are We as a Company? Managing Regulatory Uncertainty Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly discuss a recent conference Matt attended that delved into compliance and the compliance profession in the Age of Trump II.

Their discussion highlighted insights from a recent compliance panel hosted by Suffolk University Law School, featuring experts from large tech companies, a multi-state credit union, and a partner from a private law firm. The consensus among these experts is that despite the change in administration, the fundamental responsibilities and importance of compliance remain largely unchanged for organizations. Compliance is now deeply embedded in business operations, key in managing vendor risk, ensuring data protection, and upholding ethical standards.

Matt emphasizes that compliance capabilities are vital when dealing with other companies, whether they are customers or vendors. The conversation explores the convergence of vendor risk management and ethics & compliance programs and examines how organizations can sustain their integrity and manage emerging risks. Matt and Tom touch on the potential impact of new regulations, the importance of internal stakeholders in the compliance process, and the necessity of maintaining a robust risk management framework in an ever-changing regulatory environment. This episode provides valuable insights for compliance officers navigating the complexities of the modern corporate landscape.

Key highlights:

  • Compliance in the Trump Administration
  • Vendor Risk Management
  • Impact of Tariffs on Compliance
  • Who Are We as a Company?
  • Managing Regulatory Uncertainty

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1416 no Exploring Corporate Culture Disconnect The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the recently released 2025 E&C Program Effectiveness Report (Report) from LRN and deeply dive into its findings of a disconnect between top management and employees on ethics and compliance. Tom and Matt examine the significant findings of the LRN survey conducted among over 1,500 ethics and compliance professionals, which formed the basis for the 2025 Report. They emphasize the widening perception gap about corporate ethical culture between senior executives and lower-level employees and discuss the importance of transparency, consistent disciplinary measures, and engagement of frontline employees to bridge this divide. Matt and Tom also address compliance officers’ challenges in assessing their organizations’ ethical culture and suggest practical steps for fostering a more cohesive environment. Key highlights: Key Findings from the LRN Report Assessing and Addressing the Perception Gap Building Trust and Transparency Involving Employees in Policy Design Engaging with Employees and Building Community Resources: Matt in Radical Compliance LRN 2025 E&C Program Effectiveness Report Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Feb 2025 06:00:00 -0000 Exploring Corporate Culture Disconnect full 407 Tom Fox Tom and Matt review the ORN 2025 E&C Program Effectiveness Report. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the recently released 2025 E&C Program Effectiveness Report (Report) from LRN and deeply dive into its findings of a disconnect between top management and employees on ethics and compliance. Tom and Matt examine the significant findings of the LRN survey conducted among over 1,500 ethics and compliance professionals, which formed the basis for the 2025 Report. They emphasize the widening perception gap about corporate ethical culture between senior executives and lower-level employees and discuss the importance of transparency, consistent disciplinary measures, and engagement of frontline employees to bridge this divide. Matt and Tom also address compliance officers’ challenges in assessing their organizations’ ethical culture and suggest practical steps for fostering a more cohesive environment. Key highlights: Key Findings from the LRN Report Assessing and Addressing the Perception Gap Building Trust and Transparency Involving Employees in Policy Design Engaging with Employees and Building Community Resources: Matt in Radical Compliance LRN 2025 E&C Program Effectiveness Report Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the recently released 2025 E&C Program Effectiveness Report (Report) from LRN and deeply dive into its findings of a disconnect between top management and employees on ethics and compliance.

Tom and Matt examine the significant findings of the LRN survey conducted among over 1,500 ethics and compliance professionals, which formed the basis for the 2025 Report. They emphasize the widening perception gap about corporate ethical culture between senior executives and lower-level employees and discuss the importance of transparency, consistent disciplinary measures, and engagement of frontline employees to bridge this divide. Matt and Tom also address compliance officers’ challenges in assessing their organizations’ ethical culture and suggest practical steps for fostering a more cohesive environment.

Key highlights:

  • Key Findings from the LRN Report
  • Assessing and Addressing the Perception Gap
  • Building Trust and Transparency
  • Involving Employees in Policy Design
  • Engaging with Employees and Building Community

Resources:

Matt in Radical Compliance

LRN 2025 E&C Program Effectiveness Report

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1369 no The DOJ in Crisis The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the recent astonishing developments at the Justice Department involving the indictment and subsequent attempted dismissal of charges against New York City Mayor Eric Adams. Tom and Matt explore the implications for corporate compliance professionals and the broader message this dysfunction sends about ethics and the role of compliance programs under the current administration. They consider the possible repercussions for future corporate enforcement, drawing important parallels between the Justice Department’s actions and the expectations for corporate compliance. They emphasize the necessity of disentailing the ethical dysfunction at the department from the practical guidelines for compliance programs. The episode critically analyzes how political maneuvers affect the justice system and corporate compliance standards. Key highlights: The Eric Adams Indictment Resignations and Internal Conflict Separating DOJ Integrity from Compliance Guidance Tone at the Top vs. Mood at the Middle Future of Compliance Guidelines Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Feb 2025 06:00:00 -0000 The DOJ in Crisis full 406 Tom Fox Tom and Matt look at the current DOJ crisis. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the recent astonishing developments at the Justice Department involving the indictment and subsequent attempted dismissal of charges against New York City Mayor Eric Adams. Tom and Matt explore the implications for corporate compliance professionals and the broader message this dysfunction sends about ethics and the role of compliance programs under the current administration. They consider the possible repercussions for future corporate enforcement, drawing important parallels between the Justice Department’s actions and the expectations for corporate compliance. They emphasize the necessity of disentailing the ethical dysfunction at the department from the practical guidelines for compliance programs. The episode critically analyzes how political maneuvers affect the justice system and corporate compliance standards. Key highlights: The Eric Adams Indictment Resignations and Internal Conflict Separating DOJ Integrity from Compliance Guidance Tone at the Top vs. Mood at the Middle Future of Compliance Guidelines Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the recent astonishing developments at the Justice Department involving the indictment and subsequent attempted dismissal of charges against New York City Mayor Eric Adams.

Tom and Matt explore the implications for corporate compliance professionals and the broader message this dysfunction sends about ethics and the role of compliance programs under the current administration. They consider the possible repercussions for future corporate enforcement, drawing important parallels between the Justice Department’s actions and the expectations for corporate compliance. They emphasize the necessity of disentailing the ethical dysfunction at the department from the practical guidelines for compliance programs. The episode critically analyzes how political maneuvers affect the justice system and corporate compliance standards.

Key highlights:

  • The Eric Adams Indictment
  • Resignations and Internal Conflict
  • Separating DOJ Integrity from Compliance Guidance
  • Tone at the Top vs. Mood at the Middle
  • Future of Compliance Guidelines

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Compliance into the Weeds was recently honored as one of the Top 25 Regulatory Compliance Podcast.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1283 no End of FCPA and CFPB? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the Trump Administration’s attempts to end enforcement by the CFPB and corruption under the FCPA. Last week, significant alterations were made to enforcement policies related to the Foreign Corrupt Practices Act (FCPA) and the Consumer Financial Protection Bureau (CFPB), resulting in a noticeable reduction in enforcement efforts and a shift in focus towards issues like corporate bribery associated with drug cartels and human trafficking. These actions will create risks for U.S. businessmen in countries like China, who might face false charges due to the de-emphasis on traditional FCPA enforcement, and these policy shifts might expose U.S. companies to anti-corruption investigations leveraged by other countries in retaliation to Trump’s trade policies. Matt Kelly emphasizes the need for businesses to maintain robust compliance programs despite the enforcement rollback, warning that legal risks remain due to the statute of limitations, and stresses the importance of upholding corporate compliance and ethical standards to prevent corruption. Through their extensive experiences in compliance and corporate governance, both Tom and Matt highlight the complexities and potential repercussions of these enforcement changes on global business operations. Key highlights: Introduction: Unpacking the Current Situation Emphasis on Corporate Bribery in Enforcement Changes Upholding Compliance Duties Amid Enforcement Changes FCPA and CFPB Statute of Limitations Global Business Impact of Trump’s Trade Policies Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Feb 2025 06:00:00 -0000 End of FCPA and CFPB? full 407 Tom Fox Tom and Matt ask if it is the end of FCPA and CFPB. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the Trump Administration’s attempts to end enforcement by the CFPB and corruption under the FCPA. Last week, significant alterations were made to enforcement policies related to the Foreign Corrupt Practices Act (FCPA) and the Consumer Financial Protection Bureau (CFPB), resulting in a noticeable reduction in enforcement efforts and a shift in focus towards issues like corporate bribery associated with drug cartels and human trafficking. These actions will create risks for U.S. businessmen in countries like China, who might face false charges due to the de-emphasis on traditional FCPA enforcement, and these policy shifts might expose U.S. companies to anti-corruption investigations leveraged by other countries in retaliation to Trump’s trade policies. Matt Kelly emphasizes the need for businesses to maintain robust compliance programs despite the enforcement rollback, warning that legal risks remain due to the statute of limitations, and stresses the importance of upholding corporate compliance and ethical standards to prevent corruption. Through their extensive experiences in compliance and corporate governance, both Tom and Matt highlight the complexities and potential repercussions of these enforcement changes on global business operations. Key highlights: Introduction: Unpacking the Current Situation Emphasis on Corporate Bribery in Enforcement Changes Upholding Compliance Duties Amid Enforcement Changes FCPA and CFPB Statute of Limitations Global Business Impact of Trump’s Trade Policies Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly review the Trump Administration’s attempts to end enforcement by the CFPB and corruption under the FCPA.

Last week, significant alterations were made to enforcement policies related to the Foreign Corrupt Practices Act (FCPA) and the Consumer Financial Protection Bureau (CFPB), resulting in a noticeable reduction in enforcement efforts and a shift in focus towards issues like corporate bribery associated with drug cartels and human trafficking. These actions will create risks for U.S. businessmen in countries like China, who might face false charges due to the de-emphasis on traditional FCPA enforcement, and these policy shifts might expose U.S. companies to anti-corruption investigations leveraged by other countries in retaliation to Trump’s trade policies.

Matt Kelly emphasizes the need for businesses to maintain robust compliance programs despite the enforcement rollback, warning that legal risks remain due to the statute of limitations, and stresses the importance of upholding corporate compliance and ethical standards to prevent corruption. Through their extensive experiences in compliance and corporate governance, both Tom and Matt highlight the complexities and potential repercussions of these enforcement changes on global business operations.

Key highlights:

  • Introduction: Unpacking the Current Situation
  • Emphasis on Corporate Bribery in Enforcement Changes
  • Upholding Compliance Duties Amid Enforcement Changes
  • FCPA and CFPB Statute of Limitations
  • Global Business Impact of Trump’s Trade Policies

Resources:

Matt in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1364 no Why Compliance Officers Should Consider Public Office The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly explore why compliance officers are uniquely suited for public office. Tom and Matt discuss the inspiring story of Doron Clark, a Medtronic compliance officer recently elected Democratic state senator in Minnesota. This event sparked a larger conversation about why compliance professionals possess a unique skill set that could greatly benefit public office. Matt and Tom consider the various competencies of compliance officers, such as persuasion, investigation, policy development, and ethics, which are highly valuable in governance. The discussion highlights the role of compliance officers in fostering good conduct and ethical behavior within organizations, skills that can translate well to public service. They emphasize the importance of collaboration, resource allocation, and effective communication, competencies that are often lacking in today’s political climate. The episode concludes with Matt encouraging more compliance professionals to consider running for public office and the possibilities they bring for positive societal change. Key highlights: The Skill Set of Compliance Officers Challenges and Real-World Applications Local Governance and Compliance Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Feb 2025 06:00:00 -0000 Why Compliance Officers Should Consider Public Office full 404 Tom Fox Tom and Matt look at compliance professionals as elected officials. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly explore why compliance officers are uniquely suited for public office. Tom and Matt discuss the inspiring story of Doron Clark, a Medtronic compliance officer recently elected Democratic state senator in Minnesota. This event sparked a larger conversation about why compliance professionals possess a unique skill set that could greatly benefit public office. Matt and Tom consider the various competencies of compliance officers, such as persuasion, investigation, policy development, and ethics, which are highly valuable in governance. The discussion highlights the role of compliance officers in fostering good conduct and ethical behavior within organizations, skills that can translate well to public service. They emphasize the importance of collaboration, resource allocation, and effective communication, competencies that are often lacking in today’s political climate. The episode concludes with Matt encouraging more compliance professionals to consider running for public office and the possibilities they bring for positive societal change. Key highlights: The Skill Set of Compliance Officers Challenges and Real-World Applications Local Governance and Compliance Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly explore why compliance officers are uniquely suited for public office.


Tom and Matt discuss the inspiring story of Doron Clark, a Medtronic compliance officer recently elected Democratic state senator in Minnesota. This event sparked a larger conversation about why compliance professionals possess a unique skill set that could greatly benefit public office. Matt and Tom consider the various competencies of compliance officers, such as persuasion, investigation, policy development, and ethics, which are highly valuable in governance.


The discussion highlights the role of compliance officers in fostering good conduct and ethical behavior within organizations, skills that can translate well to public service. They emphasize the importance of collaboration, resource allocation, and effective communication, competencies that are often lacking in today’s political climate. The episode concludes with Matt encouraging more compliance professionals to consider running for public office and the possibilities they bring for positive societal change.


Key highlights:


  • The Skill Set of Compliance Officers
  • Challenges and Real-World Applications
  • Local Governance and Compliance


Resources


Matt in Radical Compliance


Tom


Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1021 no The IG Friday Night Massacre The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly explore the Trump Administration’s summary of the Friday night firing of 17 US Inspector Generals. They explore the background and illegality of these firings, highlighting the critical role Inspector Generals play in the federal government by investigating fraud, mismanagement, and abuse. Furthermore, they discuss the implications for compliance professionals, comparing this situation to what would be deemed unacceptable in corporate settings. The conversation also touches on potential consequences, such as increased False Claims Act lawsuits and the problematic precedent set for the rule of law within federal agencies. Key highlights: The Friday Night Massacre: What Happened? Role and Importance of Inspectors General Comparisons to Corporate Governance Potential Consequences and Future Outlook Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Jan 2025 16:31:00 -0000 The IG Friday Night Massacre full 403 Tom Fox Tom and Matt dive into the Friday night IG terminations. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly explore the Trump Administration’s summary of the Friday night firing of 17 US Inspector Generals. They explore the background and illegality of these firings, highlighting the critical role Inspector Generals play in the federal government by investigating fraud, mismanagement, and abuse. Furthermore, they discuss the implications for compliance professionals, comparing this situation to what would be deemed unacceptable in corporate settings. The conversation also touches on potential consequences, such as increased False Claims Act lawsuits and the problematic precedent set for the rule of law within federal agencies. Key highlights: The Friday Night Massacre: What Happened? Role and Importance of Inspectors General Comparisons to Corporate Governance Potential Consequences and Future Outlook Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly explore the Trump Administration’s summary of the Friday night firing of 17 US Inspector Generals.

They explore the background and illegality of these firings, highlighting the critical role Inspector Generals play in the federal government by investigating fraud, mismanagement, and abuse. Furthermore, they discuss the implications for compliance professionals, comparing this situation to what would be deemed unacceptable in corporate settings. The conversation also touches on potential consequences, such as increased False Claims Act lawsuits and the problematic precedent set for the rule of law within federal agencies.

Key highlights:

  • The Friday Night Massacre: What Happened?
  • Role and Importance of Inspectors General
  • Comparisons to Corporate Governance
  • Potential Consequences and Future Outlook

Resources:

Matt in Radical Compliance

Tom

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]]> 1355 no The CSBS and State-Level Enforcement Actions in AML The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly explore a significant enforcement action by the Conference of State Bank Supervisors (CSBS) against Block Inc. They discuss the CSBS’s role as a collective of state banking regulators, the reasons behind the $80 million fine imposed on Block, and the extensive compliance reforms the company must implement, including appointing an independent consultant. They consider the broader implications of state-level enforcement actions in areas like anti-money laundering and data privacy, especially in light of potential shifts in federal regulatory priorities. Matt and Tom consider how compliance professionals can adapt by bolstering transparency, forming compliance committees, and staying abreast of the evolving regulatory landscape. Key highlights: Understanding the CSBS and Block Inc. Enforcement Implications of State-Level Enforcement Comparative Enforcement Actions Challenges for Compliance Professionals Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Jan 2025 06:00:00 -0000 The CSBS and State-Level Enforcement Actions in AML full 402 Tom Fox Tom Fox and Matt Kelly discuss a significant enforcement action by the CSBS against Block Inc. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly explore a significant enforcement action by the Conference of State Bank Supervisors (CSBS) against Block Inc. They discuss the CSBS’s role as a collective of state banking regulators, the reasons behind the $80 million fine imposed on Block, and the extensive compliance reforms the company must implement, including appointing an independent consultant. They consider the broader implications of state-level enforcement actions in areas like anti-money laundering and data privacy, especially in light of potential shifts in federal regulatory priorities. Matt and Tom consider how compliance professionals can adapt by bolstering transparency, forming compliance committees, and staying abreast of the evolving regulatory landscape. Key highlights: Understanding the CSBS and Block Inc. Enforcement Implications of State-Level Enforcement Comparative Enforcement Actions Challenges for Compliance Professionals Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly explore a significant enforcement action by the Conference of State Bank Supervisors (CSBS) against Block Inc.

They discuss the CSBS’s role as a collective of state banking regulators, the reasons behind the $80 million fine imposed on Block, and the extensive compliance reforms the company must implement, including appointing an independent consultant. They consider the broader implications of state-level enforcement actions in areas like anti-money laundering and data privacy, especially in light of potential shifts in federal regulatory priorities. Matt and Tom consider how compliance professionals can adapt by bolstering transparency, forming compliance committees, and staying abreast of the evolving regulatory landscape.

Key highlights:

  • Understanding the CSBS and Block Inc. Enforcement
  • Implications of State-Level Enforcement
  • Comparative Enforcement Actions
  • Challenges for Compliance Professionals

Resources:

Matt in Radical Compliance

Tom

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]]> 1645 no Navigating Return to Office Policies and Corporate Speak Up Culture The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly delve into JP Morgan Chase’s treatment of employees who commented on the bank’s Return to the Office policy. JP Morgan’s recent decision to require employees to be back in the office five days a week caused the bank to disable employee comments on the internal announcement, citing backlash. Tom and Matt explore the implications this has on workplace respect, speak-up culture, and employee morale, juxtaposed with the compliance officer’s role in measuring and maintaining corporate culture. They also detail how these corporate policies might reflect broader trust issues and potential fallout from a discontented workforce. Additionally, the episode revisits Meta’s (formerly Facebook) recent rollback on DEI initiatives and its promotion of a more ‘freewheeling’ speech environment, considering the ethical and compliance ramifications of such a culture shift. The hosts compare these actions to other reported corporate behaviors that may undermine workplace respect and discuss the fragile balance a Chief Compliance Officer must maintain in fostering a fair and open workplace compliant with evolving societal norms and internal policies. Key highlights: JP Morgan’s Return to Office Policy Employee Reactions and Speak Up Culture Ethics and Compliance Implications Workplace Respect and Culture Meta’s Policy Changes and Corporate Culture Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Jan 2025 06:00:00 -0000 Navigating Return to Office Policies and Corporate Speak Up Culture full 401 Tom Fox Tom and Matt consider JP Morgan's silencing of employees who complained about RTO. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly delve into JP Morgan Chase’s treatment of employees who commented on the bank’s Return to the Office policy. JP Morgan’s recent decision to require employees to be back in the office five days a week caused the bank to disable employee comments on the internal announcement, citing backlash. Tom and Matt explore the implications this has on workplace respect, speak-up culture, and employee morale, juxtaposed with the compliance officer’s role in measuring and maintaining corporate culture. They also detail how these corporate policies might reflect broader trust issues and potential fallout from a discontented workforce. Additionally, the episode revisits Meta’s (formerly Facebook) recent rollback on DEI initiatives and its promotion of a more ‘freewheeling’ speech environment, considering the ethical and compliance ramifications of such a culture shift. The hosts compare these actions to other reported corporate behaviors that may undermine workplace respect and discuss the fragile balance a Chief Compliance Officer must maintain in fostering a fair and open workplace compliant with evolving societal norms and internal policies. Key highlights: JP Morgan’s Return to Office Policy Employee Reactions and Speak Up Culture Ethics and Compliance Implications Workplace Respect and Culture Meta’s Policy Changes and Corporate Culture Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly delve into JP Morgan Chase’s treatment of employees who commented on the bank’s Return to the Office policy.

JP Morgan’s recent decision to require employees to be back in the office five days a week caused the bank to disable employee comments on the internal announcement, citing backlash. Tom and Matt explore the implications this has on workplace respect, speak-up culture, and employee morale, juxtaposed with the compliance officer’s role in measuring and maintaining corporate culture. They also detail how these corporate policies might reflect broader trust issues and potential fallout from a discontented workforce.

Additionally, the episode revisits Meta’s (formerly Facebook) recent rollback on DEI initiatives and its promotion of a more ‘freewheeling’ speech environment, considering the ethical and compliance ramifications of such a culture shift. The hosts compare these actions to other reported corporate behaviors that may undermine workplace respect and discuss the fragile balance a Chief Compliance Officer must maintain in fostering a fair and open workplace compliant with evolving societal norms and internal policies.

Key highlights:

  • JP Morgan’s Return to Office Policy
  • Employee Reactions and Speak Up Culture
  • Ethics and Compliance Implications
  • Workplace Respect and Culture
  • Meta’s Policy Changes and Corporate Culture

Resources:

Matt in Radical Compliance

Tom

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]]> 1650 no 5 Top Compliance Stories to Watch in 2025 The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In the first episode 2025, Tom and Matt dive into the top compliance stories that could shape the upcoming year. They begin with the politically charged corruption case involving Gautam Adani, discussing its implications under the Trump administration and the potential for the Justice Department to alter its course on this high-profile prosecution. They also explore the possibility of personal liability in the TD Bank compliance scandal, the anticipated policy shifts under SEC nominee Paul Atkins, and the future of the Consumer Financial Protection Bureau (CFPB) under a Republican administration. Additionally, they address the challenges and potential impact of the DOJ Committee’s deregulation efforts and the unresolved Boeing Deferred Prosecution Agreement case’s monitorship issues. Tune in to understand what compliance officers should be watching for in 2025, as these stories could have significant ramifications for corporate compliance and enforcement practices. Key highlights: Top Compliance Stories of 2025 Gautam Adani Corruption Case TD Bank Compliance Scandal Paul Atkins and the SEC Future of the CFPB DOGE Committee and Deregulation Boeing Monitorship Controversy Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Jan 2025 06:00:00 -0000 5 Top Compliance Stories to Watch in 2025 full 400 Tom Fox Tom and Matt look at 5 stories to follow in 2025. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In the first episode 2025, Tom and Matt dive into the top compliance stories that could shape the upcoming year. They begin with the politically charged corruption case involving Gautam Adani, discussing its implications under the Trump administration and the potential for the Justice Department to alter its course on this high-profile prosecution. They also explore the possibility of personal liability in the TD Bank compliance scandal, the anticipated policy shifts under SEC nominee Paul Atkins, and the future of the Consumer Financial Protection Bureau (CFPB) under a Republican administration. Additionally, they address the challenges and potential impact of the DOJ Committee’s deregulation efforts and the unresolved Boeing Deferred Prosecution Agreement case’s monitorship issues. Tune in to understand what compliance officers should be watching for in 2025, as these stories could have significant ramifications for corporate compliance and enforcement practices. Key highlights: Top Compliance Stories of 2025 Gautam Adani Corruption Case TD Bank Compliance Scandal Paul Atkins and the SEC Future of the CFPB DOGE Committee and Deregulation Boeing Monitorship Controversy Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In the first episode 2025, Tom and Matt dive into the top compliance stories that could shape the upcoming year.

They begin with the politically charged corruption case involving Gautam Adani, discussing its implications under the Trump administration and the potential for the Justice Department to alter its course on this high-profile prosecution. They also explore the possibility of personal liability in the TD Bank compliance scandal, the anticipated policy shifts under SEC nominee Paul Atkins, and the future of the Consumer Financial Protection Bureau (CFPB) under a Republican administration. Additionally, they address the challenges and potential impact of the DOJ Committee’s deregulation efforts and the unresolved Boeing Deferred Prosecution Agreement case’s monitorship issues. Tune in to understand what compliance officers should be watching for in 2025, as these stories could have significant ramifications for corporate compliance and enforcement practices.

Key highlights:

  • Top Compliance Stories of 2025
  • Gautam Adani Corruption Case
  • TD Bank Compliance Scandal
  • Paul Atkins and the SEC
  • Future of the CFPB
  • DOGE Committee and Deregulation
  • Boeing Monitorship Controversy

Resources:

Matt in Radical Compliance

Tom

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]]> 2204 no NRA Governance Reforms: A Compliance Case Study The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into the intricate and unusual story of the National Rifle Association (NRA) and its recent corporate governance overhaul. Matt and Tom explore Judge Joel Cohen’s final ruling, which mandates extensive corporate governance reforms for the NRA. These reforms address significant issues, such as a structurally weak board, poor financial controls, and an overpowering CEO in Wayne LaPierre, who misused the organization’s resources. Necessary measures discussed include revamping the board’s audit committee and introducing annual compliance reports, along with significant protections for the role of the Chief Compliance Officer. The episode highlights the universal principles of good governance, asserting that the NRA’s reforms can serve as a valuable lesson for other organizations. Regardless of the political or ethical stance on the NRA’s activities, the implemented governance structures underscore the necessity of transparency, an empowered compliance function, and robust oversight mechanisms to prevent misuse of organizational resources. These insights are illustrated through sample agreements and templates in the court ruling, which can guide other organizations in strengthening their governance and compliance programs. Key highlights: Corporate Governance Reforms Ordered by the Court Specifics of the Court-Ordered Reforms Audit Committee and Board Reforms Compliance and Governance Templates Universal Principles of Good Governance Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Dec 2024 06:00:00 -0000 NRA Governance Reforms: A Compliance Case Study full 399 Tom Fox Tom and Matt review governance reforms for the NRA. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into the intricate and unusual story of the National Rifle Association (NRA) and its recent corporate governance overhaul. Matt and Tom explore Judge Joel Cohen’s final ruling, which mandates extensive corporate governance reforms for the NRA. These reforms address significant issues, such as a structurally weak board, poor financial controls, and an overpowering CEO in Wayne LaPierre, who misused the organization’s resources. Necessary measures discussed include revamping the board’s audit committee and introducing annual compliance reports, along with significant protections for the role of the Chief Compliance Officer. The episode highlights the universal principles of good governance, asserting that the NRA’s reforms can serve as a valuable lesson for other organizations. Regardless of the political or ethical stance on the NRA’s activities, the implemented governance structures underscore the necessity of transparency, an empowered compliance function, and robust oversight mechanisms to prevent misuse of organizational resources. These insights are illustrated through sample agreements and templates in the court ruling, which can guide other organizations in strengthening their governance and compliance programs. Key highlights: Corporate Governance Reforms Ordered by the Court Specifics of the Court-Ordered Reforms Audit Committee and Board Reforms Compliance and Governance Templates Universal Principles of Good Governance Resources Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into the intricate and unusual story of the National Rifle Association (NRA) and its recent corporate governance overhaul.


Matt and Tom explore Judge Joel Cohen’s final ruling, which mandates extensive corporate governance reforms for the NRA. These reforms address significant issues, such as a structurally weak board, poor financial controls, and an overpowering CEO in Wayne LaPierre, who misused the organization’s resources. Necessary measures discussed include revamping the board’s audit committee and introducing annual compliance reports, along with significant protections for the role of the Chief Compliance Officer.


The episode highlights the universal principles of good governance, asserting that the NRA’s reforms can serve as a valuable lesson for other organizations. Regardless of the political or ethical stance on the NRA’s activities, the implemented governance structures underscore the necessity of transparency, an empowered compliance function, and robust oversight mechanisms to prevent misuse of organizational resources. These insights are illustrated through sample agreements and templates in the court ruling, which can guide other organizations in strengthening their governance and compliance programs.


Key highlights:


  • Corporate Governance Reforms Ordered by the Court
  • Specifics of the Court-Ordered Reforms
  • Audit Committee and Board Reforms
  • Compliance and Governance Templates
  • Universal Principles of Good Governance


Resources


Matt in Radical Compliance


Tom


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]]> 1459 no Potpourri of Compliance Issues The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into a potpourri of issues, including Paul Atkins’s appointment to chair the SEC, a massaging of DOJ and the Corporate Enforcement Policy, and McKinsey’s FCPA resolution. Tom and Matt discuss various compliance issues, focusing on the implications of Paul Atkins’ appointment as SEC chairman, the challenges of enforcement and corporate penalties, the role of whistleblowers, and recent FCPA enforcement actions, including the McKinsey settlement. They explore how Atkins’ conservative views may shape SEC policies and the potential impact on compliance officers and corporate governance. Key highlights: Paul Atkins and the SEC Enforcement Challenges and Corporate Penalties Whistleblower Protections and Compliance Officers FCPA Enforcement and McKinsey Settlement Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Dec 2024 06:00:00 -0000 Potpourri of Compliance Issues full 398 Tom Fox Matt and Tom look at a potpourri of compliance issues. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into a potpourri of issues, including Paul Atkins’s appointment to chair the SEC, a massaging of DOJ and the Corporate Enforcement Policy, and McKinsey’s FCPA resolution. Tom and Matt discuss various compliance issues, focusing on the implications of Paul Atkins’ appointment as SEC chairman, the challenges of enforcement and corporate penalties, the role of whistleblowers, and recent FCPA enforcement actions, including the McKinsey settlement. They explore how Atkins’ conservative views may shape SEC policies and the potential impact on compliance officers and corporate governance. Key highlights: Paul Atkins and the SEC Enforcement Challenges and Corporate Penalties Whistleblower Protections and Compliance Officers FCPA Enforcement and McKinsey Settlement Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into a potpourri of issues, including Paul Atkins’s appointment to chair the SEC, a massaging of DOJ and the Corporate Enforcement Policy, and McKinsey’s FCPA resolution.


Tom and Matt discuss various compliance issues, focusing on the implications of Paul Atkins’ appointment as SEC chairman, the challenges of enforcement and corporate penalties, the role of whistleblowers, and recent FCPA enforcement actions, including the McKinsey settlement. They explore how Atkins’ conservative views may shape SEC policies and the potential impact on compliance officers and corporate governance.


Key highlights:

  • Paul Atkins and the SEC
  • Enforcement Challenges and Corporate Penalties
  • Whistleblower Protections and Compliance Officers
  • FCPA Enforcement and McKinsey Settlement

Resources:

Matt in Radical Compliance

Tom

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]]> 1972 no DOGE and Compliance The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into the Trump Administration’s DOGE initiatives and what it might mean for compliance. Tom and Matt discuss the implications of Elon Musk and Vivek Ramaswamy’s Department of Government Efficiency Committee (DOGE), which aims to downsize the federal government drastically. They explore the potential consequences of cutting half of all regulations and federal employees, particularly on compliance officers and corporate risk management. The conversation highlights how the reduction or abolition of federal regulations would affect various sectors, including the military, social security, and essential services, and delves into the challenges this proposal poses for compliance programs within businesses. They also consider possible outcomes such as increased state-level regulations, civil litigation, and the chaos and uncertainty that might follow. Finally, they discuss how companies should prepare for an inconsistent and unpredictable regulatory environment under a Trump administration. Key highlights: DOGE and Government Restructuring Implications for Compliance Officers Challenges of Cutting Regulations and Staff Potential Consequences of Reduced Regulations and Non-Enforcement Compliance Embedded in Business Practices State-Level Regulation and Emerging Risks Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Dec 2024 06:00:00 -0000 DOGE and Compliance full 397 Tom Fox What will the effect of the DOGE initiative be on compliance? The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into the Trump Administration’s DOGE initiatives and what it might mean for compliance. Tom and Matt discuss the implications of Elon Musk and Vivek Ramaswamy’s Department of Government Efficiency Committee (DOGE), which aims to downsize the federal government drastically. They explore the potential consequences of cutting half of all regulations and federal employees, particularly on compliance officers and corporate risk management. The conversation highlights how the reduction or abolition of federal regulations would affect various sectors, including the military, social security, and essential services, and delves into the challenges this proposal poses for compliance programs within businesses. They also consider possible outcomes such as increased state-level regulations, civil litigation, and the chaos and uncertainty that might follow. Finally, they discuss how companies should prepare for an inconsistent and unpredictable regulatory environment under a Trump administration. Key highlights: DOGE and Government Restructuring Implications for Compliance Officers Challenges of Cutting Regulations and Staff Potential Consequences of Reduced Regulations and Non-Enforcement Compliance Embedded in Business Practices State-Level Regulation and Emerging Risks Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly dive into the Trump Administration’s DOGE initiatives and what it might mean for compliance.


Tom and Matt discuss the implications of Elon Musk and Vivek Ramaswamy’s Department of Government Efficiency Committee (DOGE), which aims to downsize the federal government drastically. They explore the potential consequences of cutting half of all regulations and federal employees, particularly on compliance officers and corporate risk management. The conversation highlights how the reduction or abolition of federal regulations would affect various sectors, including the military, social security, and essential services, and delves into the challenges this proposal poses for compliance programs within businesses. They also consider possible outcomes such as increased state-level regulations, civil litigation, and the chaos and uncertainty that might follow. Finally, they discuss how companies should prepare for an inconsistent and unpredictable regulatory environment under a Trump administration.


Key highlights:


  • DOGE and Government Restructuring
  • Implications for Compliance Officers
  • Challenges of Cutting Regulations and Staff
  • Potential Consequences of Reduced Regulations and Non-Enforcement
  • Compliance Embedded in Business Practices
  • State-Level Regulation and Emerging Risks


Resources:


Matt in Radical Compliance


Tom

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]]> 1418 no DOJ Under Trump: FCPA Enforcement and Compliance The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into the Trump Administration’s DOJ nominees, FCPA enforcement going forward, and what it may all mean for compliance professionals. Tom and Matt explore the potential impacts of these nominations, notably the controversial choice of Matt Gaetz as Attorney General, and how they could shape the direction of anti-corruption enforcement and compliance practices. They also discuss the realistic aspects of other nominees, including Trump’s attorneys Todd Blanche and Emil Bove and former SEC Chairman Jay Clayton, who proposed to lead the Southern District of New York. The conversation touches on potential strategies for compliance officers, such as the increased significance of self-disclosure and the broader ramifications for corporate and foreign policy enforcement under a Trump administration. Key highlights: Trump’s DOJ Nominees: An Overview Potential Changes in FCPA Enforcement Self-Disclosure and Compliance Implications for Compliance Officers Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Nov 2024 06:00:00 -0000 DOJ Under Trump: FCPA Enforcement and Compliance full 396 Tom Fox Tom and Matt look at the DOJ, FCPA enforcement, and compliance. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into the Trump Administration’s DOJ nominees, FCPA enforcement going forward, and what it may all mean for compliance professionals. Tom and Matt explore the potential impacts of these nominations, notably the controversial choice of Matt Gaetz as Attorney General, and how they could shape the direction of anti-corruption enforcement and compliance practices. They also discuss the realistic aspects of other nominees, including Trump’s attorneys Todd Blanche and Emil Bove and former SEC Chairman Jay Clayton, who proposed to lead the Southern District of New York. The conversation touches on potential strategies for compliance officers, such as the increased significance of self-disclosure and the broader ramifications for corporate and foreign policy enforcement under a Trump administration. Key highlights: Trump’s DOJ Nominees: An Overview Potential Changes in FCPA Enforcement Self-Disclosure and Compliance Implications for Compliance Officers Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into the Trump Administration’s DOJ nominees, FCPA enforcement going forward, and what it may all mean for compliance professionals.


Tom and Matt explore the potential impacts of these nominations, notably the controversial choice of Matt Gaetz as Attorney General, and how they could shape the direction of anti-corruption enforcement and compliance practices. They also discuss the realistic aspects of other nominees, including Trump’s attorneys Todd Blanche and Emil Bove and former SEC Chairman Jay Clayton, who proposed to lead the Southern District of New York. The conversation touches on potential strategies for compliance officers, such as the increased significance of self-disclosure and the broader ramifications for corporate and foreign policy enforcement under a Trump administration.

Key highlights:

  • Trump’s DOJ Nominees: An Overview
  • Potential Changes in FCPA Enforcement
  • Self-Disclosure and Compliance
  • Implications for Compliance Officers

Resources:

Matt in Radical Compliance

Tom

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YouTube

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]]> 1760 no Understanding the Telefónica Venezolana FCPA Enforcement Action The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into the recently released FCPA enforcement action involving the Telefónica Venezolana subsidiary. They explore the bribery scheme used by Telefónica Venezolana to win an auction for U.S. dollars in 2014, resulting in a significant criminal penalty. The episode delves into the complexities of compliance in high-risk jurisdictions, the importance of incorporating anti-corruption due diligence into supply chains, and the implications of the new enforcement landscape under different administrations. Key lessons include the surprising extent of supplier risk, the long tail of FCPA enforcement, and the financial benefits of robust compliance practices. Key highlights: Details of the Bribery Scheme Consequences and Penalties for Telefónica Venezolana Compliance Challenges and Lessons Learned Risk Management in High-Risk Jurisdictions The Importance of a Robust Compliance Program Long-Term Implications of FCPA Violations Future of FCPA Enforcement Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Nov 2024 06:00:00 -0000 Understanding the Telefónica Venezolana FCPA Enforcement Action full 395 Tom Fox Tom and Matt look at the Telefónica Venezolana FCPA Enforcement Action. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into the recently released FCPA enforcement action involving the Telefónica Venezolana subsidiary. They explore the bribery scheme used by Telefónica Venezolana to win an auction for U.S. dollars in 2014, resulting in a significant criminal penalty. The episode delves into the complexities of compliance in high-risk jurisdictions, the importance of incorporating anti-corruption due diligence into supply chains, and the implications of the new enforcement landscape under different administrations. Key lessons include the surprising extent of supplier risk, the long tail of FCPA enforcement, and the financial benefits of robust compliance practices. Key highlights: Details of the Bribery Scheme Consequences and Penalties for Telefónica Venezolana Compliance Challenges and Lessons Learned Risk Management in High-Risk Jurisdictions The Importance of a Robust Compliance Program Long-Term Implications of FCPA Violations Future of FCPA Enforcement Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into the recently released FCPA enforcement action involving the Telefónica Venezolana subsidiary.


They explore the bribery scheme used by Telefónica Venezolana to win an auction for U.S. dollars in 2014, resulting in a significant criminal penalty. The episode delves into the complexities of compliance in high-risk jurisdictions, the importance of incorporating anti-corruption due diligence into supply chains, and the implications of the new enforcement landscape under different administrations. Key lessons include the surprising extent of supplier risk, the long tail of FCPA enforcement, and the financial benefits of robust compliance practices.


Key highlights:

  • Details of the Bribery Scheme
  • Consequences and Penalties for Telefónica Venezolana
  • Compliance Challenges and Lessons Learned
  • Risk Management in High-Risk Jurisdictions
  • The Importance of a Robust Compliance Program
  • Long-Term Implications of FCPA Violations
  • Future of FCPA Enforcement


Resources:


Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog


Tom


Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1651 no Risk-Based Compliance Lessons from a Young Entrepreneur’s Ice Cream Stand The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this special election day episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into a lighter yet insightful compliance story involving a young boy named Danny Doherty. At 12 years old, Danny set up a homemade ice cream stand in Massachusetts to raise money for a hockey team for children with developmental disabilities. However, the local health department shut its stand down due to risks associated with homemade dairy products, highlighting the importance of a risk-based approach in compliance activities. Tom and Matt discuss key compliance lessons from this incident, such as the necessity of addressing real risks, the potential for compliance failures despite good intentions, and the importance of effective communication by regulators. Key highlights: The Story of Danny Doherty Compliance Lessons from Danny’s Story Risk-Based Approach in Compliance The Importance of Communication in Compliance Resources: Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Nov 2024 06:00:00 -0000 Risk-Based Compliance Lessons from a Young Entrepreneur’s Ice Cream Stand full 394 Tom Fox Tom and Matt draw compliance lessons from the story of Danny Doherty. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this special election day episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into a lighter yet insightful compliance story involving a young boy named Danny Doherty. At 12 years old, Danny set up a homemade ice cream stand in Massachusetts to raise money for a hockey team for children with developmental disabilities. However, the local health department shut its stand down due to risks associated with homemade dairy products, highlighting the importance of a risk-based approach in compliance activities. Tom and Matt discuss key compliance lessons from this incident, such as the necessity of addressing real risks, the potential for compliance failures despite good intentions, and the importance of effective communication by regulators. Key highlights: The Story of Danny Doherty Compliance Lessons from Danny’s Story Risk-Based Approach in Compliance The Importance of Communication in Compliance Resources: Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this special election day episode of ‘Compliance into the Weeds,’ Tom Fox and Matt Kelly dive into a lighter yet insightful compliance story involving a young boy named Danny Doherty.


At 12 years old, Danny set up a homemade ice cream stand in Massachusetts to raise money for a hockey team for children with developmental disabilities. However, the local health department shut its stand down due to risks associated with homemade dairy products, highlighting the importance of a risk-based approach in compliance activities. Tom and Matt discuss key compliance lessons from this incident, such as the necessity of addressing real risks, the potential for compliance failures despite good intentions, and the importance of effective communication by regulators.


Key highlights:


  • The Story of Danny Doherty
  • Compliance Lessons from Danny’s Story
  • Risk-Based Approach in Compliance
  • The Importance of Communication in Compliance


Resources:


Radical Compliance


Tom


Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1247 no Leadership Lessons from The Washington Post’s Non-Endorsement The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the recent events at the Washington Post, where the newspaper decided not to endorse a presidential candidate for the first time in years. This decision, directed by owner Jeff Bezos, has led to significant backlash, including 200,000 lost subscribers and concerns about the paper’s principles. Matt and Tom discuss the implications of this move on leadership, company values, and stakeholder trust, providing insights into the governance structure of newspapers and the potential fallout of abandoning established principles. We also turn to company values and if you are going to violate them, there should be sufficient justification. Finally, what a second Trump Administration might mean for corporate compliance. Key Highlights: Washington Post’s Controversial Decision Newspaper Governance Explained Washington Post’s Mission and Principles Leadership Failures and Consequences Potential Future Implications Resources:   Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 30 Oct 2024 05:00:00 -0000 Leadership Lessons from The Washington Post’s Non-Endorsement full 394 Tom Fox Tom and Matt look at Jeff Bezos block of WaPo Presidential endorsement. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the recent events at the Washington Post, where the newspaper decided not to endorse a presidential candidate for the first time in years. This decision, directed by owner Jeff Bezos, has led to significant backlash, including 200,000 lost subscribers and concerns about the paper’s principles. Matt and Tom discuss the implications of this move on leadership, company values, and stakeholder trust, providing insights into the governance structure of newspapers and the potential fallout of abandoning established principles. We also turn to company values and if you are going to violate them, there should be sufficient justification. Finally, what a second Trump Administration might mean for corporate compliance. Key Highlights: Washington Post’s Controversial Decision Newspaper Governance Explained Washington Post’s Mission and Principles Leadership Failures and Consequences Potential Future Implications Resources:   Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the recent events at the Washington Post, where the newspaper decided not to endorse a presidential candidate for the first time in years.


This decision, directed by owner Jeff Bezos, has led to significant backlash, including 200,000 lost subscribers and concerns about the paper’s principles. Matt and Tom discuss the implications of this move on leadership, company values, and stakeholder trust, providing insights into the governance structure of newspapers and the potential fallout of abandoning established principles. We also turn to company values and if you are going to violate them, there should be sufficient justification. Finally, what a second Trump Administration might mean for corporate compliance.


Key Highlights:


  • Washington Post’s Controversial Decision
  • Newspaper Governance Explained
  • Washington Post’s Mission and Principles
  • Leadership Failures and Consequences
  • Potential Future Implications



Resources:

 

Matt in Radical Compliance


Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1636 no Unveiling RTX's Costly Compliance Failures and Corporate Misconduct The award-winning Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the RTX Foreign Corrupt Practices Act enforcement action. Their discussion unveils complex bribery schemes involving millions paid to Qatari agents and the family of the Emir to secure defense contracts. Despite strict regulatory oversight, Raytheon’s (now RTX) compliance missteps spanned from 2012 into the 2020s, resulting in massive fines. Matt and Tom scrutinize these failures, detailing the SEC and DOJ’s mandates for dual monitorships due to violations of the False Claims Act and FCPA and the Board’s critical role in addressing these issues. Additionally, a comparative look at other significant FCPA cases, including Moog’s penalties for bribery in India, highlights persistent corporate misconduct and the ongoing challenges in achieving effective corporate compliance. Key Highlights:  Overview of Raytheon’s Violations  Qatari Agent and Further Corruption  Raytheon’s Compliance Failures Management and Compliance Failures Board Oversight and Responsibilities  Reflections on Compliance and Enforcement Resources 1.    Blogs Matt in Radical Compliance 2.     Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Oct 2024 05:00:00 -0000 Unveiling RTX's Costly Compliance Failures and Corporate Misconduct full 392 Tom Fox Tom and Matt look at RTX. The award-winning Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the RTX Foreign Corrupt Practices Act enforcement action. Their discussion unveils complex bribery schemes involving millions paid to Qatari agents and the family of the Emir to secure defense contracts. Despite strict regulatory oversight, Raytheon’s (now RTX) compliance missteps spanned from 2012 into the 2020s, resulting in massive fines. Matt and Tom scrutinize these failures, detailing the SEC and DOJ’s mandates for dual monitorships due to violations of the False Claims Act and FCPA and the Board’s critical role in addressing these issues. Additionally, a comparative look at other significant FCPA cases, including Moog’s penalties for bribery in India, highlights persistent corporate misconduct and the ongoing challenges in achieving effective corporate compliance. Key Highlights:  Overview of Raytheon’s Violations  Qatari Agent and Further Corruption  Raytheon’s Compliance Failures Management and Compliance Failures Board Oversight and Responsibilities  Reflections on Compliance and Enforcement Resources 1.    Blogs Matt in Radical Compliance 2.     Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!


In this episode, Tom Fox and Matt Kelly take a deep dive into the RTX Foreign Corrupt Practices Act enforcement action.


Their discussion unveils complex bribery schemes involving millions paid to Qatari agents and the family of the Emir to secure defense contracts. Despite strict regulatory oversight, Raytheon’s (now RTX) compliance missteps spanned from 2012 into the 2020s, resulting in massive fines. Matt and Tom scrutinize these failures, detailing the SEC and DOJ’s mandates for dual monitorships due to violations of the False Claims Act and FCPA and the Board’s critical role in addressing these issues. Additionally, a comparative look at other significant FCPA cases, including Moog’s penalties for bribery in India, highlights persistent corporate misconduct and the ongoing challenges in achieving effective corporate compliance.




Key Highlights:

  •  Overview of Raytheon’s Violations
  •  Qatari Agent and Further Corruption
  •  Raytheon’s Compliance Failures
  • Management and Compliance Failures
  • Board Oversight and Responsibilities
  •  Reflections on Compliance and Enforcement

Resources

1.    Blogs

Matt in Radical Compliance

2.     Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1510 no Adventures in Squeezing Out Compliance - TD Bank's Flat Cost Paradigm The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the TD Bank BSA and AML enforcement action which led to $3bn in fines and penalties. In this episode, Tom and Matt discuss TD Bank's conscious strategy of not raising the budget, known as the Flat Cost Paradigm or Zero Expense Growth Paradigm and how this completely strangled the Bank’s compliance and AML functions. This tactic aimed to increase profits by keeping expenditures flat year after year. The impact of this strategy is particularly evident in the global AML team's expenditures on the U.S. anti-money laundering program, which decreased by 2021 compared to 2018. Despite significantly growing U.S. assets and net income, the bank refrained from increasing its budget for essential programs, a fact highlighted in the Justice Department indictment. The Bank’s strategy is a clear warning when a business puts profits over compliance.  Key Highlights ·      Introduction to the Flat Cost Paradigm ·      Details of the Budget Strategy ·      Impact on Anti-Money Laundering Efforts ·      Financial Growth Amidst Budget Constraints Resources   1.    Blogs Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog 2.     Tom   Instagram Facebook YouTube Twitter LinkedIn 3.    Enforcement Related Material A.    OCC OCC Press Release Consent Order  Civil Money Penalty    B.    DOJ   TD Bank US Holding Company Information TD Bank N.A. Information TD Bank US Holding Company Plea Agreement and Attachments TD Bank N.A. Plea Agreement and Attachments Merrick Garland Remarks Nicole Argentieri Remarks Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Oct 2024 05:00:00 -0000 Adventures in Squeezing Out Compliance - TD Bank's Flat Cost Paradigm full 391 Tom Fox Tom and Matt review the TD Bank enforcement action. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the TD Bank BSA and AML enforcement action which led to $3bn in fines and penalties. In this episode, Tom and Matt discuss TD Bank's conscious strategy of not raising the budget, known as the Flat Cost Paradigm or Zero Expense Growth Paradigm and how this completely strangled the Bank’s compliance and AML functions. This tactic aimed to increase profits by keeping expenditures flat year after year. The impact of this strategy is particularly evident in the global AML team's expenditures on the U.S. anti-money laundering program, which decreased by 2021 compared to 2018. Despite significantly growing U.S. assets and net income, the bank refrained from increasing its budget for essential programs, a fact highlighted in the Justice Department indictment. The Bank’s strategy is a clear warning when a business puts profits over compliance.  Key Highlights ·      Introduction to the Flat Cost Paradigm ·      Details of the Budget Strategy ·      Impact on Anti-Money Laundering Efforts ·      Financial Growth Amidst Budget Constraints Resources   1.    Blogs Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog 2.     Tom   Instagram Facebook YouTube Twitter LinkedIn 3.    Enforcement Related Material A.    OCC OCC Press Release Consent Order  Civil Money Penalty    B.    DOJ   TD Bank US Holding Company Information TD Bank N.A. Information TD Bank US Holding Company Plea Agreement and Attachments TD Bank N.A. Plea Agreement and Attachments Merrick Garland Remarks Nicole Argentieri Remarks Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the TD Bank BSA and AML enforcement action which led to $3bn in fines and penalties.


In this episode, Tom and Matt discuss TD Bank's conscious strategy of not raising the budget, known as the Flat Cost Paradigm or Zero Expense Growth Paradigm and how this completely strangled the Bank’s compliance and AML functions. This tactic aimed to increase profits by keeping expenditures flat year after year. The impact of this strategy is particularly evident in the global AML team's expenditures on the U.S. anti-money laundering program, which decreased by 2021 compared to 2018. Despite significantly growing U.S. assets and net income, the bank refrained from increasing its budget for essential programs, a fact highlighted in the Justice Department indictment. The Bank’s strategy is a clear warning when a business puts profits over compliance. 


Key Highlights



·      Introduction to the Flat Cost Paradigm

·      Details of the Budget Strategy

·      Impact on Anti-Money Laundering Efforts

·      Financial Growth Amidst Budget Constraints



Resources

 

1.    Blogs

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog


2.     Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

3.    Enforcement Related Material

A.    OCC

OCC Press Release

Consent Order 

Civil Money Penalty 

 

B.    DOJ

 

TD Bank US Holding Company Information

TD Bank N.A. Information

TD Bank US Holding Company Plea Agreement and Attachments

TD Bank N.A. Plea Agreement and Attachments

Merrick Garland Remarks

Nicole Argentieri Remarks

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1514 no Exploring Compliance Data Access and Testing Challenges The award winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the study, 2024 Benchmarking Study: Testing & Monitoring and Data & Systems, jointly conducted by Radical Compliance and Rethink Compliance. The study raises critical concerns about the access and effectiveness of data testing in compliance programs. While many compliance officers engage in some level of testing, there is a significant gap in comprehensive testing and access to necessary data across enterprises. Only a small percentage tracks key performance indicators (KPIs) at granular levels, such as individual or department, which are essential for understanding program effectiveness. The discussion also highlights the importance of access to data from different departments, like HR and Finance, to improve compliance monitoring and alignment with DOJ guidelines. The episode concludes with a call for continued research, emphasizing the interconnectedness of data access, comprehensive testing, and compliance success. Key Highlights: Overview of the Compliance Study Key Findings and Statistics Challenges in Compliance Testing Importance of Multiple KPIs Access to Data Issues Resources: Matt in Radical Compliance 2024 Benchmarking Study: Testing & Monitoring and Data & Systems Rethink Compliance   Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Oct 2024 05:00:00 -0000 Exploring Compliance Data Access and Testing Challenges full 390 Tom Fox Tom and Matt look at a bench marking study on compliance testing. The award winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the study, 2024 Benchmarking Study: Testing & Monitoring and Data & Systems, jointly conducted by Radical Compliance and Rethink Compliance. The study raises critical concerns about the access and effectiveness of data testing in compliance programs. While many compliance officers engage in some level of testing, there is a significant gap in comprehensive testing and access to necessary data across enterprises. Only a small percentage tracks key performance indicators (KPIs) at granular levels, such as individual or department, which are essential for understanding program effectiveness. The discussion also highlights the importance of access to data from different departments, like HR and Finance, to improve compliance monitoring and alignment with DOJ guidelines. The episode concludes with a call for continued research, emphasizing the interconnectedness of data access, comprehensive testing, and compliance success. Key Highlights: Overview of the Compliance Study Key Findings and Statistics Challenges in Compliance Testing Importance of Multiple KPIs Access to Data Issues Resources: Matt in Radical Compliance 2024 Benchmarking Study: Testing & Monitoring and Data & Systems Rethink Compliance   Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!


In this episode, Tom Fox and Matt Kelly take a deep dive into the study, 2024 Benchmarking Study: Testing & Monitoring and Data & Systems, jointly conducted by Radical Compliance and Rethink Compliance.


The study raises critical concerns about the access and effectiveness of data testing in compliance programs. While many compliance officers engage in some level of testing, there is a significant gap in comprehensive testing and access to necessary data across enterprises. Only a small percentage tracks key performance indicators (KPIs) at granular levels, such as individual or department, which are essential for understanding program effectiveness. The discussion also highlights the importance of access to data from different departments, like HR and Finance, to improve compliance monitoring and alignment with DOJ guidelines. The episode concludes with a call for continued research, emphasizing the interconnectedness of data access, comprehensive testing, and compliance success.


Key Highlights:

  • Overview of the Compliance Study
  • Key Findings and Statistics
  • Challenges in Compliance Testing
  • Importance of Multiple KPIs
  • Access to Data Issues


Resources:

Matt in Radical Compliance

2024 Benchmarking Study: Testing & Monitoring and Data & Systems

Rethink Compliance

 

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1516 no The 2024 ECCP on Data Access The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the 2024 update to the Department of Justice's guidelines for corporate compliance programs, focusing on data and data access.  Tom and Matt explore the significance of these updates and whether they stem from companies showing advancements in data analytics or the DOJ recognizing gaps in data access for compliance officers. The discussion highlights the challenges compliance officers face, especially with diverse ERP systems and data silos, and provides insights into how compliance officers can leverage these guidelines to advocate for better data access within their organizations. The episode also breaks down specific questions from the DOJ’s guidelines, offering practical advice on addressing obstacles to data, resources for data access, and data maintenance. Key Highlights ·      The Importance of Data Access in Compliance ·      Challenges in Data Access for Compliance Officers ·      DOJ's Six Key Questions on Data Access ·      Addressing Data Access Impediments ·      Tools and Resources for Data Analytics ·      Communicating with the Board on Data Analytics Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Oct 2024 05:00:00 -0000 The 2024 ECCP on Data Access full 389 Tom Fox Tom and Matt take a deep dive into the 2024 ECCP on Data Access. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the 2024 update to the Department of Justice's guidelines for corporate compliance programs, focusing on data and data access.  Tom and Matt explore the significance of these updates and whether they stem from companies showing advancements in data analytics or the DOJ recognizing gaps in data access for compliance officers. The discussion highlights the challenges compliance officers face, especially with diverse ERP systems and data silos, and provides insights into how compliance officers can leverage these guidelines to advocate for better data access within their organizations. The episode also breaks down specific questions from the DOJ’s guidelines, offering practical advice on addressing obstacles to data, resources for data access, and data maintenance. Key Highlights ·      The Importance of Data Access in Compliance ·      Challenges in Data Access for Compliance Officers ·      DOJ's Six Key Questions on Data Access ·      Addressing Data Access Impediments ·      Tools and Resources for Data Analytics ·      Communicating with the Board on Data Analytics Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the 2024 update to the Department of Justice's guidelines for corporate compliance programs, focusing on data and data access. 


Tom and Matt explore the significance of these updates and whether they stem from companies showing advancements in data analytics or the DOJ recognizing gaps in data access for compliance officers. The discussion highlights the challenges compliance officers face, especially with diverse ERP systems and data silos, and provides insights into how compliance officers can leverage these guidelines to advocate for better data access within their organizations. The episode also breaks down specific questions from the DOJ’s guidelines, offering practical advice on addressing obstacles to data, resources for data access, and data maintenance.


Key Highlights


·      The Importance of Data Access in Compliance

·      Challenges in Data Access for Compliance Officers

·      DOJ's Six Key Questions on Data Access

·      Addressing Data Access Impediments

·      Tools and Resources for Data Analytics

·      Communicating with the Board on Data Analytics


Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog


Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1549 no Argentieri Speech and Updated ECCP – The First Analysis The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the speech by Principal Deputy Assistant Attorney General Nicole M. Argentieri at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute.  Argentieri, revealed substantial updates to the department's Evaluation guidelines for effective compliance programs, focusing on whistleblower protections and the effectiveness of reporting mechanisms. Matt, reporting live from Dallas, discussed the implications of these updates, especially regarding the DOJ’s increased scrutiny on companies speak-up cultures and the protection of whistleblowers. Tom and Matt explored the practical steps compliance officers need to take to meet these new DOJ expectations, including ensuring anonymous reporting mechanisms are well-publicized and effectively utilized, fostering a culture that encourages reporting without fear of retaliation, and aligning company policies with the latest external whistleblower protection laws. They also touched on the potential challenges of balancing AI risks with these new guidelines and the broader impact on compliance programs.  Key Highlights ·      Key focus on enhancing whistleblower protections. ·      Compliance officers must ensure that reporting mechanisms are well-publicized. ·      Importance of aligning internal policies with external whistleblower protection laws to ensure comprehensive employee training. ·      The balancing the challenges of AI risks with the need to adhere to new DOJ guidelines. ·      The practical steps for compliance professionals to align their programs with DOJ’s evolving expectations. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Sep 2024 05:00:00 -0000 Argentieri Speech and Updated ECCP – The First Analysis full 388 Tom Fox Tom and Matt review the Nicole Argentieri Speech at SCCE. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the speech by Principal Deputy Assistant Attorney General Nicole M. Argentieri at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute.  Argentieri, revealed substantial updates to the department's Evaluation guidelines for effective compliance programs, focusing on whistleblower protections and the effectiveness of reporting mechanisms. Matt, reporting live from Dallas, discussed the implications of these updates, especially regarding the DOJ’s increased scrutiny on companies speak-up cultures and the protection of whistleblowers. Tom and Matt explored the practical steps compliance officers need to take to meet these new DOJ expectations, including ensuring anonymous reporting mechanisms are well-publicized and effectively utilized, fostering a culture that encourages reporting without fear of retaliation, and aligning company policies with the latest external whistleblower protection laws. They also touched on the potential challenges of balancing AI risks with these new guidelines and the broader impact on compliance programs.  Key Highlights ·      Key focus on enhancing whistleblower protections. ·      Compliance officers must ensure that reporting mechanisms are well-publicized. ·      Importance of aligning internal policies with external whistleblower protection laws to ensure comprehensive employee training. ·      The balancing the challenges of AI risks with the need to adhere to new DOJ guidelines. ·      The practical steps for compliance professionals to align their programs with DOJ’s evolving expectations. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the speech by Principal Deputy Assistant Attorney General Nicole M. Argentieri at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. 


Argentieri, revealed substantial updates to the department's Evaluation guidelines for effective compliance programs, focusing on whistleblower protections and the effectiveness of reporting mechanisms. Matt, reporting live from Dallas, discussed the implications of these updates, especially regarding the DOJ’s increased scrutiny on companies speak-up cultures and the protection of whistleblowers.


Tom and Matt explored the practical steps compliance officers need to take to meet these new DOJ expectations, including ensuring anonymous reporting mechanisms are well-publicized and effectively utilized, fostering a culture that encourages reporting without fear of retaliation, and aligning company policies with the latest external whistleblower protection laws. They also touched on the potential challenges of balancing AI risks with these new guidelines and the broader impact on compliance programs. 


Key Highlights


·      Key focus on enhancing whistleblower protections.

·      Compliance officers must ensure that reporting mechanisms are well-publicized.

·      Importance of aligning internal policies with external whistleblower protection laws to ensure comprehensive employee training.

·      The balancing the challenges of AI risks with the need to adhere to new DOJ guidelines.

·      The practical steps for compliance professionals to align their programs with DOJ’s evolving expectations.


Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog


Tom  

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YouTube

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LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1642 no Everything Old is New Again - The John Deere FCPA Enforcement Action The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the recent Securities and Exchange Commission FCPA  enforcement action involving John Deere.  The case centers on a $10 million civil penalty imposed by the SEC for bribery activities in the Thailand office of a newly acquired subsidiary, Wirtgen Group. This transgression spanned from 2017 to 2020, and despite having a code of business conduct, Wirtgen employees flouted rules by falsifying expenses, entertaining government officials at massage parlors, and engaging in a luxury sightseeing tour under the guise of a factory visit.  A critical issue was John Deere's delayed integration of Wirtgen into its compliance program, leading to internal control lapses and obvious red flags in expense reports. Although Deere has since taken significant remedial actions, including firing culpable employees and enhancing its compliance and internal audit programs, the situation underscores persistent compliance challenges even for large, sophisticated firms. This episode serves as a reminder of the essential compliance lessons from past decades that firms must steadfastly adhere to. Key Highlights ·      Details of the Bribery Scheme ·      Internal Control Violations ·      Pre and Post-Acquisition Due Diligence Issues ·      Remedial Steps and Improvements ·      Root Cause Analysis and Lessons Learned Resources Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Sep 2024 05:00:00 -0000 The John Deere FCPA Enforcement Action full 387 Tom Fox Tom and Matt look at the John Deere FCPA Enforcement Action The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the recent Securities and Exchange Commission FCPA  enforcement action involving John Deere.  The case centers on a $10 million civil penalty imposed by the SEC for bribery activities in the Thailand office of a newly acquired subsidiary, Wirtgen Group. This transgression spanned from 2017 to 2020, and despite having a code of business conduct, Wirtgen employees flouted rules by falsifying expenses, entertaining government officials at massage parlors, and engaging in a luxury sightseeing tour under the guise of a factory visit.  A critical issue was John Deere's delayed integration of Wirtgen into its compliance program, leading to internal control lapses and obvious red flags in expense reports. Although Deere has since taken significant remedial actions, including firing culpable employees and enhancing its compliance and internal audit programs, the situation underscores persistent compliance challenges even for large, sophisticated firms. This episode serves as a reminder of the essential compliance lessons from past decades that firms must steadfastly adhere to. Key Highlights ·      Details of the Bribery Scheme ·      Internal Control Violations ·      Pre and Post-Acquisition Due Diligence Issues ·      Remedial Steps and Improvements ·      Root Cause Analysis and Lessons Learned Resources Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the recent Securities and Exchange Commission FCPA  enforcement action involving John Deere. 


The case centers on a $10 million civil penalty imposed by the SEC for bribery activities in the Thailand office of a newly acquired subsidiary, Wirtgen Group. This transgression spanned from 2017 to 2020, and despite having a code of business conduct, Wirtgen employees flouted rules by falsifying expenses, entertaining government officials at massage parlors, and engaging in a luxury sightseeing tour under the guise of a factory visit. 


A critical issue was John Deere's delayed integration of Wirtgen into its compliance program, leading to internal control lapses and obvious red flags in expense reports. Although Deere has since taken significant remedial actions, including firing culpable employees and enhancing its compliance and internal audit programs, the situation underscores persistent compliance challenges even for large, sophisticated firms. This episode serves as a reminder of the essential compliance lessons from past decades that firms must steadfastly adhere to.


Key Highlights


·      Details of the Bribery Scheme

·      Internal Control Violations

·      Pre and Post-Acquisition Due Diligence Issues

·      Remedial Steps and Improvements

·      Root Cause Analysis and Lessons Learned


Resources

Matt in Radical Compliance


Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1344 no Pre-taliation Illegality - from Employment Contracts to All Contracts The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the recent SEC enforcement actions against several companies for pre-taliation clauses and related illegal intent.   Our conversation discusses recent enforcement actions by the SEC sanctioned against seven companies for a total of $3 million in civil penalties. The main issue was that these contracts required employees to forfeit any right to whistleblower awards if they reported misconduct to regulators. The conversation explores the legality of these contract clauses and the chilling effect they have on potential whistleblowers. Tom and Matt also discuss the challenges of remediation and the need for a comprehensive approach to address retaliatory clauses in all types of contracts. Key Highlights SEC Enforcement Actions on Pre-Retaliation Language The Illegality of Pre-Retaliation Clauses Addressing Pre-Retaliation Clauses: Remediation Challenges Expanding the Focus: From Employment Contracts to All Contracts Resources Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Check out the full 3-book series, The Compliance Kids on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Sep 2024 18:34:00 -0000 Pre - taliation Illegality - from Employment Contracts to All Contracts full 386 Tom Fox Pre - taliation Illegality - from Employment Contracts to All Contracts The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the recent SEC enforcement actions against several companies for pre-taliation clauses and related illegal intent.   Our conversation discusses recent enforcement actions by the SEC sanctioned against seven companies for a total of $3 million in civil penalties. The main issue was that these contracts required employees to forfeit any right to whistleblower awards if they reported misconduct to regulators. The conversation explores the legality of these contract clauses and the chilling effect they have on potential whistleblowers. Tom and Matt also discuss the challenges of remediation and the need for a comprehensive approach to address retaliatory clauses in all types of contracts. Key Highlights SEC Enforcement Actions on Pre-Retaliation Language The Illegality of Pre-Retaliation Clauses Addressing Pre-Retaliation Clauses: Remediation Challenges Expanding the Focus: From Employment Contracts to All Contracts Resources Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Check out the full 3-book series, The Compliance Kids on Amazon.com. Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the recent SEC enforcement actions against several companies for pre-taliation clauses and related illegal intent.

 

Our conversation discusses recent enforcement actions by the SEC sanctioned against seven companies for a total of $3 million in civil penalties. The main issue was that these contracts required employees to forfeit any right to whistleblower awards if they reported misconduct to regulators. The conversation explores the legality of these contract clauses and the chilling effect they have on potential whistleblowers. Tom and Matt also discuss the challenges of remediation and the need for a comprehensive approach to address retaliatory clauses in all types of contracts.

Key Highlights

  • SEC Enforcement Actions on Pre-Retaliation Language
  • The Illegality of Pre-Retaliation Clauses
  • Addressing Pre-Retaliation Clauses: Remediation Challenges
  • Expanding the Focus: From Employment Contracts to All Contracts



Resources

Matt in Radical Compliance


Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn


Check out the full 3-book series, The Compliance Kids on Amazon.com.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1375 no The BCG Declination – Key Insights for Compliance The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the recent Department of Justice (DOJ) declination for the Boston Consulting Group (BCG). They highlight why this case garnered significant attention and dissect the substantive actions BCG took to avoid prosecution, including firing implicated employees and forcing equity forfeiture. The duo also explores the seven factors that led to the declination, such as timely self-reporting, full cooperation, and improved compliance measures. The episode provides a comprehensive analysis of the BCG case, offering crucial takeaways for compliance officers on how to handle potential corruption issues and DOJ expectations. Key Highlights: Overview of the Boston Consulting Group Declination DOJ’s Factors for Declination Full Cooperation, Timely Self-Disclosure and Employee Consequences Remediation Efforts and Compliance Improvements Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Sep 2024 05:00:00 -0000 The BCG Declination – Key Insights for Compliance full 385 Tom Fox Tom and Matt take a dive into the BCG Declination. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the recent Department of Justice (DOJ) declination for the Boston Consulting Group (BCG). They highlight why this case garnered significant attention and dissect the substantive actions BCG took to avoid prosecution, including firing implicated employees and forcing equity forfeiture. The duo also explores the seven factors that led to the declination, such as timely self-reporting, full cooperation, and improved compliance measures. The episode provides a comprehensive analysis of the BCG case, offering crucial takeaways for compliance officers on how to handle potential corruption issues and DOJ expectations. Key Highlights: Overview of the Boston Consulting Group Declination DOJ’s Factors for Declination Full Cooperation, Timely Self-Disclosure and Employee Consequences Remediation Efforts and Compliance Improvements Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the recent Department of Justice (DOJ) declination for the Boston Consulting Group (BCG).

They highlight why this case garnered significant attention and dissect the substantive actions BCG took to avoid prosecution, including firing implicated employees and forcing equity forfeiture. The duo also explores the seven factors that led to the declination, such as timely self-reporting, full cooperation, and improved compliance measures. The episode provides a comprehensive analysis of the BCG case, offering crucial takeaways for compliance officers on how to handle potential corruption issues and DOJ expectations.


Key Highlights:

  • Overview of the Boston Consulting Group Declination
  • DOJ’s Factors for Declination
  • Full Cooperation, Timely Self-Disclosure and Employee Consequences
  • Remediation Efforts and Compliance Improvements


Resources:

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog


Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1547 no Does a CCO Need to be a Lawyer? The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the question of whether a law degree is necessary for Chief Compliance Officers (CCOs).  Tom and Matt begin with a discussion of a recent compensation survey by Barker Gilmore that reveals CCOs with law degrees earn significantly more than their counterparts without JDs. They explore historical and practical reasons for this pay disparity and debate the actual necessity of a law degree for fulfilling modern compliance functions. Additionally, they identify key skills and functions essential for effective compliance and consider alternative career paths and educational backgrounds suited for aspiring compliance professionals. Key Highlights ·      The Value of a Law Degree for Compliance Officers ·      Breaking Down the Pay Disparity ·      Modern Compliance Demands ·      Career Paths and Skills for Compliance Officers Resources Matt in Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Aug 2024 05:00:00 -0000 Does a CCO Need to be a Lawyer? full 384 Tom Fox Matt and Tom explore an age old question ' Does a CCO Need to be a Lawyer?' The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the question of whether a law degree is necessary for Chief Compliance Officers (CCOs).  Tom and Matt begin with a discussion of a recent compensation survey by Barker Gilmore that reveals CCOs with law degrees earn significantly more than their counterparts without JDs. They explore historical and practical reasons for this pay disparity and debate the actual necessity of a law degree for fulfilling modern compliance functions. Additionally, they identify key skills and functions essential for effective compliance and consider alternative career paths and educational backgrounds suited for aspiring compliance professionals. Key Highlights ·      The Value of a Law Degree for Compliance Officers ·      Breaking Down the Pay Disparity ·      Modern Compliance Demands ·      Career Paths and Skills for Compliance Officers Resources Matt in Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the question of whether a law degree is necessary for Chief Compliance Officers (CCOs). 


Tom and Matt begin with a discussion of a recent compensation survey by Barker Gilmore that reveals CCOs with law degrees earn significantly more than their counterparts without JDs. They explore historical and practical reasons for this pay disparity and debate the actual necessity of a law degree for fulfilling modern compliance functions. Additionally, they identify key skills and functions essential for effective compliance and consider alternative career paths and educational backgrounds suited for aspiring compliance professionals.



Key Highlights


·      The Value of a Law Degree for Compliance Officers

·      Breaking Down the Pay Disparity

·      Modern Compliance Demands

·      Career Paths and Skills for Compliance Officers


Resources

Matt in Radical Compliance

 

Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1489 no Toxic Workplace Culture at Bank of America The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the toxic workplace culture at Bank of America (BoA) around hours worked by junior employees, in spite of senior management saying the right things. BoA’s investment banking division has long been plagued by a toxic work culture, characterized by overworked junior employees and severe health crises, despite repeated assurances of reform. Tom Matt discuss these pervasive issues within BoA’s work environment. Fox highlights the tragic consequences of this toxic culture, such as the deaths of junior employees, and criticizes the company's failure to implement effective reforms, attributing this to a lack of accountability and ethical leadership. Kelly echoes this sentiment, emphasizing the necessity for senior management to set clear expectations and consequences for middle managers who perpetuate unethical behavior. Both stress the need for senior management to address the deep-seated cultural dysfunction, impose consequences, and foster a healthier, rule-abiding workplace to prevent further tragedies and promote employee well-being. Key Highlights: Toxic Workplace Culture at Bank of America Proactive Controls for Preventing Employee Overwork Consequences of Middle Managers in Corporate Culture Cultural Impact: Negative Attitudes in Organizations Resources: Matt in Radical Compliance How Bank of America Ignores Its Own Rules Meant to Prevent Dangerous Workloads, by Alexander Saeedy in the WSJ  Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Aug 2024 05:00:00 -0000 Toxic Workplace Culture at Bank of America full 398 Tom Fox Tom and Matt review the latest BoA culture scandal. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the toxic workplace culture at Bank of America (BoA) around hours worked by junior employees, in spite of senior management saying the right things. BoA’s investment banking division has long been plagued by a toxic work culture, characterized by overworked junior employees and severe health crises, despite repeated assurances of reform. Tom Matt discuss these pervasive issues within BoA’s work environment. Fox highlights the tragic consequences of this toxic culture, such as the deaths of junior employees, and criticizes the company's failure to implement effective reforms, attributing this to a lack of accountability and ethical leadership. Kelly echoes this sentiment, emphasizing the necessity for senior management to set clear expectations and consequences for middle managers who perpetuate unethical behavior. Both stress the need for senior management to address the deep-seated cultural dysfunction, impose consequences, and foster a healthier, rule-abiding workplace to prevent further tragedies and promote employee well-being. Key Highlights: Toxic Workplace Culture at Bank of America Proactive Controls for Preventing Employee Overwork Consequences of Middle Managers in Corporate Culture Cultural Impact: Negative Attitudes in Organizations Resources: Matt in Radical Compliance How Bank of America Ignores Its Own Rules Meant to Prevent Dangerous Workloads, by Alexander Saeedy in the WSJ  Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the toxic workplace culture at Bank of America (BoA) around hours worked by junior employees, in spite of senior management saying the right things.

BoA’s investment banking division has long been plagued by a toxic work culture, characterized by overworked junior employees and severe health crises, despite repeated assurances of reform. Tom Matt discuss these pervasive issues within BoA’s work environment. Fox highlights the tragic consequences of this toxic culture, such as the deaths of junior employees, and criticizes the company's failure to implement effective reforms, attributing this to a lack of accountability and ethical leadership. Kelly echoes this sentiment, emphasizing the necessity for senior management to set clear expectations and consequences for middle managers who perpetuate unethical behavior. Both stress the need for senior management to address the deep-seated cultural dysfunction, impose consequences, and foster a healthier, rule-abiding workplace to prevent further tragedies and promote employee well-being.


Key Highlights:


  • Toxic Workplace Culture at Bank of America
  • Proactive Controls for Preventing Employee Overwork
  • Consequences of Middle Managers in Corporate Culture
  • Cultural Impact: Negative Attitudes in Organizations


Resources:

Matt in Radical Compliance


How Bank of America Ignores Its Own Rules Meant to Prevent Dangerous Workloads, by Alexander Saeedy in the WSJ


 Tom

Instagram

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YouTube

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Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1849 no Securing Compliance: How CCO’s Can Combat Internal Sabotage The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into some of the nettlesome internal challenges faced by many Chief Compliance Officers (CCOs) in today’s corporate environment. On Compliance into the Weeds, Tom and Matt discuss the various challenges that CCOs face within organizations. They delve into stories of how senior management, particularly General Counsels (GCs) and Chief Financial Officers (CFOs), can sometimes undermine compliance efforts. The conversation explores issues such as budget cuts, restrictive vendor usage, structural impediments, passive-aggressive behaviors, and direct interference in investigations. They also consider potential solutions and strategies for CCOs to better navigate these struggles and ensure the effectiveness of compliance programs. Key Highlights: Budgetary Constraints and Sabotage Interference in Investigations Structural Impediments to Compliance Undermining by Engagement and Assignment Advice Going Forward Resources: Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Aug 2024 07:48:00 -0000 Securing Compliance: How CCO’s Can Combat Internal Sabotage full 382 Tom Fox Tom and Matt look at how corporations will sabotage CCOs. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into some of the nettlesome internal challenges faced by many Chief Compliance Officers (CCOs) in today’s corporate environment. On Compliance into the Weeds, Tom and Matt discuss the various challenges that CCOs face within organizations. They delve into stories of how senior management, particularly General Counsels (GCs) and Chief Financial Officers (CFOs), can sometimes undermine compliance efforts. The conversation explores issues such as budget cuts, restrictive vendor usage, structural impediments, passive-aggressive behaviors, and direct interference in investigations. They also consider potential solutions and strategies for CCOs to better navigate these struggles and ensure the effectiveness of compliance programs. Key Highlights: Budgetary Constraints and Sabotage Interference in Investigations Structural Impediments to Compliance Undermining by Engagement and Assignment Advice Going Forward Resources: Matt in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!


In this episode, Tom Fox and Matt Kelly take a deep dive into some of the nettlesome internal challenges faced by many Chief Compliance Officers (CCOs) in today’s corporate environment.


On Compliance into the Weeds, Tom and Matt discuss the various challenges that CCOs face within organizations. They delve into stories of how senior management, particularly General Counsels (GCs) and Chief Financial Officers (CFOs), can sometimes undermine compliance efforts. The conversation explores issues such as budget cuts, restrictive vendor usage, structural impediments, passive-aggressive behaviors, and direct interference in investigations. They also consider potential solutions and strategies for CCOs to better navigate these struggles and ensure the effectiveness of compliance programs.


Key Highlights:


  • Budgetary Constraints and Sabotage
  • Interference in Investigations
  • Structural Impediments to Compliance
  • Undermining by Engagement and Assignment
  • Advice Going Forward


Resources:


Matt in Radical Compliance


Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1592 no The DOJ Whistleblower Incentive Program The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the recently announced Department of Justice (DOJ) Whistleblower Incentive Program. Last week, the DOJ announced a whistleblower pilot program, offering monetary rewards to whistleblowers who report corporate misconduct. Whistleblowers can receive up to 30% of the net proceeds of a settlement resulting from their tip. The program covers various types of corporate crime, including bribery, healthcare fraud, and Foreign Corrupt Practices Act (FCPA) violations. This program puts pressure on compliance programs to quickly investigate and address reported misconduct. It also raises questions about how whistleblowers will be rewarded in cases where there is a declination or non-prosecution agreement. The SEC case involving a whistleblower award highlights the importance of handling whistleblower reports effectively. Key Highlights: DOJ Announces Whistleblower Pilot Program Covering Various Types of Corporate Misconduct Tension Between Self-Reporting and Whistleblower Reporting Recent SEC whistleblower award as a cautionary tale Resources: Matt in Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 Aug 2024 05:00:00 -0000 The DOJ Whistleblower Incentive Program full 381 Tom Fox Tom and Matt take a deep dive into the DOJ Whistleblower Incentive Program. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the recently announced Department of Justice (DOJ) Whistleblower Incentive Program. Last week, the DOJ announced a whistleblower pilot program, offering monetary rewards to whistleblowers who report corporate misconduct. Whistleblowers can receive up to 30% of the net proceeds of a settlement resulting from their tip. The program covers various types of corporate crime, including bribery, healthcare fraud, and Foreign Corrupt Practices Act (FCPA) violations. This program puts pressure on compliance programs to quickly investigate and address reported misconduct. It also raises questions about how whistleblowers will be rewarded in cases where there is a declination or non-prosecution agreement. The SEC case involving a whistleblower award highlights the importance of handling whistleblower reports effectively. Key Highlights: DOJ Announces Whistleblower Pilot Program Covering Various Types of Corporate Misconduct Tension Between Self-Reporting and Whistleblower Reporting Recent SEC whistleblower award as a cautionary tale Resources: Matt in Radical Compliance  Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the recently announced Department of Justice (DOJ) Whistleblower Incentive Program.


Last week, the DOJ announced a whistleblower pilot program, offering monetary rewards to whistleblowers who report corporate misconduct. Whistleblowers can receive up to 30% of the net proceeds of a settlement resulting from their tip. The program covers various types of corporate crime, including bribery, healthcare fraud, and Foreign Corrupt Practices Act (FCPA) violations.

This program puts pressure on compliance programs to quickly investigate and address reported misconduct. It also raises questions about how whistleblowers will be rewarded in cases where there is a declination or non-prosecution agreement. The SEC case involving a whistleblower award highlights the importance of handling whistleblower reports effectively.


Key Highlights:

  • DOJ Announces Whistleblower Pilot Program
  • Covering Various Types of Corporate Misconduct
  • Tension Between Self-Reporting and Whistleblower Reporting
  • Recent SEC whistleblower award as a cautionary tale


Resources:

Matt in Radical Compliance 

Tom

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]]> 1474 no The Boeing Plea Agreement – Questions, Questions, Questions The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the Plea Agreement filed by the DOJ in the Boeing criminal case. Today we delve into the proposed plea agreement between the Department of Justice and Boeing, following violations of the company’s 2021 Deferred Prosecution Agreement (DPA). We discuss the detailed aspects of the plea, including a $243 million criminal penalty, a $455 million compliance investment plan, a three-year prosecutor probation with a compliance monitor, and a unique interaction between Boeing’s board and the families of crash victims. Matt and Tom also explore Boeing’s obligations to integrate safety and quality programs with its ethics and compliance initiatives, and the implications of these stringent new requirements. Key Highlights: Boeing’s Compliance and Safety Issues Expansion of Corporate Compliance Role Implications for Boeing’s Compliance Culture Monitor, Oversight, and Victim’s Families Role of the Board and Compliance Spending Future Considerations and CCO Certification Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog  Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 31 Jul 2024 05:00:00 -0000 The Boeing Plea Agreement – Questions, Questions, Questions full 380 Tom Fox Tom and Matt explore the Boeing Plea Agreement. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the Plea Agreement filed by the DOJ in the Boeing criminal case. Today we delve into the proposed plea agreement between the Department of Justice and Boeing, following violations of the company’s 2021 Deferred Prosecution Agreement (DPA). We discuss the detailed aspects of the plea, including a $243 million criminal penalty, a $455 million compliance investment plan, a three-year prosecutor probation with a compliance monitor, and a unique interaction between Boeing’s board and the families of crash victims. Matt and Tom also explore Boeing’s obligations to integrate safety and quality programs with its ethics and compliance initiatives, and the implications of these stringent new requirements. Key Highlights: Boeing’s Compliance and Safety Issues Expansion of Corporate Compliance Role Implications for Boeing’s Compliance Culture Monitor, Oversight, and Victim’s Families Role of the Board and Compliance Spending Future Considerations and CCO Certification Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog  Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject.


Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!


In this episode Tom Fox and Matt Kelly take a deep dive into the Plea Agreement filed by the DOJ in the Boeing criminal case.


Today we delve into the proposed plea agreement between the Department of Justice and Boeing, following violations of the company’s 2021 Deferred Prosecution Agreement (DPA). We discuss the detailed aspects of the plea, including a $243 million criminal penalty, a $455 million compliance investment plan, a three-year prosecutor probation with a compliance monitor, and a unique interaction between Boeing’s board and the families of crash victims.


Matt and Tom also explore Boeing’s obligations to integrate safety and quality programs with its ethics and compliance initiatives, and the implications of these stringent new requirements.


Key Highlights:

  • Boeing’s Compliance and Safety Issues
  • Expansion of Corporate Compliance Role
  • Implications for Boeing’s Compliance Culture
  • Monitor, Oversight, and Victim’s Families
  • Role of the Board and Compliance Spending
  • Future Considerations and CCO Certification


Resources:


Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog


 Tom

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]]> 1265 no Major Cybersecurity Incidents and Regulatory Challenges The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the dismissal of the SEC’s enforcement action against Solar Winds and CrowdStrike cybersecurity failures. Tom and Matt begin with UnitedHealth’s costly ransomware attack, a federal judge’s ruling against the SEC’s lawsuit over SolarWinds’ cybersecurity practices, and CrowdStrike’s flawed software update impacting global corporations. The episode explores the regulatory challenges of enforcing effective cybersecurity controls and the implications for companies and their compliance programs. The discussion highlights the need for better IT general controls and the role of different stakeholders, including Congress, regulatory agencies, and audit firms, in addressing these cybersecurity risks. Key Highlights: UnitedHealth Ransomware Attack Breakdown SolarWinds Cybersecurity Lawsuit Regulatory Challenges and Implications Operational Risk Management and IT Controls Call to Action for Compliance and Audit Professionals Resources: Matt on Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Jul 2024 05:00:00 -0000 Major Cybersecurity Incidents and Regulatory Challenges full 379 Tom Fox Solar Winds and CrowdStrike The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into the dismissal of the SEC’s enforcement action against Solar Winds and CrowdStrike cybersecurity failures. Tom and Matt begin with UnitedHealth’s costly ransomware attack, a federal judge’s ruling against the SEC’s lawsuit over SolarWinds’ cybersecurity practices, and CrowdStrike’s flawed software update impacting global corporations. The episode explores the regulatory challenges of enforcing effective cybersecurity controls and the implications for companies and their compliance programs. The discussion highlights the need for better IT general controls and the role of different stakeholders, including Congress, regulatory agencies, and audit firms, in addressing these cybersecurity risks. Key Highlights: UnitedHealth Ransomware Attack Breakdown SolarWinds Cybersecurity Lawsuit Regulatory Challenges and Implications Operational Risk Management and IT Controls Call to Action for Compliance and Audit Professionals Resources: Matt on Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the dismissal of the SEC’s enforcement action against Solar Winds and CrowdStrike cybersecurity failures.

Tom and Matt begin with UnitedHealth’s costly ransomware attack, a federal judge’s ruling against the SEC’s lawsuit over SolarWinds’ cybersecurity practices, and CrowdStrike’s flawed software update impacting global corporations.

The episode explores the regulatory challenges of enforcing effective cybersecurity controls and the implications for companies and their compliance programs. The discussion highlights the need for better IT general controls and the role of different stakeholders, including Congress, regulatory agencies, and audit firms, in addressing these cybersecurity risks.


Key Highlights:


  • UnitedHealth Ransomware Attack Breakdown
  • SolarWinds Cybersecurity Lawsuit
  • Regulatory Challenges and Implications
  • Operational Risk Management and IT Controls
  • Call to Action for Compliance and Audit Professionals




Resources:

Matt on Radical Compliance

 

Tom  

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]]> 1400 no The Convergence of Cybersecurity and Internal Controls The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into a recent SEC enforcement action involving RR Donnelley, where a cyber breach was characterized as an internal control In this episode, we discuss how criminal activities in cyberspace are outpacing regulatory measures and the law’s ability to keep up. The conversation touches on the idea that access controls for valuable corporate assets, whether financial data or sensitive information, are becoming indistinguishable in the eyes of cybercriminals. The discussion includes a thought-provoking perspective on merging cybersecurity and anti-money laundering functions, as both deal with improper electronic transactions. The core concern is not just the breach itself, but also the prevention of data exfiltration. Key Highlights: Corporate Jewels: Money vs. Data Cybersecurity and Anti-Money Laundering Improper Electronic Transactions Focus on Data Exfiltration Conclusion: Preventing Data Theft Resources: Matt on Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Jul 2024 05:00:00 -0000 The Convergence of Cybersecurity and Internal Controls full 378 Tom Fox Tom and Matt review the RR Donnelly SEC enforcement action. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into a recent SEC enforcement action involving RR Donnelley, where a cyber breach was characterized as an internal control In this episode, we discuss how criminal activities in cyberspace are outpacing regulatory measures and the law’s ability to keep up. The conversation touches on the idea that access controls for valuable corporate assets, whether financial data or sensitive information, are becoming indistinguishable in the eyes of cybercriminals. The discussion includes a thought-provoking perspective on merging cybersecurity and anti-money laundering functions, as both deal with improper electronic transactions. The core concern is not just the breach itself, but also the prevention of data exfiltration. Key Highlights: Corporate Jewels: Money vs. Data Cybersecurity and Anti-Money Laundering Improper Electronic Transactions Focus on Data Exfiltration Conclusion: Preventing Data Theft Resources: Matt on Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!


In this episode, Tom Fox and Matt Kelly take a deep dive into a recent SEC enforcement action involving RR Donnelley, where a cyber breach was characterized as an internal control


In this episode, we discuss how criminal activities in cyberspace are outpacing regulatory measures and the law’s ability to keep up. The conversation touches on the idea that access controls for valuable corporate assets, whether financial data or sensitive information, are becoming indistinguishable in the eyes of cybercriminals. The discussion includes a thought-provoking perspective on merging cybersecurity and anti-money laundering functions, as both deal with improper electronic transactions. The core concern is not just the breach itself, but also the prevention of data exfiltration.



Key Highlights:

  • Corporate Jewels: Money vs. Data
  • Cybersecurity and Anti-Money Laundering
  • Improper Electronic Transactions
  • Focus on Data Exfiltration
  • Conclusion: Preventing Data Theft


Resources:

Matt on Radical Compliance

 

Tom  

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]]> 1456 no The Supreme Court and Compliance The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive analyzing term-ending Supreme Court decisions from a compliance perspective.  They address the Jarkesy decision on SEC in-house tribunals, the Loper ruling overturning the Chevron deference doctrine, and the Snyder decision that narrows the scope of federal anti-corruption law. Despite the headlines, they conclude that these rulings have minimal direct impact on corporate compliance programs, emphasizing the ongoing importance of ethical integrity and effective compliance practices. Key Highlights ·      Supreme Court Cases Impacting Compliance ·      The Jarkesy Decision: Minimal Impact on Compliance ·      The Loper Case: Chevron Deference Overturned ·      The Snyder Decision: A Controversial Ruling ·      Implications and Final Thoughts Resources Matt on Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Jul 2024 05:00:00 -0000 The Supreme Court and Compliance full 377 Tom Fox Tom and Matt look at 3 term-ending Supreme Court decisions from the compliance angle. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive analyzing term-ending Supreme Court decisions from a compliance perspective.  They address the Jarkesy decision on SEC in-house tribunals, the Loper ruling overturning the Chevron deference doctrine, and the Snyder decision that narrows the scope of federal anti-corruption law. Despite the headlines, they conclude that these rulings have minimal direct impact on corporate compliance programs, emphasizing the ongoing importance of ethical integrity and effective compliance practices. Key Highlights ·      Supreme Court Cases Impacting Compliance ·      The Jarkesy Decision: Minimal Impact on Compliance ·      The Loper Case: Chevron Deference Overturned ·      The Snyder Decision: A Controversial Ruling ·      Implications and Final Thoughts Resources Matt on Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive analyzing term-ending Supreme Court decisions from a compliance perspective. 


They address the Jarkesy decision on SEC in-house tribunals, the Loper ruling overturning the Chevron deference doctrine, and the Snyder decision that narrows the scope of federal anti-corruption law. Despite the headlines, they conclude that these rulings have minimal direct impact on corporate compliance programs, emphasizing the ongoing importance of ethical integrity and effective compliance practices.


Key Highlights


·      Supreme Court Cases Impacting Compliance

·      The Jarkesy Decision: Minimal Impact on Compliance

·      The Loper Case: Chevron Deference Overturned

·      The Snyder Decision: A Controversial Ruling

·      Implications and Final Thoughts



Resources

Matt on Radical Compliance

 


Tom  

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]]> 1721 no Navigating DOJ’s Boeing Dilemma Under DPA Violations The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the complexities surrounding the Department of Justice's potential decision to criminally prosecute Boeing under its Deferred Prosecution Agreement (DPA) related to the 737 MAX crashes.  They explore the various facets of corporate justice, including retribution, remediation, and societal interests, as well as the challenges in balancing justice for the victims and the broader implications for public safety and corporate culture. The discussion also covers the FAA’s role, the potential for new operational limits on Boeing, the impact and structure of compliance monitorships, and what compliance officers can learn from this high-stakes scenario. Key Highlights ·      DOJ and Boeing: The 737 MAX Dilemma ·      Corporate Justice: Individuals vs. Corporations ·      Balancing Justice and Corporate Interests ·      Deferred Prosecution Agreements: Compliance Challenges ·      07:33 Financial Penalties vs. Operational Limits ·      The Potential of Monitorships ·      FAA's Role and Challenges ·      Compliance Lessons and Future Considerations Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Jun 2024 04:00:00 -0000 Navigating DOJ’s Boeing Dilemma Under DPA Violations full 376 Tom Fox Tom and Matt explore the DOJ conundrum over Boeing. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the complexities surrounding the Department of Justice's potential decision to criminally prosecute Boeing under its Deferred Prosecution Agreement (DPA) related to the 737 MAX crashes.  They explore the various facets of corporate justice, including retribution, remediation, and societal interests, as well as the challenges in balancing justice for the victims and the broader implications for public safety and corporate culture. The discussion also covers the FAA’s role, the potential for new operational limits on Boeing, the impact and structure of compliance monitorships, and what compliance officers can learn from this high-stakes scenario. Key Highlights ·      DOJ and Boeing: The 737 MAX Dilemma ·      Corporate Justice: Individuals vs. Corporations ·      Balancing Justice and Corporate Interests ·      Deferred Prosecution Agreements: Compliance Challenges ·      07:33 Financial Penalties vs. Operational Limits ·      The Potential of Monitorships ·      FAA's Role and Challenges ·      Compliance Lessons and Future Considerations Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly take a deep dive into the complexities surrounding the Department of Justice's potential decision to criminally prosecute Boeing under its Deferred Prosecution Agreement (DPA) related to the 737 MAX crashes. 

They explore the various facets of corporate justice, including retribution, remediation, and societal interests, as well as the challenges in balancing justice for the victims and the broader implications for public safety and corporate culture. The discussion also covers the FAA’s role, the potential for new operational limits on Boeing, the impact and structure of compliance monitorships, and what compliance officers can learn from this high-stakes scenario.

Key Highlights

·      DOJ and Boeing: The 737 MAX Dilemma

·      Corporate Justice: Individuals vs. Corporations

·      Balancing Justice and Corporate Interests

·      Deferred Prosecution Agreements: Compliance Challenges

·      07:33 Financial Penalties vs. Operational Limits

·      The Potential of Monitorships

·      FAA's Role and Challenges

·      Compliance Lessons and Future Considerations

Resources

Matt on Radical Compliance

 Tom  

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]]> 1766 no AI Accountability and Explainability The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly delve into the recent speech by Michael Hsu, the head of the Office of the Comptroller of the Currency, on the accountability challenges posed by artificial intelligence in the banking sector.  The discussion highlights Hsu's emphasis on the lack of a robust accountability framework for AI, illustrating the issue with the Air Canada chatbot incident. The conversation also touches on potential systemic risks AI could pose to the financial sector, the need for explainable AI, and the shared responsibility model used in cloud computing as a potential template for addressing these challenges. The episode underscores the necessity for compliance officers to ensure contracts and IT controls are in place and stresses the importance of developing trust and accountability mechanisms before widespread AI adoption. Key Highlights ·      AI Accountability: A Regulator's Perspective ·      Case Study: Air Canada's AI Mishap ·      Legal and Technological Challenges ·      Exploring Solutions and Shared Responsibility Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Jun 2024 04:00:00 -0000 AI Accountability and Explainability full 375 Tom Fox Tom and Matt take a deep dive into AI accountability and explainability. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly delve into the recent speech by Michael Hsu, the head of the Office of the Comptroller of the Currency, on the accountability challenges posed by artificial intelligence in the banking sector.  The discussion highlights Hsu's emphasis on the lack of a robust accountability framework for AI, illustrating the issue with the Air Canada chatbot incident. The conversation also touches on potential systemic risks AI could pose to the financial sector, the need for explainable AI, and the shared responsibility model used in cloud computing as a potential template for addressing these challenges. The episode underscores the necessity for compliance officers to ensure contracts and IT controls are in place and stresses the importance of developing trust and accountability mechanisms before widespread AI adoption. Key Highlights ·      AI Accountability: A Regulator's Perspective ·      Case Study: Air Canada's AI Mishap ·      Legal and Technological Challenges ·      Exploring Solutions and Shared Responsibility Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode Tom Fox and Matt Kelly delve into the recent speech by Michael Hsu, the head of the Office of the Comptroller of the Currency, on the accountability challenges posed by artificial intelligence in the banking sector. 

The discussion highlights Hsu's emphasis on the lack of a robust accountability framework for AI, illustrating the issue with the Air Canada chatbot incident. The conversation also touches on potential systemic risks AI could pose to the financial sector, the need for explainable AI, and the shared responsibility model used in cloud computing as a potential template for addressing these challenges. The episode underscores the necessity for compliance officers to ensure contracts and IT controls are in place and stresses the importance of developing trust and accountability mechanisms before widespread AI adoption.

Key Highlights

·      AI Accountability: A Regulator's Perspective

·      Case Study: Air Canada's AI Mishap

·      Legal and Technological Challenges

·      Exploring Solutions and Shared Responsibility

Resources

Matt on Radical Compliance

 Tom  

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Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1534 no Analyzing The Trump Conviction: Compliance Lessons from an Unprecedented Case The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance Into the Weeds’, Tom and Matt take a deep dive into last week’s trial verdict against Donald Trump in NYC and lessons for the compliance professional. We explore the importance of internal controls, consistent consequence management, and effective leadership. They also delve into how compliance officers can learn from the storytelling strategies used in the trial and emphasize the application of the rule of law. Key Highlights: Overview of Trump’s Criminal Conviction Internal Controls and Compliance Lessons Consequences Management and Consistent Enforcement Ethical Leadership and Communication Who is your audience? Storytelling in Compliance Final Thoughts and Rule of Law Resources: Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Jun 2024 04:00:00 -0000 Compliance Lessons from an Unprecedented Case full 374 Tom Fox The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of ‘Compliance Into the Weeds’, Tom and Matt take a deep dive into last week’s trial verdict against Donald Trump in NYC and lessons for the compliance professional. We explore the importance of internal controls, consistent consequence management, and effective leadership. They also delve into how compliance officers can learn from the storytelling strategies used in the trial and emphasize the application of the rule of law. Key Highlights: Overview of Trump’s Criminal Conviction Internal Controls and Compliance Lessons Consequences Management and Consistent Enforcement Ethical Leadership and Communication Who is your audience? Storytelling in Compliance Final Thoughts and Rule of Law Resources: Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode of ‘Compliance Into the Weeds’, Tom and Matt take a deep dive into last week’s trial verdict against Donald Trump in NYC and lessons for the compliance professional.

We explore the importance of internal controls, consistent consequence management, and effective leadership. They also delve into how compliance officers can learn from the storytelling strategies used in the trial and emphasize the application of the rule of law.

Key Highlights:

  • Overview of Trump’s Criminal Conviction
  • Internal Controls and Compliance Lessons
  • Consequences Management and Consistent Enforcement
  • Ethical Leadership and Communication
  • Who is your audience? Storytelling in Compliance
  • Final Thoughts and Rule of Law


Resources:

Matt on Radical Compliance

 Tom  

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]]> 1529 no Of Fat Fingers, Internal Controls and Compliance The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt delve deep into Citigroup’s $126 million trading error, resulting from poor internal controls. They discuss how a simple ‘fat finger’ error by a trader led to a major flash crash on European stock exchanges in 2022, and how the failure of Citigroup’s internal controls allowed it to happen. The discussion covers multiple compliance lessons, including the importance of understanding the human element in control design, the need for adequate staffing and monitoring, and the necessity of consistent global risk management. Fox and Kelly also highlight the importance of addressing findings from internal audits and maintaining urgency in improving internal controls. They emphasize that companies should think creatively about risk management, taking into account various global factors, including holidays and local regulations. Key Highlights: The Citigroup Internal Control Fiasco Compliance Lessons from Citigroup's Mistake The Human Element in Compliance and Control Failures Global Consistency in Risk Management Resources: Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 May 2024 04:00:00 -0000 Of Fat Fingers, Internal Controls and Compliance full 373 Tom Fox In this episode Tom and Matt delve deep into Citigroup's $126 million trading error, resulting from poor internal controls. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt delve deep into Citigroup’s $126 million trading error, resulting from poor internal controls. They discuss how a simple ‘fat finger’ error by a trader led to a major flash crash on European stock exchanges in 2022, and how the failure of Citigroup’s internal controls allowed it to happen. The discussion covers multiple compliance lessons, including the importance of understanding the human element in control design, the need for adequate staffing and monitoring, and the necessity of consistent global risk management. Fox and Kelly also highlight the importance of addressing findings from internal audits and maintaining urgency in improving internal controls. They emphasize that companies should think creatively about risk management, taking into account various global factors, including holidays and local regulations. Key Highlights: The Citigroup Internal Control Fiasco Compliance Lessons from Citigroup's Mistake The Human Element in Compliance and Control Failures Global Consistency in Risk Management Resources: Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom and Matt delve deep into Citigroup’s $126 million trading error, resulting from poor internal controls.

They discuss how a simple ‘fat finger’ error by a trader led to a major flash crash on European stock exchanges in 2022, and how the failure of Citigroup’s internal controls allowed it to happen. The discussion covers multiple compliance lessons, including the importance of understanding the human element in control design, the need for adequate staffing and monitoring, and the necessity of consistent global risk management.

Fox and Kelly also highlight the importance of addressing findings from internal audits and maintaining urgency in improving internal controls. They emphasize that companies should think creatively about risk management, taking into account various global factors, including holidays and local regulations.


Key Highlights:

  • The Citigroup Internal Control Fiasco
  • Compliance Lessons from Citigroup's Mistake
  • The Human Element in Compliance and Control Failures
  • Global Consistency in Risk Management

Resources:

Matt on Radical Compliance

 Tom  

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]]> 1733 no Sustainability and Managing 3rd Party Risk The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into a recent report by Prevalent on Third Party Risk Management in 2024 and Microsoft’s 2024 Environmental Sustainability Report. Tom and Matt discuss the challenge companies face in aligning their sustainability goals with their supply chain management. They question whether sustainability functions within a company have the authority to influence supply chain decisions, such as rejecting suppliers that do not meet sustainability criteria. We discuss the  Microsoft Report, noting that while the company acknowledges it has not yet achieved the ability to reject non-compliant suppliers, it suggests a target of improvement by 2030. The core issue highlighted is whether sustainability initiatives will have significant influence over supply chain decisions in the future.  Key Highlights: Intersection of Supply Chain Risk Management and Sustainability The Role of Sustainability in Supply Chain Decisions Microsoft’s Journey Towards Sustainable Supply Chain Management The Energy Industry Model Resources: Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 May 2024 04:00:00 -0000 Sustainability and Managing 3rd Party Risk full 372 Tom Fox Tom and Matt take a deep dive into third party risk management issues. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly take a deep dive into a recent report by Prevalent on Third Party Risk Management in 2024 and Microsoft’s 2024 Environmental Sustainability Report. Tom and Matt discuss the challenge companies face in aligning their sustainability goals with their supply chain management. They question whether sustainability functions within a company have the authority to influence supply chain decisions, such as rejecting suppliers that do not meet sustainability criteria. We discuss the  Microsoft Report, noting that while the company acknowledges it has not yet achieved the ability to reject non-compliant suppliers, it suggests a target of improvement by 2030. The core issue highlighted is whether sustainability initiatives will have significant influence over supply chain decisions in the future.  Key Highlights: Intersection of Supply Chain Risk Management and Sustainability The Role of Sustainability in Supply Chain Decisions Microsoft’s Journey Towards Sustainable Supply Chain Management The Energy Industry Model Resources: Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into a recent report by Prevalent on Third Party Risk Management in 2024 and Microsoft’s 2024 Environmental Sustainability Report.

Tom and Matt discuss the challenge companies face in aligning their sustainability goals with their supply chain management. They question whether sustainability functions within a company have the authority to influence supply chain decisions, such as rejecting suppliers that do not meet sustainability criteria.

We discuss the  Microsoft Report, noting that while the company acknowledges it has not yet achieved the ability to reject non-compliant suppliers, it suggests a target of improvement by 2030. The core issue highlighted is whether sustainability initiatives will have significant influence over supply chain decisions in the future. 


Key Highlights:

  • Intersection of Supply Chain Risk Management and Sustainability
  • The Role of Sustainability in Supply Chain Decisions
  • Microsoft’s Journey Towards Sustainable Supply Chain Management
  • The Energy Industry Model


Resources:

Matt on Radical Compliance

Tom  

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]]> 1807 no Scathing Report on Culture at The FDIC The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look at the absolutely scathing report issued by the law firm Cleary Gottlieb on the toxic culture of harassment and abuse at the Federal Deposit Insurance Corporation. A recent scandal has been unveiled in the U.S. banking sector, spotlighting the Federal Deposit Insurance Corporation (FDIC). A report has unveiled a toxic corporate culture riddled with instances of harassment, whistleblower retaliation, and poor leadership under Chairman Martin Gruenberg. Fox, viewing the scandal as a pivotal moment, emphasizes the need for accountability and radical change within the organization, particularly in addressing the issues revealed in the report. Despite the daunting challenges, Fox maintains a level of optimism, believing that with the right management and leadership changes, the FDIC can rectify its corporate culture. Kelly recognizes the deep-seated cultural issues brought to light by the report, nonetheless, he believes that due to the FDIC's relatively small size, with the right leadership and cultural shifts, it is possible to turn the organization around. Both experts' perspectives are rooted in their understanding of corporate culture and governance, and their beliefs in the power of effective leadership and cultural change. Key Highlights: Toxic Culture Exposed in FDIC Report Ethical Culture Assessment in Banking Regulation Systems Toxic Culture: Mismanagement & Whistleblower Retaliation Structure and Toxic Corporate Environment Transformative Potential within the FDIC Resources: Matt Kelly on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 May 2024 04:00:00 -0000 Scathing Report on Culture at The FDIC full 371 Tom Fox Tom and Matt look at the report on the FDIC and its toxic culture. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look at the absolutely scathing report issued by the law firm Cleary Gottlieb on the toxic culture of harassment and abuse at the Federal Deposit Insurance Corporation. A recent scandal has been unveiled in the U.S. banking sector, spotlighting the Federal Deposit Insurance Corporation (FDIC). A report has unveiled a toxic corporate culture riddled with instances of harassment, whistleblower retaliation, and poor leadership under Chairman Martin Gruenberg. Fox, viewing the scandal as a pivotal moment, emphasizes the need for accountability and radical change within the organization, particularly in addressing the issues revealed in the report. Despite the daunting challenges, Fox maintains a level of optimism, believing that with the right management and leadership changes, the FDIC can rectify its corporate culture. Kelly recognizes the deep-seated cultural issues brought to light by the report, nonetheless, he believes that due to the FDIC's relatively small size, with the right leadership and cultural shifts, it is possible to turn the organization around. Both experts' perspectives are rooted in their understanding of corporate culture and governance, and their beliefs in the power of effective leadership and cultural change. Key Highlights: Toxic Culture Exposed in FDIC Report Ethical Culture Assessment in Banking Regulation Systems Toxic Culture: Mismanagement & Whistleblower Retaliation Structure and Toxic Corporate Environment Transformative Potential within the FDIC Resources: Matt Kelly on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom and Matt look at the absolutely scathing report issued by the law firm Cleary Gottlieb on the toxic culture of harassment and abuse at the Federal Deposit Insurance Corporation.

A recent scandal has been unveiled in the U.S. banking sector, spotlighting the Federal Deposit Insurance Corporation (FDIC). A report has unveiled a toxic corporate culture riddled with instances of harassment, whistleblower retaliation, and poor leadership under Chairman Martin Gruenberg.

Fox, viewing the scandal as a pivotal moment, emphasizes the need for accountability and radical change within the organization, particularly in addressing the issues revealed in the report. Despite the daunting challenges, Fox maintains a level of optimism, believing that with the right management and leadership changes, the FDIC can rectify its corporate culture.

Kelly recognizes the deep-seated cultural issues brought to light by the report, nonetheless, he believes that due to the FDIC's relatively small size, with the right leadership and cultural shifts, it is possible to turn the organization around. Both experts' perspectives are rooted in their understanding of corporate culture and governance, and their beliefs in the power of effective leadership and cultural change.


Key Highlights:

  • Toxic Culture Exposed in FDIC Report
  • Ethical Culture Assessment in Banking Regulation Systems
  • Toxic Culture: Mismanagement & Whistleblower Retaliation
  • Structure and Toxic Corporate Environment
  • Transformative Potential within the FDIC


Resources:

Matt Kelly on Radical Compliance

Tom 

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]]> 1617 no The WACKO Enforcement Action Involving BF Borgers The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly look into an absolutely wacko SEC enforcement action involving BF Borgers and its founder and principal, Benjamin Borger’s. The auditing sector was recently rocked by the Securities and Exchange Commission’s (SEC) investigation into BF Borgers CPA, an auditing firm with over 1,600 problematic disclosures. The incident, which serves as a reminder of the critical role played by audit committees in ensuring appropriate audit procedures,. Only a fraudster can admire the audacity of Benjamin F. Borgers in fabricating audit reports for hundreds of clients, which underscores the need for enhanced governance and regulatory measures to prevent similar incidents in the future. We discuss the impact on smaller public companies, focusing on their struggles to find competent and affordable audit firms. Matt raised the question of where the company’s audit committees were during all this fraudulent work. He also speculates on potential legal repercussions for Borgers and his firm. Both perspectives highlight the gravity of the situation, the need for improved oversight, and potential consequences of such actions. Key Highlights: Audit Quality Oversight in Regulatory Environment Finding New Auditors After Losing Previous Firm Limited Options for Small Company Auditors Proactive Monitoring of Audit Firms by Committees Resources: Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 May 2024 04:00:00 -0000 The WACKO Enforcement Action Involving BF Borgers full 370 Tom Fox Tom and Matt look at the SEC enforcement action involving BF Borgers. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly look into an absolutely wacko SEC enforcement action involving BF Borgers and its founder and principal, Benjamin Borger’s. The auditing sector was recently rocked by the Securities and Exchange Commission’s (SEC) investigation into BF Borgers CPA, an auditing firm with over 1,600 problematic disclosures. The incident, which serves as a reminder of the critical role played by audit committees in ensuring appropriate audit procedures,. Only a fraudster can admire the audacity of Benjamin F. Borgers in fabricating audit reports for hundreds of clients, which underscores the need for enhanced governance and regulatory measures to prevent similar incidents in the future. We discuss the impact on smaller public companies, focusing on their struggles to find competent and affordable audit firms. Matt raised the question of where the company’s audit committees were during all this fraudulent work. He also speculates on potential legal repercussions for Borgers and his firm. Both perspectives highlight the gravity of the situation, the need for improved oversight, and potential consequences of such actions. Key Highlights: Audit Quality Oversight in Regulatory Environment Finding New Auditors After Losing Previous Firm Limited Options for Small Company Auditors Proactive Monitoring of Audit Firms by Committees Resources: Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly look into an absolutely wacko SEC enforcement action involving BF Borgers and its founder and principal, Benjamin Borger’s.

The auditing sector was recently rocked by the Securities and Exchange Commission’s (SEC) investigation into BF Borgers CPA, an auditing firm with over 1,600 problematic disclosures. The incident, which serves as a reminder of the critical role played by audit committees in ensuring appropriate audit procedures,.

Only a fraudster can admire the audacity of Benjamin F. Borgers in fabricating audit reports for hundreds of clients, which underscores the need for enhanced governance and regulatory measures to prevent similar incidents in the future.

We discuss the impact on smaller public companies, focusing on their struggles to find competent and affordable audit firms. Matt raised the question of where the company’s audit committees were during all this fraudulent work. He also speculates on potential legal repercussions for Borgers and his firm. Both perspectives highlight the gravity of the situation, the need for improved oversight, and potential consequences of such actions.

Key Highlights:

  • Audit Quality Oversight in Regulatory Environment
  • Finding New Auditors After Losing Previous Firm
  • Limited Options for Small Company Auditors
  • Proactive Monitoring of Audit Firms by Committees


Resources:

Matt on Radical Compliance

 Tom  

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]]> 1381 no What Are Boards Doing About AI (Hint: Not Much) The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look into corporate reports on their Boards’ oversight of AI.  As the world ventures deeper into the age of artificial intelligence (AI), the issue of corporate governance over AI is emerging as a crucial point of discussion. Tech giants such as Google are facing demands for more board-level attention to AI risk management due to concerns about the lack of transparency and oversight. Tom highlights this lack of detailed consideration of AI at the board level, raising doubts about whether boards are suitably prepared for AI's rapid development and potential enforcement risks. His concerns are rooted in limited mentions of AI in proxy statements of S&P 500 companies, suggesting current practices might not be sufficient for the future.  Meanwhile, Matt emphasizes the need for boards to start considering staffing, expertise, and risk management related to AI without necessarily forming dedicated AI committees at present. Kelly's concerns stem from the lack of detail in proxy statements about what boards are currently doing with AI, especially in tech-heavy companies like Google, indicating the need for potential formation of dedicated committees or sub-specializations in the future.  Key Highlights ·      AI Risk Management: Tech vs. Non-Tech Perspectives ·      Enhancing Corporate Governance Through AI Oversight ·      Technology Risk Oversight in Evolving Companies ·      AI Oversight for Corporate Boards: Future Risks Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 May 2024 04:00:00 -0000 What Are Boards Doing About AI (Hint: Not Much) full 369 Tom Fox Tom and Matt look into corporate reports on their Boards’ oversight of AI. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look into corporate reports on their Boards’ oversight of AI.  As the world ventures deeper into the age of artificial intelligence (AI), the issue of corporate governance over AI is emerging as a crucial point of discussion. Tech giants such as Google are facing demands for more board-level attention to AI risk management due to concerns about the lack of transparency and oversight. Tom highlights this lack of detailed consideration of AI at the board level, raising doubts about whether boards are suitably prepared for AI's rapid development and potential enforcement risks. His concerns are rooted in limited mentions of AI in proxy statements of S&P 500 companies, suggesting current practices might not be sufficient for the future.  Meanwhile, Matt emphasizes the need for boards to start considering staffing, expertise, and risk management related to AI without necessarily forming dedicated AI committees at present. Kelly's concerns stem from the lack of detail in proxy statements about what boards are currently doing with AI, especially in tech-heavy companies like Google, indicating the need for potential formation of dedicated committees or sub-specializations in the future.  Key Highlights ·      AI Risk Management: Tech vs. Non-Tech Perspectives ·      Enhancing Corporate Governance Through AI Oversight ·      Technology Risk Oversight in Evolving Companies ·      AI Oversight for Corporate Boards: Future Risks Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look into corporate reports on their Boards’ oversight of AI. 

As the world ventures deeper into the age of artificial intelligence (AI), the issue of corporate governance over AI is emerging as a crucial point of discussion. Tech giants such as Google are facing demands for more board-level attention to AI risk management due to concerns about the lack of transparency and oversight. Tom highlights this lack of detailed consideration of AI at the board level, raising doubts about whether boards are suitably prepared for AI's rapid development and potential enforcement risks. His concerns are rooted in limited mentions of AI in proxy statements of S&P 500 companies, suggesting current practices might not be sufficient for the future. 

Meanwhile, Matt emphasizes the need for boards to start considering staffing, expertise, and risk management related to AI without necessarily forming dedicated AI committees at present. Kelly's concerns stem from the lack of detail in proxy statements about what boards are currently doing with AI, especially in tech-heavy companies like Google, indicating the need for potential formation of dedicated committees or sub-specializations in the future.

 Key Highlights

·      AI Risk Management: Tech vs. Non-Tech Perspectives

·      Enhancing Corporate Governance Through AI Oversight

·      Technology Risk Oversight in Evolving Companies

·      AI Oversight for Corporate Boards: Future Risks

Resources

Matt on Radical Compliance

 Tom  

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]]> 1424 no Digital Transformation in Sports Betting: Preventing Fraudulent Activities The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into imbroglio involving Jontay Porter and gambling on NBA games. The recent scandal involving the lifetime suspension of Jontay Porter from the NBA due to questionable prop bets, has sent shockwaves through the sports betting industry. Tom views this incident as a stark warning for compliance professionals, underscoring the importance of data analytics in detecting anomalies and misconduct. He notes that thorough data analysis can expose even lesser-known players like Porter to inappropriate behavior while also commending the NBA’s swift and decisive action to preserve the integrity of the game. Matt, a digital transformation advocate in sports betting, believes the scandal highlights the benefits of digital transformation in the industry. He stresses the crucial role of data analytics in identifying suspicious activity and potential misconduct, agreeing with the NBA’s decision to suspend Porter and protect the sport’s integrity. Both Fox and Kelly’s perspectives are shaped by their backgrounds in compliance and digital transformation, respectively, emphasizing the profound impact of data analytics in these areas. Key Highlights: NBA Suspension: Data Analytics in Sports Betting Sports Betting Fraud Prevention through Digital Transformation Unveiling Unusual Patterns in Financial Transactions Location-Based Anomalies in Investigative Analytics Consequence Management Resources: Tom on the FCPA Compliance Report Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Apr 2024 04:00:00 -0000 Digital Transformation in Sports Betting: Preventing Fraudulent Activities full 368 Tom Fox Tom and Matt look at compliance lessons from the Jontay Porter betting scandal. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into imbroglio involving Jontay Porter and gambling on NBA games. The recent scandal involving the lifetime suspension of Jontay Porter from the NBA due to questionable prop bets, has sent shockwaves through the sports betting industry. Tom views this incident as a stark warning for compliance professionals, underscoring the importance of data analytics in detecting anomalies and misconduct. He notes that thorough data analysis can expose even lesser-known players like Porter to inappropriate behavior while also commending the NBA’s swift and decisive action to preserve the integrity of the game. Matt, a digital transformation advocate in sports betting, believes the scandal highlights the benefits of digital transformation in the industry. He stresses the crucial role of data analytics in identifying suspicious activity and potential misconduct, agreeing with the NBA’s decision to suspend Porter and protect the sport’s integrity. Both Fox and Kelly’s perspectives are shaped by their backgrounds in compliance and digital transformation, respectively, emphasizing the profound impact of data analytics in these areas. Key Highlights: NBA Suspension: Data Analytics in Sports Betting Sports Betting Fraud Prevention through Digital Transformation Unveiling Unusual Patterns in Financial Transactions Location-Based Anomalies in Investigative Analytics Consequence Management Resources: Tom on the FCPA Compliance Report Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom and Matt take a deep dive into imbroglio involving Jontay Porter and gambling on NBA games.

The recent scandal involving the lifetime suspension of Jontay Porter from the NBA due to questionable prop bets, has sent shockwaves through the sports betting industry.

Tom views this incident as a stark warning for compliance professionals, underscoring the importance of data analytics in detecting anomalies and misconduct. He notes that thorough data analysis can expose even lesser-known players like Porter to inappropriate behavior while also commending the NBA’s swift and decisive action to preserve the integrity of the game.

Matt, a digital transformation advocate in sports betting, believes the scandal highlights the benefits of digital transformation in the industry. He stresses the crucial role of data analytics in identifying suspicious activity and potential misconduct, agreeing with the NBA’s decision to suspend Porter and protect the sport’s integrity.

Both Fox and Kelly’s perspectives are shaped by their backgrounds in compliance and digital transformation, respectively, emphasizing the profound impact of data analytics in these areas.


Key Highlights:

  • NBA Suspension: Data Analytics in Sports Betting
  • Sports Betting Fraud Prevention through Digital Transformation
  • Unveiling Unusual Patterns in Financial Transactions
  • Location-Based Anomalies in Investigative Analytics
  • Consequence Management


Resources:

Tom on the FCPA Compliance Report

Tom  

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]]> 1231 no Do We Need More Centralized Compliance? The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into recent study on bias in workplace hiring and use the study to consider if compliance needs to be more centralized. The topic of discriminatory patterns in hiring is an interesting, yet contentious issue. It encompasses biases in recruitment based on factors such as names, gender, and race, which unfortunately, are still prevalent in various companies. Tom believes that these discriminatory practices hamper equal opportunities and hence, need to be addressed earnestly. Drawing from his likely experience in promoting fair employment practices, he emphasizes the need for diversity and inclusion initiatives. On the other hand, Matt attributes such discriminatory hiring patterns to inherent biases and prejudices of employers. He argues that discriminatory practices result in a lack of diversity in the workplace as qualified individuals are overlooked based on their race, gender, or age. Following from his perspective on the matter, Kelly champions the execution of policies that foster equality and fairness in the hiring process.  Key Highlights ·      Bias in Hiring Practices Based on Names ·      Bias Reduction Through Centralized Recruitment Operations ·      Enhancing Control Environment through Internal Audits ·      Ethical Alignment for Compliance Management Success Resources Matt on Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 16 Apr 2024 04:00:00 -0000 Do We Need More Centralized Compliance? full 367 Tom Fox Tom and Matt consider if we need more centralized compliance? The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into recent study on bias in workplace hiring and use the study to consider if compliance needs to be more centralized. The topic of discriminatory patterns in hiring is an interesting, yet contentious issue. It encompasses biases in recruitment based on factors such as names, gender, and race, which unfortunately, are still prevalent in various companies. Tom believes that these discriminatory practices hamper equal opportunities and hence, need to be addressed earnestly. Drawing from his likely experience in promoting fair employment practices, he emphasizes the need for diversity and inclusion initiatives. On the other hand, Matt attributes such discriminatory hiring patterns to inherent biases and prejudices of employers. He argues that discriminatory practices result in a lack of diversity in the workplace as qualified individuals are overlooked based on their race, gender, or age. Following from his perspective on the matter, Kelly champions the execution of policies that foster equality and fairness in the hiring process.  Key Highlights ·      Bias in Hiring Practices Based on Names ·      Bias Reduction Through Centralized Recruitment Operations ·      Enhancing Control Environment through Internal Audits ·      Ethical Alignment for Compliance Management Success Resources Matt on Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into recent study on bias in workplace hiring and use the study to consider if compliance needs to be more centralized.

The topic of discriminatory patterns in hiring is an interesting, yet contentious issue. It encompasses biases in recruitment based on factors such as names, gender, and race, which unfortunately, are still prevalent in various companies. Tom believes that these discriminatory practices hamper equal opportunities and hence, need to be addressed earnestly. Drawing from his likely experience in promoting fair employment practices, he emphasizes the need for diversity and inclusion initiatives. On the other hand, Matt attributes such discriminatory hiring patterns to inherent biases and prejudices of employers. He argues that discriminatory practices result in a lack of diversity in the workplace as qualified individuals are overlooked based on their race, gender, or age. Following from his perspective on the matter, Kelly champions the execution of policies that foster equality and fairness in the hiring process. 

Key Highlights

·      Bias in Hiring Practices Based on Names

·      Bias Reduction Through Centralized Recruitment Operations

·      Enhancing Control Environment through Internal Audits

·      Ethical Alignment for Compliance Management Success

Resources

Matt on Radical Compliance

 


Tom  

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]]> 1262 no The Complexity of Risk Assessments The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the variables a compliance professional should consider when performing a risk assessment. We also say a few words about our experiences in the total solar eclipse of April 8. Risk assessments in compliance encompass the careful evaluation of both external and internal risks, necessitating a carefully planned process for overseeing various risk assessments within a company. This task, while intricate and often challenging, is a crucial aspect of compliance. Fox emphasizes the necessity to precisely define the scope of risk assessments, which could involve assessing external threats, internal controls, or both. He proposes that companies could benefit from the guidance of internal audits, external consultants, or professional service firms.  Similarly, Matt acknowledges its complex and challenging nature. Kelly underscores the importance of a disciplined, coherent approach to managing risk assessments across different parts of an organization, suggesting the possibility of involving assistance from third-party firms or internal audit teams. Both Fox and Kelly's perspectives underscore the importance of strategic planning, effective management, and possible external input in conducting risk assessments in compliance programs.  Key Highlights ·      Comprehensive Approach to Conducting Risk Assessments ·      Collaborative Risk Assessment for Compliance Optimization ·      Enhancing Compliance through Internal Control Testing ·      Strategic Integration of Compliance in Enterprise Risk ·      Celestial Event Viewing: The Influence of Clouds Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Apr 2024 04:00:00 -0000 The Complexity of Risk Assessments full 366 Tom Fox Tom and Matt take a fresh look at risk assessments. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the variables a compliance professional should consider when performing a risk assessment. We also say a few words about our experiences in the total solar eclipse of April 8. Risk assessments in compliance encompass the careful evaluation of both external and internal risks, necessitating a carefully planned process for overseeing various risk assessments within a company. This task, while intricate and often challenging, is a crucial aspect of compliance. Fox emphasizes the necessity to precisely define the scope of risk assessments, which could involve assessing external threats, internal controls, or both. He proposes that companies could benefit from the guidance of internal audits, external consultants, or professional service firms.  Similarly, Matt acknowledges its complex and challenging nature. Kelly underscores the importance of a disciplined, coherent approach to managing risk assessments across different parts of an organization, suggesting the possibility of involving assistance from third-party firms or internal audit teams. Both Fox and Kelly's perspectives underscore the importance of strategic planning, effective management, and possible external input in conducting risk assessments in compliance programs.  Key Highlights ·      Comprehensive Approach to Conducting Risk Assessments ·      Collaborative Risk Assessment for Compliance Optimization ·      Enhancing Compliance through Internal Control Testing ·      Strategic Integration of Compliance in Enterprise Risk ·      Celestial Event Viewing: The Influence of Clouds Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the variables a compliance professional should consider when performing a risk assessment. We also say a few words about our experiences in the total solar eclipse of April 8.

Risk assessments in compliance encompass the careful evaluation of both external and internal risks, necessitating a carefully planned process for overseeing various risk assessments within a company. This task, while intricate and often challenging, is a crucial aspect of compliance. Fox emphasizes the necessity to precisely define the scope of risk assessments, which could involve assessing external threats, internal controls, or both. He proposes that companies could benefit from the guidance of internal audits, external consultants, or professional service firms. 

Similarly, Matt acknowledges its complex and challenging nature. Kelly underscores the importance of a disciplined, coherent approach to managing risk assessments across different parts of an organization, suggesting the possibility of involving assistance from third-party firms or internal audit teams. Both Fox and Kelly's perspectives underscore the importance of strategic planning, effective management, and possible external input in conducting risk assessments in compliance programs.

 Key Highlights

·      Comprehensive Approach to Conducting Risk Assessments

·      Collaborative Risk Assessment for Compliance Optimization

·      Enhancing Compliance through Internal Control Testing

·      Strategic Integration of Compliance in Enterprise Risk

·      Celestial Event Viewing: The Influence of Clouds

Resources

Matt on Radical Compliance

 Tom  

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Facebook

YouTube

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]]> 1740 no Trafigura FCPA Enforcement Action The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC enforcement actions involving the Swiss trading company Trafigura. The topic at hand is the Trafigura FCPA enforcement action, a pivotal case that shines a light on the methods of the Justice Department in dealing with corporate misconduct. This case involves a Swiss company, Trafigura, that was culpable of bribery allegations in Brazil and faced scrutiny for its failure to disclose such schemes. Matt zeroes in on the absence of a compliance monitor in Trafigura’s case, highlighting the company’s extensive misconduct and questioning whether enhanced compliance reporting could adequately replace such a monitor. He advocates for reforming corporate culture through monitoring and expresses confusion over the DOJ’s inconsistent enforcement strategy. Fox notes Trafigura’s failure to self-disclose and cooperate and its history of recidivist behavior. He too questions the effectiveness of enhanced compliance reporting as a substitute for a compliance monitor and expresses concern over the Justice Department’s prioritization of fines over reform. Key Highlights: FCPA Enforcement Action: Importance of Compliance Enhancing Fraud Detection Through Forensic Collaboration Evolution in DOJ Compliance Enforcement Strategies Enforcement Discrepancies in Recidivist Oversight What does it all mean for the compliance professional? Resources: Matt on Radical Compliance Tom on the FCPA Compliance and Ethics Blog  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Apr 2024 04:00:00 -0000 Trafigura FCPA Enforcement Action full 365 Tom Fox Tom and Matt take a deep dive into the Trafigura FCPA Enforcement Action. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC enforcement actions involving the Swiss trading company Trafigura. The topic at hand is the Trafigura FCPA enforcement action, a pivotal case that shines a light on the methods of the Justice Department in dealing with corporate misconduct. This case involves a Swiss company, Trafigura, that was culpable of bribery allegations in Brazil and faced scrutiny for its failure to disclose such schemes. Matt zeroes in on the absence of a compliance monitor in Trafigura’s case, highlighting the company’s extensive misconduct and questioning whether enhanced compliance reporting could adequately replace such a monitor. He advocates for reforming corporate culture through monitoring and expresses confusion over the DOJ’s inconsistent enforcement strategy. Fox notes Trafigura’s failure to self-disclose and cooperate and its history of recidivist behavior. He too questions the effectiveness of enhanced compliance reporting as a substitute for a compliance monitor and expresses concern over the Justice Department’s prioritization of fines over reform. Key Highlights: FCPA Enforcement Action: Importance of Compliance Enhancing Fraud Detection Through Forensic Collaboration Evolution in DOJ Compliance Enforcement Strategies Enforcement Discrepancies in Recidivist Oversight What does it all mean for the compliance professional? Resources: Matt on Radical Compliance Tom on the FCPA Compliance and Ethics Blog  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance?

Look no further than Compliance into the Weeds!

In this episode, Tom and Matt take a deep dive into the recent SEC enforcement actions involving the Swiss trading company Trafigura.

The topic at hand is the Trafigura FCPA enforcement action, a pivotal case that shines a light on the methods of the Justice Department in dealing with corporate misconduct. This case involves a Swiss company, Trafigura, that was culpable of bribery allegations in Brazil and faced scrutiny for its failure to disclose such schemes.

Matt zeroes in on the absence of a compliance monitor in Trafigura’s case, highlighting the company’s extensive misconduct and questioning whether enhanced compliance reporting could adequately replace such a monitor. He advocates for reforming corporate culture through monitoring and expresses confusion over the DOJ’s inconsistent enforcement strategy.

Fox notes Trafigura’s failure to self-disclose and cooperate and its history of recidivist behavior. He too questions the effectiveness of enhanced compliance reporting as a substitute for a compliance monitor and expresses concern over the Justice Department’s prioritization of fines over reform.

Key Highlights:

  • FCPA Enforcement Action: Importance of Compliance
  • Enhancing Fraud Detection Through Forensic Collaboration
  • Evolution in DOJ Compliance Enforcement Strategies
  • Enforcement Discrepancies in Recidivist Oversight
  • What does it all mean for the compliance professional?


Resources:

Matt on Radical Compliance

Tom on the FCPA Compliance and Ethics Blog

 Tom  

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]]> 1541 no AI Washing and Compliance The award winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC enforcement actions involving AI washing and what it all may mean for the compliance professional. The evolving landscape of Artificial Intelligence (AI) has brought on a new paradigm of risk management in AI disclosures. This has caught the attention of regulatory bodies like the SEC, thereby necessitating a heightened focus on transparency and the implementation of comprehensive risk strategies. Tom advocates for the integration of AI risk reporting into the overall risk management strategy, emphasizing the need for governance and the right risk control measures. His views are shaped by his understanding of the potential repercussions of misleading AI disclosures and the significance of transparency in warding off enforcement actions from regulatory bodies. Matt echoes a similar sentiment, underscoring the importance of recognizing and managing AI risks. His perspective is influenced by the unique challenges that AI poses, calling for strategically tailored governance and risk management practices to navigate the complexities of AI technology. Key Highlights: AI Misrepresentation Enforcement by SEC Transparency in AI Risk Reporting for Compliance Integrating AI Risk into Overall Risk Management Collaborative Roles for Effective AI Governance A theory of unified risk management What does all this mean for compliance and the compliance professional? Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 Mar 2024 04:00:00 -0000 AI Washing and Compliance full 364 Tom Fox Tom and Matt look at AI washing and what it means for compliance. The award winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC enforcement actions involving AI washing and what it all may mean for the compliance professional. The evolving landscape of Artificial Intelligence (AI) has brought on a new paradigm of risk management in AI disclosures. This has caught the attention of regulatory bodies like the SEC, thereby necessitating a heightened focus on transparency and the implementation of comprehensive risk strategies. Tom advocates for the integration of AI risk reporting into the overall risk management strategy, emphasizing the need for governance and the right risk control measures. His views are shaped by his understanding of the potential repercussions of misleading AI disclosures and the significance of transparency in warding off enforcement actions from regulatory bodies. Matt echoes a similar sentiment, underscoring the importance of recognizing and managing AI risks. His perspective is influenced by the unique challenges that AI poses, calling for strategically tailored governance and risk management practices to navigate the complexities of AI technology. Key Highlights: AI Misrepresentation Enforcement by SEC Transparency in AI Risk Reporting for Compliance Integrating AI Risk into Overall Risk Management Collaborative Roles for Effective AI Governance A theory of unified risk management What does all this mean for compliance and the compliance professional? Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance?

Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC enforcement actions involving AI washing and what it all may mean for the compliance professional.

The evolving landscape of Artificial Intelligence (AI) has brought on a new paradigm of risk management in AI disclosures. This has caught the attention of regulatory bodies like the SEC, thereby necessitating a heightened focus on transparency and the implementation of comprehensive risk strategies.

Tom advocates for the integration of AI risk reporting into the overall risk management strategy, emphasizing the need for governance and the right risk control measures. His views are shaped by his understanding of the potential repercussions of misleading AI disclosures and the significance of transparency in warding off enforcement actions from regulatory bodies.

Matt echoes a similar sentiment, underscoring the importance of recognizing and managing AI risks. His perspective is influenced by the unique challenges that AI poses, calling for strategically tailored governance and risk management practices to navigate the complexities of AI technology.


Key Highlights:

  • AI Misrepresentation Enforcement by SEC
  • Transparency in AI Risk Reporting for Compliance
  • Integrating AI Risk into Overall Risk Management
  • Collaborative Roles for Effective AI Governance
  • A theory of unified risk management
  • What does all this mean for compliance and the compliance professional?


Resources

Matt on Radical Compliance

Tom  

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]]> 1505 SEC Climate Change Reporting and a Unified Risk Management Process The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC climate reporting rules and how this could lead to a unified risk management process. The topic of the recently proposed SEC climate change reporting rule, which requires companies to disclose their greenhouse gas emissions and climate-related risks, raises intriguing discussions across various sectors. This rule emphasizes the importance of transparency, necessitating companies to adapt their risk disclosure frameworks to encompass a range of risks, including cybersecurity, climate change, anticorruption, and financial reporting. Tom sees this rule as a much-anticipated development with significant implications for companies. He advocates for a comprehensive risk management strategy that aligns with the SEC’s push for holistic risk disclosures, taking into consideration the continuous relevance of climate change regulations at multiple levels. On the other hand, Matt acknowledges the significant challenges and changes that the rule has encountered, particularly litigation from both oil and gas interests and environmental groups. Despite the legal and political uncertainties, he underscores the importance of prioritizing climate change disclosures, given the existence of similar rules in California and Europe.   Key Highlights: Climate risk disclosure mandates for companies Enhancing transparency in risk management A theory of unified risk management What does all this mean for compliance and the compliance professional? Resources: Matt on Radical Compliance  Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Mar 2024 04:00:00 -0000 SEC Climate Change Reporting and a Unified Risk Management Process full 363 Tom Fox Matt and Tom consider a Unified Risk Management Process. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC climate reporting rules and how this could lead to a unified risk management process. The topic of the recently proposed SEC climate change reporting rule, which requires companies to disclose their greenhouse gas emissions and climate-related risks, raises intriguing discussions across various sectors. This rule emphasizes the importance of transparency, necessitating companies to adapt their risk disclosure frameworks to encompass a range of risks, including cybersecurity, climate change, anticorruption, and financial reporting. Tom sees this rule as a much-anticipated development with significant implications for companies. He advocates for a comprehensive risk management strategy that aligns with the SEC’s push for holistic risk disclosures, taking into consideration the continuous relevance of climate change regulations at multiple levels. On the other hand, Matt acknowledges the significant challenges and changes that the rule has encountered, particularly litigation from both oil and gas interests and environmental groups. Despite the legal and political uncertainties, he underscores the importance of prioritizing climate change disclosures, given the existence of similar rules in California and Europe.   Key Highlights: Climate risk disclosure mandates for companies Enhancing transparency in risk management A theory of unified risk management What does all this mean for compliance and the compliance professional? Resources: Matt on Radical Compliance  Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance?

Look no further than Compliance into the Weeds!

In this episode, Tom and Matt take a deep dive into the recent SEC climate reporting rules and how this could lead to a unified risk management process.

The topic of the recently proposed SEC climate change reporting rule, which requires companies to disclose their greenhouse gas emissions and climate-related risks, raises intriguing discussions across various sectors. This rule emphasizes the importance of transparency, necessitating companies to adapt their risk disclosure frameworks to encompass a range of risks, including cybersecurity, climate change, anticorruption, and financial reporting.

Tom sees this rule as a much-anticipated development with significant implications for companies. He advocates for a comprehensive risk management strategy that aligns with the SEC’s push for holistic risk disclosures, taking into consideration the continuous relevance of climate change regulations at multiple levels. On the other hand, Matt acknowledges the significant challenges and changes that the rule has encountered, particularly litigation from both oil and gas interests and environmental groups. Despite the legal and political uncertainties, he underscores the importance of prioritizing climate change disclosures, given the existence of similar rules in California and Europe.

 

Key Highlights:

  • Climate risk disclosure mandates for companies
  • Enhancing transparency in risk management
  • A theory of unified risk management
  • What does all this mean for compliance and the compliance professional?


Resources:

Matt on Radical Compliance

 Tom 

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]]> 1297 no Monaco on DOJ Whistleblower Initiative and AI The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into a recent speech by Deputy Attorney General Lisa Monaco on the DOJ’s creation of a whistleblower program and compliance oversight of AI. The Department of Justice Whistleblower Awards Program is a recent development that has prompted considerable discussion due to its possible implications and the potential range of awards. The program, which is designed to protect whistleblowers, raises a number of complex issues, particularly for compliance officers. According to Tom, the program is aligned with those from other regulatory bodies, like the SEC, and is not necessarily groundbreaking. He points out potential limitations in the range of awards and questions the efficiency of the review process. Matt views the program as a significant, yet familiar, development for compliance officers. He highlights that the program seems to follow an existing trend, rather than pioneering a new approach and points out the need for further clarification on the eligibility criteria and the procedure for issuing awards. Both Fox and Kelly, from their extensive experience in the field, emphasize the program’s potential benefits for whistleblowers seeking protection but concur that there are still many details to be clarified. Key Highlights: Navigating DOJ Whistleblower Program: Award Dynamics Navigating Compliance in DOJ’s Whistleblower Program Enhancing Criminal Penalties for AI-based Crimes Enforcement Challenges in AI Technology Governance Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Mar 2024 04:00:00 -0000 Monaco on DOJ Whistleblower Initiative and AI full 362 Tom Fox The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into a recent speech by Deputy Attorney General Lisa Monaco on the DOJ’s creation of a whistleblower program and compliance oversight of AI. The Department of Justice Whistleblower Awards Program is a recent development that has prompted considerable discussion due to its possible implications and the potential range of awards. The program, which is designed to protect whistleblowers, raises a number of complex issues, particularly for compliance officers. According to Tom, the program is aligned with those from other regulatory bodies, like the SEC, and is not necessarily groundbreaking. He points out potential limitations in the range of awards and questions the efficiency of the review process. Matt views the program as a significant, yet familiar, development for compliance officers. He highlights that the program seems to follow an existing trend, rather than pioneering a new approach and points out the need for further clarification on the eligibility criteria and the procedure for issuing awards. Both Fox and Kelly, from their extensive experience in the field, emphasize the program’s potential benefits for whistleblowers seeking protection but concur that there are still many details to be clarified. Key Highlights: Navigating DOJ Whistleblower Program: Award Dynamics Navigating Compliance in DOJ’s Whistleblower Program Enhancing Criminal Penalties for AI-based Crimes Enforcement Challenges in AI Technology Governance Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into a recent speech by Deputy Attorney General Lisa Monaco on the DOJ’s creation of a whistleblower program and compliance oversight of AI.

The Department of Justice Whistleblower Awards Program is a recent development that has prompted considerable discussion due to its possible implications and the potential range of awards. The program, which is designed to protect whistleblowers, raises a number of complex issues, particularly for compliance officers. According to Tom, the program is aligned with those from other regulatory bodies, like the SEC, and is not necessarily groundbreaking. He points out potential limitations in the range of awards and questions the efficiency of the review process.

Matt views the program as a significant, yet familiar, development for compliance officers. He highlights that the program seems to follow an existing trend, rather than pioneering a new approach and points out the need for further clarification on the eligibility criteria and the procedure for issuing awards. Both Fox and Kelly, from their extensive experience in the field, emphasize the program’s potential benefits for whistleblowers seeking protection but concur that there are still many details to be clarified.


Key Highlights:

  • Navigating DOJ Whistleblower Program: Award Dynamics
  • Navigating Compliance in DOJ’s Whistleblower Program
  • Enhancing Criminal Penalties for AI-based Crimes
  • Enforcement Challenges in AI Technology Governance


Resources

Matt on Radical Compliance

Tom  

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LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1669 no The Gunvor FCPA Enforcement Action The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recently released Gunvor FCPA Enforcement Action. The Gunvor FCPA case, a high-profile instance of bribery involving Ecuadorian government officials, serves as a stark reminder of the perils of corruption in international business and the critical need for stringent compliance measures. Tom emphasizes the importance of adherence to anti-corruption laws and regulations. He stresses the necessity for robust compliance programs and internal controls to prevent such violations, and the potential fallout of non-compliance, including reputational damage, financial penalties, and legal repercussions. Matt Kelly sees the Gunvor FCPA case as a significant example of the consequences companies face when engaging in corrupt practices. He would underscore the importance of strong compliance programs, ethical business practices, transparency, and accountability to prevent similar instances of bribery and corruption in the future. Check out the key lessons learned from this matter. Key Highlights: Bribery Scheme in Gunvor's Ecuador Dealings Ethical Practices and Regulatory Compliance Strengthening Gunvor's Bribery Scheme: FCPA Enforcement Consequences Proactive Transparency in Mitigating Legal Penalties Resources: Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Mar 2024 05:00:00 -0000 The Gunvor FCPA Enforcement Action full 361 Tom Fox Tom and Matt consider the Gunvor FCPA Enforcement Action. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recently released Gunvor FCPA Enforcement Action. The Gunvor FCPA case, a high-profile instance of bribery involving Ecuadorian government officials, serves as a stark reminder of the perils of corruption in international business and the critical need for stringent compliance measures. Tom emphasizes the importance of adherence to anti-corruption laws and regulations. He stresses the necessity for robust compliance programs and internal controls to prevent such violations, and the potential fallout of non-compliance, including reputational damage, financial penalties, and legal repercussions. Matt Kelly sees the Gunvor FCPA case as a significant example of the consequences companies face when engaging in corrupt practices. He would underscore the importance of strong compliance programs, ethical business practices, transparency, and accountability to prevent similar instances of bribery and corruption in the future. Check out the key lessons learned from this matter. Key Highlights: Bribery Scheme in Gunvor's Ecuador Dealings Ethical Practices and Regulatory Compliance Strengthening Gunvor's Bribery Scheme: FCPA Enforcement Consequences Proactive Transparency in Mitigating Legal Penalties Resources: Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recently released Gunvor FCPA Enforcement Action.

The Gunvor FCPA case, a high-profile instance of bribery involving Ecuadorian government officials, serves as a stark reminder of the perils of corruption in international business and the critical need for stringent compliance measures. Tom emphasizes the importance of adherence to anti-corruption laws and regulations. He stresses the necessity for robust compliance programs and internal controls to prevent such violations, and the potential fallout of non-compliance, including reputational damage, financial penalties, and legal repercussions.

Matt Kelly sees the Gunvor FCPA case as a significant example of the consequences companies face when engaging in corrupt practices. He would underscore the importance of strong compliance programs, ethical business practices, transparency, and accountability to prevent similar instances of bribery and corruption in the future. Check out the key lessons learned from this matter.


Key Highlights:

  • Bribery Scheme in Gunvor's Ecuador Dealings
  • Ethical Practices and Regulatory Compliance Strengthening
  • Gunvor's Bribery Scheme: FCPA Enforcement Consequences
  • Proactive Transparency in Mitigating Legal Penalties


Resources:

Matt on Radical Compliance

Tom  

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]]> 1557 no The ACFE 2024 Anti-Fraud Technology Benchmarking Report The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look at the recent ACFE publication of its 2024 Anti-Fraud Technology Benchmarking Report and what it means for compliance professionals. The ACFE 2024 Antifraud Technology Benchmarking report unveils an intriguing shift towards the use of AI in antifraud analytics, with a significant 83% of respondents planning to adopt generative AI in the coming years. However, the report also highlights a gap in current practices, with only a quarter of organizations utilizing analytics for corruption and bribery detection. Tom views this report as a crucial tool for understanding the evolving landscape of fraud detection. He emphasizes the importance of staying ahead of technological advancements and the potential risks of not having sophisticated tools for managing fraud investigations. Similarly, Matt underscores the report’s insights into the challenges faced by antifraud professionals. He stresses the importance of aligning analytical capabilities with manpower resources and the critical role of experienced professionals in managing complex issues like bribery and corruption. Both perspectives highlight the need for a strategic blend of technology and human expertise in the ever-evolving world of compliance and audit. Key Highlights: Generative AI Integration in Antifraud Analytics Generative AI Impact on Fraud Examination Trends AI’s Role in Fraud Detection and Compliance Detecting Financial Fraud Through Advanced Analytics Resources: Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Feb 2024 05:00:00 -0000 The ACFE 2024 Anti-Fraud Technology Benchmarking Report full 360 Tom Fox Tom and Matt go into the weeds into The ACFE 2024 Anti-Fraud Technology Benchmarking Report. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look at the recent ACFE publication of its 2024 Anti-Fraud Technology Benchmarking Report and what it means for compliance professionals. The ACFE 2024 Antifraud Technology Benchmarking report unveils an intriguing shift towards the use of AI in antifraud analytics, with a significant 83% of respondents planning to adopt generative AI in the coming years. However, the report also highlights a gap in current practices, with only a quarter of organizations utilizing analytics for corruption and bribery detection. Tom views this report as a crucial tool for understanding the evolving landscape of fraud detection. He emphasizes the importance of staying ahead of technological advancements and the potential risks of not having sophisticated tools for managing fraud investigations. Similarly, Matt underscores the report’s insights into the challenges faced by antifraud professionals. He stresses the importance of aligning analytical capabilities with manpower resources and the critical role of experienced professionals in managing complex issues like bribery and corruption. Both perspectives highlight the need for a strategic blend of technology and human expertise in the ever-evolving world of compliance and audit. Key Highlights: Generative AI Integration in Antifraud Analytics Generative AI Impact on Fraud Examination Trends AI’s Role in Fraud Detection and Compliance Detecting Financial Fraud Through Advanced Analytics Resources: Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look at the recent ACFE publication of its 2024 Anti-Fraud Technology Benchmarking Report and what it means for compliance professionals.

The ACFE 2024 Antifraud Technology Benchmarking report unveils an intriguing shift towards the use of AI in antifraud analytics, with a significant 83% of respondents planning to adopt generative AI in the coming years. However, the report also highlights a gap in current practices, with only a quarter of organizations utilizing analytics for corruption and bribery detection. Tom views this report as a crucial tool for understanding the evolving landscape of fraud detection. He emphasizes the importance of staying ahead of technological advancements and the potential risks of not having sophisticated tools for managing fraud investigations.

Similarly, Matt underscores the report’s insights into the challenges faced by antifraud professionals. He stresses the importance of aligning analytical capabilities with manpower resources and the critical role of experienced professionals in managing complex issues like bribery and corruption. Both perspectives highlight the need for a strategic blend of technology and human expertise in the ever-evolving world of compliance and audit.


Key Highlights:

  • Generative AI Integration in Antifraud Analytics
  • Generative AI Impact on Fraud Examination Trends
  • AI’s Role in Fraud Detection and Compliance
  • Detecting Financial Fraud Through Advanced Analytics


Resources:

Matt on Radical Compliance

Tom  

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YouTube

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Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1572 no Compliance and Internal Controls in the Trump Organization The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look at the Trump Organization Monitor and Independent Director of Compliance required in the trial court Order.  The topic of internal controls within the Trump Organization has recently come under scrutiny, with the need for improved financial practices and systems of accounting control becoming increasingly apparent. Tom views internal controls as the backbone of financial reporting and compliance. He points out the inconsistencies and errors in the Trump Organization's financial disclosures, emphasizing the need for accurate certifications and attestations about the organization's financial health. Similarly, Matt underscores the importance of consistent and accurate financial disclosures. He raises concerns about the lack of basic financial controls within the Trump Organization and sees the need for a significant overhaul of internal controls to ensure transparency, accuracy, and compliance with financial reporting standards. Both Fox and Kelly's perspectives are shaped by their extensive experience in the field of compliance and their understanding of the critical role internal controls play in maintaining financial integrity.  Key Highlights ·      Compliance Monitor's Oversight in Fraud Detection ·      Navigating Financial Compliance in the Trump Organization ·      Implementing Effective Accounting Control Systems at Trump ·      Enhancing Financial Integrity in the Trump Organization Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Feb 2024 05:00:00 -0000 Compliance and Internal Controls in the Trump Organization full 359 Tom Fox Tom and Matt look at Compliance and Internal Controls in the Trump Organization. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look at the Trump Organization Monitor and Independent Director of Compliance required in the trial court Order.  The topic of internal controls within the Trump Organization has recently come under scrutiny, with the need for improved financial practices and systems of accounting control becoming increasingly apparent. Tom views internal controls as the backbone of financial reporting and compliance. He points out the inconsistencies and errors in the Trump Organization's financial disclosures, emphasizing the need for accurate certifications and attestations about the organization's financial health. Similarly, Matt underscores the importance of consistent and accurate financial disclosures. He raises concerns about the lack of basic financial controls within the Trump Organization and sees the need for a significant overhaul of internal controls to ensure transparency, accuracy, and compliance with financial reporting standards. Both Fox and Kelly's perspectives are shaped by their extensive experience in the field of compliance and their understanding of the critical role internal controls play in maintaining financial integrity.  Key Highlights ·      Compliance Monitor's Oversight in Fraud Detection ·      Navigating Financial Compliance in the Trump Organization ·      Implementing Effective Accounting Control Systems at Trump ·      Enhancing Financial Integrity in the Trump Organization Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt look at the Trump Organization Monitor and Independent Director of Compliance required in the trial court Order. 

The topic of internal controls within the Trump Organization has recently come under scrutiny, with the need for improved financial practices and systems of accounting control becoming increasingly apparent. Tom views internal controls as the backbone of financial reporting and compliance. He points out the inconsistencies and errors in the Trump Organization's financial disclosures, emphasizing the need for accurate certifications and attestations about the organization's financial health. Similarly, Matt underscores the importance of consistent and accurate financial disclosures. He raises concerns about the lack of basic financial controls within the Trump Organization and sees the need for a significant overhaul of internal controls to ensure transparency, accuracy, and compliance with financial reporting standards. Both Fox and Kelly's perspectives are shaped by their extensive experience in the field of compliance and their understanding of the critical role internal controls play in maintaining financial integrity.

 Key Highlights

·      Compliance Monitor's Oversight in Fraud Detection

·      Navigating Financial Compliance in the Trump Organization

·      Implementing Effective Accounting Control Systems at Trump

·      Enhancing Financial Integrity in the Trump Organization


Resources

Matt on Radical Compliance

Tom  

Instagram

Facebook

YouTube

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]]> 1290 no Down The Rabbit Hole on SEC Enforcement Waivers The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt go down a rabbit hole regarding the SEC waiving penalties for messaging app violations. The Securities and Exchange Commission (SEC) has been making headlines for its crackdown on broker dealers who violate record-keeping rules by using off-channel messaging apps like WhatsApp or Snapchat. This has led to hefty fines, yet the SEC has been granting waivers to these same firms, allowing them to continue operating in the securities world. This paradoxical approach has raised eyebrows, including those of Tom Fox and Matt Kelly. Fox finds the SEC's actions both curious and concerning. He believes that if a waiver program exists, it should be publicly announced and the reasons for granting waivers should be transparent to ensure appropriate scrutiny. Kelly, on the other hand, expresses surprise and disappointment at the lack of transparency from the SEC, suggesting that the waiver program and its reasons should be made clear to the public. Find out more in this fascinating edition of Compliance into the Weeds. Key Highlights: SEC Sanctions for Off-Channel Messaging Violations SEC Enforcement and Waivers for Internal Violations Cracking down on Off Channel Communications The Need for Public Announcements in SEC Enforcement Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Feb 2024 05:00:00 -0000 Down The Rabbit Hole on SEC Enforcement Waivers full 358 Tom Fox Why is the SEC granting enforcement waivers for messaging apps violations? The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt go down a rabbit hole regarding the SEC waiving penalties for messaging app violations. The Securities and Exchange Commission (SEC) has been making headlines for its crackdown on broker dealers who violate record-keeping rules by using off-channel messaging apps like WhatsApp or Snapchat. This has led to hefty fines, yet the SEC has been granting waivers to these same firms, allowing them to continue operating in the securities world. This paradoxical approach has raised eyebrows, including those of Tom Fox and Matt Kelly. Fox finds the SEC's actions both curious and concerning. He believes that if a waiver program exists, it should be publicly announced and the reasons for granting waivers should be transparent to ensure appropriate scrutiny. Kelly, on the other hand, expresses surprise and disappointment at the lack of transparency from the SEC, suggesting that the waiver program and its reasons should be made clear to the public. Find out more in this fascinating edition of Compliance into the Weeds. Key Highlights: SEC Sanctions for Off-Channel Messaging Violations SEC Enforcement and Waivers for Internal Violations Cracking down on Off Channel Communications The Need for Public Announcements in SEC Enforcement Resources Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt go down a rabbit hole regarding the SEC waiving penalties for messaging app violations.

The Securities and Exchange Commission (SEC) has been making headlines for its crackdown on broker dealers who violate record-keeping rules by using off-channel messaging apps like WhatsApp or Snapchat. This has led to hefty fines, yet the SEC has been granting waivers to these same firms, allowing them to continue operating in the securities world. This paradoxical approach has raised eyebrows, including those of Tom Fox and Matt Kelly. Fox finds the SEC's actions both curious and concerning. He believes that if a waiver program exists, it should be publicly announced and the reasons for granting waivers should be transparent to ensure appropriate scrutiny. Kelly, on the other hand, expresses surprise and disappointment at the lack of transparency from the SEC, suggesting that the waiver program and its reasons should be made clear to the public. Find out more in this fascinating edition of Compliance into the Weeds.


Key Highlights:

  • SEC Sanctions for Off-Channel Messaging Violations
  • SEC Enforcement and Waivers for Internal Violations
  • Cracking down on Off Channel Communications
  • The Need for Public Announcements in SEC Enforcement


Resources

Matt on Radical Compliance

 Tom  

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YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1228 no To Monitor or Not to Monitor: What is even the Question? The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the seeming inconsistency in approaches to monitorships (or lack thereof) in two recent DOJ enforcement actions involving eBay and SAP.  The Department of Justice's (DOJ) seemingly inconsistent approach to corporate enforcement and compliance monitoring has been a topic of much debate and confusion. Or has it? This inconsistency is particularly evident in the assignment of compliance monitors and CCO certification, as seen in the contrasting cases of eBay and SAP. Does the DOJ have a contradictory approach? What are the criteria for assigning monitors? Are local U.S. Attorneys may be following their own agendas, leading to this inconsistency. Is there a lack of logic and effectiveness in the DOJ's policies. To delve deeper into this issue, join Tom Fox and Matt Kelly in this episode of the Compliance into the Weeds. Key Highlights ·      Effectiveness and Consistency of Compliance Monitors ·      Incentivizing self-disclosure and remediation in corporate enforcement ·      Inconsistent assignment of monitors based on misconduct ·      Inconsistent enforcement practices by U.S. Attorneys Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 Feb 2024 05:00:00 -0000 To Monitor or Not to Monitor: What is even the Question? full 357 Tom Fox Tom and Matt look at seemingly different enforcement results re: monitorships. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the seeming inconsistency in approaches to monitorships (or lack thereof) in two recent DOJ enforcement actions involving eBay and SAP.  The Department of Justice's (DOJ) seemingly inconsistent approach to corporate enforcement and compliance monitoring has been a topic of much debate and confusion. Or has it? This inconsistency is particularly evident in the assignment of compliance monitors and CCO certification, as seen in the contrasting cases of eBay and SAP. Does the DOJ have a contradictory approach? What are the criteria for assigning monitors? Are local U.S. Attorneys may be following their own agendas, leading to this inconsistency. Is there a lack of logic and effectiveness in the DOJ's policies. To delve deeper into this issue, join Tom Fox and Matt Kelly in this episode of the Compliance into the Weeds. Key Highlights ·      Effectiveness and Consistency of Compliance Monitors ·      Incentivizing self-disclosure and remediation in corporate enforcement ·      Inconsistent assignment of monitors based on misconduct ·      Inconsistent enforcement practices by U.S. Attorneys Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the seeming inconsistency in approaches to monitorships (or lack thereof) in two recent DOJ enforcement actions involving eBay and SAP. 

The Department of Justice's (DOJ) seemingly inconsistent approach to corporate enforcement and compliance monitoring has been a topic of much debate and confusion. Or has it? This inconsistency is particularly evident in the assignment of compliance monitors and CCO certification, as seen in the contrasting cases of eBay and SAP. Does the DOJ have a contradictory approach? What are the criteria for assigning monitors? Are local U.S. Attorneys may be following their own agendas, leading to this inconsistency. Is there a lack of logic and effectiveness in the DOJ's policies. To delve deeper into this issue, join Tom Fox and Matt Kelly in this episode of the Compliance into the Weeds.

Key Highlights

·      Effectiveness and Consistency of Compliance Monitors

·      Incentivizing self-disclosure and remediation in corporate enforcement

·      Inconsistent assignment of monitors based on misconduct

·      Inconsistent enforcement practices by U.S. Attorneys

Resources

Matt on Radical Compliance

Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1268 no Oscar Season and Internal Controls The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into a payments and internal controls miasma involving actors Tom Holland and Tom Hollander. The recent incident involving British actor Tom Hollander, who accidentally received a payment intended for Tom Holland due to a mix-up at their shared talent agency, has brought to light the critical importance of robust accounting controls for payments. Tom emphasizes the need for a second set of eyes to oversee payments and ensure they are going to the correct recipients. He suggests that smaller organizations can implement human review controls, while larger ones may need to rely on technology such as robotic process automation. Matt is highlighting the potential legal and regulatory consequences of sending payments to the wrong recipients. He stresses the need for organizations to demonstrate to regulators that errors are rare and accidental and that they have effective assurance processes in place. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of Compliance into the Weeds. Key Highlights: Payment Mix-up Highlights Importance of Internal Controls Error Prevention and Correction in Payments Mitigating Compliance Risks with Internal Controls Resources: Matt on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 31 Jan 2024 05:00:00 -0000 Oscar Season and Internal Controls full 356 Tom Fox Tom and Matt take a dive into Oscar season and internal controls. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into a payments and internal controls miasma involving actors Tom Holland and Tom Hollander. The recent incident involving British actor Tom Hollander, who accidentally received a payment intended for Tom Holland due to a mix-up at their shared talent agency, has brought to light the critical importance of robust accounting controls for payments. Tom emphasizes the need for a second set of eyes to oversee payments and ensure they are going to the correct recipients. He suggests that smaller organizations can implement human review controls, while larger ones may need to rely on technology such as robotic process automation. Matt is highlighting the potential legal and regulatory consequences of sending payments to the wrong recipients. He stresses the need for organizations to demonstrate to regulators that errors are rare and accidental and that they have effective assurance processes in place. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of Compliance into the Weeds. Key Highlights: Payment Mix-up Highlights Importance of Internal Controls Error Prevention and Correction in Payments Mitigating Compliance Risks with Internal Controls Resources: Matt on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into a payments and internal controls miasma involving actors Tom Holland and Tom Hollander.

The recent incident involving British actor Tom Hollander, who accidentally received a payment intended for Tom Holland due to a mix-up at their shared talent agency, has brought to light the critical importance of robust accounting controls for payments. Tom emphasizes the need for a second set of eyes to oversee payments and ensure they are going to the correct recipients. He suggests that smaller organizations can implement human review controls, while larger ones may need to rely on technology such as robotic process automation. Matt is highlighting the potential legal and regulatory consequences of sending payments to the wrong recipients. He stresses the need for organizations to demonstrate to regulators that errors are rare and accidental and that they have effective assurance processes in place. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of Compliance into the Weeds.


Key Highlights:

  • Payment Mix-up Highlights Importance of Internal Controls
  • Error Prevention and Correction in Payments
  • Mitigating Compliance Risks with Internal Controls


Resources:

Matt on Radical Compliance

Tom 

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YouTube

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LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1052 no Pre-Taliation is Illegal as to All The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC enforcement action for pre-taliation against JPMorgan and what it means for whistleblower programs going forward. The Securities and Exchange Commission (SEC) has been ramping up fines for companies found guilty of retaliation, as evidenced by the recent JP Morgan securities case, which resulted in an $18 million sanction. This development underscores the importance of compliance and the need for companies to protect individuals’ rights to report misconduct. Tom views this as a significant shift, expanding the range of individuals who may be affected by retaliation claims. He predicts a broader legal discussion and increased protection for those who bring claims related to misconduct. Matt emphasizes the need for companies to be proactive in preventing retaliation. He points out that enforcement has been increasing since 2016 and that companies should already be aware that they cannot restrict employees from reporting wrongdoing to the SEC. Join Tom Fox and Matt Kelly as they delve deeper into this topic on the Compliance into the Weeds podcast. Key Highlights: The underlying facts Expanding Retaliation Risk in Corporate Settings Retaliation Clauses and Whistleblower Protection CBRE’s Swift Remediation Efforts and SEC Settlement Resources: Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Jan 2024 05:00:00 -0000 Pre-Taliation is Illegal as to All full 355 Tom Fox Tom and Matt take up a game changing pre-taliation case. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC enforcement action for pre-taliation against JPMorgan and what it means for whistleblower programs going forward. The Securities and Exchange Commission (SEC) has been ramping up fines for companies found guilty of retaliation, as evidenced by the recent JP Morgan securities case, which resulted in an $18 million sanction. This development underscores the importance of compliance and the need for companies to protect individuals’ rights to report misconduct. Tom views this as a significant shift, expanding the range of individuals who may be affected by retaliation claims. He predicts a broader legal discussion and increased protection for those who bring claims related to misconduct. Matt emphasizes the need for companies to be proactive in preventing retaliation. He points out that enforcement has been increasing since 2016 and that companies should already be aware that they cannot restrict employees from reporting wrongdoing to the SEC. Join Tom Fox and Matt Kelly as they delve deeper into this topic on the Compliance into the Weeds podcast. Key Highlights: The underlying facts Expanding Retaliation Risk in Corporate Settings Retaliation Clauses and Whistleblower Protection CBRE’s Swift Remediation Efforts and SEC Settlement Resources: Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC enforcement action for pre-taliation against JPMorgan and what it means for whistleblower programs going forward.

The Securities and Exchange Commission (SEC) has been ramping up fines for companies found guilty of retaliation, as evidenced by the recent JP Morgan securities case, which resulted in an $18 million sanction. This development underscores the importance of compliance and the need for companies to protect individuals’ rights to report misconduct. Tom views this as a significant shift, expanding the range of individuals who may be affected by retaliation claims. He predicts a broader legal discussion and increased protection for those who bring claims related to misconduct. Matt emphasizes the need for companies to be proactive in preventing retaliation. He points out that enforcement has been increasing since 2016 and that companies should already be aware that they cannot restrict employees from reporting wrongdoing to the SEC. Join Tom Fox and Matt Kelly as they delve deeper into this topic on the Compliance into the Weeds podcast.


Key Highlights:

  • The underlying facts
  • Expanding Retaliation Risk in Corporate Settings
  • Retaliation Clauses and Whistleblower Protection
  • CBRE’s Swift Remediation Efforts and SEC Settlement


Resources:

Matt on Radical Compliance

 Tom  

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]]> 1127 no The SAP Foreign Corrupt Practices Act Enforcement Action The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the ERP software giant SAP.  The recent $220 million fine imposed on German software giant, SAP, for violations of the FCPA underscores the critical role of internal audits in maintaining corporate compliance. Despite having a comprehensive FCPA compliance program, SAP's lack of control over its subsidiaries led to bribery activities, a situation that Tom and Matt believe could have been prevented with a robust internal audit function. Fox emphasized the need for strong internal audits to identify and address issues within different parts of an organization. Similarly, Kelly, underscored the importance of internal audits in identifying and rectifying control lapses. To delve deeper into this topic and understand the implications of the SAP case, join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds.  Key Highlights ·      The bribery schemes and geographic scope ·      What is culture? ·      Third parties and corruption risks ·      The fine and penalty ·      The comeback ·      Lessons learned for the compliance professional Resources Matt on Radical Compliance Tom   Tom on the FCPA Compliance and Ethics Blog Instagram Facebook YouTube Twitter LinkedIn For more information on Ethico and a free White Paper on top compliance issues in 2024, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Jan 2024 05:00:00 -0000 The SAP Foreign Corrupt Practices Act Enforcement Action full 354 Tom Fox Tom and Matt take a deep dive into the The SAP Foreign Corrupt Practices Act Enforcement Action. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the ERP software giant SAP.  The recent $220 million fine imposed on German software giant, SAP, for violations of the FCPA underscores the critical role of internal audits in maintaining corporate compliance. Despite having a comprehensive FCPA compliance program, SAP's lack of control over its subsidiaries led to bribery activities, a situation that Tom and Matt believe could have been prevented with a robust internal audit function. Fox emphasized the need for strong internal audits to identify and address issues within different parts of an organization. Similarly, Kelly, underscored the importance of internal audits in identifying and rectifying control lapses. To delve deeper into this topic and understand the implications of the SAP case, join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds.  Key Highlights ·      The bribery schemes and geographic scope ·      What is culture? ·      Third parties and corruption risks ·      The fine and penalty ·      The comeback ·      Lessons learned for the compliance professional Resources Matt on Radical Compliance Tom   Tom on the FCPA Compliance and Ethics Blog Instagram Facebook YouTube Twitter LinkedIn For more information on Ethico and a free White Paper on top compliance issues in 2024, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the ERP software giant SAP. 

The recent $220 million fine imposed on German software giant, SAP, for violations of the FCPA underscores the critical role of internal audits in maintaining corporate compliance. Despite having a comprehensive FCPA compliance program, SAP's lack of control over its subsidiaries led to bribery activities, a situation that Tom and Matt believe could have been prevented with a robust internal audit function. Fox emphasized the need for strong internal audits to identify and address issues within different parts of an organization. Similarly, Kelly, underscored the importance of internal audits in identifying and rectifying control lapses. To delve deeper into this topic and understand the implications of the SAP case, join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds. 

Key Highlights

·      The bribery schemes and geographic scope

·      What is culture?

·      Third parties and corruption risks

·      The fine and penalty

·      The comeback

·      Lessons learned for the compliance professional

Resources

Matt on Radical Compliance

Tom  

Tom on the FCPA Compliance and Ethics Blog

Instagram

Facebook

YouTube

Twitter

LinkedIn


For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1659 no FTC and Rite-Aid: Compliance Issues with AI Facial Recognition The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent FTC enforcement action involving Rite-Aid and its inappropriate use of AI-generated facial recognition. The adoption of AI technologies, as demonstrated by the Rite Aid case, underscores the critical need for robust compliance oversight. This case, involving the use of AI-driven facial recognition technology, resulted in compliance risks and a high rate of false positives, highlighting the potential pitfalls of AI technologies when not properly managed. Tom emphasized the importance of a comprehensive process to assess, manage, and monitor the risks associated with new technologies. He believes that collaboration among different stakeholders is key to understanding and mitigating potential risks. Matt stressed the need for careful consideration of how new technologies will impact business processes and the importance of correct governance from both a technical and human perspective. Join Tom Fox and Matt Kelly in this episode of the Compliance into the Weeds podcast as they delve deeper into the importance of robust governance in adopting AI technologies. Key Highlights: The Impact of AI Facial Recognition Technology Concerns of AI Facial Recognition and Racial Profiling Issues with AI Facial Recognition Training Collaborative Risk Management for AI Implementation Resources: Matt Kelly on LinkedIn Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Jan 2024 05:00:00 -0000 FTC and Rite-Aid: Compliance Issues with AI Facial Recognition full 353 Tom Fox Tom and Matt look at AI facial recognition from the compliance perspective. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent FTC enforcement action involving Rite-Aid and its inappropriate use of AI-generated facial recognition. The adoption of AI technologies, as demonstrated by the Rite Aid case, underscores the critical need for robust compliance oversight. This case, involving the use of AI-driven facial recognition technology, resulted in compliance risks and a high rate of false positives, highlighting the potential pitfalls of AI technologies when not properly managed. Tom emphasized the importance of a comprehensive process to assess, manage, and monitor the risks associated with new technologies. He believes that collaboration among different stakeholders is key to understanding and mitigating potential risks. Matt stressed the need for careful consideration of how new technologies will impact business processes and the importance of correct governance from both a technical and human perspective. Join Tom Fox and Matt Kelly in this episode of the Compliance into the Weeds podcast as they delve deeper into the importance of robust governance in adopting AI technologies. Key Highlights: The Impact of AI Facial Recognition Technology Concerns of AI Facial Recognition and Racial Profiling Issues with AI Facial Recognition Training Collaborative Risk Management for AI Implementation Resources: Matt Kelly on LinkedIn Matt on Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent FTC enforcement action involving Rite-Aid and its inappropriate use of AI-generated facial recognition.

The adoption of AI technologies, as demonstrated by the Rite Aid case, underscores the critical need for robust compliance oversight. This case, involving the use of AI-driven facial recognition technology, resulted in compliance risks and a high rate of false positives, highlighting the potential pitfalls of AI technologies when not properly managed. Tom emphasized the importance of a comprehensive process to assess, manage, and monitor the risks associated with new technologies. He believes that collaboration among different stakeholders is key to understanding and mitigating potential risks. Matt stressed the need for careful consideration of how new technologies will impact business processes and the importance of correct governance from both a technical and human perspective. Join Tom Fox and Matt Kelly in this episode of the Compliance into the Weeds podcast as they delve deeper into the importance of robust governance in adopting AI technologies.


Key Highlights:


  • The Impact of AI Facial Recognition Technology

  • Concerns of AI Facial Recognition and Racial Profiling

  • Issues with AI Facial Recognition Training

  • Collaborative Risk Management for AI Implementation


Resources:

Matt Kelly on LinkedIn

Matt on Radical Compliance

 Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1412 no Key Compliance Issues for 2024 The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into issues Matt has on his radar for compliance professionals in 2024. Matt Kelly is well known for zigging when everyone else is zagging. At the start of each year, he publishes a column that looks at key issues for compliance professionals in the year ahead. This podcast takes a deep dive into these issues. The rapidly evolving landscape of AI, cybersecurity, and governance is increasingly shaped by regulatory and compliance trends. In this context, industry experts Tom Fox and Matt Kelly offer insightful perspectives. We consider governmental oversight of AI, with more specific AI regulations in 2024, while also highlighting the potential of AI integration into compliance products and platforms. We also look at issues with the SEC, PCAOB, and DOJ.  Join Tom Fox and Matt Kelly as they delve deeper into these topics in this episode of the award-winning Compliance into the Weeds. Key Highlights: FEPA and its enforcement NOCLAR and the PCAOB SEC v. Solar Winds and its CISO AI-Regulation and Business Use SEC right to disgorgement  Resources: Matt Kelly on LinkedIn Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Jan 2024 05:00:00 -0000 Key Compliance Issues for 2024 full 352 Tom Fox Tom and Matt consider some key compliance issues for 2024. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into issues Matt has on his radar for compliance professionals in 2024. Matt Kelly is well known for zigging when everyone else is zagging. At the start of each year, he publishes a column that looks at key issues for compliance professionals in the year ahead. This podcast takes a deep dive into these issues. The rapidly evolving landscape of AI, cybersecurity, and governance is increasingly shaped by regulatory and compliance trends. In this context, industry experts Tom Fox and Matt Kelly offer insightful perspectives. We consider governmental oversight of AI, with more specific AI regulations in 2024, while also highlighting the potential of AI integration into compliance products and platforms. We also look at issues with the SEC, PCAOB, and DOJ.  Join Tom Fox and Matt Kelly as they delve deeper into these topics in this episode of the award-winning Compliance into the Weeds. Key Highlights: FEPA and its enforcement NOCLAR and the PCAOB SEC v. Solar Winds and its CISO AI-Regulation and Business Use SEC right to disgorgement  Resources: Matt Kelly on LinkedIn Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into issues Matt has on his radar for compliance professionals in 2024.

Matt Kelly is well known for zigging when everyone else is zagging. At the start of each year, he publishes a column that looks at key issues for compliance professionals in the year ahead. This podcast takes a deep dive into these issues. The rapidly evolving landscape of AI, cybersecurity, and governance is increasingly shaped by regulatory and compliance trends. In this context, industry experts Tom Fox and Matt Kelly offer insightful perspectives. We consider governmental oversight of AI, with more specific AI regulations in 2024, while also highlighting the potential of AI integration into compliance products and platforms. We also look at issues with the SEC, PCAOB, and DOJ.  Join Tom Fox and Matt Kelly as they delve deeper into these topics in this episode of the award-winning Compliance into the Weeds.


Key Highlights:

  • FEPA and its enforcement
  • NOCLAR and the PCAOB
  • SEC v. Solar Winds and its CISO
  • AI-Regulation and Business Use
  • SEC right to disgorgement 


Resources:

Matt Kelly on LinkedIn

Matt on Radical Compliance

Tom  

Instagram

Facebook

YouTube

Twitter

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]]> 2267 no Congress Fills a Gap - FEPA The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the Foreign Extortion Prevention Act (FEPA), a groundbreaking law that aims to combat corruption by criminalizing foreign government officials who solicit or accept bribes from US entities. This law complements the Foreign Corrupt Practices Act (FCPA), which penalizes companies for offering bribes, and introduces new challenges and implications for anti-corruption measures. Tom views FEPA as a long-overdue measure that fills a gap in anti-corruption efforts. He agrees with Matt emphasizes that FEPA addresses a long-standing concern of anti-corruption advocates. Both Fox and Kelly anticipate further guidance from the Department of Justice on how this new law will interact with existing measures under the FCPA. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.  Key Highlights: Combating Foreign Corruption: FIFA's Powerful Impact Implications of FIFA Cooperation on FCPA Prosecution Extradition Challenges in FIFA Corruption Cases The Impact of the Name and Shame List Resources: Matt Kelly on LinkedIn Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Dec 2023 05:00:00 -0000 Congress Fills a Gap - FEPA full 351 Tom Fox Tom and Matt look at FEPA. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the Foreign Extortion Prevention Act (FEPA), a groundbreaking law that aims to combat corruption by criminalizing foreign government officials who solicit or accept bribes from US entities. This law complements the Foreign Corrupt Practices Act (FCPA), which penalizes companies for offering bribes, and introduces new challenges and implications for anti-corruption measures. Tom views FEPA as a long-overdue measure that fills a gap in anti-corruption efforts. He agrees with Matt emphasizes that FEPA addresses a long-standing concern of anti-corruption advocates. Both Fox and Kelly anticipate further guidance from the Department of Justice on how this new law will interact with existing measures under the FCPA. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.  Key Highlights: Combating Foreign Corruption: FIFA's Powerful Impact Implications of FIFA Cooperation on FCPA Prosecution Extradition Challenges in FIFA Corruption Cases The Impact of the Name and Shame List Resources: Matt Kelly on LinkedIn Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the Foreign Extortion Prevention Act (FEPA), a groundbreaking law that aims to combat corruption by criminalizing foreign government officials who solicit or accept bribes from US entities.

This law complements the Foreign Corrupt Practices Act (FCPA), which penalizes companies for offering bribes, and introduces new challenges and implications for anti-corruption measures. Tom views FEPA as a long-overdue measure that fills a gap in anti-corruption efforts. He agrees with Matt emphasizes that FEPA addresses a long-standing concern of anti-corruption advocates. Both Fox and Kelly anticipate further guidance from the Department of Justice on how this new law will interact with existing measures under the FCPA. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.

 Key Highlights:

  • Combating Foreign Corruption: FIFA's Powerful Impact
  • Implications of FIFA Cooperation on FCPA Prosecution
  • Extradition Challenges in FIFA Corruption Cases
  • The Impact of the Name and Shame List


Resources:

Matt Kelly on LinkedIn

Tom

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]]> 1390 no The Importance of Empathy and Moral Clarity in Campus Anti-Discrimination The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into data analytics and highlight the Bank Of America CFPB enforcement action for failures in a data analytics program. The recent congressional testimonies of university presidents from Harvard, MIT, and the University of Pennsylvania have ignited a heated debate over their handling of anti-Semitism and discrimination on campuses. Tom criticizes the presidents for their lack of moral clarity and empathy in their responses to questions about anti-Semitism on campus. He emphasizes the crucial role of chief compliance officers in guiding ethical leadership and decision-making in such sensitive situations. Matt echoes Fox's sentiments, stressing the importance of empathy, moral clarity, and ethical values in addressing and preventing campus discrimination. He criticizes the presidents for their inability to effectively express these qualities in their responses to questions about discrimination policies. Join Tom Fox and Matt Kelly as they delve deeper into this issue on this episode of Compliance into the Weeds. Key Highlights Fallout from Private College Testimony on Anti-Semitism Navigating Multiple Stakeholders in Universities The Power of Wealthy Donors and Alumni The Role of Empathy in Ethical Leadership Resources: Matt Kelly on LinkedIn Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Dec 2023 05:00:00 -0000 The Importance of Empathy and Moral Clarity in Campus Anti-Discrimination full 350 Tom Fox The Importance of Empathy and Moral Clarity in Campus Anti-Discrimination The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into data analytics and highlight the Bank Of America CFPB enforcement action for failures in a data analytics program. The recent congressional testimonies of university presidents from Harvard, MIT, and the University of Pennsylvania have ignited a heated debate over their handling of anti-Semitism and discrimination on campuses. Tom criticizes the presidents for their lack of moral clarity and empathy in their responses to questions about anti-Semitism on campus. He emphasizes the crucial role of chief compliance officers in guiding ethical leadership and decision-making in such sensitive situations. Matt echoes Fox's sentiments, stressing the importance of empathy, moral clarity, and ethical values in addressing and preventing campus discrimination. He criticizes the presidents for their inability to effectively express these qualities in their responses to questions about discrimination policies. Join Tom Fox and Matt Kelly as they delve deeper into this issue on this episode of Compliance into the Weeds. Key Highlights Fallout from Private College Testimony on Anti-Semitism Navigating Multiple Stakeholders in Universities The Power of Wealthy Donors and Alumni The Role of Empathy in Ethical Leadership Resources: Matt Kelly on LinkedIn Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into data analytics and highlight the Bank Of America CFPB enforcement action for failures in a data analytics program.

The recent congressional testimonies of university presidents from Harvard, MIT, and the University of Pennsylvania have ignited a heated debate over their handling of anti-Semitism and discrimination on campuses. Tom criticizes the presidents for their lack of moral clarity and empathy in their responses to questions about anti-Semitism on campus. He emphasizes the crucial role of chief compliance officers in guiding ethical leadership and decision-making in such sensitive situations. Matt echoes Fox's sentiments, stressing the importance of empathy, moral clarity, and ethical values in addressing and preventing campus discrimination. He criticizes the presidents for their inability to effectively express these qualities in their responses to questions about discrimination policies. Join Tom Fox and Matt Kelly as they delve deeper into this issue on this episode of Compliance into the Weeds.

Key Highlights

  • Fallout from Private College Testimony on Anti-Semitism
  • Navigating Multiple Stakeholders in Universities
  • The Power of Wealthy Donors and Alumni
  • The Role of Empathy in Ethical Leadership


Resources:

Matt Kelly on LinkedIn

Tom 

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]]> 1419 no Data Analytics, BoA and DOJ Pronouncements The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into data analytics and highlight the Bank Of America CFPB enforcement action for failures in a data analytics program. Data analytics is a powerful tool in the realm of compliance and risk management, providing invaluable insights that can help organizations identify potential risks and assess the effectiveness of their compliance programs. Tom emphasizes the importance of continuous monitoring using data analytics, citing a case where Bank of America was fined $12 million due to poor use of data analytics. He advocates for the use of analytics algorithms as ongoing monitoring tools and encourages business units to take an active role in managing their risks. Matt underscores the significance of data analytics in identifying and managing compliance risks. He echoes Fox's sentiments on the need for continuous monitoring and the involvement of business units in risk management. They also note that both the DOJ and SEC are ramping up their focus on data analytics for corporate compliance, setting higher expectations, especially for larger corporations. This shift is not only transforming the landscape of corporate compliance but also reshaping the way companies approach self-disclosure of misconduct. Join Fox and Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into the implications of the DOJ and SEC's increasing focus on data analytics for corporate compliance. Key Highlights The Importance of Continuous Data Analytics Bank of America's Compliance Risk Management Effective Monitoring and Surveillance in Financial Services DOJ's Expectations for Corporate Data Analytics Uncovering Fraud Through Data Analytics Resources: Matt’s blog posts in Radical Compliance A $12M Lesson on Data Analytics Some Vague Hints on Analytics, FCPA   Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Dec 2023 05:00:00 -0000 Data Analytics, BoA and DOJ Pronouncements full 349 Tom Fox Tom and Matt take a deep dive into data analytics and the BoA CFPB action. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into data analytics and highlight the Bank Of America CFPB enforcement action for failures in a data analytics program. Data analytics is a powerful tool in the realm of compliance and risk management, providing invaluable insights that can help organizations identify potential risks and assess the effectiveness of their compliance programs. Tom emphasizes the importance of continuous monitoring using data analytics, citing a case where Bank of America was fined $12 million due to poor use of data analytics. He advocates for the use of analytics algorithms as ongoing monitoring tools and encourages business units to take an active role in managing their risks. Matt underscores the significance of data analytics in identifying and managing compliance risks. He echoes Fox's sentiments on the need for continuous monitoring and the involvement of business units in risk management. They also note that both the DOJ and SEC are ramping up their focus on data analytics for corporate compliance, setting higher expectations, especially for larger corporations. This shift is not only transforming the landscape of corporate compliance but also reshaping the way companies approach self-disclosure of misconduct. Join Fox and Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into the implications of the DOJ and SEC's increasing focus on data analytics for corporate compliance. Key Highlights The Importance of Continuous Data Analytics Bank of America's Compliance Risk Management Effective Monitoring and Surveillance in Financial Services DOJ's Expectations for Corporate Data Analytics Uncovering Fraud Through Data Analytics Resources: Matt’s blog posts in Radical Compliance A $12M Lesson on Data Analytics Some Vague Hints on Analytics, FCPA   Tom Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into data analytics and highlight the Bank Of America CFPB enforcement action for failures in a data analytics program.

Data analytics is a powerful tool in the realm of compliance and risk management, providing invaluable insights that can help organizations identify potential risks and assess the effectiveness of their compliance programs. Tom emphasizes the importance of continuous monitoring using data analytics, citing a case where Bank of America was fined $12 million due to poor use of data analytics. He advocates for the use of analytics algorithms as ongoing monitoring tools and encourages business units to take an active role in managing their risks. Matt underscores the significance of data analytics in identifying and managing compliance risks. He echoes Fox's sentiments on the need for continuous monitoring and the involvement of business units in risk management.

They also note that both the DOJ and SEC are ramping up their focus on data analytics for corporate compliance, setting higher expectations, especially for larger corporations. This shift is not only transforming the landscape of corporate compliance but also reshaping the way companies approach self-disclosure of misconduct. Join Fox and Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into the implications of the DOJ and SEC's increasing focus on data analytics for corporate compliance.

Key Highlights

  • The Importance of Continuous Data Analytics
  • Bank of America's Compliance Risk Management
  • Effective Monitoring and Surveillance in Financial Services
  • DOJ's Expectations for Corporate Data Analytics
  • Uncovering Fraud Through Data Analytics


Resources:

Matt’s blog posts in Radical Compliance

A $12M Lesson on Data Analytics

Some Vague Hints on Analytics, FCPA 

 Tom

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]]> 1489 no Binance Pays $4+ Billion for Criminal Acts The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the Binance enforcement action brought by the DOJ, OFAC, FinCEN, and the CFTC. In a landmark case that has sent shockwaves through the cryptocurrency industry, Binance, the world's largest cryptocurrency trading platform, has been slapped with a staggering $4.3 billion fine for intentionally violating anti-money laundering laws and other financial regulations. Tom views this as a significant turning point, marking the end of the libertarian experiment around cryptocurrency and alternative financial systems. He believes that the hefty penalties imposed on Binance, along with other smaller enforcement actions in the crypto world, are a clear message from regulators that the crypto sector must comply with US laws and regulations. Matt echoes Fox's sentiments, emphasizing that the enforcement actions against Binance and other cryptocurrency ventures signify the end of the libertarian experiment around cryptocurrency. He underscores the deliberate and intentional nature of Binance's violations, stating that they knowingly deceived and evaded compliance regulations. Join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into this case and its implications for the cryptocurrency industry.  Key Highlights Binance's $4.3 Billion AML Violation Deceptive Evasion of Regulations in Cryptocurrency Extensive Monitorship to Address Compliance Deficiencies Binance's Non-Compliance Leads to Legal Consequences Personal Liability of the CCO End of Crypto?  Resources: Matt’s blog post in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Nov 2023 05:00:00 -0000 Binance Pays $4+ Billion for Criminal Acts full 348 Tom Fox Tom and Matt take a deep dive into the Binance $4bn+ enforcement action. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the Binance enforcement action brought by the DOJ, OFAC, FinCEN, and the CFTC. In a landmark case that has sent shockwaves through the cryptocurrency industry, Binance, the world's largest cryptocurrency trading platform, has been slapped with a staggering $4.3 billion fine for intentionally violating anti-money laundering laws and other financial regulations. Tom views this as a significant turning point, marking the end of the libertarian experiment around cryptocurrency and alternative financial systems. He believes that the hefty penalties imposed on Binance, along with other smaller enforcement actions in the crypto world, are a clear message from regulators that the crypto sector must comply with US laws and regulations. Matt echoes Fox's sentiments, emphasizing that the enforcement actions against Binance and other cryptocurrency ventures signify the end of the libertarian experiment around cryptocurrency. He underscores the deliberate and intentional nature of Binance's violations, stating that they knowingly deceived and evaded compliance regulations. Join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into this case and its implications for the cryptocurrency industry.  Key Highlights Binance's $4.3 Billion AML Violation Deceptive Evasion of Regulations in Cryptocurrency Extensive Monitorship to Address Compliance Deficiencies Binance's Non-Compliance Leads to Legal Consequences Personal Liability of the CCO End of Crypto?  Resources: Matt’s blog post in Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the Binance enforcement action brought by the DOJ, OFAC, FinCEN, and the CFTC.

In a landmark case that has sent shockwaves through the cryptocurrency industry, Binance, the world's largest cryptocurrency trading platform, has been slapped with a staggering $4.3 billion fine for intentionally violating anti-money laundering laws and other financial regulations. Tom views this as a significant turning point, marking the end of the libertarian experiment around cryptocurrency and alternative financial systems. He believes that the hefty penalties imposed on Binance, along with other smaller enforcement actions in the crypto world, are a clear message from regulators that the crypto sector must comply with US laws and regulations.

Matt echoes Fox's sentiments, emphasizing that the enforcement actions against Binance and other cryptocurrency ventures signify the end of the libertarian experiment around cryptocurrency. He underscores the deliberate and intentional nature of Binance's violations, stating that they knowingly deceived and evaded compliance regulations. Join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into this case and its implications for the cryptocurrency industry.

 Key Highlights

  • Binance's $4.3 Billion AML Violation
  • Deceptive Evasion of Regulations in Cryptocurrency
  • Extensive Monitorship to Address Compliance Deficiencies
  • Binance's Non-Compliance Leads to Legal Consequences
  • Personal Liability of the CCO
  • End of Crypto?

 Resources:

Matt’s blog post in Radical Compliance


Tom  

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]]> 1437 no OIG Says CCO Should be Independent The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent OIG guidance for healthcare compliance professionals and healthcare compliance programs which notes that CCOs should be independent from the General Counsel’s Office. The Office of Inspector General (OIG) has recently released guidelines that underscore the importance of independence for compliance officers in the healthcare sector. These guidelines, seen as a significant development in the field, stipulate that compliance should be separate from legal and finance departments, and outline the responsibilities of healthcare compliance officers. Tom views this as a clear call for compliance officers to be independent and report directly to the CEO and the board. He suggests that this trend towards independence may extend beyond healthcare. Matt echoes this sentiment, highlighting the OIG's strong endorsement of the independence of compliance officers. He believes this aligns with the emphasis on independence and autonomy that leading voices in the regulatory world have been advocating for. Join Tom Fox and Matt Kelly as they delve deeper into this topic in this episode of the Compliance into the Weeds podcast.  Key Highlights: The Importance of CCO Independence in Compliance Programs The role of a healthcare CCO Do you need a Law Degree to be a CCO in Healthcare Compliance The Growing Significance of CCO Independence Resources: Matt’s blog post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Nov 2023 08:42:00 -0000 OIG Says CCO Should be Independent full 347 Tom Fox Tom and Matt look at the new OIG compliance program guidance. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent OIG guidance for healthcare compliance professionals and healthcare compliance programs which notes that CCOs should be independent from the General Counsel’s Office. The Office of Inspector General (OIG) has recently released guidelines that underscore the importance of independence for compliance officers in the healthcare sector. These guidelines, seen as a significant development in the field, stipulate that compliance should be separate from legal and finance departments, and outline the responsibilities of healthcare compliance officers. Tom views this as a clear call for compliance officers to be independent and report directly to the CEO and the board. He suggests that this trend towards independence may extend beyond healthcare. Matt echoes this sentiment, highlighting the OIG's strong endorsement of the independence of compliance officers. He believes this aligns with the emphasis on independence and autonomy that leading voices in the regulatory world have been advocating for. Join Tom Fox and Matt Kelly as they delve deeper into this topic in this episode of the Compliance into the Weeds podcast.  Key Highlights: The Importance of CCO Independence in Compliance Programs The role of a healthcare CCO Do you need a Law Degree to be a CCO in Healthcare Compliance The Growing Significance of CCO Independence Resources: Matt’s blog post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent OIG guidance for healthcare compliance professionals and healthcare compliance programs which notes that CCOs should be independent from the General Counsel’s Office.

The Office of Inspector General (OIG) has recently released guidelines that underscore the importance of independence for compliance officers in the healthcare sector. These guidelines, seen as a significant development in the field, stipulate that compliance should be separate from legal and finance departments, and outline the responsibilities of healthcare compliance officers.

Tom views this as a clear call for compliance officers to be independent and report directly to the CEO and the board. He suggests that this trend towards independence may extend beyond healthcare. Matt echoes this sentiment, highlighting the OIG's strong endorsement of the independence of compliance officers. He believes this aligns with the emphasis on independence and autonomy that leading voices in the regulatory world have been advocating for. Join Tom Fox and Matt Kelly as they delve deeper into this topic in this episode of the Compliance into the Weeds podcast. 

Key Highlights:

  • The Importance of CCO Independence in Compliance Programs
  • The role of a healthcare CCO
  • Do you need a Law Degree to be a CCO in Healthcare Compliance
  • The Growing Significance of CCO Independence

Resources:

Matt’s blog post in Radical Compliance

Tom 

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]]> 1187 no Remediation During an Enforcement Action The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the issue of how and whether you should remediate during an enforcement action. The importance of early and continuous remediation of compliance issues cannot be overstated. It is a critical aspect of maintaining a healthy relationship with regulators and ensuring effective strategies are in place to address any uncovered issues. Tom firmly believes in the necessity of initiating the remediation process as early as possible, even during the investigation phase. He emphasizes the importance of regular communication with regulators and the potential risks of delaying remediation. Matt echoes Fox's sentiments. He highlights the confidence that early remediation brings to compliance officers and the increased likelihood of successful resolution. Join Tom Fox and Matt Kelly as they delve deeper into this topic in this episode of the Compliance into the Weeds podcast.  Key Highlights: Proactive Remediation for Effective Compliance Management Navigating Personnel Matters During Remediation Logical and Consistent Employee Discipline Compliance Remediation Strategies for Confident Compliance Officers  Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Nov 2023 05:00:00 -0000 Remediation During an Enforcement Action full Tom Fox Tom and Matt tackle the question of how to remediate during an enforcement action. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the issue of how and whether you should remediate during an enforcement action. The importance of early and continuous remediation of compliance issues cannot be overstated. It is a critical aspect of maintaining a healthy relationship with regulators and ensuring effective strategies are in place to address any uncovered issues. Tom firmly believes in the necessity of initiating the remediation process as early as possible, even during the investigation phase. He emphasizes the importance of regular communication with regulators and the potential risks of delaying remediation. Matt echoes Fox's sentiments. He highlights the confidence that early remediation brings to compliance officers and the increased likelihood of successful resolution. Join Tom Fox and Matt Kelly as they delve deeper into this topic in this episode of the Compliance into the Weeds podcast.  Key Highlights: Proactive Remediation for Effective Compliance Management Navigating Personnel Matters During Remediation Logical and Consistent Employee Discipline Compliance Remediation Strategies for Confident Compliance Officers  Resources Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the issue of how and whether you should remediate during an enforcement action.

The importance of early and continuous remediation of compliance issues cannot be overstated. It is a critical aspect of maintaining a healthy relationship with regulators and ensuring effective strategies are in place to address any uncovered issues. Tom firmly believes in the necessity of initiating the remediation process as early as possible, even during the investigation phase. He emphasizes the importance of regular communication with regulators and the potential risks of delaying remediation.

Matt echoes Fox's sentiments. He highlights the confidence that early remediation brings to compliance officers and the increased likelihood of successful resolution. Join Tom Fox and Matt Kelly as they delve deeper into this topic in this episode of the Compliance into the Weeds podcast.


 Key Highlights:

  • Proactive Remediation for Effective Compliance Management
  • Navigating Personnel Matters During Remediation
  • Logical and Consistent Employee Discipline Compliance
  • Remediation Strategies for Confident Compliance Officers


 Resources

Matt on Radical Compliance

Tom  

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LinkedIn

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]]> 1282 SEC Sues Solar Winds and CISO The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more thoroughly, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC Civil Complaint against Solar Winds and its CISO, Timothy Brown, for undisclosed failures in the company’s cybersecurity compliance program disclosures prior to, during, and after the infamous Solar Winds data hack. The recent SEC lawsuit against SolarWinds Corp and its CISO, Tim Brown, following the 2020 data breach has sparked a critical conversation about executive liability in cybersecurity disclosures. Matt views this lawsuit as a significant development that raises essential questions about the personal liability of senior executives for inaccurate or misleading disclosures about cybersecurity risks. He emphasizes the potential implications this case could have for other executives in charge of trouble, such as compliance officers. Tom underscores the concerns regarding the accuracy and transparency of SolarWinds' cybersecurity disclosures. He highlights the evidence of a culture of deception within the company and the need to hold executives accountable for inaccurate disclosures. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.  Key Highlights: Liability of Senior Executives in Cybersecurity SolarWinds' Orion Software: Russian Government Cyberattack Personal Liability for Misleading Cybersecurity Disclosures Implementing Relevant Controls for Cybersecurity  Resources: Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Nov 2023 04:00:00 -0000 SEC Sues Solar Winds and CISO full 346 Tom Fox Tom and Matt take a deep dive into the SEC suit against Solar Winds and Tim Brown for false disclosures. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more thoroughly, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC Civil Complaint against Solar Winds and its CISO, Timothy Brown, for undisclosed failures in the company’s cybersecurity compliance program disclosures prior to, during, and after the infamous Solar Winds data hack. The recent SEC lawsuit against SolarWinds Corp and its CISO, Tim Brown, following the 2020 data breach has sparked a critical conversation about executive liability in cybersecurity disclosures. Matt views this lawsuit as a significant development that raises essential questions about the personal liability of senior executives for inaccurate or misleading disclosures about cybersecurity risks. He emphasizes the potential implications this case could have for other executives in charge of trouble, such as compliance officers. Tom underscores the concerns regarding the accuracy and transparency of SolarWinds' cybersecurity disclosures. He highlights the evidence of a culture of deception within the company and the need to hold executives accountable for inaccurate disclosures. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.  Key Highlights: Liability of Senior Executives in Cybersecurity SolarWinds' Orion Software: Russian Government Cyberattack Personal Liability for Misleading Cybersecurity Disclosures Implementing Relevant Controls for Cybersecurity  Resources: Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more thoroughly, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recent SEC Civil Complaint against Solar Winds and its CISO, Timothy Brown, for undisclosed failures in the company’s cybersecurity compliance program disclosures prior to, during, and after the infamous Solar Winds data hack.

The recent SEC lawsuit against SolarWinds Corp and its CISO, Tim Brown, following the 2020 data breach has sparked a critical conversation about executive liability in cybersecurity disclosures. Matt views this lawsuit as a significant development that raises essential questions about the personal liability of senior executives for inaccurate or misleading disclosures about cybersecurity risks. He emphasizes the potential implications this case could have for other executives in charge of trouble, such as compliance officers.

Tom underscores the concerns regarding the accuracy and transparency of SolarWinds' cybersecurity disclosures. He highlights the evidence of a culture of deception within the company and the need to hold executives accountable for inaccurate disclosures. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.


 Key Highlights:

  • Liability of Senior Executives in Cybersecurity
  • SolarWinds' Orion Software: Russian Government Cyberattack
  • Personal Liability for Misleading Cybersecurity Disclosures
  • Implementing Relevant Controls for Cybersecurity

 Resources:

Tom  

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]]> 1681 no Szabolcs Fekete and the Consequences of Ethical Breaches The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more thoroughly, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt deeply dive into the termination of Citibank employee Szabolcs Fekete over cheating on his expense account, then lying about it and drawing out broad lessons for the compliance professional. The importance of trust, accountability, and ethics in the workplace cannot be overstated. These elements are the bedrock of a healthy corporate culture and are crucial for maintaining a positive and productive work environment. Tom believes that a broader conversation about these topics is necessary within corporations. He emphasizes the need for employees to understand the importance of trust, accountability, and adherence to policies and procedures. Matt echoes these sentiments. He shares a poignant story about a CEO who had to fire a cleaner for embezzlement and dishonesty, underlining the critical role of trust in upholding ethical standards. Both Fox and Kelly acknowledge the cynicism among the public and the workforce regarding ethical enforcement, and they advocate for a commitment to doing the right thing, even when it is difficult. Join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into this crucial topic. Key Highlights: Expense Report Dishonesty and Wrongful Termination Citibank’s Expense Report Policy and Trust The Consequences of Ethical Breaches The importance of trust and ethical enforcement  Resources Matt in Radical Compliance Jane Croft in the FT Pilita Clark in the FT Tom  Threads Instagram Facebook YouTube Twitter Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Oct 2023 04:00:00 -0000 Szabolcs Fekete and the Consequences of Ethical Breaches full 345 Tom Fox Today, Tom and Matt look at Szabolcs Fekete and the Consequences of Ethical Breaches. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more thoroughly, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt deeply dive into the termination of Citibank employee Szabolcs Fekete over cheating on his expense account, then lying about it and drawing out broad lessons for the compliance professional. The importance of trust, accountability, and ethics in the workplace cannot be overstated. These elements are the bedrock of a healthy corporate culture and are crucial for maintaining a positive and productive work environment. Tom believes that a broader conversation about these topics is necessary within corporations. He emphasizes the need for employees to understand the importance of trust, accountability, and adherence to policies and procedures. Matt echoes these sentiments. He shares a poignant story about a CEO who had to fire a cleaner for embezzlement and dishonesty, underlining the critical role of trust in upholding ethical standards. Both Fox and Kelly acknowledge the cynicism among the public and the workforce regarding ethical enforcement, and they advocate for a commitment to doing the right thing, even when it is difficult. Join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into this crucial topic. Key Highlights: Expense Report Dishonesty and Wrongful Termination Citibank’s Expense Report Policy and Trust The Consequences of Ethical Breaches The importance of trust and ethical enforcement  Resources Matt in Radical Compliance Jane Croft in the FT Pilita Clark in the FT Tom  Threads Instagram Facebook YouTube Twitter Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more thoroughly, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt deeply dive into the termination of Citibank employee Szabolcs Fekete over cheating on his expense account, then lying about it and drawing out broad lessons for the compliance professional.

The importance of trust, accountability, and ethics in the workplace cannot be overstated. These elements are the bedrock of a healthy corporate culture and are crucial for maintaining a positive and productive work environment. Tom believes that a broader conversation about these topics is necessary within corporations. He emphasizes the need for employees to understand the importance of trust, accountability, and adherence to policies and procedures.

Matt echoes these sentiments. He shares a poignant story about a CEO who had to fire a cleaner for embezzlement and dishonesty, underlining the critical role of trust in upholding ethical standards. Both Fox and Kelly acknowledge the cynicism among the public and the workforce regarding ethical enforcement, and they advocate for a commitment to doing the right thing, even when it is difficult. Join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into this crucial topic.

Key Highlights:

  • Expense Report Dishonesty and Wrongful Termination
  • Citibank’s Expense Report Policy and Trust
  • The Consequences of Ethical Breaches
  • The importance of trust and ethical enforcement

 Resources

Matt in Radical Compliance

Jane Croft in the FT

Pilita Clark in the FT

Tom 

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]]> 1372 no A Deep Dive into Policies and Procedures The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt deeply dive into the recent enforcement action against Deutsche Bank for AML violations and greenwashing to consider best practices for policies and procedures. In the complex business world, the importance of tailored policies for compliance and risk management cannot be overstated. Tom Fox and Matt Kelly bring their unique perspectives to this topic, emphasizing the need for well-designed, specific policies and procedures to mitigate compliance risks and potential harm. Drawing from his experience, Fox believes that generic policies are insufficient and stresses the need for policies specific to a company’s needs, risks, and operations. On the other hand, Kelly criticizes copying and pasting policies from regulations without considering the organization’s unique characteristics and needs. He underscores the importance of conducting risk assessments and gap analyses to design effective policies. Join Tom Fox and Matt Kelly as they delve deeper into this topic on this episode of the Compliance into the Weeds podcast.  Key Highlights: The Importance of Tailored Policies and Procedures Risks and Consequences of Generic Policies Tailoring Policies and Procedures for Compliance Ongoing Monitoring of Policies and Procedures Resources: Matt in Radical Compliance Tom  Threads Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Oct 2023 04:00:00 -0000 A Deep Dive into Policies and Procedures full 344 Tom Fox Tom and Matt take a deep dive into policies and procedures. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt deeply dive into the recent enforcement action against Deutsche Bank for AML violations and greenwashing to consider best practices for policies and procedures. In the complex business world, the importance of tailored policies for compliance and risk management cannot be overstated. Tom Fox and Matt Kelly bring their unique perspectives to this topic, emphasizing the need for well-designed, specific policies and procedures to mitigate compliance risks and potential harm. Drawing from his experience, Fox believes that generic policies are insufficient and stresses the need for policies specific to a company’s needs, risks, and operations. On the other hand, Kelly criticizes copying and pasting policies from regulations without considering the organization’s unique characteristics and needs. He underscores the importance of conducting risk assessments and gap analyses to design effective policies. Join Tom Fox and Matt Kelly as they delve deeper into this topic on this episode of the Compliance into the Weeds podcast.  Key Highlights: The Importance of Tailored Policies and Procedures Risks and Consequences of Generic Policies Tailoring Policies and Procedures for Compliance Ongoing Monitoring of Policies and Procedures Resources: Matt in Radical Compliance Tom  Threads Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt deeply dive into the recent enforcement action against Deutsche Bank for AML violations and greenwashing to consider best practices for policies and procedures.

In the complex business world, the importance of tailored policies for compliance and risk management cannot be overstated. Tom Fox and Matt Kelly bring their unique perspectives to this topic, emphasizing the need for well-designed, specific policies and procedures to mitigate compliance risks and potential harm.

Drawing from his experience, Fox believes that generic policies are insufficient and stresses the need for policies specific to a company’s needs, risks, and operations. On the other hand, Kelly criticizes copying and pasting policies from regulations without considering the organization’s unique characteristics and needs. He underscores the importance of conducting risk assessments and gap analyses to design effective policies. Join Tom Fox and Matt Kelly as they delve deeper into this topic on this episode of the Compliance into the Weeds podcast.

 Key Highlights:

  • The Importance of Tailored Policies and Procedures
  • Risks and Consequences of Generic Policies
  • Tailoring Policies and Procedures for Compliance
  • Ongoing Monitoring of Policies and Procedures

Resources:

Matt in Radical Compliance

Tom 

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]]> 1268 no New M&A Safe Harbor The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent speech by DAG Lisa Monaco, creating a Safe Harbor for M&A under the FCPA and beyond. The Justice Department has recently unveiled a new policy aimed at fostering cooperation and compliance within the corporate sector, especially during acquisitions. This policy, which offers companies the chance to avoid charges for compliance violations discovered during the acquisition process, has sparked a lively discussion among compliance experts. Matt views this policy with a mix of curiosity and uncertainty. He acknowledges its potential benefits but also raises concerns about its practical execution, particularly in relation to antitrust enforcement and the treatment of companies new to acquisitions. The application of the policy across various DOJ divisions and its interactions with other enforcement organizations intrigue Tom. He also questions whether acquiring companies will still receive a “free pass” if the acquired company engages in antitrust behavior. To delve deeper into these perspectives and explore the potential implications of this new policy, join Tom Fox and Matt Kelly in the latest episode of the Compliance into the Weeds podcast. Key Highlights: Cooperation and Compliance Incentives for M&A Exemption of Acquisition Target’s Aggravating Factors DOJ’s Emphasis on Pre-Acquisition Compliance Involvement Enforcement Policy’s Impact and Curiosity  Resources: Matt in Radical Compliance Tom  Threads Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Oct 2023 04:00:00 -0000 New M&A Safe Harbor full 343 Tom Fox In this episode, Tom and Matt consider the recent speech by DAG Lisa Monaco, creating a Safe Harbor for M&A under the FCPA and beyond. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent speech by DAG Lisa Monaco, creating a Safe Harbor for M&A under the FCPA and beyond. The Justice Department has recently unveiled a new policy aimed at fostering cooperation and compliance within the corporate sector, especially during acquisitions. This policy, which offers companies the chance to avoid charges for compliance violations discovered during the acquisition process, has sparked a lively discussion among compliance experts. Matt views this policy with a mix of curiosity and uncertainty. He acknowledges its potential benefits but also raises concerns about its practical execution, particularly in relation to antitrust enforcement and the treatment of companies new to acquisitions. The application of the policy across various DOJ divisions and its interactions with other enforcement organizations intrigue Tom. He also questions whether acquiring companies will still receive a “free pass” if the acquired company engages in antitrust behavior. To delve deeper into these perspectives and explore the potential implications of this new policy, join Tom Fox and Matt Kelly in the latest episode of the Compliance into the Weeds podcast. Key Highlights: Cooperation and Compliance Incentives for M&A Exemption of Acquisition Target’s Aggravating Factors DOJ’s Emphasis on Pre-Acquisition Compliance Involvement Enforcement Policy’s Impact and Curiosity  Resources: Matt in Radical Compliance Tom  Threads Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent speech by DAG Lisa Monaco, creating a Safe Harbor for M&A under the FCPA and beyond.

The Justice Department has recently unveiled a new policy aimed at fostering cooperation and compliance within the corporate sector, especially during acquisitions. This policy, which offers companies the chance to avoid charges for compliance violations discovered during the acquisition process, has sparked a lively discussion among compliance experts. Matt views this policy with a mix of curiosity and uncertainty. He acknowledges its potential benefits but also raises concerns about its practical execution, particularly in relation to antitrust enforcement and the treatment of companies new to acquisitions.

The application of the policy across various DOJ divisions and its interactions with other enforcement organizations intrigue Tom. He also questions whether acquiring companies will still receive a “free pass” if the acquired company engages in antitrust behavior. To delve deeper into these perspectives and explore the potential implications of this new policy, join Tom Fox and Matt Kelly in the latest episode of the Compliance into the Weeds podcast.

Key Highlights:

  • Cooperation and Compliance Incentives for M&A
  • Exemption of Acquisition Target’s Aggravating Factors
  • DOJ’s Emphasis on Pre-Acquisition Compliance Involvement
  • Enforcement Policy’s Impact and Curiosity

 Resources:

Matt in Radical Compliance

Tom 

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]]> 1329 no DE Shaw Enforcement Action for Pre-taliation The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent SEC pre-taliation enforcement action involving DE Shaw. The recent $10 million settlement by financial services firm De Shaw over a retaliation case has sparked a significant conversation about whistleblower policies. This case, the largest of its kind, centered around employment agreements that prohibited employees from speaking to governmental agencies without company authorization, a practice that has been illegal since 2011 under the Dodd Frank Act. Matt views this as a significant issue, emphasizing the need for clear processes and alignment between policies and employment templates. He also expresses surprise at the rarity of instances where pretaliation clauses actually deter whistleblowers, suggesting that the problem lies in the language used in employment agreements. Tom sees this as a problem of process. He believes that companies need to have a clear process in place to ensure that changes in employment policies are reflected throughout all relevant documents and agreements. He criticizes companies like De Shaw for updating their policies but failing to update their employment templates, which led to the inclusion of language that prevented whistleblowers from coming forward. Join Tom Fox and Matt Kelly as they delve deeper into this topic on the Compliance into the Weeds podcast.    Key Highlights: Largest pre-taliation settlement in financial services Persistent Non-Compliance Issues with Dodd Frank The Rise of Multimillion-Dollar Penalties Resources: Matt in LinkedIn Tom  Threads Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Oct 2023 04:00:00 -0000 DE Shaw Enforcement Action for Pre-taliation full 342 Tom Fox Tom and Matt take a look at the SEC enforcement action with DE Shaw for Pre-taliation. The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent SEC pre-taliation enforcement action involving DE Shaw. The recent $10 million settlement by financial services firm De Shaw over a retaliation case has sparked a significant conversation about whistleblower policies. This case, the largest of its kind, centered around employment agreements that prohibited employees from speaking to governmental agencies without company authorization, a practice that has been illegal since 2011 under the Dodd Frank Act. Matt views this as a significant issue, emphasizing the need for clear processes and alignment between policies and employment templates. He also expresses surprise at the rarity of instances where pretaliation clauses actually deter whistleblowers, suggesting that the problem lies in the language used in employment agreements. Tom sees this as a problem of process. He believes that companies need to have a clear process in place to ensure that changes in employment policies are reflected throughout all relevant documents and agreements. He criticizes companies like De Shaw for updating their policies but failing to update their employment templates, which led to the inclusion of language that prevented whistleblowers from coming forward. Join Tom Fox and Matt Kelly as they delve deeper into this topic on the Compliance into the Weeds podcast.    Key Highlights: Largest pre-taliation settlement in financial services Persistent Non-Compliance Issues with Dodd Frank The Rise of Multimillion-Dollar Penalties Resources: Matt in LinkedIn Tom  Threads Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent SEC pre-taliation enforcement action involving DE Shaw.

The recent $10 million settlement by financial services firm De Shaw over a retaliation case has sparked a significant conversation about whistleblower policies. This case, the largest of its kind, centered around employment agreements that prohibited employees from speaking to governmental agencies without company authorization, a practice that has been illegal since 2011 under the Dodd Frank Act. Matt views this as a significant issue, emphasizing the need for clear processes and alignment between policies and employment templates. He also expresses surprise at the rarity of instances where pretaliation clauses actually deter whistleblowers, suggesting that the problem lies in the language used in employment agreements.

Tom sees this as a problem of process. He believes that companies need to have a clear process in place to ensure that changes in employment policies are reflected throughout all relevant documents and agreements. He criticizes companies like De Shaw for updating their policies but failing to update their employment templates, which led to the inclusion of language that prevented whistleblowers from coming forward. Join Tom Fox and Matt Kelly as they delve deeper into this topic on the Compliance into the Weeds podcast.

 

 Key Highlights:

  • Largest pre-taliation settlement in financial services
  • Persistent Non-Compliance Issues with Dodd Frank
  • The Rise of Multimillion-Dollar Penalties


Resources:

Matt in LinkedIn

Tom 

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]]> 1046 no 3M OFAC Enforcement Action The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent OFAC enforcement action involving 3M. 3 3M, found itself in hot water after violating Iran sanctions, leading to a hefty fine of $9,618,477 from the Treasury Department and OFAC. This violation, involving a subsidiary selling goods to a German reseller who then sold them directly to Iran, including to a sanctioned entity.  Tom points out the significant failures in controls and monitoring within the company that led to the violation. He emphasizes the importance of end user statements and monitoring in compliance functions to prevent such violations. On the other hand, Matt acknowledges that while 3M made an effort to comply with the Iran nuclear deal, changes in the arrangement that were not properly communicated or approved led to a violation of the sanctions agreement. He also underscores the importance of monitoring and obtaining end user statements to ensure compliance with export control laws.  Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.  Key Highlights ·      Sanctions Compliance and Ongoing Monitoring ·      Challenges and Consequences of Sanctions Compliance ·      Sanctions Settlement for Selling Goods to Iran ·      Anticipated Impact of Recent Events on 3M  Resources Matt in LinkedIn Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 Sep 2023 04:00:00 -0000 3M OFAC Enforcement Action full 341 Tom Fox Tom and Matt take on the 3M OFAC Enforcement Action. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent OFAC enforcement action involving 3M. 3 3M, found itself in hot water after violating Iran sanctions, leading to a hefty fine of $9,618,477 from the Treasury Department and OFAC. This violation, involving a subsidiary selling goods to a German reseller who then sold them directly to Iran, including to a sanctioned entity.  Tom points out the significant failures in controls and monitoring within the company that led to the violation. He emphasizes the importance of end user statements and monitoring in compliance functions to prevent such violations. On the other hand, Matt acknowledges that while 3M made an effort to comply with the Iran nuclear deal, changes in the arrangement that were not properly communicated or approved led to a violation of the sanctions agreement. He also underscores the importance of monitoring and obtaining end user statements to ensure compliance with export control laws.  Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.  Key Highlights ·      Sanctions Compliance and Ongoing Monitoring ·      Challenges and Consequences of Sanctions Compliance ·      Sanctions Settlement for Selling Goods to Iran ·      Anticipated Impact of Recent Events on 3M  Resources Matt in LinkedIn Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent OFAC enforcement action involving 3M.

3 3M, found itself in hot water after violating Iran sanctions, leading to a hefty fine of $9,618,477 from the Treasury Department and OFAC. This violation, involving a subsidiary selling goods to a German reseller who then sold them directly to Iran, including to a sanctioned entity. 

Tom points out the significant failures in controls and monitoring within the company that led to the violation. He emphasizes the importance of end user statements and monitoring in compliance functions to prevent such violations. On the other hand, Matt acknowledges that while 3M made an effort to comply with the Iran nuclear deal, changes in the arrangement that were not properly communicated or approved led to a violation of the sanctions agreement. He also underscores the importance of monitoring and obtaining end user statements to ensure compliance with export control laws. 

Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.

 Key Highlights

·      Sanctions Compliance and Ongoing Monitoring

·      Challenges and Consequences of Sanctions Compliance

·      Sanctions Settlement for Selling Goods to Iran

·      Anticipated Impact of Recent Events on 3M

 Resources

Matt in LinkedIn

Matt on Radical Compliance


Tom  

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]]> 1271 no MGM Grand Data Breach The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent MGM Reports data breach and what it may mean for CCOs and Danny Ocean. The MGM Grand data breach, a significant cyber-attack that disrupted MGM Resorts' operations across the U.S., has raised serious concerns about cybersecurity and regulatory requirements. Tom and Matt discuss the potential financial impact and regulatory investigations that may arise from the breach, emphasizes the severity of the situation and the potential consequences for MGM.  They also question MGM's disaster recovery and business continuity plans and raises concerns about the network design vulnerabilities that allowed the attack to have such a widespread impact. He also discusses the implications of the breach in relation to new SEC rules mandating the disclosure of material cybersecurity events by public companies. Join Tom Fox and Matt Kelly as they delve deeper into these issues in this episode of the Compliance into the Weeds podcast.  Key Highlights ·      MGM Grand Cyber Attack Disrupts Operations ·      Understanding the Impact of Qualitatively Material Cybersecurity Incidents ·      Navigating Material Cybersecurity Event Disclosure Requirements ·      Inadequate backup plans leading to operational disruptions ·      MGM's Ransomware Attack and Business Continuity  Resources Matt in LinkedIn Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Sep 2023 04:00:00 -0000 MGM Grand Data Breach full 340 Tom Fox Tom and Matt take a deep dive into the recent MGM Grand Data Breach. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent MGM Reports data breach and what it may mean for CCOs and Danny Ocean. The MGM Grand data breach, a significant cyber-attack that disrupted MGM Resorts' operations across the U.S., has raised serious concerns about cybersecurity and regulatory requirements. Tom and Matt discuss the potential financial impact and regulatory investigations that may arise from the breach, emphasizes the severity of the situation and the potential consequences for MGM.  They also question MGM's disaster recovery and business continuity plans and raises concerns about the network design vulnerabilities that allowed the attack to have such a widespread impact. He also discusses the implications of the breach in relation to new SEC rules mandating the disclosure of material cybersecurity events by public companies. Join Tom Fox and Matt Kelly as they delve deeper into these issues in this episode of the Compliance into the Weeds podcast.  Key Highlights ·      MGM Grand Cyber Attack Disrupts Operations ·      Understanding the Impact of Qualitatively Material Cybersecurity Incidents ·      Navigating Material Cybersecurity Event Disclosure Requirements ·      Inadequate backup plans leading to operational disruptions ·      MGM's Ransomware Attack and Business Continuity  Resources Matt in LinkedIn Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent MGM Reports data breach and what it may mean for CCOs and Danny Ocean.

The MGM Grand data breach, a significant cyber-attack that disrupted MGM Resorts' operations across the U.S., has raised serious concerns about cybersecurity and regulatory requirements. Tom and Matt discuss the potential financial impact and regulatory investigations that may arise from the breach, emphasizes the severity of the situation and the potential consequences for MGM. 

They also question MGM's disaster recovery and business continuity plans and raises concerns about the network design vulnerabilities that allowed the attack to have such a widespread impact. He also discusses the implications of the breach in relation to new SEC rules mandating the disclosure of material cybersecurity events by public companies. Join Tom Fox and Matt Kelly as they delve deeper into these issues in this episode of the Compliance into the Weeds podcast.

 Key Highlights

·      MGM Grand Cyber Attack Disrupts Operations

·      Understanding the Impact of Qualitatively Material Cybersecurity Incidents

·      Navigating Material Cybersecurity Event Disclosure Requirements

·      Inadequate backup plans leading to operational disruptions

·      MGM's Ransomware Attack and Business Continuity

 Resources

Matt in LinkedIn

Matt on Radical Compliance


Tom  

Instagram

Facebook

YouTube

Twitter

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Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1623 no Failure to Have Effective Compliance Program The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent DOJ enforcement action involving Verizon Business Network Services for failure to have an effective cyber security compliance program. The recent case of Verizon's non-compliance with cybersecurity standards and subsequent remediation efforts has sparked a significant conversation in the realm of cyber compliance. Tom views this case as a roadmap for companies to enhance their cybersecurity programs, emphasizing the importance of gap analysis and pressure testing. He draws parallels between cybersecurity compliance and the Foreign Corrupt Practices Act (FCPA) compliance, suggesting that Verizon's case could serve as an example for other companies.  Matt applauds Verizon's voluntary self-disclosure and extensive remediation efforts. He underscores the importance of disclosure, cooperation, and remediation in both cybersecurity and corruption cases, viewing Verizon's actions as a positive example for other companies. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.  Key Highlights ·      Verizon's Cybersecurity Program Failures ·      Enhancing Cybersecurity Compliance through Remediation Measures ·      Automating Compliance Efforts with GRC Tools ·      Potential Penalties for Non-Disclosure of Cybersecurity Issues  Resources Matt in LinkedIn Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Sep 2023 04:00:00 -0000 Failure to Have Effective Compliance Program full 339 Tom Fox Tom and Matt consider the recent DOJ enforcement action involving Verizon Business Network Services for failure to have an effective cyber security compliance program. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent DOJ enforcement action involving Verizon Business Network Services for failure to have an effective cyber security compliance program. The recent case of Verizon's non-compliance with cybersecurity standards and subsequent remediation efforts has sparked a significant conversation in the realm of cyber compliance. Tom views this case as a roadmap for companies to enhance their cybersecurity programs, emphasizing the importance of gap analysis and pressure testing. He draws parallels between cybersecurity compliance and the Foreign Corrupt Practices Act (FCPA) compliance, suggesting that Verizon's case could serve as an example for other companies.  Matt applauds Verizon's voluntary self-disclosure and extensive remediation efforts. He underscores the importance of disclosure, cooperation, and remediation in both cybersecurity and corruption cases, viewing Verizon's actions as a positive example for other companies. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.  Key Highlights ·      Verizon's Cybersecurity Program Failures ·      Enhancing Cybersecurity Compliance through Remediation Measures ·      Automating Compliance Efforts with GRC Tools ·      Potential Penalties for Non-Disclosure of Cybersecurity Issues  Resources Matt in LinkedIn Matt on Radical Compliance Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent DOJ enforcement action involving Verizon Business Network Services for failure to have an effective cyber security compliance program.

The recent case of Verizon's non-compliance with cybersecurity standards and subsequent remediation efforts has sparked a significant conversation in the realm of cyber compliance. Tom views this case as a roadmap for companies to enhance their cybersecurity programs, emphasizing the importance of gap analysis and pressure testing. He draws parallels between cybersecurity compliance and the Foreign Corrupt Practices Act (FCPA) compliance, suggesting that Verizon's case could serve as an example for other companies. 

Matt applauds Verizon's voluntary self-disclosure and extensive remediation efforts. He underscores the importance of disclosure, cooperation, and remediation in both cybersecurity and corruption cases, viewing Verizon's actions as a positive example for other companies. Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast. 

Key Highlights

·      Verizon's Cybersecurity Program Failures

·      Enhancing Cybersecurity Compliance through Remediation Measures

·      Automating Compliance Efforts with GRC Tools

·      Potential Penalties for Non-Disclosure of Cybersecurity Issues

 Resources

Matt in LinkedIn

Matt on Radical Compliance

Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1199 no Risk Assessments, Control Environments and Plug Power The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent pronouncements from the SEC regarding risk assessments together with control environments and all this played out in the Plug Power enforcement action. The importance of risk assessments and a strong control environment in companies cannot be overstated. These elements are crucial for effective internal controls and proper financial reporting, as emphasized by the SEC's chief accountant, Paul Munter. In this episode Tom and Matt underscore the need for thorough evaluation of potential pitfalls in risk assessments, citing insufficient personnel, changes in board or management composition, and hasty adoption of new strategies or technologies as potential triggers for flawed assessments.  They highlight the significance of small control failures and entity-level failures, such as weaknesses in IT controls, as indicators of a weak control environment.. Join Tom Fox and Matt Kelly as they delve deeper into the topic of risk assessment in the latest episode of the Compliance into the Weeds podcast.  Key Highlights ·      Munter’s statement ·      Enhancing Control Environment through Risk Assessments ·      The Importance of Risk Assessments and Controls ·      Attracting and Retaining Competent Individuals ·      Flaws in Risk Assessment Beyond Insufficient Personnel ·      Lessons Learned  Resources Matt in LinkedIn Matt blogged twice on these issues. A report on Munter’s statements here and on the Plug Power enforcement action here Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Sep 2023 10:49:59 -0000 Risk Assessments, Control Environments and Plug Power full 338 Tom Fox Tom and Matt take a deep dive into inadequate risk assessments. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent pronouncements from the SEC regarding risk assessments together with control environments and all this played out in the Plug Power enforcement action. The importance of risk assessments and a strong control environment in companies cannot be overstated. These elements are crucial for effective internal controls and proper financial reporting, as emphasized by the SEC's chief accountant, Paul Munter. In this episode Tom and Matt underscore the need for thorough evaluation of potential pitfalls in risk assessments, citing insufficient personnel, changes in board or management composition, and hasty adoption of new strategies or technologies as potential triggers for flawed assessments.  They highlight the significance of small control failures and entity-level failures, such as weaknesses in IT controls, as indicators of a weak control environment.. Join Tom Fox and Matt Kelly as they delve deeper into the topic of risk assessment in the latest episode of the Compliance into the Weeds podcast.  Key Highlights ·      Munter’s statement ·      Enhancing Control Environment through Risk Assessments ·      The Importance of Risk Assessments and Controls ·      Attracting and Retaining Competent Individuals ·      Flaws in Risk Assessment Beyond Insufficient Personnel ·      Lessons Learned  Resources Matt in LinkedIn Matt blogged twice on these issues. A report on Munter’s statements here and on the Plug Power enforcement action here Tom   Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent pronouncements from the SEC regarding risk assessments together with control environments and all this played out in the Plug Power enforcement action.

The importance of risk assessments and a strong control environment in companies cannot be overstated. These elements are crucial for effective internal controls and proper financial reporting, as emphasized by the SEC's chief accountant, Paul Munter. In this episode Tom and Matt underscore the need for thorough evaluation of potential pitfalls in risk assessments, citing insufficient personnel, changes in board or management composition, and hasty adoption of new strategies or technologies as potential triggers for flawed assessments. 

They highlight the significance of small control failures and entity-level failures, such as weaknesses in IT controls, as indicators of a weak control environment.. Join Tom Fox and Matt Kelly as they delve deeper into the topic of risk assessment in the latest episode of the Compliance into the Weeds podcast.

 Key Highlights

·      Munter’s statement

·      Enhancing Control Environment through Risk Assessments

·      The Importance of Risk Assessments and Controls

·      Attracting and Retaining Competent Individuals

·      Flaws in Risk Assessment Beyond Insufficient Personnel

·      Lessons Learned

 Resources

Matt in LinkedIn

Matt blogged twice on these issues. A report on Munter’s statements here and on the Plug Power enforcement action here

Tom  

Instagram

Facebook

YouTube

Twitter

LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1323 no 3M FCPA Enforcement Action The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent FCPA enforcement action involving the Chinese business unit of 3M. The importance of post-event documentation and monitoring in preventing fraud and corruption cannot be overstated, as highlighted by the recent FCPA incident involving 3M China. Tom believes that while training and control environment adjustments are crucial, they may not be enough to prevent misconduct if individuals are determined to commit such acts. He emphasizes the need for hard evidence, such as post-event documentation, and recommends looking to the heavily regulated pharmaceutical sector for guidance. Matt stresses the importance of rigorous post-event documentation to ensure the legitimacy of business activities. Both Fox and Kelly gained these insights from their extensive experience in the field of compliance and their analysis of various fraud cases. To learn more about their unique perspectives on post-event documentation and monitoring, join them on this episode of the Compliance into the Weeds podcast.  Key Highlights ·      Background facts ·      GTE in FCPA enforcement actions ·      What happens when conduct is done secretly ·      Concerns over the use of messaging apps ·      Lessons Learned  Resources Matt in LinkedIn Tom -blog post on the FCPA Compliance and Ethics Blog Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 30 Aug 2023 04:00:00 -0000 3M FCPA Enforcement Action full 337 Tom Fox Tom and Matt take a deep dive into the 3M FCPA Enforcement Action. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent FCPA enforcement action involving the Chinese business unit of 3M. The importance of post-event documentation and monitoring in preventing fraud and corruption cannot be overstated, as highlighted by the recent FCPA incident involving 3M China. Tom believes that while training and control environment adjustments are crucial, they may not be enough to prevent misconduct if individuals are determined to commit such acts. He emphasizes the need for hard evidence, such as post-event documentation, and recommends looking to the heavily regulated pharmaceutical sector for guidance. Matt stresses the importance of rigorous post-event documentation to ensure the legitimacy of business activities. Both Fox and Kelly gained these insights from their extensive experience in the field of compliance and their analysis of various fraud cases. To learn more about their unique perspectives on post-event documentation and monitoring, join them on this episode of the Compliance into the Weeds podcast.  Key Highlights ·      Background facts ·      GTE in FCPA enforcement actions ·      What happens when conduct is done secretly ·      Concerns over the use of messaging apps ·      Lessons Learned  Resources Matt in LinkedIn Tom -blog post on the FCPA Compliance and Ethics Blog Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent FCPA enforcement action involving the Chinese business unit of 3M.

The importance of post-event documentation and monitoring in preventing fraud and corruption cannot be overstated, as highlighted by the recent FCPA incident involving 3M China. Tom believes that while training and control environment adjustments are crucial, they may not be enough to prevent misconduct if individuals are determined to commit such acts. He emphasizes the need for hard evidence, such as post-event documentation, and recommends looking to the heavily regulated pharmaceutical sector for guidance.

Matt stresses the importance of rigorous post-event documentation to ensure the legitimacy of business activities. Both Fox and Kelly gained these insights from their extensive experience in the field of compliance and their analysis of various fraud cases. To learn more about their unique perspectives on post-event documentation and monitoring, join them on this episode of the Compliance into the Weeds podcast. 

Key Highlights

·      Background facts

·      GTE in FCPA enforcement actions

·      What happens when conduct is done secretly

·      Concerns over the use of messaging apps

·      Lessons Learned

 Resources

Matt in LinkedIn

Tom -blog post on the FCPA Compliance and Ethics Blog

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1178 no Messaging App Enforcement and Internal Controls The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent SEC and CFTC enforcement actions around messaging app non-compliance. Join Tom and Matt as they take a deep dive into the enforcement actions and then consider how such claims would impact non-regulated industries. Regulated industries, particularly broker-dealer firms like Wells Fargo and Morgan Stanley, are facing enforcement actions and hefty fines for their employees' use of messaging apps like WhatsApp and Snapchat that allow record preservation to be disabled. The involvement of senior managers in these misconducts has prompted the SEC to require an independent compliance consultant in settlements. The conversation between Tom and Matt emphasizes the importance of messaging policies and procedures in regulated industries and the need for stricter compliance measures. They also discuss the complexities and potential consequences of record-keeping obligations and the regulatory concerns over the use of messaging apps. The conversation briefly touches on the future of AI chatbots in customer service, with differing perspectives on their ethical implications. Overall, the conversation highlights the significance of messaging policies, enforcement, and compliance in regulated industries. Key Highlights ·      Enforcement Actions Against Regulated Industries ·      Enforcement actions and messaging policies ·      Record-keeping obligations for broker dealers and other industries ·      Regulatory concerns over the use of messaging apps ·      Internal Controls and non-regulated industries  Resources Matt  LinkedIn Blog Post in Radical Compliance No Smoke and No Fire: The Rise of Internal Controls Absent Anti-Bribery Violations in FCPA Enforcement by Karen Woody in Cardoza Law Review Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Aug 2023 04:00:00 -0000 Messaging App Enforcement and Internal Controls full 336 Tom Fox Matt and Tom look at the latest round of enforcement actions against regulated industries around ephemeral messaging. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent SEC and CFTC enforcement actions around messaging app non-compliance. Join Tom and Matt as they take a deep dive into the enforcement actions and then consider how such claims would impact non-regulated industries. Regulated industries, particularly broker-dealer firms like Wells Fargo and Morgan Stanley, are facing enforcement actions and hefty fines for their employees' use of messaging apps like WhatsApp and Snapchat that allow record preservation to be disabled. The involvement of senior managers in these misconducts has prompted the SEC to require an independent compliance consultant in settlements. The conversation between Tom and Matt emphasizes the importance of messaging policies and procedures in regulated industries and the need for stricter compliance measures. They also discuss the complexities and potential consequences of record-keeping obligations and the regulatory concerns over the use of messaging apps. The conversation briefly touches on the future of AI chatbots in customer service, with differing perspectives on their ethical implications. Overall, the conversation highlights the significance of messaging policies, enforcement, and compliance in regulated industries. Key Highlights ·      Enforcement Actions Against Regulated Industries ·      Enforcement actions and messaging policies ·      Record-keeping obligations for broker dealers and other industries ·      Regulatory concerns over the use of messaging apps ·      Internal Controls and non-regulated industries  Resources Matt  LinkedIn Blog Post in Radical Compliance No Smoke and No Fire: The Rise of Internal Controls Absent Anti-Bribery Violations in FCPA Enforcement by Karen Woody in Cardoza Law Review Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent SEC and CFTC enforcement actions around messaging app non-compliance.

Join Tom and Matt as they take a deep dive into the enforcement actions and then consider how such claims would impact non-regulated industries. Regulated industries, particularly broker-dealer firms like Wells Fargo and Morgan Stanley, are facing enforcement actions and hefty fines for their employees' use of messaging apps like WhatsApp and Snapchat that allow record preservation to be disabled. The involvement of senior managers in these misconducts has prompted the SEC to require an independent compliance consultant in settlements.

The conversation between Tom and Matt emphasizes the importance of messaging policies and procedures in regulated industries and the need for stricter compliance measures. They also discuss the complexities and potential consequences of record-keeping obligations and the regulatory concerns over the use of messaging apps. The conversation briefly touches on the future of AI chatbots in customer service, with differing perspectives on their ethical implications. Overall, the conversation highlights the significance of messaging policies, enforcement, and compliance in regulated industries.

Key Highlights

·      Enforcement Actions Against Regulated Industries

·      Enforcement actions and messaging policies

·      Record-keeping obligations for broker dealers and other industries

·      Regulatory concerns over the use of messaging apps

·      Internal Controls and non-regulated industries

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

No Smoke and No Fire: The Rise of Internal Controls Absent Anti-Bribery Violations in FCPA Enforcement by Karen Woody in Cardoza Law Review

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1433 no Responses to PCAOB Proposal On Audits The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the PCAOB proposal for fraud and compliance audits. In this episode, we dive into the heated debate surrounding the proposed rule on auditors and fraud risk audits in this episode of Compliance into the Weeds. Compliance professionals and the audit community have contrasting perspectives on the PCAOB proposal to require audit firms to look more aggressively for compliance and legal violations at their client companies, and then report any such violations more promptly to the company’s board of directors. Discover the stipulations compliance professionals want to include, such as meeting with the chief ethics and compliance officer and reviewing the state of the compliance program. On the other hand, hear why the audit community, represented by the PCAOB, opposes the rule, arguing that auditors lack the necessary expertise and that fees would skyrocket without significant benefits. Gain insights into the complexities and challenges of asking auditors to take on compliance responsibilities. Tune in to understand the potential implications of the proposed rule on audit firms, compliance professionals, and investors.  Key Highlights ·       The PCAOB proposal implications for auditors, with a focus on effects on fraud risk audits. ·       The difference in how compliance professionals and auditors perceive the impending rule. ·       The practical difficulties auditors face when tasked with compliance roles. ·       What are the potential cost and liability hikes for auditors, heralded by the enforcement of the rule? ·       The uncertainties enveloping the approval and implementation process for the proposed rule.  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Aug 2023 04:00:00 -0000 Responses to PCAOB Proposal On Audits full 335 Tom Fox Tom and Matt are back to look a the responses to the PCAOB proposed rule on fraud and related audits. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the PCAOB proposal for fraud and compliance audits. In this episode, we dive into the heated debate surrounding the proposed rule on auditors and fraud risk audits in this episode of Compliance into the Weeds. Compliance professionals and the audit community have contrasting perspectives on the PCAOB proposal to require audit firms to look more aggressively for compliance and legal violations at their client companies, and then report any such violations more promptly to the company’s board of directors. Discover the stipulations compliance professionals want to include, such as meeting with the chief ethics and compliance officer and reviewing the state of the compliance program. On the other hand, hear why the audit community, represented by the PCAOB, opposes the rule, arguing that auditors lack the necessary expertise and that fees would skyrocket without significant benefits. Gain insights into the complexities and challenges of asking auditors to take on compliance responsibilities. Tune in to understand the potential implications of the proposed rule on audit firms, compliance professionals, and investors.  Key Highlights ·       The PCAOB proposal implications for auditors, with a focus on effects on fraud risk audits. ·       The difference in how compliance professionals and auditors perceive the impending rule. ·       The practical difficulties auditors face when tasked with compliance roles. ·       What are the potential cost and liability hikes for auditors, heralded by the enforcement of the rule? ·       The uncertainties enveloping the approval and implementation process for the proposed rule.  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the PCAOB proposal for fraud and compliance audits.

In this episode, we dive into the heated debate surrounding the proposed rule on auditors and fraud risk audits in this episode of Compliance into the Weeds. Compliance professionals and the audit community have contrasting perspectives on the PCAOB proposal to require audit firms to look more aggressively for compliance and legal violations at their client companies, and then report any such violations more promptly to the company’s board of directors. Discover the stipulations compliance professionals want to include, such as meeting with the chief ethics and compliance officer and reviewing the state of the compliance program. On the other hand, hear why the audit community, represented by the PCAOB, opposes the rule, arguing that auditors lack the necessary expertise and that fees would skyrocket without significant benefits. Gain insights into the complexities and challenges of asking auditors to take on compliance responsibilities. Tune in to understand the potential implications of the proposed rule on audit firms, compliance professionals, and investors.

 Key Highlights

·       The PCAOB proposal implications for auditors, with a focus on effects on fraud risk audits.

·       The difference in how compliance professionals and auditors perceive the impending rule.

·       The practical difficulties auditors face when tasked with compliance roles.

·       What are the potential cost and liability hikes for auditors, heralded by the enforcement of the rule?

·       The uncertainties enveloping the approval and implementation process for the proposed rule.

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1467 no SEC Rules for Cyber Breach Disclosure The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recently released SEC rules on cyber breach disclosures.  This new era of cyber security calls for increased accountability and transparency from companies to protect investors and citizens from cyber threats. The U.S. Securities and Exchange Commission (SEC) recently adopted new cyber disclosure rules requiring companies to disclose material cybersecurity incidents and risks in their annual reports. This policy change will require companies to analyze and disclose the impacts of any material cybersecurity incidents, as well as any potential exemptions from disclosure that companies may seek.   Key Highlights  ·      New Cyber Breach Disclosure Rules ·      Material Breaches ·      Role of the Board  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Aug 2023 04:00:00 -0000 SEC Rules for Cyber Breach Disclosure full 334 Tom Fox Tom and Matt take a deep dive into the recently released SEC rules on cyber breach disclosures. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recently released SEC rules on cyber breach disclosures.  This new era of cyber security calls for increased accountability and transparency from companies to protect investors and citizens from cyber threats. The U.S. Securities and Exchange Commission (SEC) recently adopted new cyber disclosure rules requiring companies to disclose material cybersecurity incidents and risks in their annual reports. This policy change will require companies to analyze and disclose the impacts of any material cybersecurity incidents, as well as any potential exemptions from disclosure that companies may seek.   Key Highlights  ·      New Cyber Breach Disclosure Rules ·      Material Breaches ·      Role of the Board  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt take a deep dive into the recently released SEC rules on cyber breach disclosures. 

This new era of cyber security calls for increased accountability and transparency from companies to protect investors and citizens from cyber threats. The U.S. Securities and Exchange Commission (SEC) recently adopted new cyber disclosure rules requiring companies to disclose material cybersecurity incidents and risks in their annual reports. This policy change will require companies to analyze and disclose the impacts of any material cybersecurity incidents, as well as any potential exemptions from disclosure that companies may seek. 

 Key Highlights 

·      New Cyber Breach Disclosure Rules

·      Material Breaches

·      Role of the Board

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1469 no Auditing AI For Compliance The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the current difficulties for auditors to perform an audit on AI. The use of AI in the tech world has brought with it a new concern: implicit bias. Auditing AI code is necessary to ensure that AI applications are free from bias and secure from cyber threats. This complex process involves examining the code of AI programs to ensure that they are functioning as intended and are not producing biased or unethical outcomes. In addition to auditing code, employers must also audit the outcomes of AI tools, and consider ethical considerations when defining the data that the AI is looking at. As AI hiring audits become increasingly necessary, it is more important than ever to ensure that AI applications are free from bias and secure from cyber threats.  Key Highlights ·      AI Implicit Bias ·      Auditing AI Code ·      AI Hiring Audits  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 25 Jul 2023 04:00:00 -0000 Auditing AI For Compliance full 333 Tom Fox Tom and Matt look at challenges for auditors around auditing AI. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the current difficulties for auditors to perform an audit on AI. The use of AI in the tech world has brought with it a new concern: implicit bias. Auditing AI code is necessary to ensure that AI applications are free from bias and secure from cyber threats. This complex process involves examining the code of AI programs to ensure that they are functioning as intended and are not producing biased or unethical outcomes. In addition to auditing code, employers must also audit the outcomes of AI tools, and consider ethical considerations when defining the data that the AI is looking at. As AI hiring audits become increasingly necessary, it is more important than ever to ensure that AI applications are free from bias and secure from cyber threats.  Key Highlights ·      AI Implicit Bias ·      Auditing AI Code ·      AI Hiring Audits  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the current difficulties for auditors to perform an audit on AI.

The use of AI in the tech world has brought with it a new concern: implicit bias. Auditing AI code is necessary to ensure that AI applications are free from bias and secure from cyber threats. This complex process involves examining the code of AI programs to ensure that they are functioning as intended and are not producing biased or unethical outcomes. In addition to auditing code, employers must also audit the outcomes of AI tools, and consider ethical considerations when defining the data that the AI is looking at. As AI hiring audits become increasingly necessary, it is more important than ever to ensure that AI applications are free from bias and secure from cyber threats.

 Key Highlights

·      AI Implicit Bias

·      Auditing AI Code

·      AI Hiring Audits

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1405 no BOA Enforcement Action for Bogus Accounts https://compliancepodcastnetwork.net/compliance-into-the-weeds-boa-enforcement-action-for-bogus-accounts/ The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt take up the recent CFTC enforcement action involving Bank of America. In yet another reminder of the importance of ethical practices within the banking industry, Bank of America recently faced civil charges for misconduct, including a junk fees scheme and opening credit cards for customers without their authorization. This follows in the footsteps of similar misconduct from Wells Fargo in the mid-2010s, which resulted in a hefty $185 million fine. To address the issue, Bank of America has agreed to discontinue its flawed incentive program and develop a compliance plan within 90 days. Banks must remain vigilant in their compliance efforts, capture customer consent and documentation, and have data analytics capabilities, or risk similar fines. Furthermore, this penalty emphasizes the need for banks to keep their practices updated with regulations.   Key Highlights  ·      Facts of enforcement action ·      BOA penalty ·      BOA remediation ·      Comparisons to Wells Fargo ·      Banks behaving badly  Resources: Matt Kelly LinkedIn Blog Post in Radical Compliance Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Jul 2023 04:00:00 -0000 BOA Enforcement Action for Bogus Accounts full 332 Tom Fox Tom and Matt take up the recent CFTC enforcement action involving Bank of America. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt take up the recent CFTC enforcement action involving Bank of America. In yet another reminder of the importance of ethical practices within the banking industry, Bank of America recently faced civil charges for misconduct, including a junk fees scheme and opening credit cards for customers without their authorization. This follows in the footsteps of similar misconduct from Wells Fargo in the mid-2010s, which resulted in a hefty $185 million fine. To address the issue, Bank of America has agreed to discontinue its flawed incentive program and develop a compliance plan within 90 days. Banks must remain vigilant in their compliance efforts, capture customer consent and documentation, and have data analytics capabilities, or risk similar fines. Furthermore, this penalty emphasizes the need for banks to keep their practices updated with regulations.   Key Highlights  ·      Facts of enforcement action ·      BOA penalty ·      BOA remediation ·      Comparisons to Wells Fargo ·      Banks behaving badly  Resources: Matt Kelly LinkedIn Blog Post in Radical Compliance Tom Fox Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt take up the recent CFTC enforcement action involving Bank of America.

In yet another reminder of the importance of ethical practices within the banking industry, Bank of America recently faced civil charges for misconduct, including a junk fees scheme and opening credit cards for customers without their authorization. This follows in the footsteps of similar misconduct from Wells Fargo in the mid-2010s, which resulted in a hefty $185 million fine. To address the issue, Bank of America has agreed to discontinue its flawed incentive program and develop a compliance plan within 90 days. Banks must remain vigilant in their compliance efforts, capture customer consent and documentation, and have data analytics capabilities, or risk similar fines. Furthermore, this penalty emphasizes the need for banks to keep their practices updated with regulations.


  Key Highlights 

·      Facts of enforcement action

·      BOA penalty

·      BOA remediation

·      Comparisons to Wells Fargo

·      Banks behaving badly


 Resources:

Matt Kelly

LinkedIn


Blog Post in Radical Compliance


Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1311 no Compliance into the Weeds Takes a Eurotrip with Compliance Man The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds!  In this episode, co-hosts Tom Fox and Matt Kelly are joined by Compliance Man himself Tim Khasanov-Batirov. We consider how the Airbus scandal has highlighted the importance of compliance and ethics in corporate conduct in France, and the need for reliable data in ESG reporting, artificial intelligence, and third party risk management. We also discuss the challenges faced by American and European compliance professionals, and the need for Diversity, Equity and Inclusion (DEI) in creating a strong speak up culture. They discussed the EU Whistleblower Directive, which states that anonymous reports should be allowed, and the importance of clean conduct in government agencies. Compliance practitioners have an important role to play in this process, and the EU is leading the world's discussions around ESG reporting. Key Highlights  ·      ESG Reporting Requirements ·      AI and DEI in Compliance ·      European Compliance Challenges ·      European Compliance vs US ·      AI and Compliance in France Resources Matt  LinkedIn Tom  Instagram Facebook YouTube Twitter LinkedIn Tim LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Jul 2023 04:00:00 -0000 Compliance into the Weeds Takes a Eurotrip with Compliance Man full 331 Tom Fox Matt and Tom are joined by Compliance Man for a Eurotrip. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds!  In this episode, co-hosts Tom Fox and Matt Kelly are joined by Compliance Man himself Tim Khasanov-Batirov. We consider how the Airbus scandal has highlighted the importance of compliance and ethics in corporate conduct in France, and the need for reliable data in ESG reporting, artificial intelligence, and third party risk management. We also discuss the challenges faced by American and European compliance professionals, and the need for Diversity, Equity and Inclusion (DEI) in creating a strong speak up culture. They discussed the EU Whistleblower Directive, which states that anonymous reports should be allowed, and the importance of clean conduct in government agencies. Compliance practitioners have an important role to play in this process, and the EU is leading the world's discussions around ESG reporting. Key Highlights  ·      ESG Reporting Requirements ·      AI and DEI in Compliance ·      European Compliance Challenges ·      European Compliance vs US ·      AI and Compliance in France Resources Matt  LinkedIn Tom  Instagram Facebook YouTube Twitter LinkedIn Tim LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! 

In this episode, co-hosts Tom Fox and Matt Kelly are joined by Compliance Man himself Tim Khasanov-Batirov. We consider how the Airbus scandal has highlighted the importance of compliance and ethics in corporate conduct in France, and the need for reliable data in ESG reporting, artificial intelligence, and third party risk management. We also discuss the challenges faced by American and European compliance professionals, and the need for Diversity, Equity and Inclusion (DEI) in creating a strong speak up culture. They discussed the EU Whistleblower Directive, which states that anonymous reports should be allowed, and the importance of clean conduct in government agencies. Compliance practitioners have an important role to play in this process, and the EU is leading the world's discussions around ESG reporting.

Key Highlights 

·      ESG Reporting Requirements

·      AI and DEI in Compliance

·      European Compliance Challenges

·      European Compliance vs US

·      AI and Compliance in France

Resources

Matt 

LinkedIn

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Tim

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2275 no What is Driving Compliance Engagement at the Board? The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds!  In this episode, co-hosts Tom Fox and Matt Kelly dissect the Navex 2023 State of Risk and Compliance Report. Tom and Matt delve into Navex's annual benchmarking report, which surveyed 1,300 compliance professionals. The report revealed that 53% of respondents described their compliance programs as mature. The speakers question whether the board is driving the conversation or if compliance officers are requesting updates due to potential liability. The report's findings on cybersecurity and privacy concerns, survey results on where compliance should reside in a company, and the importance of having a mature anti-bribery anti-corruption compliance program are all discussed. Tune in to hear more about how compliance officers can address pressing concerns such as cybersecurity breaches and attacks.  Key Highlights  ·      Navex's benchmark report on compliance programs ·      Board-Compliance Officer Relationship & Cybersecurity in Compliance ·      Necessity of Dedicated Compliance Committees ·      Survey Finds Diverse Views on Compliance Placement in Companies ·      The Importance of Anti-Bribery Compliance for Cybersecurity ·      Compliance Officer Reporting to CISO Dynamics  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Jun 2023 04:00:00 -0000 What is Driving Compliance Engagement at the Board? full 330 Tom Fox Tom and Matt review the Navex 2023 State of Risk and Compliance Report to ask: what is driving Board engagement. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds!  In this episode, co-hosts Tom Fox and Matt Kelly dissect the Navex 2023 State of Risk and Compliance Report. Tom and Matt delve into Navex's annual benchmarking report, which surveyed 1,300 compliance professionals. The report revealed that 53% of respondents described their compliance programs as mature. The speakers question whether the board is driving the conversation or if compliance officers are requesting updates due to potential liability. The report's findings on cybersecurity and privacy concerns, survey results on where compliance should reside in a company, and the importance of having a mature anti-bribery anti-corruption compliance program are all discussed. Tune in to hear more about how compliance officers can address pressing concerns such as cybersecurity breaches and attacks.  Key Highlights  ·      Navex's benchmark report on compliance programs ·      Board-Compliance Officer Relationship & Cybersecurity in Compliance ·      Necessity of Dedicated Compliance Committees ·      Survey Finds Diverse Views on Compliance Placement in Companies ·      The Importance of Anti-Bribery Compliance for Cybersecurity ·      Compliance Officer Reporting to CISO Dynamics  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! 

In this episode, co-hosts Tom Fox and Matt Kelly dissect the Navex 2023 State of Risk and Compliance Report. Tom and Matt delve into Navex's annual benchmarking report, which surveyed 1,300 compliance professionals. The report revealed that 53% of respondents described their compliance programs as mature. The speakers question whether the board is driving the conversation or if compliance officers are requesting updates due to potential liability. The report's findings on cybersecurity and privacy concerns, survey results on where compliance should reside in a company, and the importance of having a mature anti-bribery anti-corruption compliance program are all discussed. Tune in to hear more about how compliance officers can address pressing concerns such as cybersecurity breaches and attacks. 

Key Highlights 

·      Navex's benchmark report on compliance programs

·      Board-Compliance Officer Relationship & Cybersecurity in Compliance

·      Necessity of Dedicated Compliance Committees

·      Survey Finds Diverse Views on Compliance Placement in Companies

·      The Importance of Anti-Bribery Compliance for Cybersecurity

·      Compliance Officer Reporting to CISO Dynamics

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1505 no A Material Weaknesses Catastrophe The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, co-hosts Tom Fox and Matt Kelly dissect a disastrous 10k report filed by Ammo Incorporated, exposing the company’s shocking governance and compliance breakdown. The lack of personnel, internal control processes, and proper segregation of duties are just some of the material weaknesses that led to this corporate disaster. The hosts provide insightful lessons on what companies should avoid to maintain internal governance, share tips on approaching remediation, and emphasize the importance of self-awareness among senior management and the board. Tune in to hear how this niche investigative story was uncovered, and how Twitter played a crucial role in the investigation. Don’t miss Compliance into the Weeds – the podcast that will change the way you think about governance and compliance!  Key Highlights  ·      Material weaknesses in internal governance practices ·      Material weaknesses in operations at Ammo ·      Challenges with Ammo Inc.'s strategic shift and internal controls ·      Remediating Company Failures: Story's Disclosure  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Jun 2023 04:00:00 -0000 A Material Weaknesses Catastrophe full 329 Tom Fox Tom and Matt look at a company which created material weaknesses catastrophe in its 10-K. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, co-hosts Tom Fox and Matt Kelly dissect a disastrous 10k report filed by Ammo Incorporated, exposing the company’s shocking governance and compliance breakdown. The lack of personnel, internal control processes, and proper segregation of duties are just some of the material weaknesses that led to this corporate disaster. The hosts provide insightful lessons on what companies should avoid to maintain internal governance, share tips on approaching remediation, and emphasize the importance of self-awareness among senior management and the board. Tune in to hear how this niche investigative story was uncovered, and how Twitter played a crucial role in the investigation. Don’t miss Compliance into the Weeds – the podcast that will change the way you think about governance and compliance!  Key Highlights  ·      Material weaknesses in internal governance practices ·      Material weaknesses in operations at Ammo ·      Challenges with Ammo Inc.'s strategic shift and internal controls ·      Remediating Company Failures: Story's Disclosure  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds!

In this episode, co-hosts Tom Fox and Matt Kelly dissect a disastrous 10k report filed by Ammo Incorporated, exposing the company’s shocking governance and compliance breakdown. The lack of personnel, internal control processes, and proper segregation of duties are just some of the material weaknesses that led to this corporate disaster. The hosts provide insightful lessons on what companies should avoid to maintain internal governance, share tips on approaching remediation, and emphasize the importance of self-awareness among senior management and the board. Tune in to hear how this niche investigative story was uncovered, and how Twitter played a crucial role in the investigation. Don’t miss Compliance into the Weeds – the podcast that will change the way you think about governance and compliance!

 Key Highlights 

·      Material weaknesses in internal governance practices

·      Material weaknesses in operations at Ammo

·      Challenges with Ammo Inc.'s strategic shift and internal controls

·      Remediating Company Failures: Story's Disclosure

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1299 PCAOB: Expanding Audit Duties-the Impact and Concerns The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds!  Tom Fox and Matt Kelly are back with another thought-provoking episode discussing the proposed new Audit Standard 2405 by the PCAOB. This new proposal requires auditors to evaluate legal violations and noncompliance that could have a material impact on financial statements. While some people believe this is a good idea, others question the cost and whether audit firms are trained for this task. The discussions covered a range of topics, including internal control evaluations, expanding audit duties, Wells Fargo case study, the potential for increased audit fees, and reporting noncompliance to law enforcement. The hosts urge listeners to read the proposal and provide feedback as the final standard is expected to be approved by the SEC. This is a must-listen for compliance professionals who want to stay up-to-date and think critically on the latest audit news.  Key Highlights  ·      Auditing Process for Legal and Compliance Issues ·      New Standards for Auditors Beyond Financial Reporting ·      Expanding PCAOB's Legal Obligations for Auditors ·      Expanding Audit Firm Duties: Impact and Concerns ·      Commenting on Proposed Audit Rule Notable Quotes: “This seems like a huge expansion of what auditors have done in the past.” “Certainly, for example, a large FCPA violation if you're looking at $1,000,000,000 fine, and that would definitely strike me as material.” “The proposal to expand the duties of audit firms is a dramatic expansion of what they were previously asked to do, and it is unclear whether they are fully equipped to handle this responsibility.” “Internal auditors and compliance officers may also have concerns.” Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Jun 2023 04:00:00 -0000 PCAOB: Expanding Audit Duties-the Impact and Concerns full 328 Tom Fox Tom and Matt look at the PCAOB proposed rule to expand audits to consider compliance failures. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds!  Tom Fox and Matt Kelly are back with another thought-provoking episode discussing the proposed new Audit Standard 2405 by the PCAOB. This new proposal requires auditors to evaluate legal violations and noncompliance that could have a material impact on financial statements. While some people believe this is a good idea, others question the cost and whether audit firms are trained for this task. The discussions covered a range of topics, including internal control evaluations, expanding audit duties, Wells Fargo case study, the potential for increased audit fees, and reporting noncompliance to law enforcement. The hosts urge listeners to read the proposal and provide feedback as the final standard is expected to be approved by the SEC. This is a must-listen for compliance professionals who want to stay up-to-date and think critically on the latest audit news.  Key Highlights  ·      Auditing Process for Legal and Compliance Issues ·      New Standards for Auditors Beyond Financial Reporting ·      Expanding PCAOB's Legal Obligations for Auditors ·      Expanding Audit Firm Duties: Impact and Concerns ·      Commenting on Proposed Audit Rule Notable Quotes: “This seems like a huge expansion of what auditors have done in the past.” “Certainly, for example, a large FCPA violation if you're looking at $1,000,000,000 fine, and that would definitely strike me as material.” “The proposal to expand the duties of audit firms is a dramatic expansion of what they were previously asked to do, and it is unclear whether they are fully equipped to handle this responsibility.” “Internal auditors and compliance officers may also have concerns.” Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! 

Tom Fox and Matt Kelly are back with another thought-provoking episode discussing the proposed new Audit Standard 2405 by the PCAOB. This new proposal requires auditors to evaluate legal violations and noncompliance that could have a material impact on financial statements. While some people believe this is a good idea, others question the cost and whether audit firms are trained for this task. The discussions covered a range of topics, including internal control evaluations, expanding audit duties, Wells Fargo case study, the potential for increased audit fees, and reporting noncompliance to law enforcement. The hosts urge listeners to read the proposal and provide feedback as the final standard is expected to be approved by the SEC. This is a must-listen for compliance professionals who want to stay up-to-date and think critically on the latest audit news.

 Key Highlights 

·      Auditing Process for Legal and Compliance Issues

·      New Standards for Auditors Beyond Financial Reporting

·      Expanding PCAOB's Legal Obligations for Auditors

·      Expanding Audit Firm Duties: Impact and Concerns

·      Commenting on Proposed Audit Rule

Notable Quotes:

“This seems like a huge expansion of what auditors have done in the past.”

“Certainly, for example, a large FCPA violation if you're looking at $1,000,000,000 fine, and that would definitely strike me as material.”

“The proposal to expand the duties of audit firms is a dramatic expansion of what they were previously asked to do, and it is unclear whether they are fully equipped to handle this responsibility.”

“Internal auditors and compliance officers may also have concerns.”

Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1267 no Compliance and Middle Managers The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! Join Tom and Matt as they delve into middle managers' crucial role in fostering a culture of ethics and compliance within organizations. In this episode, the hosts discuss compliance officers' challenges in working with middle managers and share some practical tips on building alliances, teaching soft skills, and developing personal relationships. They also examine the use of incentives and consequence management in promoting compliance and highlight the need for positive incentives for middle managers. Take advantage of this insightful and thought-provoking discussion on enforcing internal controls in a compliance program and learn more about the different ways to ensure compliance in gift travel and entertainment expenses. Tune in now to stay ahead in the world of compliance! Key Highlights: The Role of Middle Managers in Compliance Training Middle Managers on Ethical Leadership Investing in middle managers for ethical conduct Compliance: Incentives and Consequence Management  Notable Quotes: “Compliance officers need to think about because you live and die in the success of your corporate culture, and the middle managers are the custodians of that culture.” “Compliance officers should think about how do I help middle managers. How do I coach them on how to be good leaders?” “Nothing is as significant as that personal touch point.” “If the middle manager either turned a blind eye to the unethical practice or should have known about it but was just so aimless about it and didn't care, should that middle manager suffer consequences along with the frontline employees who committed the offense? And the answer was generally yes.”  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 Jun 2023 04:00:00 -0000 Compliance and Middle Managers full 327 Tom Fox Today, Tom and Matt consider the role of Compliance and Middle Managers. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! Join Tom and Matt as they delve into middle managers' crucial role in fostering a culture of ethics and compliance within organizations. In this episode, the hosts discuss compliance officers' challenges in working with middle managers and share some practical tips on building alliances, teaching soft skills, and developing personal relationships. They also examine the use of incentives and consequence management in promoting compliance and highlight the need for positive incentives for middle managers. Take advantage of this insightful and thought-provoking discussion on enforcing internal controls in a compliance program and learn more about the different ways to ensure compliance in gift travel and entertainment expenses. Tune in now to stay ahead in the world of compliance! Key Highlights: The Role of Middle Managers in Compliance Training Middle Managers on Ethical Leadership Investing in middle managers for ethical conduct Compliance: Incentives and Consequence Management  Notable Quotes: “Compliance officers need to think about because you live and die in the success of your corporate culture, and the middle managers are the custodians of that culture.” “Compliance officers should think about how do I help middle managers. How do I coach them on how to be good leaders?” “Nothing is as significant as that personal touch point.” “If the middle manager either turned a blind eye to the unethical practice or should have known about it but was just so aimless about it and didn't care, should that middle manager suffer consequences along with the frontline employees who committed the offense? And the answer was generally yes.”  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Join Tom and Matt as they delve into middle managers' crucial role in fostering a culture of ethics and compliance within organizations. In this episode, the hosts discuss compliance officers' challenges in working with middle managers and share some practical tips on building alliances, teaching soft skills, and developing personal relationships. They also examine the use of incentives and consequence management in promoting compliance and highlight the need for positive incentives for middle managers. Take advantage of this insightful and thought-provoking discussion on enforcing internal controls in a compliance program and learn more about the different ways to ensure compliance in gift travel and entertainment expenses. Tune in now to stay ahead in the world of compliance!

Key Highlights:

  • The Role of Middle Managers in Compliance
  • Training Middle Managers on Ethical Leadership
  • Investing in middle managers for ethical conduct
  • Compliance: Incentives and Consequence Management


 Notable Quotes:

“Compliance officers need to think about because you live and die in the success of your corporate culture, and the middle managers are the custodians of that culture.”

“Compliance officers should think about how do I help middle managers. How do I coach them on how to be good leaders?”

“Nothing is as significant as that personal touch point.”

“If the middle manager either turned a blind eye to the unethical practice or should have known about it but was just so aimless about it and didn't care, should that middle manager suffer consequences along with the frontline employees who committed the offense? And the answer was generally yes.”

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1318 no A Compliance Response on Messaging Apps The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! Join Tom Fox and Matt Kelly on “Compliance into the Weeds” as they delve into the recent SEC crackdown on messaging apps and improper employee use. The hosts explore the challenges of regulating messaging app use and provide solutions emphasizing the importance of corporate culture and risk management strategies. Hear from experts like the DOJ representative who spoke at Compliance Week 2023 and a defense contractor who offers tech solutions to monitor messaging apps on employees’ phones. With GDPR and FINRA regulations to consider, the podcast presents a comprehensive plan for compliance officers that focuses on effective controls, processes, and consequences for policy infractions. Don’t miss out on this informative podcast highlighting the importance of cultivating relationships with internal audit teams, IT teams, and other control departments to ensure proper compliance measures.  Key Highlights:  Risk management of employee messaging app usage Tech solution for monitoring employees’ messaging Corporate Culture Approach to Compliance in Financial Firms Compliance Challenges in Monitoring Employee Communications Building Relationships for Effective Compliance Management  Notable Quotes: “Assess your risks, put a risk management strategy in place, execute that strategy, train your employees, monitor the effectiveness, and remediate as appropriate.” “And the tech company CEO said it is in his mind, People the policies, procedures, people and processes a more culture compliance strategy could work, but you would need to convince employees.” “If they are also violating the policy, that’s bad. And that shows you have a corporate culture problem.” “If it’s corporate culture, how is this any different than any difficult issue we’ve seen in compliance over the past 15 years?” Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 May 2023 04:00:00 -0000 A Compliance Response on Messaging Apps full 326 Tom Fox Tom and Matt look at some compliance solutions for the messaging apps problem. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! Join Tom Fox and Matt Kelly on “Compliance into the Weeds” as they delve into the recent SEC crackdown on messaging apps and improper employee use. The hosts explore the challenges of regulating messaging app use and provide solutions emphasizing the importance of corporate culture and risk management strategies. Hear from experts like the DOJ representative who spoke at Compliance Week 2023 and a defense contractor who offers tech solutions to monitor messaging apps on employees’ phones. With GDPR and FINRA regulations to consider, the podcast presents a comprehensive plan for compliance officers that focuses on effective controls, processes, and consequences for policy infractions. Don’t miss out on this informative podcast highlighting the importance of cultivating relationships with internal audit teams, IT teams, and other control departments to ensure proper compliance measures.  Key Highlights:  Risk management of employee messaging app usage Tech solution for monitoring employees’ messaging Corporate Culture Approach to Compliance in Financial Firms Compliance Challenges in Monitoring Employee Communications Building Relationships for Effective Compliance Management  Notable Quotes: “Assess your risks, put a risk management strategy in place, execute that strategy, train your employees, monitor the effectiveness, and remediate as appropriate.” “And the tech company CEO said it is in his mind, People the policies, procedures, people and processes a more culture compliance strategy could work, but you would need to convince employees.” “If they are also violating the policy, that’s bad. And that shows you have a corporate culture problem.” “If it’s corporate culture, how is this any different than any difficult issue we’ve seen in compliance over the past 15 years?” Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Join Tom Fox and Matt Kelly on “Compliance into the Weeds” as they delve into the recent SEC crackdown on messaging apps and improper employee use. The hosts explore the challenges of regulating messaging app use and provide solutions emphasizing the importance of corporate culture and risk management strategies. Hear from experts like the DOJ representative who spoke at Compliance Week 2023 and a defense contractor who offers tech solutions to monitor messaging apps on employees’ phones. With GDPR and FINRA regulations to consider, the podcast presents a comprehensive plan for compliance officers that focuses on effective controls, processes, and consequences for policy infractions. Don’t miss out on this informative podcast highlighting the importance of cultivating relationships with internal audit teams, IT teams, and other control departments to ensure proper compliance measures.

 Key Highlights: 

  • Risk management of employee messaging app usage
  • Tech solution for monitoring employees’ messaging
  • Corporate Culture Approach to Compliance in Financial Firms
  • Compliance Challenges in Monitoring Employee Communications
  • Building Relationships for Effective Compliance Management


 Notable Quotes:

“Assess your risks, put a risk management strategy in place, execute that strategy, train your employees, monitor the effectiveness, and remediate as appropriate.”

“And the tech company CEO said it is in his mind, People the policies, procedures, people and processes a more culture compliance strategy could work, but you would need to convince employees.”

“If they are also violating the policy, that’s bad. And that shows you have a corporate culture problem.”

“If it’s corporate culture, how is this any different than any difficult issue we’ve seen in compliance over the past 15 years?”

Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1432 no COSO Fraud Risk Management Framework The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! Get ready to dive into the fraud risk management and prevention world with Compliance into the Weeds, hosted by Tom Fox and Matt Kelly. In this episode, they break down the recently released fraud risk framework by COSO and the Association of Certified Fraud Examiners and how it’s necessary for today’s cyber-based fraud and cryptocurrency. They stress the importance of data analytics and internal hotlines to prevent fraud and that all employees need to be trained to detect and prevent fraud in their industry. The hosts also discuss how financial reporting controls may not always detect fraud and how anti-fraud controls are essential. With the rise of new types of fraud like ESG and greenwashing, the hosts recommend the fraud risk report for audit and compliance professionals to stay informed about risks swirling around corporations today. Take advantage of this informative and fascinating podcast. Tune in to Compliance into the Weeds now.  Key Highlights: ·      Fraud Risk Management: COSO Report 2nd Edition ·      Effective Fraud Prevention Training for Employees ·      Importance of Anti-Fraud Controls in Fighting Fraud ·      COSO Fraud Risk Guidance and the Fraud Pentagon Notable Quotes: “But when you think about it, we have a lot of external factors, such as the rise of cryptocurrency, which is riddled with fraud and corruption risk. New methods of cyber-based fraud, which didn’t exist, say, 2016, the 2010s before that. Rise of ransomware in particular, which wasn’t quite a big thing back then that it is all over the place now.” “Most frauds, you the risk management function, you might never catch them. By looking for them, you’ll have to depend on somebody else coming to you from the enterprise, say, I think this person over here is doing something sketchy.” “Fraud is having a moment. And fraud risk is on the forefront of many people’s minds from many different areas.” “We need to do better at finding ways to assess and understand your fraud risk and then implementing new controls as necessary to push that risk down to acceptable levels.” Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 May 2023 04:00:00 -0000 COSO Fraud Risk Management Framework full 325 Tom Fox Matt and Tom take a deep dive into the COSO Fraud Risk Management Framework. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! Get ready to dive into the fraud risk management and prevention world with Compliance into the Weeds, hosted by Tom Fox and Matt Kelly. In this episode, they break down the recently released fraud risk framework by COSO and the Association of Certified Fraud Examiners and how it’s necessary for today’s cyber-based fraud and cryptocurrency. They stress the importance of data analytics and internal hotlines to prevent fraud and that all employees need to be trained to detect and prevent fraud in their industry. The hosts also discuss how financial reporting controls may not always detect fraud and how anti-fraud controls are essential. With the rise of new types of fraud like ESG and greenwashing, the hosts recommend the fraud risk report for audit and compliance professionals to stay informed about risks swirling around corporations today. Take advantage of this informative and fascinating podcast. Tune in to Compliance into the Weeds now.  Key Highlights: ·      Fraud Risk Management: COSO Report 2nd Edition ·      Effective Fraud Prevention Training for Employees ·      Importance of Anti-Fraud Controls in Fighting Fraud ·      COSO Fraud Risk Guidance and the Fraud Pentagon Notable Quotes: “But when you think about it, we have a lot of external factors, such as the rise of cryptocurrency, which is riddled with fraud and corruption risk. New methods of cyber-based fraud, which didn’t exist, say, 2016, the 2010s before that. Rise of ransomware in particular, which wasn’t quite a big thing back then that it is all over the place now.” “Most frauds, you the risk management function, you might never catch them. By looking for them, you’ll have to depend on somebody else coming to you from the enterprise, say, I think this person over here is doing something sketchy.” “Fraud is having a moment. And fraud risk is on the forefront of many people’s minds from many different areas.” “We need to do better at finding ways to assess and understand your fraud risk and then implementing new controls as necessary to push that risk down to acceptable levels.” Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Get ready to dive into the fraud risk management and prevention world with Compliance into the Weeds, hosted by Tom Fox and Matt Kelly. In this episode, they break down the recently released fraud risk framework by COSO and the Association of Certified Fraud Examiners and how it’s necessary for today’s cyber-based fraud and cryptocurrency. They stress the importance of data analytics and internal hotlines to prevent fraud and that all employees need to be trained to detect and prevent fraud in their industry. The hosts also discuss how financial reporting controls may not always detect fraud and how anti-fraud controls are essential. With the rise of new types of fraud like ESG and greenwashing, the hosts recommend the fraud risk report for audit and compliance professionals to stay informed about risks swirling around corporations today. Take advantage of this informative and fascinating podcast. Tune in to Compliance into the Weeds now.

 Key Highlights:

·      Fraud Risk Management: COSO Report 2nd Edition

·      Effective Fraud Prevention Training for Employees

·      Importance of Anti-Fraud Controls in Fighting Fraud

·      COSO Fraud Risk Guidance and the Fraud Pentagon

Notable Quotes:

“But when you think about it, we have a lot of external factors, such as the rise of cryptocurrency, which is riddled with fraud and corruption risk. New methods of cyber-based fraud, which didn’t exist, say, 2016, the 2010s before that. Rise of ransomware in particular, which wasn’t quite a big thing back then that it is all over the place now.”

“Most frauds, you the risk management function, you might never catch them. By looking for them, you’ll have to depend on somebody else coming to you from the enterprise, say, I think this person over here is doing something sketchy.”

“Fraud is having a moment. And fraud risk is on the forefront of many people’s minds from many different areas.”

“We need to do better at finding ways to assess and understand your fraud risk and then implementing new controls as necessary to push that risk down to acceptable levels.”

Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1579 no ComEd 2023 Compliance Report The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking to stay updated on compliance and ethics? Look no further than Compliance into the Weeds, with co-hosts Tom Fox and Matt Kelly!  Looking to stay updated on compliance and ethics? Tune in to the Compliance into the Weeds podcast with hosts. In this episode, they tackle the corruption scandal involving ComEd and its parent Exelon, and highlight the progress made in their compliance program reforms. With the release of their second public progress report, compliance and corporate executives can learn from changing ComEd's company culture and supply chain overhaul. The podcast also dives into integrating compliance concerns into HR processes and identifying supervisory groups that may need closer monitoring. Don't miss out on this informative and insightful episode available now! Key Highlights  ·      Significance of the report ·      Compliance and the Supply Chain ·      Compliance and Exit Interview ·      Using this report going forward  Notable Quotes: “I just have to acknowledge that state of Illinois finally convicted someone for corruption.” “These reports provide not just simply a roadmap of how to change culture, but really a way to think through what may seem like an insurmountable problem.” “I applaud Exelon for establishing this comprehensive supply chain risk management effort and making supply chain compliance a big part of its supply chain risk program.” “It is compliance, which is driving overall supply chain risk management and business efficiency, which is inevitably lead will inevitably lead greater profitability if done correctly and that with a variety of other areas and companies having supply chain risk.”  Resources Matt  LinkedIn Blog Post in Radical Compliance Check out our prior podcast on ComEd’s 2022 Compliance Report here Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 May 2023 04:00:00 -0000 ComEd 2023 Compliance Report full 324 Tom Fox Tom and Matt take a deep dive into the 2023 ComEd Compliance Report. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking to stay updated on compliance and ethics? Look no further than Compliance into the Weeds, with co-hosts Tom Fox and Matt Kelly!  Looking to stay updated on compliance and ethics? Tune in to the Compliance into the Weeds podcast with hosts. In this episode, they tackle the corruption scandal involving ComEd and its parent Exelon, and highlight the progress made in their compliance program reforms. With the release of their second public progress report, compliance and corporate executives can learn from changing ComEd's company culture and supply chain overhaul. The podcast also dives into integrating compliance concerns into HR processes and identifying supervisory groups that may need closer monitoring. Don't miss out on this informative and insightful episode available now! Key Highlights  ·      Significance of the report ·      Compliance and the Supply Chain ·      Compliance and Exit Interview ·      Using this report going forward  Notable Quotes: “I just have to acknowledge that state of Illinois finally convicted someone for corruption.” “These reports provide not just simply a roadmap of how to change culture, but really a way to think through what may seem like an insurmountable problem.” “I applaud Exelon for establishing this comprehensive supply chain risk management effort and making supply chain compliance a big part of its supply chain risk program.” “It is compliance, which is driving overall supply chain risk management and business efficiency, which is inevitably lead will inevitably lead greater profitability if done correctly and that with a variety of other areas and companies having supply chain risk.”  Resources Matt  LinkedIn Blog Post in Radical Compliance Check out our prior podcast on ComEd’s 2022 Compliance Report here Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking to stay updated on compliance and ethics? Look no further than Compliance into the Weeds, with co-hosts Tom Fox and Matt Kelly! 

Looking to stay updated on compliance and ethics? Tune in to the Compliance into the Weeds podcast with hosts. In this episode, they tackle the corruption scandal involving ComEd and its parent Exelon, and highlight the progress made in their compliance program reforms. With the release of their second public progress report, compliance and corporate executives can learn from changing ComEd's company culture and supply chain overhaul. The podcast also dives into integrating compliance concerns into HR processes and identifying supervisory groups that may need closer monitoring. Don't miss out on this informative and insightful episode available now!

Key Highlights 

·      Significance of the report

·      Compliance and the Supply Chain

·      Compliance and Exit Interview

·      Using this report going forward

 Notable Quotes:

“I just have to acknowledge that state of Illinois finally convicted someone for corruption.”

“These reports provide not just simply a roadmap of how to change culture, but really a way to think through what may seem like an insurmountable problem.”

“I applaud Exelon for establishing this comprehensive supply chain risk management effort and making supply chain compliance a big part of its supply chain risk program.”

“It is compliance, which is driving overall supply chain risk management and business efficiency, which is inevitably lead will inevitably lead greater profitability if done correctly and that with a variety of other areas and companies having supply chain risk.”

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Check out our prior podcast on ComEd’s 2022 Compliance Report here

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1577 no BAT Sanctions Enforcement Action The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! Tom Fox and Matt Kelly dive into the recent enforcement action against British American Tobacco (BAT) for violating North Korean sanctions. After years of evading sanctions and funneling over $630 million, regulators have imposed the maximum penalty. Join the podcast to understand the scheme enacted by BAT and the consequences of their actions. They also discuss the need for clarity around who is responsible for ensuring compliance with OFAC and the Justice Department for the next 5 years. With potential penalties looming, the consequences senior management could face, and the extent of compliance commitments expected of BAT, this is a case you want to take advantage of. Listen to Tom and Matt make sense of this perplexing case and what it means for companies in countries like North Korea.  Key Highlights:  ·   Sanctions enforcement on British American Tobacco ·   The North Korean Scheme of British American Tobacco ·   British American Tobacco's Sanctions Compliance Penalty and Requirements ·   Legal implications of BAT's North Korea joint venture Notable Quotes: “I almost think we should just name this series, ‘the hits just keep on coming’ as sanctions is the new FCPA.” “This is a long-running, complicated scheme involving the highest levels of BAT knew this was going on to evade sanctions risks.” “Short of Activision Blizzard, this case strikes me as 1 of the most egregious that we have seen in any form of trade control, export control, trade sanctions, FCPA, or other major corporate white collar.” “They talk about how BAT and its subsidiaries knew full well that US sanctions said you can't do business with North Korea; they were upset over how BAT publicly announced it.”  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 May 2023 04:00:00 -0000 BAT Sanctions Enforcement Action full 323 Tom Fox Matt and Tom take a deep dive into the BAT sanctions enforcement action. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! Tom Fox and Matt Kelly dive into the recent enforcement action against British American Tobacco (BAT) for violating North Korean sanctions. After years of evading sanctions and funneling over $630 million, regulators have imposed the maximum penalty. Join the podcast to understand the scheme enacted by BAT and the consequences of their actions. They also discuss the need for clarity around who is responsible for ensuring compliance with OFAC and the Justice Department for the next 5 years. With potential penalties looming, the consequences senior management could face, and the extent of compliance commitments expected of BAT, this is a case you want to take advantage of. Listen to Tom and Matt make sense of this perplexing case and what it means for companies in countries like North Korea.  Key Highlights:  ·   Sanctions enforcement on British American Tobacco ·   The North Korean Scheme of British American Tobacco ·   British American Tobacco's Sanctions Compliance Penalty and Requirements ·   Legal implications of BAT's North Korea joint venture Notable Quotes: “I almost think we should just name this series, ‘the hits just keep on coming’ as sanctions is the new FCPA.” “This is a long-running, complicated scheme involving the highest levels of BAT knew this was going on to evade sanctions risks.” “Short of Activision Blizzard, this case strikes me as 1 of the most egregious that we have seen in any form of trade control, export control, trade sanctions, FCPA, or other major corporate white collar.” “They talk about how BAT and its subsidiaries knew full well that US sanctions said you can't do business with North Korea; they were upset over how BAT publicly announced it.”  Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Tom Fox and Matt Kelly dive into the recent enforcement action against British American Tobacco (BAT) for violating North Korean sanctions. After years of evading sanctions and funneling over $630 million, regulators have imposed the maximum penalty. Join the podcast to understand the scheme enacted by BAT and the consequences of their actions. They also discuss the need for clarity around who is responsible for ensuring compliance with OFAC and the Justice Department for the next 5 years. With potential penalties looming, the consequences senior management could face, and the extent of compliance commitments expected of BAT, this is a case you want to take advantage of. Listen to Tom and Matt make sense of this perplexing case and what it means for companies in countries like North Korea. 

Key Highlights:

 ·   Sanctions enforcement on British American Tobacco

·   The North Korean Scheme of British American Tobacco

·   British American Tobacco's Sanctions Compliance Penalty and Requirements

·   Legal implications of BAT's North Korea joint venture


Notable Quotes:

“I almost think we should just name this series, ‘the hits just keep on coming’ as sanctions is the new FCPA.”

“This is a long-running, complicated scheme involving the highest levels of BAT knew this was going on to evade sanctions risks.”

“Short of Activision Blizzard, this case strikes me as 1 of the most egregious that we have seen in any form of trade control, export control, trade sanctions, FCPA, or other major corporate white collar.”

“They talk about how BAT and its subsidiaries knew full well that US sanctions said you can't do business with North Korea; they were upset over how BAT publicly announced it.”

 Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1219 no Seagate Sanctions Enforcement Action The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt discuss the recent $300 million fine against Seagate Technology Corporation for violating US sanctions against Huawei. They analyze Seagate's approach to sanctions compliance, especially when compared to Microsoft's response to similar violations. With billions of dollars in sales at stake, the implications of these cases for compliance officers are huge. With frank insights, deep knowledge, and engaging dialogue, Compliance into the Weeds is a must-listen for anyone interested in sanctions compliance and the world of business. Key Highlights: ·      Seagate's controversial business dealings with Huawei ·      Seagate's Sanction Violations and Compliance Programs ·      Seagate's Violation of Foreign Product Rule ·      Expanding Lessons for Compliance Officers  Notable Quotes: "Sanctions is going to be the new FCPA risk," according to the US Justice Department." "The failure to acknowledge your culpability is a key multiplier under the federal sentencing guidelines. And so if this had been any criminal penalty, this fine and penalty would have gone through the roof." "Look to your left, look to your right, see what other people are doing, what they're getting in trouble for, and incorporate those lessons learned into your risk assessment." "Sanctions are hard, and companies can misunderstand this. Well, very specifically, the rule that got Seagate into trouble is known as Foreign Direct Product Rule or what is it exactly, the foreign-produced direct product rule?" Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Apr 2023 04:00:00 -0000 Seagate Sanctions Enforcement Action full Tom Fox Tom and Matt take a deep dive into the Seagate sanctions enforcement action. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt discuss the recent $300 million fine against Seagate Technology Corporation for violating US sanctions against Huawei. They analyze Seagate's approach to sanctions compliance, especially when compared to Microsoft's response to similar violations. With billions of dollars in sales at stake, the implications of these cases for compliance officers are huge. With frank insights, deep knowledge, and engaging dialogue, Compliance into the Weeds is a must-listen for anyone interested in sanctions compliance and the world of business. Key Highlights: ·      Seagate's controversial business dealings with Huawei ·      Seagate's Sanction Violations and Compliance Programs ·      Seagate's Violation of Foreign Product Rule ·      Expanding Lessons for Compliance Officers  Notable Quotes: "Sanctions is going to be the new FCPA risk," according to the US Justice Department." "The failure to acknowledge your culpability is a key multiplier under the federal sentencing guidelines. And so if this had been any criminal penalty, this fine and penalty would have gone through the roof." "Look to your left, look to your right, see what other people are doing, what they're getting in trouble for, and incorporate those lessons learned into your risk assessment." "Sanctions are hard, and companies can misunderstand this. Well, very specifically, the rule that got Seagate into trouble is known as Foreign Direct Product Rule or what is it exactly, the foreign-produced direct product rule?" Resources Matt  LinkedIn Blog Post in Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

In this episode, Tom and Matt discuss the recent $300 million fine against Seagate Technology Corporation for violating US sanctions against Huawei. They analyze Seagate's approach to sanctions compliance, especially when compared to Microsoft's response to similar violations. With billions of dollars in sales at stake, the implications of these cases for compliance officers are huge. With frank insights, deep knowledge, and engaging dialogue, Compliance into the Weeds is a must-listen for anyone interested in sanctions compliance and the world of business.

Key Highlights:

·      Seagate's controversial business dealings with Huawei

·      Seagate's Sanction Violations and Compliance Programs

·      Seagate's Violation of Foreign Product Rule

·      Expanding Lessons for Compliance Officers

 Notable Quotes:

"Sanctions is going to be the new FCPA risk," according to the US Justice Department."

"The failure to acknowledge your culpability is a key multiplier under the federal sentencing guidelines. And so if this had been any criminal penalty, this fine and penalty would have gone through the roof."

"Look to your left, look to your right, see what other people are doing, what they're getting in trouble for, and incorporate those lessons learned into your risk assessment."

"Sanctions are hard, and companies can misunderstand this. Well, very specifically, the rule that got Seagate into trouble is known as Foreign Direct Product Rule or what is it exactly, the foreign-produced direct product rule?"

Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1219 SOX Compliance, PCAOB Inspections and Audits The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Join Tom Fox and Matt Kelly in the latest episode of "Compliance into the Weeds" as they delve into the world of SOX compliance. In this discussion, Matt shares insights from recent webinars and Cornerstone Research studies on class action lawsuits related to accounting issues, while Tom emphasizes the importance of preventing accounting fraud through robust internal control systems.  They shed light on the role of IT controls in ensuring the integrity and security of financial systems, as well as the challenges auditors face in verifying their effectiveness. They go on to discuss how companies can mitigate the risk of fraud by implementing strong access and cybersecurity controls and adapting to new business environments. Don't miss out on this captivating episode which offers practical tips and strategies for compliance officers and industry professionals alike! Key Highlights ·      Current SOX compliance priorities ·      The cost of lawsuits involving SOX compliance failures, financial accounting and financial restatements are going up ·      2023 PCAOB inspection priorities  Notable Quotes: “None of those numbers are going in the right direction for SOX compliance officers.” “A lot of what SOX compliance is and a lot of what auditors are looking at relates to IT controls.” “We rely so much on IT now to run the accounting system, the accounts payable, the finance function, a lot of what you need to assure a strong accounting system is really how are you governing software that is running those apps.” “That, however, assumes that you've got strong cybersecurity and strong access controls around getting into that portal.”  Resources Matt  on LinkedIn Matt’s 3 articles on Radical Compliance a.     SOX Compliance b.     Lawsuits over SOX failures c.     PCAOB Inspection Priorities Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Apr 2023 04:00:00 -0000 SOX Compliance, PCAOB Inspections and Audits full 321 Tom Fox Matt and Tom take a deep dive into current SOX compliance issues. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Join Tom Fox and Matt Kelly in the latest episode of "Compliance into the Weeds" as they delve into the world of SOX compliance. In this discussion, Matt shares insights from recent webinars and Cornerstone Research studies on class action lawsuits related to accounting issues, while Tom emphasizes the importance of preventing accounting fraud through robust internal control systems.  They shed light on the role of IT controls in ensuring the integrity and security of financial systems, as well as the challenges auditors face in verifying their effectiveness. They go on to discuss how companies can mitigate the risk of fraud by implementing strong access and cybersecurity controls and adapting to new business environments. Don't miss out on this captivating episode which offers practical tips and strategies for compliance officers and industry professionals alike! Key Highlights ·      Current SOX compliance priorities ·      The cost of lawsuits involving SOX compliance failures, financial accounting and financial restatements are going up ·      2023 PCAOB inspection priorities  Notable Quotes: “None of those numbers are going in the right direction for SOX compliance officers.” “A lot of what SOX compliance is and a lot of what auditors are looking at relates to IT controls.” “We rely so much on IT now to run the accounting system, the accounts payable, the finance function, a lot of what you need to assure a strong accounting system is really how are you governing software that is running those apps.” “That, however, assumes that you've got strong cybersecurity and strong access controls around getting into that portal.”  Resources Matt  on LinkedIn Matt’s 3 articles on Radical Compliance a.     SOX Compliance b.     Lawsuits over SOX failures c.     PCAOB Inspection Priorities Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Join Tom Fox and Matt Kelly in the latest episode of "Compliance into the Weeds" as they delve into the world of SOX compliance. In this discussion, Matt shares insights from recent webinars and Cornerstone Research studies on class action lawsuits related to accounting issues, while Tom emphasizes the importance of preventing accounting fraud through robust internal control systems. 

They shed light on the role of IT controls in ensuring the integrity and security of financial systems, as well as the challenges auditors face in verifying their effectiveness. They go on to discuss how companies can mitigate the risk of fraud by implementing strong access and cybersecurity controls and adapting to new business environments. Don't miss out on this captivating episode which offers practical tips and strategies for compliance officers and industry professionals alike!

Key Highlights

·      Current SOX compliance priorities

·      The cost of lawsuits involving SOX compliance failures, financial accounting and financial restatements are going up

·      2023 PCAOB inspection priorities

 Notable Quotes:

“None of those numbers are going in the right direction for SOX compliance officers.”

“A lot of what SOX compliance is and a lot of what auditors are looking at relates to IT controls.”

“We rely so much on IT now to run the accounting system, the accounts payable, the finance function, a lot of what you need to assure a strong accounting system is really how are you governing software that is running those apps.”

“That, however, assumes that you've got strong cybersecurity and strong access controls around getting into that portal.”

 Resources

Matt  on LinkedIn

Matt’s 3 articles on Radical Compliance

a.     SOX Compliance

b.     Lawsuits over SOX failures

c.     PCAOB Inspection Priorities

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1516 no Microsoft OFAC Enforcement Action The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, join Tom and Matt as they delve into Microsoft's recent sanctions enforcement action with OFAC. They explore what went wrong and how you can avoid costly compliance failures, from potential red flags to reseller relationships. But it's not all doom and gloom as they discuss how Microsoft implemented a three lines of defense model for sanctions compliance, setting a benchmark for the industry. With Tom and Matt going into the weeds on the importance of centralization and persistent screening technology, this podcast is a must-listen for any compliance officer looking to stay ahead of the curve. Tune in now to find out more!"  Key Highlights  ·      Sanctions compliance case involving Microsoft  ·      Microsoft's Sanctions Compliance Model ·      Microsoft's Sanctions Compliance Program Remediation ·      Sanctions Compliance and OFAC Guidance ·      Impact of Russia invasion on Microsoft operations  Notable Quote: "It's well worth giving the case a good look. So it was, I thought, a great lesson on resellers and the way the hardware and software industry did business."?  Resources Matt  on LinkedIn Matt on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Apr 2023 04:00:00 -0000 Microsoft OFAC Enforcement Action full 320 Tom Fox Tom and Matt take a deep dive into the recent OFAC enforcement action involving Microsoft. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, join Tom and Matt as they delve into Microsoft's recent sanctions enforcement action with OFAC. They explore what went wrong and how you can avoid costly compliance failures, from potential red flags to reseller relationships. But it's not all doom and gloom as they discuss how Microsoft implemented a three lines of defense model for sanctions compliance, setting a benchmark for the industry. With Tom and Matt going into the weeds on the importance of centralization and persistent screening technology, this podcast is a must-listen for any compliance officer looking to stay ahead of the curve. Tune in now to find out more!"  Key Highlights  ·      Sanctions compliance case involving Microsoft  ·      Microsoft's Sanctions Compliance Model ·      Microsoft's Sanctions Compliance Program Remediation ·      Sanctions Compliance and OFAC Guidance ·      Impact of Russia invasion on Microsoft operations  Notable Quote: "It's well worth giving the case a good look. So it was, I thought, a great lesson on resellers and the way the hardware and software industry did business."?  Resources Matt  on LinkedIn Matt on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, join Tom and Matt as they delve into Microsoft's recent sanctions enforcement action with OFAC. They explore what went wrong and how you can avoid costly compliance failures, from potential red flags to reseller relationships. But it's not all doom and gloom as they discuss how Microsoft implemented a three lines of defense model for sanctions compliance, setting a benchmark for the industry. With Tom and Matt going into the weeds on the importance of centralization and persistent screening technology, this podcast is a must-listen for any compliance officer looking to stay ahead of the curve. Tune in now to find out more!" 

Key Highlights 

·      Sanctions compliance case involving Microsoft 

·      Microsoft's Sanctions Compliance Model

·      Microsoft's Sanctions Compliance Program Remediation

·      Sanctions Compliance and OFAC Guidance

·      Impact of Russia invasion on Microsoft operations

 Notable Quote:

"It's well worth giving the case a good look. So it was, I thought, a great lesson on resellers and the way the hardware and software industry did business."?

 Resources

Matt  on LinkedIn

Matt on Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1216 no COSO Framework for Sustainability Controls and Reporting The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, join Tom and Matt as they discuss a new sustainability framework that companies can use to improve their sustainability efforts. The document emphasizes the importance of data governance and using a recognized control framework for effective financial reporting, similar to COSO. The hosts explore the challenges of collecting and managing sustainability data, while highlighting the need for organizations to have a Chief Data Governance Officer and an in-house data committee. They discuss the importance of competent leadership, effective communication, and the role of vendors offering sustainability supporting solutions. Tune in to discover how the right oversight mechanisms can save organizations money by streamlining IT vendors and why sustainability data reporting is the new challenge of achieving Sarbanes Oxley compliance in the 2000s.  Key Highlights ·      COSO Internal Control Framework for Sustainability Disclosures ·      Comparing Sustainability and Ethics/Compliance Frameworks ·      Challenges in Sustainability Data Collection ·      Importance of Data Governance in Large Enterprises  Notable Quotes 1.     “ESG and sustainable business information, on the other hand, tends to be longer term and more qualitative.”  2.     Revenue numbers are in dollar returns and carbon emissions are not. 3.    Radically different sorts of disclosures and data there, but you have to think through.  4.    You're going to have to make sure that the data governance mechanisms you have? Do you have a Chief Data Governance Officer? Some organizations do. Do you have an in house data committee to think about are we collecting all of this data?  Resources Matt  on LinkedIn Matt on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Apr 2023 04:00:00 -0000 COSO Framework for Sustainability Controls and Reporting full 319 Tom Fox Tom and Matt looks at the new COSO Framework for Sustainability. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, join Tom and Matt as they discuss a new sustainability framework that companies can use to improve their sustainability efforts. The document emphasizes the importance of data governance and using a recognized control framework for effective financial reporting, similar to COSO. The hosts explore the challenges of collecting and managing sustainability data, while highlighting the need for organizations to have a Chief Data Governance Officer and an in-house data committee. They discuss the importance of competent leadership, effective communication, and the role of vendors offering sustainability supporting solutions. Tune in to discover how the right oversight mechanisms can save organizations money by streamlining IT vendors and why sustainability data reporting is the new challenge of achieving Sarbanes Oxley compliance in the 2000s.  Key Highlights ·      COSO Internal Control Framework for Sustainability Disclosures ·      Comparing Sustainability and Ethics/Compliance Frameworks ·      Challenges in Sustainability Data Collection ·      Importance of Data Governance in Large Enterprises  Notable Quotes 1.     “ESG and sustainable business information, on the other hand, tends to be longer term and more qualitative.”  2.     Revenue numbers are in dollar returns and carbon emissions are not. 3.    Radically different sorts of disclosures and data there, but you have to think through.  4.    You're going to have to make sure that the data governance mechanisms you have? Do you have a Chief Data Governance Officer? Some organizations do. Do you have an in house data committee to think about are we collecting all of this data?  Resources Matt  on LinkedIn Matt on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, join Tom and Matt as they discuss a new sustainability framework that companies can use to improve their sustainability efforts. The document emphasizes the importance of data governance and using a recognized control framework for effective financial reporting, similar to COSO. The hosts explore the challenges of collecting and managing sustainability data, while highlighting the need for organizations to have a Chief Data Governance Officer and an in-house data committee. They discuss the importance of competent leadership, effective communication, and the role of vendors offering sustainability supporting solutions. Tune in to discover how the right oversight mechanisms can save organizations money by streamlining IT vendors and why sustainability data reporting is the new challenge of achieving Sarbanes Oxley compliance in the 2000s.

 Key Highlights

·      COSO Internal Control Framework for Sustainability Disclosures

·      Comparing Sustainability and Ethics/Compliance Frameworks

·      Challenges in Sustainability Data Collection

·      Importance of Data Governance in Large Enterprises

 Notable Quotes

1.     “ESG and sustainable business information, on the other hand, tends to be longer term and more qualitative.” 

2.     Revenue numbers are in dollar returns and carbon emissions are not.

3.    Radically different sorts of disclosures and data there, but you have to think through. 

4.    You're going to have to make sure that the data governance mechanisms you have? Do you have a Chief Data Governance Officer? Some organizations do. Do you have an in house data committee to think about are we collecting all of this data?

 Resources

Matt  on LinkedIn

Matt on Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1194 no Blackbaud-Failures in Cyber Breach Disclosures The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we discuss the consequences of insufficient disclosure regarding cybersecurity risks as demonstrated in the recent Blackbaud SEC enforcement action. The SEC requires companies to proactively disclose material events and the Delaware Court of Chancery is making it clear that senior executives are responsible for ensuring compliance with disclosure requirements. Tune in next week to hear more Compliance into the Weeds from Tom and Matt.  Key Highlights ·      The cost of poor communication: $3 million lesson from Blackbaud's FCC fine. ·      Disclosure Controls and the Sarbanes Oxley Act ·      The Consequences of Failing to Comply with the SEC and FCC Regulations on Reporting Data Breaches ·      SEC Cracking Heads and What's Next  Notable Quotes: 1.      "Do words still matter? I think that they do." 2.     "I couldn't think of at least 3 million reasons why that was a bad idea in hindsight, and maybe they should have been more forthcoming." 3.      "Oh, well, actually, you know, we missed the revenue target, but we forgot to tell the CFO, people would be fired. You know, there would be heads stuck on the pikes. In front of the office lobby or something like that." 4.     "A compromise of our data security that results in customer or donor personal or payment card data being obtained by unauthorized persons could, and that's the word. Could adversely affect our reputation with our customers and others."  Resources Matt  on LinkedIn Matt on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Mar 2023 04:00:00 -0000 Blackbaud-Failures in Cyber Breach Disclosures full 318 Tom Fox Tom and Matt take a deep dive into cyber breach disclosure failures. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we discuss the consequences of insufficient disclosure regarding cybersecurity risks as demonstrated in the recent Blackbaud SEC enforcement action. The SEC requires companies to proactively disclose material events and the Delaware Court of Chancery is making it clear that senior executives are responsible for ensuring compliance with disclosure requirements. Tune in next week to hear more Compliance into the Weeds from Tom and Matt.  Key Highlights ·      The cost of poor communication: $3 million lesson from Blackbaud's FCC fine. ·      Disclosure Controls and the Sarbanes Oxley Act ·      The Consequences of Failing to Comply with the SEC and FCC Regulations on Reporting Data Breaches ·      SEC Cracking Heads and What's Next  Notable Quotes: 1.      "Do words still matter? I think that they do." 2.     "I couldn't think of at least 3 million reasons why that was a bad idea in hindsight, and maybe they should have been more forthcoming." 3.      "Oh, well, actually, you know, we missed the revenue target, but we forgot to tell the CFO, people would be fired. You know, there would be heads stuck on the pikes. In front of the office lobby or something like that." 4.     "A compromise of our data security that results in customer or donor personal or payment card data being obtained by unauthorized persons could, and that's the word. Could adversely affect our reputation with our customers and others."  Resources Matt  on LinkedIn Matt on Radical Compliance Tom  Instagram Facebook YouTube Twitter LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we discuss the consequences of insufficient disclosure regarding cybersecurity risks as demonstrated in the recent Blackbaud SEC enforcement action. The SEC requires companies to proactively disclose material events and the Delaware Court of Chancery is making it clear that senior executives are responsible for ensuring compliance with disclosure requirements. Tune in next week to hear more Compliance into the Weeds from Tom and Matt. 

Key Highlights

·      The cost of poor communication: $3 million lesson from Blackbaud's FCC fine.

·      Disclosure Controls and the Sarbanes Oxley Act

·      The Consequences of Failing to Comply with the SEC and FCC Regulations on Reporting Data Breaches

·      SEC Cracking Heads and What's Next 

Notable Quotes:

1.      "Do words still matter? I think that they do."

2.     "I couldn't think of at least 3 million reasons why that was a bad idea in hindsight, and maybe they should have been more forthcoming."

3.      "Oh, well, actually, you know, we missed the revenue target, but we forgot to tell the CFO, people would be fired. You know, there would be heads stuck on the pikes. In front of the office lobby or something like that."

4.     "A compromise of our data security that results in customer or donor personal or payment card data being obtained by unauthorized persons could, and that's the word. Could adversely affect our reputation with our customers and others."

 Resources

Matt  on LinkedIn

Matt on Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1211 no SVB Failure-Lessons for Compliance The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I continue our exploration of the collapse of Silicon Valley Bank (SVB) and take a deeper dive into the compliance angles. Silicon Valley Bank had taken some big risks which led to depositors having a near-death experience, shareholders losing all their money, and taxpayers ultimately supporting the bank's bailout. Despite the auditors giving an anodyne report on the bank’s risk management, the board, management and regulators all missed the big strategic risks. As a result, the bank collapsed, leaving Matt to question whether stakeholders were given the right assurance on the right things. Key Highlights ·      What risk management strategies did SVB senior management and Board miss or ignore that could have prevented the financial disaster? ·      Why did SVB's management decline to pursue improvements to their risk management practices after being warned by BlackRock consultants?  ·      Did regulators miss the red flags raised by the San Francisco Fed examiners 18 months before the collapse of SVB? Notable Quotes: 1.     "We should remember that really, the auditors’ report is going to give assurance on two points: Number one, is there a risk of material misstatement in the financial statements? And number two, does the audit firm have any substantial doubt about the organization's ability to continue as a going concern for roughly the next twelve months or so? That's how long it is. But it's those two things." 2.     "When you have Elizabeth Warren and conservatives both raising hell at the same time, it's a valid issue to go and look at then because that does not happen too often." 3.    "It's like nobody had thought about this when really once we rolled back DoddFrank protections and supervisory constraints specifically for mid-sized banks, which Republicans pushed through in 2018, once that happened, that became the systemic risk that regulators had to think about." 4.    "Everybody kind of sort of knew there was a problem, but a whole lot of finger pointing and not enough planning and assurance and communication to the public at large and to investors."  Resources Matt  on LinkedIn Matt on Radical Compliance Tom on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Mar 2023 04:00:00 -0000 SVB Failure-Lessons for Compliance full Tom Fox Tom and Matt take a deep dive into the SVB failure to mine it for the compliance lessons. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I continue our exploration of the collapse of Silicon Valley Bank (SVB) and take a deeper dive into the compliance angles. Silicon Valley Bank had taken some big risks which led to depositors having a near-death experience, shareholders losing all their money, and taxpayers ultimately supporting the bank's bailout. Despite the auditors giving an anodyne report on the bank’s risk management, the board, management and regulators all missed the big strategic risks. As a result, the bank collapsed, leaving Matt to question whether stakeholders were given the right assurance on the right things. Key Highlights ·      What risk management strategies did SVB senior management and Board miss or ignore that could have prevented the financial disaster? ·      Why did SVB's management decline to pursue improvements to their risk management practices after being warned by BlackRock consultants?  ·      Did regulators miss the red flags raised by the San Francisco Fed examiners 18 months before the collapse of SVB? Notable Quotes: 1.     "We should remember that really, the auditors’ report is going to give assurance on two points: Number one, is there a risk of material misstatement in the financial statements? And number two, does the audit firm have any substantial doubt about the organization's ability to continue as a going concern for roughly the next twelve months or so? That's how long it is. But it's those two things." 2.     "When you have Elizabeth Warren and conservatives both raising hell at the same time, it's a valid issue to go and look at then because that does not happen too often." 3.    "It's like nobody had thought about this when really once we rolled back DoddFrank protections and supervisory constraints specifically for mid-sized banks, which Republicans pushed through in 2018, once that happened, that became the systemic risk that regulators had to think about." 4.    "Everybody kind of sort of knew there was a problem, but a whole lot of finger pointing and not enough planning and assurance and communication to the public at large and to investors."  Resources Matt  on LinkedIn Matt on Radical Compliance Tom on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I continue our exploration of the collapse of Silicon Valley Bank (SVB) and take a deeper dive into the compliance angles. Silicon Valley Bank had taken some big risks which led to depositors having a near-death experience, shareholders losing all their money, and taxpayers ultimately supporting the bank's bailout. Despite the auditors giving an anodyne report on the bank’s risk management, the board, management and regulators all missed the big strategic risks. As a result, the bank collapsed, leaving Matt to question whether stakeholders were given the right assurance on the right things.

Key Highlights

·      What risk management strategies did SVB senior management and Board miss or ignore that could have prevented the financial disaster?

·      Why did SVB's management decline to pursue improvements to their risk management practices after being warned by BlackRock consultants? 

·      Did regulators miss the red flags raised by the San Francisco Fed examiners 18 months before the collapse of SVB?

Notable Quotes:

1.     "We should remember that really, the auditors’ report is going to give assurance on two points: Number one, is there a risk of material misstatement in the financial statements? And number two, does the audit firm have any substantial doubt about the organization's ability to continue as a going concern for roughly the next twelve months or so? That's how long it is. But it's those two things."

2.     "When you have Elizabeth Warren and conservatives both raising hell at the same time, it's a valid issue to go and look at then because that does not happen too often."

3.    "It's like nobody had thought about this when really once we rolled back DoddFrank protections and supervisory constraints specifically for mid-sized banks, which Republicans pushed through in 2018, once that happened, that became the systemic risk that regulators had to think about."

4.    "Everybody kind of sort of knew there was a problem, but a whole lot of finger pointing and not enough planning and assurance and communication to the public at large and to investors."

 Resources

Matt  on LinkedIn

Matt on Radical Compliance

Tom on LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1690 Beneath the Bailout: The Collapse of Silicon Valley Bank The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I explore the collapse of Silicon Valley Bank (SBV) and its outcomes. We discuss the consequences if the Federal government fails to bail out Signature Bank in New York and Silicon Valley Bank. The Dodd Frank Act is examined and note that the SBV Chief Risk Officer left 8 months ago and was never replaced is a huge red flag. Will this event cause the Federal Reserve will pause interest rates hikes? Why did Libertarians from the tech industry scream for bail outs? Tom and Matt expertly unpack the complex details within the industry and provide insight and analysis into this relevant and timely industry topic.  Key Highlights The Impact of Silicon Bank and SBV's Failures on the Banking Industry [02:01] Implications of Unsold Silicon Valley Bank Assets on Taxpayers [05:04] Challenge of Businesses Dealing with Employee Benefits under Federal Government Regulations [09:04] Effects of Changes to the Dodd-Frank Act on Midsized Banks [12:54] The Impact of Regulatory Ease on Business Failures [16:47] The Reasons Behind Silicon Valley Bank's Chief Risk Officer Quitting [20:53] The Impact of Social Media on Interest Rate Decisions by the Federal Reserve [24:52]  Notable Quotes: 1.     "So those loans were bringing in maybe 2 or 3 percent interest, but SVP had to be paying out interest rates that might be more at 4 percent. That difference is what undermined the capital structure and the balance sheet of SVB until people started getting skittish, and then they said, Maybe I should pull my money out, which made the bank even more weak, so people got even more skittish." 2.     "The big issue, and this is why the business customer angle is important, is that under FDIC rules, a bank's deposits are insured up to 250,000 dollars per account." 3.     "Is it a business if you can never fail? This was not too big to fail. This was we are not going to let anybody fail." 4.    " You may not know where your key suppliers or your key customers or your key third parties are banking. Maybe you have that information. But does that mean you're going to have to assess the financial health of those financial institutions of your customers? And know if they're going to be able to pay you of your vendors or third-party suppliers? They can meet their payroll to deliver their services."  Resources Matt  on LinkedIn Tom on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Mar 2023 04:00:00 -0000 Beneath the Bailout: The Collapse of Silicon Valley Bank full 316 Tom Fox Tom and Matt take a deep dive into the failure of Silicon Valley Bank. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I explore the collapse of Silicon Valley Bank (SBV) and its outcomes. We discuss the consequences if the Federal government fails to bail out Signature Bank in New York and Silicon Valley Bank. The Dodd Frank Act is examined and note that the SBV Chief Risk Officer left 8 months ago and was never replaced is a huge red flag. Will this event cause the Federal Reserve will pause interest rates hikes? Why did Libertarians from the tech industry scream for bail outs? Tom and Matt expertly unpack the complex details within the industry and provide insight and analysis into this relevant and timely industry topic.  Key Highlights The Impact of Silicon Bank and SBV's Failures on the Banking Industry [02:01] Implications of Unsold Silicon Valley Bank Assets on Taxpayers [05:04] Challenge of Businesses Dealing with Employee Benefits under Federal Government Regulations [09:04] Effects of Changes to the Dodd-Frank Act on Midsized Banks [12:54] The Impact of Regulatory Ease on Business Failures [16:47] The Reasons Behind Silicon Valley Bank's Chief Risk Officer Quitting [20:53] The Impact of Social Media on Interest Rate Decisions by the Federal Reserve [24:52]  Notable Quotes: 1.     "So those loans were bringing in maybe 2 or 3 percent interest, but SVP had to be paying out interest rates that might be more at 4 percent. That difference is what undermined the capital structure and the balance sheet of SVB until people started getting skittish, and then they said, Maybe I should pull my money out, which made the bank even more weak, so people got even more skittish." 2.     "The big issue, and this is why the business customer angle is important, is that under FDIC rules, a bank's deposits are insured up to 250,000 dollars per account." 3.     "Is it a business if you can never fail? This was not too big to fail. This was we are not going to let anybody fail." 4.    " You may not know where your key suppliers or your key customers or your key third parties are banking. Maybe you have that information. But does that mean you're going to have to assess the financial health of those financial institutions of your customers? And know if they're going to be able to pay you of your vendors or third-party suppliers? They can meet their payroll to deliver their services."  Resources Matt  on LinkedIn Tom on LinkedIn Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I explore the collapse of Silicon Valley Bank (SBV) and its outcomes. We discuss the consequences if the Federal government fails to bail out Signature Bank in New York and Silicon Valley Bank. The Dodd Frank Act is examined and note that the SBV Chief Risk Officer left 8 months ago and was never replaced is a huge red flag. Will this event cause the Federal Reserve will pause interest rates hikes? Why did Libertarians from the tech industry scream for bail outs? Tom and Matt expertly unpack the complex details within the industry and provide insight and analysis into this relevant and timely industry topic.

 Key Highlights

The Impact of Silicon Bank and SBV's Failures on the Banking Industry [02:01]

Implications of Unsold Silicon Valley Bank Assets on Taxpayers [05:04]

Challenge of Businesses Dealing with Employee Benefits under Federal Government Regulations [09:04]

Effects of Changes to the Dodd-Frank Act on Midsized Banks [12:54]

The Impact of Regulatory Ease on Business Failures [16:47]

The Reasons Behind Silicon Valley Bank's Chief Risk Officer Quitting [20:53]

The Impact of Social Media on Interest Rate Decisions by the Federal Reserve [24:52]

 Notable Quotes:

1.     "So those loans were bringing in maybe 2 or 3 percent interest, but SVP had to be paying out interest rates that might be more at 4 percent. That difference is what undermined the capital structure and the balance sheet of SVB until people started getting skittish, and then they said, Maybe I should pull my money out, which made the bank even more weak, so people got even more skittish."

2.     "The big issue, and this is why the business customer angle is important, is that under FDIC rules, a bank's deposits are insured up to 250,000 dollars per account."

3.     "Is it a business if you can never fail? This was not too big to fail. This was we are not going to let anybody fail."

4.    " You may not know where your key suppliers or your key customers or your key third parties are banking. Maybe you have that information. But does that mean you're going to have to assess the financial health of those financial institutions of your customers? And know if they're going to be able to pay you of your vendors or third-party suppliers? They can meet their payroll to deliver their services."

 Resources

Matt  on LinkedIn

Tom on LinkedIn

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1675 no Updated DOJ Mandate on Clawbacks The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I dive into the hot topic of clawbacks, with a focus on Deputy Attorney General, Lisa Monaco's new pilot program and Kenneth Polite's take on the use of prosecutorial discretion for organizations. Our hosts explore the opportunities for corporate compliance and HR personnel for clawback solutions and the use of the Federation Corrupt Practices Act (FCPA). They also discuss the need for thorough documentation of personnel involved with and/or accused of illegal conduct, as well as the potential costs to shareholders. Bottom line: Tom Fox and Matt Kelly are here to take you on a deep dive into the complexities of clawbacks and help organizations get compliant and stay compliant. Key Highlights Prosecutorial Discretion and Credit [00:05:24] Implications of the Foreign Corrupt Practices Act on Corporate Compliance and HR [00:09:41] The Mathematics of Corporate Policy Development and Management [00:13:59] Corporate Compliance and the Foreign Corrupt Practices Act [00:17:47] Balancing Compliance and Risk in Business Practices [00:21:49]  Notable Quotes: 1.     "It is part of the department's larger effort to hold individuals more accountable and to have companies basically be participants in that project and to have companies embrace the culture of compliance, how would you hold individuals accountable if you're the company, you'd have that clawback clause over their head, and then you would now have more incentive to actually use it, which is not necessarily an easy thing." 2.     "What we expect companies that use programs to address not only employees who engaged and wrongdoing a connection with conduct under investigation, but also those who had supervisory authority over the employees or business area engaged in in the misconduct and knew of or were willfully blind to the misconduct."  3.     "You must have the clawback policies in place, at the time of resolution, then get a reserve credit for those clawback compensation moneys that you must successively claw it back within the term of the resolution."  4.     "If you do try to recoup the compensation and you fail, you'll still be eligible for up to 25 percent of whatever you were trying to recoup.""  Resources Matt in Radical Compliance Tom in FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Mar 2023 05:00:00 -0000 Updated DOJ Mandate on Clawbacks full 315 Tom Fox Matt and Tom take a deep dive into the Monaco and Polite speeches (and ECCP) on clawbacks. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I dive into the hot topic of clawbacks, with a focus on Deputy Attorney General, Lisa Monaco's new pilot program and Kenneth Polite's take on the use of prosecutorial discretion for organizations. Our hosts explore the opportunities for corporate compliance and HR personnel for clawback solutions and the use of the Federation Corrupt Practices Act (FCPA). They also discuss the need for thorough documentation of personnel involved with and/or accused of illegal conduct, as well as the potential costs to shareholders. Bottom line: Tom Fox and Matt Kelly are here to take you on a deep dive into the complexities of clawbacks and help organizations get compliant and stay compliant. Key Highlights Prosecutorial Discretion and Credit [00:05:24] Implications of the Foreign Corrupt Practices Act on Corporate Compliance and HR [00:09:41] The Mathematics of Corporate Policy Development and Management [00:13:59] Corporate Compliance and the Foreign Corrupt Practices Act [00:17:47] Balancing Compliance and Risk in Business Practices [00:21:49]  Notable Quotes: 1.     "It is part of the department's larger effort to hold individuals more accountable and to have companies basically be participants in that project and to have companies embrace the culture of compliance, how would you hold individuals accountable if you're the company, you'd have that clawback clause over their head, and then you would now have more incentive to actually use it, which is not necessarily an easy thing." 2.     "What we expect companies that use programs to address not only employees who engaged and wrongdoing a connection with conduct under investigation, but also those who had supervisory authority over the employees or business area engaged in in the misconduct and knew of or were willfully blind to the misconduct."  3.     "You must have the clawback policies in place, at the time of resolution, then get a reserve credit for those clawback compensation moneys that you must successively claw it back within the term of the resolution."  4.     "If you do try to recoup the compensation and you fail, you'll still be eligible for up to 25 percent of whatever you were trying to recoup.""  Resources Matt in Radical Compliance Tom in FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I dive into the hot topic of clawbacks, with a focus on Deputy Attorney General, Lisa Monaco's new pilot program and Kenneth Polite's take on the use of prosecutorial discretion for organizations. Our hosts explore the opportunities for corporate compliance and HR personnel for clawback solutions and the use of the Federation Corrupt Practices Act (FCPA). They also discuss the need for thorough documentation of personnel involved with and/or accused of illegal conduct, as well as the potential costs to shareholders. Bottom line: Tom Fox and Matt Kelly are here to take you on a deep dive into the complexities of clawbacks and help organizations get compliant and stay compliant.

Key Highlights

Prosecutorial Discretion and Credit [00:05:24]

Implications of the Foreign Corrupt Practices Act on Corporate Compliance and HR [00:09:41]

The Mathematics of Corporate Policy Development and Management [00:13:59]

Corporate Compliance and the Foreign Corrupt Practices Act [00:17:47]

Balancing Compliance and Risk in Business Practices [00:21:49]

 Notable Quotes:

1.     "It is part of the department's larger effort to hold individuals more accountable and to have companies basically be participants in that project and to have companies embrace the culture of compliance, how would you hold individuals accountable if you're the company, you'd have that clawback clause over their head, and then you would now have more incentive to actually use it, which is not necessarily an easy thing."

2.     "What we expect companies that use programs to address not only employees who engaged and wrongdoing a connection with conduct under investigation, but also those who had supervisory authority over the employees or business area engaged in in the misconduct and knew of or were willfully blind to the misconduct." 

3.     "You must have the clawback policies in place, at the time of resolution, then get a reserve credit for those clawback compensation moneys that you must successively claw it back within the term of the resolution." 

4.     "If you do try to recoup the compensation and you fail, you'll still be eligible for up to 25 percent of whatever you were trying to recoup.""

 Resources

Matt in Radical Compliance

Tom in FCPA Compliance and Ethics Blog

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1451 no Creating a Data Analytics Program The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into data analytics. Tom and Matt provide information on how to capture the data within the enterprise and create a road map within the framework of DOJ's guidance. Additionally, they cover how Excel can be used and suggest giving the data "spit and polish" in order to run it through analytics programs. Compliance into the Weed's podcast is a must-listen for anyone needing information and strategies to excel in their work. Key Highlights ·      The Implementation of Data Analytics Programs [00:03:21] ·      The Business Relationships and Risk Assessment of Data Collection [00:07:17] ·      The Benefits of Utilizing Internal Resources for Compliance Analytics [00:10:48]  ·      Organizing and Utilizing Compliance Data [00:14:42]   ·      Creating a Road Map with Excel [00:18:04] Notable Quotes 1.     "We all talk about data handling. We all say it's important. We go here a justice department official at some conference. He or she will talk about how important data analytics is how they use data analytics. And of course, if they in the public sector can afford to do it, then certainly, we in the private sector must be able to do it. Because government has no money and if they can do it, we must be able to do it."  2.     "It's easy to think it's important in the abstract, but how are you actually going to do it? That's the part that compliance officers need to think through."  3.     "We're really looking for outlier transactions. We're looking for anomalous events of some kind. We're also looking for trend analysis to see if big huge swaths of transactions are moving in a certain direction that might be troublesome." 4.     "You need to be, I think, maybe more on your game with devising a good business case for data analytics. It's easy to think it's important in the abstract, but how are you actually going to do it?"  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Mar 2023 05:00:00 -0000 Creating a Data Analytics Program full 314 Tom Fox Tom and Matt take a deep dive into creating a data analytics program. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into data analytics. Tom and Matt provide information on how to capture the data within the enterprise and create a road map within the framework of DOJ's guidance. Additionally, they cover how Excel can be used and suggest giving the data "spit and polish" in order to run it through analytics programs. Compliance into the Weed's podcast is a must-listen for anyone needing information and strategies to excel in their work. Key Highlights ·      The Implementation of Data Analytics Programs [00:03:21] ·      The Business Relationships and Risk Assessment of Data Collection [00:07:17] ·      The Benefits of Utilizing Internal Resources for Compliance Analytics [00:10:48]  ·      Organizing and Utilizing Compliance Data [00:14:42]   ·      Creating a Road Map with Excel [00:18:04] Notable Quotes 1.     "We all talk about data handling. We all say it's important. We go here a justice department official at some conference. He or she will talk about how important data analytics is how they use data analytics. And of course, if they in the public sector can afford to do it, then certainly, we in the private sector must be able to do it. Because government has no money and if they can do it, we must be able to do it."  2.     "It's easy to think it's important in the abstract, but how are you actually going to do it? That's the part that compliance officers need to think through."  3.     "We're really looking for outlier transactions. We're looking for anomalous events of some kind. We're also looking for trend analysis to see if big huge swaths of transactions are moving in a certain direction that might be troublesome." 4.     "You need to be, I think, maybe more on your game with devising a good business case for data analytics. It's easy to think it's important in the abstract, but how are you actually going to do it?"  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into data analytics. Tom and Matt provide information on how to capture the data within the enterprise and create a road map within the framework of DOJ's guidance. Additionally, they cover how Excel can be used and suggest giving the data "spit and polish" in order to run it through analytics programs. Compliance into the Weed's podcast is a must-listen for anyone needing information and strategies to excel in their work.

Key Highlights

·      The Implementation of Data Analytics Programs [00:03:21]

·      The Business Relationships and Risk Assessment of Data Collection [00:07:17]

·      The Benefits of Utilizing Internal Resources for Compliance Analytics [00:10:48] 

·      Organizing and Utilizing Compliance Data [00:14:42]  

·      Creating a Road Map with Excel [00:18:04]

Notable Quotes

1.     "We all talk about data handling. We all say it's important. We go here a justice department official at some conference. He or she will talk about how important data analytics is how they use data analytics. And of course, if they in the public sector can afford to do it, then certainly, we in the private sector must be able to do it. Because government has no money and if they can do it, we must be able to do it." 

2.     "It's easy to think it's important in the abstract, but how are you actually going to do it? That's the part that compliance officers need to think through." 

3.     "We're really looking for outlier transactions. We're looking for anomalous events of some kind. We're also looking for trend analysis to see if big huge swaths of transactions are moving in a certain direction that might be troublesome."

4.     "You need to be, I think, maybe more on your game with devising a good business case for data analytics. It's easy to think it's important in the abstract, but how are you actually going to do it?"

 Resources

Matt Kelly in Radical Compliance


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1360 no Having a Values Conversation The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into having a values conversation to help companies start a conversation about values. If companies do not focus on values, a vacuum is created where employees are left to make their own decisions, and those decisions may not always be in the company's best interest. Tune into Compliance into the Weeds-Having a Values Conversation to learn how to start the conversation and create a culture of safety. Key Highlights ·      The Importance of Workplace Safety [00:04:58]: ·      The Need for Embedding Conversations about Values in the Workplace [00:09:00] ·      Creating a Positive Corporate Culture. [00:12:26] ·      The Dangers of Not Doing Corporate Compliance Properly [00:15:56]  Notable Quotes  1.     "It makes a lot of sense to try and embed an awareness of them at the beginning, but it feels weird. It's kind of outside of people's comfort zone. It's especially outside of your comfort zone if you are not an ethics and compliance professional."  2.     "These questions can help people like that. And as you had mentioned before, middle managers are the crucial element in all of this."  3.     "It's easy for senior executives. To talk about ethical values. I think for a lot of low-level employees, those messages go in 1 ear and out the other because Why does anybody ever pay attention to what senior management says? It's your middle manager. It's your boss. You pay attention to what they say."  4.     "And these questions really are geared to help those managers, that audience, and their crucial tool."  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Feb 2023 05:00:00 -0000 Having a Values Conversation full 313 Tom Fox Matt and Tom look at how to have a conversation on values, compliance and ethics. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into having a values conversation to help companies start a conversation about values. If companies do not focus on values, a vacuum is created where employees are left to make their own decisions, and those decisions may not always be in the company's best interest. Tune into Compliance into the Weeds-Having a Values Conversation to learn how to start the conversation and create a culture of safety. Key Highlights ·      The Importance of Workplace Safety [00:04:58]: ·      The Need for Embedding Conversations about Values in the Workplace [00:09:00] ·      Creating a Positive Corporate Culture. [00:12:26] ·      The Dangers of Not Doing Corporate Compliance Properly [00:15:56]  Notable Quotes  1.     "It makes a lot of sense to try and embed an awareness of them at the beginning, but it feels weird. It's kind of outside of people's comfort zone. It's especially outside of your comfort zone if you are not an ethics and compliance professional."  2.     "These questions can help people like that. And as you had mentioned before, middle managers are the crucial element in all of this."  3.     "It's easy for senior executives. To talk about ethical values. I think for a lot of low-level employees, those messages go in 1 ear and out the other because Why does anybody ever pay attention to what senior management says? It's your middle manager. It's your boss. You pay attention to what they say."  4.     "And these questions really are geared to help those managers, that audience, and their crucial tool."  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into having a values conversation to help companies start a conversation about values. If companies do not focus on values, a vacuum is created where employees are left to make their own decisions, and those decisions may not always be in the company's best interest. Tune into Compliance into the Weeds-Having a Values Conversation to learn how to start the conversation and create a culture of safety.

Key Highlights

·      The Importance of Workplace Safety [00:04:58]:

·      The Need for Embedding Conversations about Values in the Workplace [00:09:00]

·      Creating a Positive Corporate Culture. [00:12:26]

·      The Dangers of Not Doing Corporate Compliance Properly [00:15:56]

 Notable Quotes

 1.     "It makes a lot of sense to try and embed an awareness of them at the beginning, but it feels weird. It's kind of outside of people's comfort zone. It's especially outside of your comfort zone if you are not an ethics and compliance professional." 

2.     "These questions can help people like that. And as you had mentioned before, middle managers are the crucial element in all of this." 

3.     "It's easy for senior executives. To talk about ethical values. I think for a lot of low-level employees, those messages go in 1 ear and out the other because Why does anybody ever pay attention to what senior management says? It's your middle manager. It's your boss. You pay attention to what they say." 

4.     "And these questions really are geared to help those managers, that audience, and their crucial tool."

 Resources

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1118 no ChatGPT for the Compliance Professional The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into ChatGPT, a natural language processing tool that works by indexing every piece of written content on the Internet. We discuss the impact of the Biden administration's proposals for AI and discusses NIST's voluntary AI framework and  the utility of chat GPT in the workplace. What should your organization consider about incorporating AI into both their shipping decisions and mission-critical processes. If you're interested in efficient and advanced AI technology, you don't want to miss this episode.  Key Highlights Include ·      Impact of Chat GPT on Jobs -The Quality of Chat CPG for non-English Speakers ·      The Biden Administration's Nonbinding Guidelines for Artificial Intelligence. ·      The Benefits of Adopting a Voluntary AI Framework by NIST for Defense Contractors ·      The Impact of Artificial Intelligence on Shipping and Work Processes  Notable Quotes 1. "Chat GPT can answer pretty much anything. It won't necessarily tell you where it is getting this information. It will just give you information pretty much like the way Tom, I am answering your question right now. Just imagine text-based bot answering those questions in the same way. That's what it is."  2. "Will it make your job easier? Probably for a lot of people who struggle to come up with written content. Yes, it could. But specifically then for compliance officers and let's bring it back to what matters for our audience. We'll chat GPT as used by others make my job harder. Compliance officers. Now I think, actually, you have a lot to worry about there, and we could get into that."  3. "But I just view this as a huge boom to anyone who is interested in research, anyone who is interested in learning, can't replace the weekly and business journalist, Matt. So you're good to go at Radical Compliance."  4. "But you have identified really, I think, the heart of the problem that compliance officers need to think about now. Because to me, it's just 1 more tool." Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Feb 2023 05:00:00 -0000 ChatGPT for the Compliance Professional full 312 Tom Fox Tom and Matt go into the weeds on ChatGPT for compliance professionals. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into ChatGPT, a natural language processing tool that works by indexing every piece of written content on the Internet. We discuss the impact of the Biden administration's proposals for AI and discusses NIST's voluntary AI framework and  the utility of chat GPT in the workplace. What should your organization consider about incorporating AI into both their shipping decisions and mission-critical processes. If you're interested in efficient and advanced AI technology, you don't want to miss this episode.  Key Highlights Include ·      Impact of Chat GPT on Jobs -The Quality of Chat CPG for non-English Speakers ·      The Biden Administration's Nonbinding Guidelines for Artificial Intelligence. ·      The Benefits of Adopting a Voluntary AI Framework by NIST for Defense Contractors ·      The Impact of Artificial Intelligence on Shipping and Work Processes  Notable Quotes 1. "Chat GPT can answer pretty much anything. It won't necessarily tell you where it is getting this information. It will just give you information pretty much like the way Tom, I am answering your question right now. Just imagine text-based bot answering those questions in the same way. That's what it is."  2. "Will it make your job easier? Probably for a lot of people who struggle to come up with written content. Yes, it could. But specifically then for compliance officers and let's bring it back to what matters for our audience. We'll chat GPT as used by others make my job harder. Compliance officers. Now I think, actually, you have a lot to worry about there, and we could get into that."  3. "But I just view this as a huge boom to anyone who is interested in research, anyone who is interested in learning, can't replace the weekly and business journalist, Matt. So you're good to go at Radical Compliance."  4. "But you have identified really, I think, the heart of the problem that compliance officers need to think about now. Because to me, it's just 1 more tool." Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into ChatGPT, a natural language processing tool that works by indexing every piece of written content on the Internet. We discuss the impact of the Biden administration's proposals for AI and discusses NIST's voluntary AI framework and  the utility of chat GPT in the workplace. What should your organization consider about incorporating AI into both their shipping decisions and mission-critical processes. If you're interested in efficient and advanced AI technology, you don't want to miss this episode. 

Key Highlights Include


·      Impact of Chat GPT on Jobs -The Quality of Chat CPG for non-English Speakers

·      The Biden Administration's Nonbinding Guidelines for Artificial Intelligence.

·      The Benefits of Adopting a Voluntary AI Framework by NIST for Defense Contractors

·      The Impact of Artificial Intelligence on Shipping and Work Processes

 Notable Quotes

1. "Chat GPT can answer pretty much anything. It won't necessarily tell you where it is getting this information. It will just give you information pretty much like the way Tom, I am answering your question right now. Just imagine text-based bot answering those questions in the same way. That's what it is." 

2. "Will it make your job easier? Probably for a lot of people who struggle to come up with written content. Yes, it could. But specifically then for compliance officers and let's bring it back to what matters for our audience. We'll chat GPT as used by others make my job harder. Compliance officers. Now I think, actually, you have a lot to worry about there, and we could get into that." 

3. "But I just view this as a huge boom to anyone who is interested in research, anyone who is interested in learning, can't replace the weekly and business journalist, Matt. So you're good to go at Radical Compliance." 

4. "But you have identified really, I think, the heart of the problem that compliance officers need to think about now. Because to me, it's just 1 more tool."

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1531 no Activision Blizzard Settlement with SEC The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into the recent Activision Blizzard settlement with the SEC for the company’s failings around internal controls regarding the detection and prevention of sexual harassment and its whistleblower protection laws.  Some of the highlights include: ·      The background facts. ·      The toxic culture which led to the claims. ·      The denials by company officers that anything was wrong or to the validity of the claims.  ·      How does this ruling tie into the Delaware court decision on the duty of oversight? ·      Must there be a material risk for the creation of an information system? ·      What about CCO certification? ·      What does it all mean for CCOs going forward?  Resources SEC Order Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Feb 2023 05:00:00 -0000 Activision Blizzard Settlement with SEC full 311 Tom Fox Tom and Matt take a deep dive into the Activision Blizzard SEC settlement for failure to warn investors about its poor corporate culture. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into the recent Activision Blizzard settlement with the SEC for the company’s failings around internal controls regarding the detection and prevention of sexual harassment and its whistleblower protection laws.  Some of the highlights include: ·      The background facts. ·      The toxic culture which led to the claims. ·      The denials by company officers that anything was wrong or to the validity of the claims.  ·      How does this ruling tie into the Delaware court decision on the duty of oversight? ·      Must there be a material risk for the creation of an information system? ·      What about CCO certification? ·      What does it all mean for CCOs going forward?  Resources SEC Order Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into the recent Activision Blizzard settlement with the SEC for the company’s failings around internal controls regarding the detection and prevention of sexual harassment and its whistleblower protection laws.  Some of the highlights include:

·      The background facts.

·      The toxic culture which led to the claims.

·      The denials by company officers that anything was wrong or to the validity of the claims. 

·      How does this ruling tie into the Delaware court decision on the duty of oversight?

·      Must there be a material risk for the creation of an information system?

·      What about CCO certification?

·      What does it all mean for CCOs going forward?

 Resources

SEC Order

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1732 McDonald’s and Duty of Corporate Officer Oversight The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into recent decision by the Delaware Court of Chancery in the McDonald’s case creating a duty of oversight for corporate officers. Some of the highlights include: ·      Why bad facts can make bad law? ·      The sordid facts of David Fairhurst during his tenure at McDonald’s. ·      The legal rationale. ·      What is Caremark and how did it influence this decision? ·      What does it mean for CCOs? ·      How does this decision intertwine with the Monaco Doctrine, CCO certification and the new Corporate Enforcement Policy?  Resources Tom with a multipart series on the FCPA Compliance and Ethics Blog Matt Kelly with two posts in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Feb 2023 05:00:00 -0000 McDonald’s and Duty of Corporate Officer Oversight full 310 Tom Fox Tom and Matt take a deep dive into the Delaware Court of Chancery decision which creates a duty of oversight for corporate officers. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into recent decision by the Delaware Court of Chancery in the McDonald’s case creating a duty of oversight for corporate officers. Some of the highlights include: ·      Why bad facts can make bad law? ·      The sordid facts of David Fairhurst during his tenure at McDonald’s. ·      The legal rationale. ·      What is Caremark and how did it influence this decision? ·      What does it mean for CCOs? ·      How does this decision intertwine with the Monaco Doctrine, CCO certification and the new Corporate Enforcement Policy?  Resources Tom with a multipart series on the FCPA Compliance and Ethics Blog Matt Kelly with two posts in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into recent decision by the Delaware Court of Chancery in the McDonald’s case creating a duty of oversight for corporate officers. Some of the highlights include:


·      Why bad facts can make bad law?

·      The sordid facts of David Fairhurst during his tenure at McDonald’s.

·      The legal rationale.

·      What is Caremark and how did it influence this decision?

·      What does it mean for CCOs?

·      How does this decision intertwine with the Monaco Doctrine, CCO certification and the new Corporate Enforcement Policy?

 Resources

Tom with a multipart series on the FCPA Compliance and Ethics Blog

Matt Kelly with two posts in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2028 no Update to the Corporate Enforcement Policy The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into the recent Kenneth Polite speech announcing changes to the Corporate Enforcement Policy. Some of the highlights include: ·      What are the policy reasons for the change? ·      Real credit now being given for effective compliance programs. ·      What about self-disclosure? ·      What is the new definition of an effective compliance program? ·      Is the DOJ trying to avoid 5th Amendment concerns? Will it work? ·      New percentage discounts and what they really mean? ·      Why does Matt have more questions?  Resources Tom cited in CCI Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Jan 2023 00:00:00 -0000 Update to the Corporate Enforcement Policy full 309 Tom Fox Tom and Matt take a deep dive into the changes in the DOJ Corporate Enforcement Policy. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into the recent Kenneth Polite speech announcing changes to the Corporate Enforcement Policy. Some of the highlights include: ·      What are the policy reasons for the change? ·      Real credit now being given for effective compliance programs. ·      What about self-disclosure? ·      What is the new definition of an effective compliance program? ·      Is the DOJ trying to avoid 5th Amendment concerns? Will it work? ·      New percentage discounts and what they really mean? ·      Why does Matt have more questions?  Resources Tom cited in CCI Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a deep dive into the recent Kenneth Polite speech announcing changes to the Corporate Enforcement Policy. Some of the highlights include:

·      What are the policy reasons for the change?

·      Real credit now being given for effective compliance programs.

·      What about self-disclosure?

·      What is the new definition of an effective compliance program?

·      Is the DOJ trying to avoid 5th Amendment concerns? Will it work?

·      New percentage discounts and what they really mean?

·      Why does Matt have more questions?

 Resources

Tom cited in CCI

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1545 no Easterbrook, McDonalds Board & Discretionary Firings The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a look the recent SEC enforcement action involving Steve Easterbrook and McDonald’s. Some of the highlights include: ·      Matt tells the tale. ·      Should Easterbrook have originally been fired for cause for violating the company Code of Conduct? ·      What were the factors for the Board in not terminating for cause? ·      Should Easterbrook have been awarded a golden parachute the first time around?  ·      Why did the SEC issue a Cease and Desist Order against McDonalds?  ·      What, if anything, should McDonalds have disclosed?  ·      What does this case say about clawbacks? Corporate culture? ·      What are the lessons learned?  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Jan 2023 05:00:00 -0000 Easterbrook, McDonalds Board & Discretionary Firings full 308 Tom Fox Tom and Matt look at the SEC enforcement action against McDonalds for failures to disclose in the Steve Easterbrook firing. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a look the recent SEC enforcement action involving Steve Easterbrook and McDonald’s. Some of the highlights include: ·      Matt tells the tale. ·      Should Easterbrook have originally been fired for cause for violating the company Code of Conduct? ·      What were the factors for the Board in not terminating for cause? ·      Should Easterbrook have been awarded a golden parachute the first time around?  ·      Why did the SEC issue a Cease and Desist Order against McDonalds?  ·      What, if anything, should McDonalds have disclosed?  ·      What does this case say about clawbacks? Corporate culture? ·      What are the lessons learned?  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a look the recent SEC enforcement action involving Steve Easterbrook and McDonald’s. Some of the highlights include:

·      Matt tells the tale.

·      Should Easterbrook have originally been fired for cause for violating the company Code of Conduct?

·      What were the factors for the Board in not terminating for cause?

·      Should Easterbrook have been awarded a golden parachute the first time around? 

·      Why did the SEC issue a Cease and Desist Order against McDonalds? 

·      What, if anything, should McDonalds have disclosed? 

·      What does this case say about clawbacks? Corporate culture?

·      What are the lessons learned?

 Resources

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1442 no DFS Fines Coinbase The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a look at the recent NY state Department of Financial Services sanction involving the crypto trading platform Coinbase, which just agreed to pay $50 million to the DFS and to spend another $50 million over the next two years to improve its compliance program. Some of the highlights include: ·      What was the fine and associated spending for?  ·      What did the Coinbase compliance program fail on? ·      How did Coinbase’s explosive growth fuel a culture of non-compliance.  ·      How did Coinbase fall further and further behind?  ·      Why and how did the Coinbase solution worsen the problem?  ·      Why does a company need to start with solid foundation of clearly defined procedures?  ·      What is the role of an effective and efficient technology? ·      What are the lessons learned?  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Jan 2023 05:00:00 -0000 DFS Fines Coinbase full 307 Tom Fox Tom and Matt take a deep dive into the DFS fine involving crypto trading platform Coinbase. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a look at the recent NY state Department of Financial Services sanction involving the crypto trading platform Coinbase, which just agreed to pay $50 million to the DFS and to spend another $50 million over the next two years to improve its compliance program. Some of the highlights include: ·      What was the fine and associated spending for?  ·      What did the Coinbase compliance program fail on? ·      How did Coinbase’s explosive growth fuel a culture of non-compliance.  ·      How did Coinbase fall further and further behind?  ·      Why and how did the Coinbase solution worsen the problem?  ·      Why does a company need to start with solid foundation of clearly defined procedures?  ·      What is the role of an effective and efficient technology? ·      What are the lessons learned?  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I take a look at the recent NY state Department of Financial Services sanction involving the crypto trading platform Coinbase, which just agreed to pay $50 million to the DFS and to spend another $50 million over the next two years to improve its compliance program. Some of the highlights include:

·      What was the fine and associated spending for? 

·      What did the Coinbase compliance program fail on?

·      How did Coinbase’s explosive growth fuel a culture of non-compliance. 

·      How did Coinbase fall further and further behind? 

·      Why and how did the Coinbase solution worsen the problem? 

·      Why does a company need to start with solid foundation of clearly defined procedures? 

·      What is the role of an effective and efficient technology?

·      What are the lessons learned?

 Resources

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1525 no Compliance Issues & Events We Are Looking at for 2023 The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I consider a list of compliance issues and events worth watching in the next 12 months, likely to happen in the coming year that will be most consequential for corporate compliance and audit professionals. For 2023 (at least at this point) it is the following: ·      SEC rules on greenhouse gases.  ·      PCAOB enforcement.  ·      The FTC and privacy enforcement.  ·      Fallout from the Oracle FCPA enforcement action. ·      New DOJ corporate crime enforcement policies. ·      An ESG controller. ·      Crash and burn of Elon Musk style corporate governance.   Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Jan 2023 05:00:00 -0000 Compliance Issues & Events We Are Looking at for 2023 full 306 Tom Fox Tom and Matt look at some compliance issues and events they are following for 2023. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I consider a list of compliance issues and events worth watching in the next 12 months, likely to happen in the coming year that will be most consequential for corporate compliance and audit professionals. For 2023 (at least at this point) it is the following: ·      SEC rules on greenhouse gases.  ·      PCAOB enforcement.  ·      The FTC and privacy enforcement.  ·      Fallout from the Oracle FCPA enforcement action. ·      New DOJ corporate crime enforcement policies. ·      An ESG controller. ·      Crash and burn of Elon Musk style corporate governance.   Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt and I consider a list of compliance issues and events worth watching in the next 12 months, likely to happen in the coming year that will be most consequential for corporate compliance and audit professionals. For 2023 (at least at this point) it is the following:


·      SEC rules on greenhouse gases. 

·      PCAOB enforcement. 

·      The FTC and privacy enforcement. 

·      Fallout from the Oracle FCPA enforcement action.

·      New DOJ corporate crime enforcement policies.

·      An ESG controller.

·      Crash and burn of Elon Musk style corporate governance. 


 Resources

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1806 no The Danske Bank AML Enforcement Action The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the Danske Bank AML enforcement action, the bank recently pled guilty to money-laundering violations through its Estonia subsidiaries. Some of the highlights included: ·      The background facts.  ·      What did the home bank know and when? ·      Did a tech failure set this all in motion? ·      The Bank’s attempts to hide the violations from US authorities. ·      Why is the US and not Denmark bringing an enforcement action against a Danish bank? ·      What about CCO certification? ·      The role of the Danish monitor.  Resources Tom in the FCPA Compliance and Ethics Blog Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Dec 2022 05:00:00 -0000 The Danske Bank AML Enforcement Action full 305 Tom Fox Tom and Matt take a deep dive into the Danske Bank AML enforcement action. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the Danske Bank AML enforcement action, the bank recently pled guilty to money-laundering violations through its Estonia subsidiaries. Some of the highlights included: ·      The background facts.  ·      What did the home bank know and when? ·      Did a tech failure set this all in motion? ·      The Bank’s attempts to hide the violations from US authorities. ·      Why is the US and not Denmark bringing an enforcement action against a Danish bank? ·      What about CCO certification? ·      The role of the Danish monitor.  Resources Tom in the FCPA Compliance and Ethics Blog Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the Danske Bank AML enforcement action, the bank recently pled guilty to money-laundering violations through its Estonia subsidiaries.

Some of the highlights included:

·      The background facts. 

·      What did the home bank know and when?

·      Did a tech failure set this all in motion?

·      The Bank’s attempts to hide the violations from US authorities.

·      Why is the US and not Denmark bringing an enforcement action against a Danish bank?

·      What about CCO certification?

·      The role of the Danish monitor.

 Resources

Tom in the FCPA Compliance and Ethics Blog

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1348 no OCC ALJ Slams ex-Wells Fargo Execs The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we continue the ongoing saga of Wells Fargo and its fraudulent accounts scandal. Recently an administrative law judge has affirmed that three former audit and risk management executives at Wells Fargo should face millions in penalties for their sloppy oversight during the bank’s fake-account scandal in the 2010s. The defendants were Claudia Russ Anderson, former group risk officer for Wells Fargo’s community banking division; David Julian, former chief auditor; and Paul McLinko, former executive audit director. Some of the highlights include: ·      The background facts.  ·      Will the fallout from the Wells Fargo fake accounts scandal ever end? (Hint-When our Sun goes supernova.) ·      What is failure to provide a credible challenge? ·      Why are these execs trying to defend their inaction? ·      Why a clear line of authority is needed in compliance. ·      A root cause analysis is a basic Hallmark of an effective compliance program. Why was it separately called out? ·      What are the lessons learned for compliance?  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Dec 2022 05:00:00 -0000 OCC ALJ Slams ex-Wells Fargo Execs full 304 Tom Fox Matt and Tom take a deep dive into a recent ruling by an ALJ on 3 former Wells Fargo execs. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we continue the ongoing saga of Wells Fargo and its fraudulent accounts scandal. Recently an administrative law judge has affirmed that three former audit and risk management executives at Wells Fargo should face millions in penalties for their sloppy oversight during the bank’s fake-account scandal in the 2010s. The defendants were Claudia Russ Anderson, former group risk officer for Wells Fargo’s community banking division; David Julian, former chief auditor; and Paul McLinko, former executive audit director. Some of the highlights include: ·      The background facts.  ·      Will the fallout from the Wells Fargo fake accounts scandal ever end? (Hint-When our Sun goes supernova.) ·      What is failure to provide a credible challenge? ·      Why are these execs trying to defend their inaction? ·      Why a clear line of authority is needed in compliance. ·      A root cause analysis is a basic Hallmark of an effective compliance program. Why was it separately called out? ·      What are the lessons learned for compliance?  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we continue the ongoing saga of Wells Fargo and its fraudulent accounts scandal. Recently an administrative law judge has affirmed that three former audit and risk management executives at Wells Fargo should face millions in penalties for their sloppy oversight during the bank’s fake-account scandal in the 2010s. The defendants were Claudia Russ Anderson, former group risk officer for Wells Fargo’s community banking division; David Julian, former chief auditor; and Paul McLinko, former executive audit director.

Some of the highlights include:

·      The background facts. 

·      Will the fallout from the Wells Fargo fake accounts scandal ever end? (Hint-When our Sun goes supernova.)

·      What is failure to provide a credible challenge?

·      Why are these execs trying to defend their inaction?

·      Why a clear line of authority is needed in compliance.

·      A root cause analysis is a basic Hallmark of an effective compliance program. Why was it separately called out?

·      What are the lessons learned for compliance?

 Resources

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1530 no ABB FCPA Resolution The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject. In this episode, we consider the ABB Foreign Corrupt Practices Act resolution. We deep dive into the case and ask three key questions: (1) How did ABB obtain such a superior resolution? (2) As a three-time FCPA violator, how did the company avoid a monitor? (3) Why was there no requirement for Chief Compliance Officer (CCO) certification? Some of the highlights included: The background facts. The corrupt supplier’s ABB used to facilitate their bribery and corruption. The convoluted self-disclosure in this matter. (Should they have used Twitter with the notation #committedbribery?) What constituted extraordinary cooperation during the pendency of the investigation? What are the implications of real-time sharing during an investigation? What were the steps which demonstrated the exception remediation? A root cause analysis is a basic Hallmark of an effective compliance program. Why was it separately called out? Did the DOJ change its policy from mandatory CCO certification to discretionary?  Resources Tom has a five-part series in the FCPA Compliance and Ethics Blog Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 Dec 2022 05:00:00 -0000 ABB FCPA Resolution full 303 Tom Fox Tom and Matt take a deep dive into the ABB FCPA resolution. The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject. In this episode, we consider the ABB Foreign Corrupt Practices Act resolution. We deep dive into the case and ask three key questions: (1) How did ABB obtain such a superior resolution? (2) As a three-time FCPA violator, how did the company avoid a monitor? (3) Why was there no requirement for Chief Compliance Officer (CCO) certification? Some of the highlights included: The background facts. The corrupt supplier’s ABB used to facilitate their bribery and corruption. The convoluted self-disclosure in this matter. (Should they have used Twitter with the notation #committedbribery?) What constituted extraordinary cooperation during the pendency of the investigation? What are the implications of real-time sharing during an investigation? What were the steps which demonstrated the exception remediation? A root cause analysis is a basic Hallmark of an effective compliance program. Why was it separately called out? Did the DOJ change its policy from mandatory CCO certification to discretionary?  Resources Tom has a five-part series in the FCPA Compliance and Ethics Blog Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject. In this episode, we consider the ABB Foreign Corrupt Practices Act resolution. We deep dive into the case and ask three key questions: (1) How did ABB obtain such a superior resolution? (2) As a three-time FCPA violator, how did the company avoid a monitor? (3) Why was there no requirement for Chief Compliance Officer (CCO) certification?

Some of the highlights included:

  • The background facts.
  • The corrupt supplier’s ABB used to facilitate their bribery and corruption.
  • The convoluted self-disclosure in this matter. (Should they have used Twitter with the notation #committedbribery?)
  • What constituted extraordinary cooperation during the pendency of the investigation?
  • What are the implications of real-time sharing during an investigation?
  • What were the steps which demonstrated the exception remediation?
  • A root cause analysis is a basic Hallmark of an effective compliance program. Why was it separately called out?
  • Did the DOJ change its policy from mandatory CCO certification to discretionary?

 Resources

Tom has a five-part series in the FCPA Compliance and Ethics Blog

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1587 no Mental Health and Compliance Officers The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the very prescient topic of mental health and compliance officers. There is a mental health crisis in the U.S. workforce today, and that applies to compliance officers as well. Matt recently moderated a webinar, hosted by Ethico, on how mental health issues can affect corporate culture and compliance officers themselves. The panelists included Paul Liebman, head of compliance at Harvard University; and Sarah Ross, a former compliance officer at Novartis who now runs a consulting business on burnout, depression, and related issues; and Nick Gallo, co-CEO at Ethico. Some of the highlights included: How the Covid-19 pandemic accelerated the issues of mental health for all workers. We had some great suggestions from the panelists and webinar participants. Understanding the difference between mental health and mental illness, is critical. Consider how your company could weave mental health awareness into training, and especially manager training. Define boundaries between work and personal life. Why find yourself a friend in your field can be a critical mental health safety check. If you feel like you have someone to speak to about stress, you’re more likely to understand and confront that stress. True for compliance officers and other employees alike. There is a strong connection between mental health and a speakup culture generally. If employees feel afraid to speak up about feeling stressed or overworked, would they be equally reluctant to speak up about misconduct.  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 30 Nov 2022 05:00:00 -0000 Mental Health and Compliance Officers full 302 Tom Fox In this episode, we consider the very prescient topic of mental health and compliance officers. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the very prescient topic of mental health and compliance officers. There is a mental health crisis in the U.S. workforce today, and that applies to compliance officers as well. Matt recently moderated a webinar, hosted by Ethico, on how mental health issues can affect corporate culture and compliance officers themselves. The panelists included Paul Liebman, head of compliance at Harvard University; and Sarah Ross, a former compliance officer at Novartis who now runs a consulting business on burnout, depression, and related issues; and Nick Gallo, co-CEO at Ethico. Some of the highlights included: How the Covid-19 pandemic accelerated the issues of mental health for all workers. We had some great suggestions from the panelists and webinar participants. Understanding the difference between mental health and mental illness, is critical. Consider how your company could weave mental health awareness into training, and especially manager training. Define boundaries between work and personal life. Why find yourself a friend in your field can be a critical mental health safety check. If you feel like you have someone to speak to about stress, you’re more likely to understand and confront that stress. True for compliance officers and other employees alike. There is a strong connection between mental health and a speakup culture generally. If employees feel afraid to speak up about feeling stressed or overworked, would they be equally reluctant to speak up about misconduct.  Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the very prescient topic of mental health and compliance officers. There is a mental health crisis in the U.S. workforce today, and that applies to compliance officers as well. Matt recently moderated a webinar, hosted by Ethico, on how mental health issues can affect corporate culture and compliance officers themselves. The panelists included Paul Liebman, head of compliance at Harvard University; and Sarah Ross, a former compliance officer at Novartis who now runs a consulting business on burnout, depression, and related issues; and Nick Gallo, co-CEO at Ethico.

Some of the highlights included:

  • How the Covid-19 pandemic accelerated the issues of mental health for all workers.
  • We had some great suggestions from the panelists and webinar participants.
  • Understanding the difference between mental health and mental illness, is critical.
  • Consider how your company could weave mental health awareness into training, and especially manager training.
  • Define boundaries between work and personal life.
  • Why find yourself a friend in your field can be a critical mental health safety check. If you feel like you have someone to speak to about stress, you’re more likely to understand and confront that stress. True for compliance officers and other employees alike.
  • There is a strong connection between mental health and a speakup culture generally. If employees feel afraid to speak up about feeling stressed or overworked, would they be equally reluctant to speak up about misconduct.

 Resources

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1233 no From $34 Billion to $0 in One Week-FTX and Controls The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent collapse of the crypto currency trading platform FTX. We look at it from a variety of angles. Highlights include: ·       Where does FTX rate in terms of catastrophic business failures? ·       What were the internal control failures? ·       How much fraud was involved? ·       FTX is domiciled outside the US. What does that mean for the review process? ·       Will this lead to regulation over crypto?  Resources Matt Levine in Bloomberg on FTX’s balance sheet Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Nov 2022 05:00:00 -0000 From $34 Billion to $0 in One Week-FTX and Controls full 301 Tom Fox In this episode, we consider the recent collapse of the crypto currency trading platform FTX. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent collapse of the crypto currency trading platform FTX. We look at it from a variety of angles. Highlights include: ·       Where does FTX rate in terms of catastrophic business failures? ·       What were the internal control failures? ·       How much fraud was involved? ·       FTX is domiciled outside the US. What does that mean for the review process? ·       Will this lead to regulation over crypto?  Resources Matt Levine in Bloomberg on FTX’s balance sheet Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent collapse of the crypto currency trading platform FTX. We look at it from a variety of angles. Highlights include:

·       Where does FTX rate in terms of catastrophic business failures?

·       What were the internal control failures?

·       How much fraud was involved?

·       FTX is domiciled outside the US. What does that mean for the review process?

·       Will this lead to regulation over crypto?

 Resources

Matt Levine in Bloomberg on FTX’s balance sheet

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1409 no 300th Anniversary Episode - Policies Policies Policies The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this special 300th Anniversary episode, we consider a recent academic paper which suggests that policies play a small role in persuading employees not to engage in bribery and corruption. Highlights include: ·       What did the paper conclude? ·       What is the role of procedures? ·       Tom details the one function of policies. ·       How does an operationalized compliance program work? ·       What is the intersection of policies and internal controls?  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Nov 2022 05:00:00 -0000 300th Anniversary Episode - Policies Policies Policies full 300 Tom Fox In this special 300th anniversary episode, Tom and Matt look a recent academic paper suggesting compliance policies are of little value. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this special 300th Anniversary episode, we consider a recent academic paper which suggests that policies play a small role in persuading employees not to engage in bribery and corruption. Highlights include: ·       What did the paper conclude? ·       What is the role of procedures? ·       Tom details the one function of policies. ·       How does an operationalized compliance program work? ·       What is the intersection of policies and internal controls?  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this special 300th Anniversary episode, we consider a recent academic paper which suggests that policies play a small role in persuading employees not to engage in bribery and corruption. Highlights include:

·       What did the paper conclude?

·       What is the role of procedures?

·       Tom details the one function of policies.

·       How does an operationalized compliance program work?

·       What is the intersection of policies and internal controls?

 Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1717 no Thinking about Clawbacks The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent SEC requirement for companies to publicly report clawback provisions and their effects in conjunction with the DOJ requirements for clawbacks. Highlights include: ·       What are clawbacks? ·       What does the SEC rule require? ·       Are clawbacks the mirror of executive incentives? ·       How does the DOJ position, as laid out in the Monaco Memo differ (if any) from the SEC requirements? ·       How far down the corporate chain must a clawback provision impact?  Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Nov 2022 04:00:00 -0000 Thinking about Clawbacks full 299 Tom Fox In this episode we consider the recently announced clawback requirements from both the DOJ and SEC. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent SEC requirement for companies to publicly report clawback provisions and their effects in conjunction with the DOJ requirements for clawbacks. Highlights include: ·       What are clawbacks? ·       What does the SEC rule require? ·       Are clawbacks the mirror of executive incentives? ·       How does the DOJ position, as laid out in the Monaco Memo differ (if any) from the SEC requirements? ·       How far down the corporate chain must a clawback provision impact?  Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent SEC requirement for companies to publicly report clawback provisions and their effects in conjunction with the DOJ requirements for clawbacks. Highlights include:

·       What are clawbacks?

·       What does the SEC rule require?

·       Are clawbacks the mirror of executive incentives?

·       How does the DOJ position, as laid out in the Monaco Memo differ (if any) from the SEC requirements?

·       How far down the corporate chain must a clawback provision impact?

 Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1623 no Lafarge and the Cost of Moral Bankruptcy The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent guilty plea by Lafarge, the French cement giant now owned by Holcim, for paying bribes and protection money to ISIS and doing business in Syria with ISIS. Highlights include: ·       What are the background facts? ·       What were the bribery and payment schemes? ·       What are the compliance lessons learned? ·       How will the victim status play out? ·       Who will guarantee the compliance of Lafarge with the Plea Agreement.  Resources Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Oct 2022 04:00:00 -0000 Lafarge and the Cost of Moral Bankruptcy full 298 Tom Fox In this episode, we consider the recent guilty plea by Lafarge, the French cement giant now owned by Holcim, for paying bribes and protection money to ISIS and doing business in Syria with ISIS. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent guilty plea by Lafarge, the French cement giant now owned by Holcim, for paying bribes and protection money to ISIS and doing business in Syria with ISIS. Highlights include: ·       What are the background facts? ·       What were the bribery and payment schemes? ·       What are the compliance lessons learned? ·       How will the victim status play out? ·       Who will guarantee the compliance of Lafarge with the Plea Agreement.  Resources Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent guilty plea by Lafarge, the French cement giant now owned by Holcim, for paying bribes and protection money to ISIS and doing business in Syria with ISIS. Highlights include:

·       What are the background facts?

·       What were the bribery and payment schemes?

·       What are the compliance lessons learned?

·       How will the victim status play out?

·       Who will guarantee the compliance of Lafarge with the Plea Agreement.

 Resources

Tom in the FCPA Compliance and Ethics Blog

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1692 no External Auditors, Fraud Risks and Compliance The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent statement by Paul Munter, the SEC’s acting chief accountant, where he urged auditors to do better at assessing fraud risk among their clients. Highlights include: ·       Why did the SEC raise these points in the first place? What are they trying to tell auditors that they’re doing wrong? ·       Are auditors really equipped to be more aggressive in fraud risk assessment and investigation? ·       What should compliance officers be thinking about vis a vis the SEC’s statement?  ·       What is the role of compliance in in anti-fraud? ·       How will this impact compliance audits by external auditors and fraud examiners?  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Oct 2022 04:00:00 -0000 External Auditors, Fraud Risks and Compliance full 297 Tom Fox Tom and Matt break down the SEC statement on external auditors assessing fraud risk and consider the implications for the compliance professional. The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent statement by Paul Munter, the SEC’s acting chief accountant, where he urged auditors to do better at assessing fraud risk among their clients. Highlights include: ·       Why did the SEC raise these points in the first place? What are they trying to tell auditors that they’re doing wrong? ·       Are auditors really equipped to be more aggressive in fraud risk assessment and investigation? ·       What should compliance officers be thinking about vis a vis the SEC’s statement?  ·       What is the role of compliance in in anti-fraud? ·       How will this impact compliance audits by external auditors and fraud examiners?  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we consider the recent statement by Paul Munter, the SEC’s acting chief accountant, where he urged auditors to do better at assessing fraud risk among their clients. Highlights include:

·       Why did the SEC raise these points in the first place? What are they trying to tell auditors that they’re doing wrong?

·       Are auditors really equipped to be more aggressive in fraud risk assessment and investigation?

·       What should compliance officers be thinking about vis a vis the SEC’s statement? 

·       What is the role of compliance in in anti-fraud?

·       How will this impact compliance audits by external auditors and fraud examiners?

 Resources

Matt in Radical Compliance

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]]> 1668 no A Hockey Scandal in Canada Now the award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at burgeoning scandal from north of the border in Hockey Canada. Highlights include: What happens when your sport is also your national religion? How can you affect a change across an entire sports culture. Who are your stakeholders and are you protecting them? The Wide World of Sports misconduct. When (and if and how) will management start to listen?  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Oct 2022 04:00:00 -0000 A Hockey Scandal in Canada full 296 Tom Fox Inspired by Matt's holiday in Canada, in this episode we consider a hockey scandal in Canada. Now the award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at burgeoning scandal from north of the border in Hockey Canada. Highlights include: What happens when your sport is also your national religion? How can you affect a change across an entire sports culture. Who are your stakeholders and are you protecting them? The Wide World of Sports misconduct. When (and if and how) will management start to listen?  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Now the award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at burgeoning scandal from north of the border in Hockey Canada. Highlights include:

  1. What happens when your sport is also your national religion?
  2. How can you affect a change across an entire sports culture.
  3. Who are your stakeholders and are you protecting them?
  4. The Wide World of Sports misconduct.
  5. When (and if and how) will management start to listen?

 Resources

Matt in Radical Compliance

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]]> 1247 no The Oracle FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced SEC Foreign Corrupt Practices Act enforcement action involving Oracle. Highlights include: Recidivist behavior in same countries with similar schemes. Policy, procedure and internal controls failures. Why no monitor. Compliance programs lessons learned. What about the DOJ?  Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Background The Schemes in Action Parking in India The Comeback and DOJ What it all means Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Oct 2022 04:00:00 -0000 The Oracle FCPA Enforcement Action full 295 Tom Fox Tom and Matt take a deep dive into the Oracle FCPA Enforcement Action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced SEC Foreign Corrupt Practices Act enforcement action involving Oracle. Highlights include: Recidivist behavior in same countries with similar schemes. Policy, procedure and internal controls failures. Why no monitor. Compliance programs lessons learned. What about the DOJ?  Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Background The Schemes in Action Parking in India The Comeback and DOJ What it all means Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced SEC Foreign Corrupt Practices Act enforcement action involving Oracle. Highlights include:

  1. Recidivist behavior in same countries with similar schemes.
  2. Policy, procedure and internal controls failures.
  3. Why no monitor.
  4. Compliance programs lessons learned.
  5. What about the DOJ?

 Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

  1. Background
  2. The Schemes in Action
  3. Parking in India
  4. The Comeback and DOJ
  5. What it all means

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]]> 1261 no Monaco Doctrine and Memo Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced Monaco Doctrine as encapsulated in the Monaco Memo. Highlights include: Corporate accountability. Timeliness in turning over evidence of wrongdoing. Baby Carrots in evaluating corporate history of misconduct. Additions to Evaluation of Corporate Compliance Programs. Tweaks to the Yates Memo formulation. Monitors and Monitorships.  Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Introduction Self-Disclosure Corporate Compliance Programs Monitors The heat is on Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Sep 2022 04:00:00 -0000 Monaco Doctrine and Memo full 294 Tom Fox In this episode, we look at the recently announced Monaco Doctrine as encapsulated in the Monaco Memo Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced Monaco Doctrine as encapsulated in the Monaco Memo. Highlights include: Corporate accountability. Timeliness in turning over evidence of wrongdoing. Baby Carrots in evaluating corporate history of misconduct. Additions to Evaluation of Corporate Compliance Programs. Tweaks to the Yates Memo formulation. Monitors and Monitorships.  Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Introduction Self-Disclosure Corporate Compliance Programs Monitors The heat is on Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recently announced Monaco Doctrine as encapsulated in the Monaco Memo. Highlights include:

  1. Corporate accountability.
  2. Timeliness in turning over evidence of wrongdoing.
  3. Baby Carrots in evaluating corporate history of misconduct.
  4. Additions to Evaluation of Corporate Compliance Programs.
  5. Tweaks to the Yates Memo formulation.
  6. Monitors and Monitorships.

 Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

  1. Introduction
  2. Self-Disclosure
  3. Corporate Compliance Programs
  4. Monitors
  5. The heat is on

Monaco Memo

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]]> 2169 no Polite Speech-A Jolt for Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recent speech Assistant Attorney General Kenneth A. Polite delivered at the University of Texas Law School. The speech focused on corporate and individual accountability in FCPA enforcement actions. Highlights and questions posed include: ·      What are clawbacks and how would they work in practice? ·      Does a lack of corporate clawbacks lead to aggravating factors? ·      How much credit will a company receive by instituting clawbacks? ·      CCO certifications are here to stay. ·      How does the Polite Speech relate to the Monaco Memo.  Resources Matt in Radical Compliance Text of Polite Speech Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Sep 2022 04:00:00 -0000 Polite Speech-A Jolt for Compliance full 293 Tom Fox What are corporate clawbacks and why is there institution so significant for compliance? Tom and Matt explore on this episode of Compliance into the Weeds. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recent speech Assistant Attorney General Kenneth A. Polite delivered at the University of Texas Law School. The speech focused on corporate and individual accountability in FCPA enforcement actions. Highlights and questions posed include: ·      What are clawbacks and how would they work in practice? ·      Does a lack of corporate clawbacks lead to aggravating factors? ·      How much credit will a company receive by instituting clawbacks? ·      CCO certifications are here to stay. ·      How does the Polite Speech relate to the Monaco Memo.  Resources Matt in Radical Compliance Text of Polite Speech Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the recent speech Assistant Attorney General Kenneth A. Polite delivered at the University of Texas Law School. The speech focused on corporate and individual accountability in FCPA enforcement actions. Highlights and questions posed include:

·      What are clawbacks and how would they work in practice?

·      Does a lack of corporate clawbacks lead to aggravating factors?

·      How much credit will a company receive by instituting clawbacks?

·      CCO certifications are here to stay.

·      How does the Polite Speech relate to the Monaco Memo. 

Resources

Matt in Radical Compliance

Text of Polite Speech

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]]> 2096 no Suicide Prevention Hotline and a Speak Up Culture Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the implementation of a national suicide prevention hotline, 988 and consider what it might teach compliance professionals.  Highlights and questions posed include: ·      What is the new national Suicide Prevention hotline?  ·      How does it inform your corporate hotline and speak up culture? ·      How do you teach the trait of listening? ·      Engaged employees are more effective employees. ·      How easy are the mechanics of your hotline to navigate.  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Sep 2022 04:00:00 -0000 Suicide Prevention and a Speak Up Culture full 292 Tom Fox Tom and Matt look at data from the first month of the operation of the National Suicide Prevention Hotline and mine it for compliance data. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the implementation of a national suicide prevention hotline, 988 and consider what it might teach compliance professionals.  Highlights and questions posed include: ·      What is the new national Suicide Prevention hotline?  ·      How does it inform your corporate hotline and speak up culture? ·      How do you teach the trait of listening? ·      Engaged employees are more effective employees. ·      How easy are the mechanics of your hotline to navigate.  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we look at the implementation of a national suicide prevention hotline, 988 and consider what it might teach compliance professionals.  Highlights and questions posed include:

·      What is the new national Suicide Prevention hotline? 

·      How does it inform your corporate hotline and speak up culture?

·      How do you teach the trait of listening?

·      Engaged employees are more effective employees.

·      How easy are the mechanics of your hotline to navigate. 

Resources

Matt in Radical Compliance

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]]> 1103 no Cyber Security Failures Alleged in Mudge Whistleblower Compliant Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we mine the whistleblower allegations by Peiter Zatko, AKA “Mudge” made against Twitter for lessons for the cyber-security professional and wide compliance discipline.  Highlights and questions posed include: ·      The allegations made by Mudge.  ·      Why does an organization need a CISO (or CCO or CECO)?  ·      How did Twitter get hacked, its employees duped and its controls by-passed? ·      What is pedestrian yet telling in this saga? ·      Why data mapping is mandatory if not critical? ·      Where were the external auditors? ·      Is there a Caremark claim here? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 Sep 2022 04:00:00 -0000 Cyber Security Failures Alleged in Mudge Whistleblower Compliant full 191 Tom Fox Tom and Matt continue their deep dive into the Mudge allegations re: Twitter. This week, hacked, duped and internal control failures. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we mine the whistleblower allegations by Peiter Zatko, AKA “Mudge” made against Twitter for lessons for the cyber-security professional and wide compliance discipline.  Highlights and questions posed include: ·      The allegations made by Mudge.  ·      Why does an organization need a CISO (or CCO or CECO)?  ·      How did Twitter get hacked, its employees duped and its controls by-passed? ·      What is pedestrian yet telling in this saga? ·      Why data mapping is mandatory if not critical? ·      Where were the external auditors? ·      Is there a Caremark claim here? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we mine the whistleblower allegations by Peiter Zatko, AKA “Mudge” made against Twitter for lessons for the cyber-security professional and wide compliance discipline.  Highlights and questions posed include:

·      The allegations made by Mudge. 

·      Why does an organization need a CISO (or CCO or CECO)? 

·      How did Twitter get hacked, its employees duped and its controls by-passed?

·      What is pedestrian yet telling in this saga?

·      Why data mapping is mandatory if not critical?

·      Where were the external auditors?

·      Is there a Caremark claim here?

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1041 no Mudge and Whistleblower Allegations Against Twitter Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the recently publicly released whistleblower allegations by Peiter Zatko, AKA “Mudge,” made against his former employer Twitter. Highlights include: The allegations made by Mudge. What possible enforcement actions and legal ramifications could develop? What does this mean for the Twitter/Elon Musk litigation? Where was the Board, and who was the Board? Is there more to come? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 31 Aug 2022 04:00:00 -0000 Mudge and Whistleblower Allegations Against Twitter full 290 Tom Fox In this episode, we explore whistleblower allegations by Peiter Zatko, made against his former employer Twitter. Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the recently publicly released whistleblower allegations by Peiter Zatko, AKA “Mudge,” made against his former employer Twitter. Highlights include: The allegations made by Mudge. What possible enforcement actions and legal ramifications could develop? What does this mean for the Twitter/Elon Musk litigation? Where was the Board, and who was the Board? Is there more to come? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the recently publicly released whistleblower allegations by Peiter Zatko, AKA “Mudge,” made against his former employer Twitter. Highlights include:

  • The allegations made by Mudge.
  • What possible enforcement actions and legal ramifications could develop?
  • What does this mean for the Twitter/Elon Musk litigation?
  • Where was the Board, and who was the Board?
  • Is there more to come?

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1593 no HanesBrands Cyber Security Breach Disclosure Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the recent disclosure by HanesBrands of a cyber security breach which cost the company over $100MM in sales in Q2 2022. Highlights include: Why the public disclosure. What might the SEC rules around disclosure be when adopted. Why CISOs and IT (and a whole host of other corp functions) needs to talk to compliance. What if this were a physical breach? How and where to get started. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Aug 2022 04:00:00 -0000 HanesBrands Cyber Security Breach Disclosure full 289 Tom Fox In this episode, we explore the recent disclosure by HanesBrands of a cyber security breach in Q2. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the recent disclosure by HanesBrands of a cyber security breach which cost the company over $100MM in sales in Q2 2022. Highlights include: Why the public disclosure. What might the SEC rules around disclosure be when adopted. Why CISOs and IT (and a whole host of other corp functions) needs to talk to compliance. What if this were a physical breach? How and where to get started. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the recent disclosure by HanesBrands of a cyber security breach which cost the company over $100MM in sales in Q2 2022. Highlights include:

  • Why the public disclosure.
  • What might the SEC rules around disclosure be when adopted.
  • Why CISOs and IT (and a whole host of other corp functions) needs to talk to compliance.
  • What if this were a physical breach?
  • How and where to get started.

Resources

Matt in Radical Compliance

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]]> 1330 no CFPB on Data Protection Minimums Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the recent CFPB circular which noted a company’s failure to implement adequate data protection measures can qualify as an unfair practice prohibited under the Consumer Financial Protection Act.  Highlights include: ·      The CFPB is going to start bringing charges against more companies for sloppy data protection programs.  ·      Three Key data protection security controls.  ·      Why CISOs and IT needs to talk to compliance. ·      The role of auditing and monitoring. ·      How and where to get started. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Aug 2022 04:00:00 -0000 CFPB on Data Protection Minimums full 288 Tom Fox Matt and Tom take a deep dive into the recent CFPB circular on data protection standards. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the recent CFPB circular which noted a company’s failure to implement adequate data protection measures can qualify as an unfair practice prohibited under the Consumer Financial Protection Act.  Highlights include: ·      The CFPB is going to start bringing charges against more companies for sloppy data protection programs.  ·      Three Key data protection security controls.  ·      Why CISOs and IT needs to talk to compliance. ·      The role of auditing and monitoring. ·      How and where to get started. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the recent CFPB circular which noted a company’s failure to implement adequate data protection measures can qualify as an unfair practice prohibited under the Consumer Financial Protection Act.  Highlights include:

·      The CFPB is going to start bringing charges against more companies for sloppy data protection programs. 

·      Three Key data protection security controls. 

·      Why CISOs and IT needs to talk to compliance.

·      The role of auditing and monitoring.

·      How and where to get started.

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1204 no What is a ‘Reasonably Designed’ Compliance Program Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the new requirements for CCO certification by considering what is meant by the term ‘reasonably designed’ compliance program. Highlights include: ·      What does ‘reasonably designed’ mean in practice and the eyes of the DOJ? ·      Should the DOJ articulate a standard? ·      Are CCOs certifying under greater risk? ·      What have other thought leaders opined? ·      Does this standard impact ‘effective’ compliance programs? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Aug 2022 04:00:00 -0000 What is a ‘Reasonably Designed’ Compliance Program full Tom Fox In this episode, we continue our exploration of the new requirements for CCO certification by considering the term ‘reasonably designed’ compliance program. Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the new requirements for CCO certification by considering what is meant by the term ‘reasonably designed’ compliance program. Highlights include: ·      What does ‘reasonably designed’ mean in practice and the eyes of the DOJ? ·      Should the DOJ articulate a standard? ·      Are CCOs certifying under greater risk? ·      What have other thought leaders opined? ·      Does this standard impact ‘effective’ compliance programs? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we explore the new requirements for CCO certification by considering what is meant by the term ‘reasonably designed’ compliance program. Highlights include:

·      What does ‘reasonably designed’ mean in practice and the eyes of the DOJ?

·      Should the DOJ articulate a standard?

·      Are CCOs certifying under greater risk?

·      What have other thought leaders opined?

·      Does this standard impact ‘effective’ compliance programs?

Resources

Matt in Radical Compliance


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1614 Internal Controls Lessons from Cyber Failures in Wisconsin Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we deep dive into recent failures detected in the state of Wisconsin regarding cyber security risks around election integrity. Highlights include: The risks were uncovered. What is a material risk? Why Multi-Factor Authentication is important cyber security control. What are the consequences of a single point of failure? How and when should redefine a hazard? What does CISA say about MFAs? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Aug 2022 04:00:00 -0000 Internal Controls Lessons from Cyber Failures in Wisconsin full 286 Tom Fox Matt and Tom take a deep dive into recent failures detected in the state of Wisconsin cyber security risks around election integrity Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we deep dive into recent failures detected in the state of Wisconsin regarding cyber security risks around election integrity. Highlights include: The risks were uncovered. What is a material risk? Why Multi-Factor Authentication is important cyber security control. What are the consequences of a single point of failure? How and when should redefine a hazard? What does CISA say about MFAs? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we deep dive into recent failures detected in the state of Wisconsin regarding cyber security risks around election integrity. Highlights include:

  • The risks were uncovered.
  • What is a material risk?
  • Why Multi-Factor Authentication is important cyber security control.
  • What are the consequences of a single point of failure?
  • How and when should redefine a hazard?
  • What does CISA say about MFAs?

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1430 no Lessons from the Biotronik Anti-Kickback Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recent settlement by Biotronik with the DOJ over allegations of the violation of the Anti-Kickback Statue  Highlights include: ·      Background facts. ·      Training programs as cover for bribes. ·      What is lavish entertainment? ·      What were the internal control failures? ·      Controls for high-risk payments. ·      Lessons learned for the ABC compliance professional. Resources Tom in the FCPA Compliance and Ethics Blog Part 1-Background Part 2-the Bribery Schemes and Lessons Learned Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 Jul 2022 04:00:00 -0000 Lessons from the Biotronik Anti-Kickback Enforcement Action full 285 Tom Fox Tom and Matt go into the weeds to review the Biotronik FCA claim. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recent settlement by Biotronik with the DOJ over allegations of the violation of the Anti-Kickback Statue  Highlights include: ·      Background facts. ·      Training programs as cover for bribes. ·      What is lavish entertainment? ·      What were the internal control failures? ·      Controls for high-risk payments. ·      Lessons learned for the ABC compliance professional. Resources Tom in the FCPA Compliance and Ethics Blog Part 1-Background Part 2-the Bribery Schemes and Lessons Learned Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recent settlement by Biotronik with the DOJ over allegations of the violation of the Anti-Kickback Statue  Highlights include:

·      Background facts.

·      Training programs as cover for bribes.

·      What is lavish entertainment?

·      What were the internal control failures?

·      Controls for high-risk payments.

·      Lessons learned for the ABC compliance professional.

Resources

Tom in the FCPA Compliance and Ethics Blog

Part 1-Background

Part 2-the Bribery Schemes and Lessons Learned

Matt in Radical Compliance

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]]> 1366 no The Wild and Wacky World of Control Failures Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recent story of an in-house attorney who was disbarred for fraudulent activities in creating fraudulent claims and fraudulent settlements.  Highlights include: ·      Background facts. ·      Conflicts of Interests. ·      What were the internal control failures? ·      Were they material? ·      Lessons for the compliance professional. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Jul 2022 04:00:00 -0000 The Wild and Wacky World of Control Failures full 284 Tom Fox In this episode, we take a deep dive into the recent story of an in-house attorney who was disbarred for creating fraudulent claims and fraudulent settlements. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recent story of an in-house attorney who was disbarred for fraudulent activities in creating fraudulent claims and fraudulent settlements.  Highlights include: ·      Background facts. ·      Conflicts of Interests. ·      What were the internal control failures? ·      Were they material? ·      Lessons for the compliance professional. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recent story of an in-house attorney who was disbarred for fraudulent activities in creating fraudulent claims and fraudulent settlements.  Highlights include:

·      Background facts.

·      Conflicts of Interests.

·      What were the internal control failures?

·      Were they material?

·      Lessons for the compliance professional.

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1457 no DFS Fines Carnival Cruise Lines for Cyber Failures Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recent New York, Department of Financial Services enforcement action against Carnival Cruise Lines for failures in its cybersecurity reporting obligations.  Highlights include: ·      Why is Carnival Cruise Lines subject to the DFS? ·      What violations occurred? ·      Why were there false certifications? ·      What were the tactical cyber security violations? ·      Were they material? ·      Lessons for the compliance professional. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Jul 2022 04:00:00 -0000 DFS Fines Carnival Cruise Lines for Cyber Failures full 283 Tom Fox In this episode, we take a deep dive into the recent DFS enforcement action against Carnival Cruise Lines for failures in its cybersecurity reporting obligations. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recent New York, Department of Financial Services enforcement action against Carnival Cruise Lines for failures in its cybersecurity reporting obligations.  Highlights include: ·      Why is Carnival Cruise Lines subject to the DFS? ·      What violations occurred? ·      Why were there false certifications? ·      What were the tactical cyber security violations? ·      Were they material? ·      Lessons for the compliance professional. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recent New York, Department of Financial Services enforcement action against Carnival Cruise Lines for failures in its cybersecurity reporting obligations.  Highlights include:

·      Why is Carnival Cruise Lines subject to the DFS?

·      What violations occurred?

·      Why were there false certifications?

·      What were the tactical cyber security violations?

·      Were they material?

·      Lessons for the compliance professional.

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1211 no Dobbs and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into some of the issues for compliance professionals in the wake of the Dobbs decision.  Highlights include: ·      What should compliance professional do now? ·      What are your policies and procedures? ·      Forced-birth v. women’s right states. ·      Where does you company stand? ·      Preparing for compliance challenges ahead. ·      The next wave of civil rights issues destroyed. ·      Ethical practices v. obeying state laws ·      Social media outreach. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Report Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Jun 2022 04:00:00 -0000 Dobbs and Compliance full 282 Tom Fox In this episode, we take a deep dive into some of the issues for compliance professionals in the wake of the Dobbs decision. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into some of the issues for compliance professionals in the wake of the Dobbs decision.  Highlights include: ·      What should compliance professional do now? ·      What are your policies and procedures? ·      Forced-birth v. women’s right states. ·      Where does you company stand? ·      Preparing for compliance challenges ahead. ·      The next wave of civil rights issues destroyed. ·      Ethical practices v. obeying state laws ·      Social media outreach. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Report Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into some of the issues for compliance professionals in the wake of the Dobbs decision.  Highlights include:

·      What should compliance professional do now?

·      What are your policies and procedures?

·      Forced-birth v. women’s right states.

·      Where does you company stand?

·      Preparing for compliance challenges ahead.

·      The next wave of civil rights issues destroyed.

·      Ethical practices v. obeying state laws

·      Social media outreach.

Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Report

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1561 no Unintended Consequences of CCO Certifications Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into some of the unintended consequences of CCO certifications as required by the Department of Justice.  Highlights include: ·      What happened to reasonable and proportional? ·      What about control override? ·      What is the purpose of compliance training? ·      What is effective compliance training? ·      Is compliance training complimentary to compliance training effectiveness? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Jun 2022 04:00:00 -0000 Unintended Consequences of CCO Certifications full 281 Tom Fox In this episode, Tom and Matt look at some of the unintended consequences of CCO certifications required by the DOJ. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into some of the unintended consequences of CCO certifications as required by the Department of Justice.  Highlights include: ·      What happened to reasonable and proportional? ·      What about control override? ·      What is the purpose of compliance training? ·      What is effective compliance training? ·      Is compliance training complimentary to compliance training effectiveness? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into some of the unintended consequences of CCO certifications as required by the Department of Justice.  Highlights include:

·      What happened to reasonable and proportional?

·      What about control override?

·      What is the purpose of compliance training?

·      What is effective compliance training?

·      Is compliance training complimentary to compliance training effectiveness?

Resources


Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1509 no Compliance Craziness Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we deep dive into some recent crazy stories involving CCOs, compliance professionals and the compliance function.  Highlights include: ·      New CCO at Facebook and the results. ·      Did Penn State CCO engage in retaliation, discrimination and harassment? ·      Is a contract non-renewal retaliation? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Jun 2022 04:00:00 -0000 Compliance Craziness full 280 Tom Fox Tom and Matt look at some unusual recent compliance stories. Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we deep dive into some recent crazy stories involving CCOs, compliance professionals and the compliance function.  Highlights include: ·      New CCO at Facebook and the results. ·      Did Penn State CCO engage in retaliation, discrimination and harassment? ·      Is a contract non-renewal retaliation? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In this episode, we deep dive into some recent crazy stories involving CCOs, compliance professionals and the compliance function.  Highlights include:


·      New CCO at Facebook and the results.

·      Did Penn State CCO engage in retaliation, discrimination and harassment?

·      Is a contract non-renewal retaliation?


Resources


Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1464 no Compliance Lessons from the Army Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recently released GAO report on failures in the US Army SHARP program, largely around policies and procedures, with a dash of culture thrown in.  Highlights include: ·      Why has SHARP failed? ·      What is the role of policies and procedures in compliance? What about culture? ·      How can assess your own internal training and communications? ·      What are the 3 questions every compliance professional should ask? ·      What are the lessons for the civilian compliance world? ·      Where does the Army go from here? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Jun 2022 04:00:00 -0000 Compliance Lessons from the Army full 279 Tom Fox In this episode, we take a deep dive into the recently released GAO report on failures in the US Army SHARP program, largely around policies and procedures, with a dash of culture thrown in. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recently released GAO report on failures in the US Army SHARP program, largely around policies and procedures, with a dash of culture thrown in.  Highlights include: ·      Why has SHARP failed? ·      What is the role of policies and procedures in compliance? What about culture? ·      How can assess your own internal training and communications? ·      What are the 3 questions every compliance professional should ask? ·      What are the lessons for the civilian compliance world? ·      Where does the Army go from here? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, we take a deep dive into the recently released GAO report on failures in the US Army SHARP program, largely around policies and procedures, with a dash of culture thrown in.  Highlights include:

·      Why has SHARP failed?

·      What is the role of policies and procedures in compliance? What about culture?

·      How can assess your own internal training and communications?

·      What are the 3 questions every compliance professional should ask?

·      What are the lessons for the civilian compliance world?

·      Where does the Army go from here?

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1289 Compliance Lessons from Uvalde Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In perhaps our most somber podcast ever, Matt and Tom take a deep dive into some of the failures which led to the tragedy in Uvalde, TX, and lessons for the compliance professional. Highlights include: ·      Why have controls? ·      How can a control over-ride impact safety? ·      How can you prepare for emergencies? · Thought-out lines of communication created before the emergency. ·      When leadership is tested.    ·      What is the difference between ethical values and ethical priorities? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Jun 2022 04:00:00 -0000 Compliance Lessons from Uvalde full 277 Tom Fox In perhaps their most somber podcast ever, Matt and Tom take a deep dive into the some of the failures which led to the tragedy in Uvalde TX and lessons for the compliance professional. Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In perhaps our most somber podcast ever, Matt and Tom take a deep dive into some of the failures which led to the tragedy in Uvalde, TX, and lessons for the compliance professional. Highlights include: ·      Why have controls? ·      How can a control over-ride impact safety? ·      How can you prepare for emergencies? · Thought-out lines of communication created before the emergency. ·      When leadership is tested.    ·      What is the difference between ethical values and ethical priorities? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. In perhaps our most somber podcast ever, Matt and Tom take a deep dive into some of the failures which led to the tragedy in Uvalde, TX, and lessons for the compliance professional. Highlights include:

·      Why have controls?

·      How can a control over-ride impact safety?

·      How can you prepare for emergencies?

· Thought-out lines of communication created before the emergency.

·      When leadership is tested.   

·      What is the difference between ethical values and ethical priorities?

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1946 no DOJ Expectations for Compliance & CCOs Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recent speech by Kenneth Polite, the Assistant Attorney General for the Criminal Division. Every compliance professional needs to read his remarks in depth as they give significant insight into what the DOJ expects in compliance programs and CCOs involved in enforcement actions. Highlights include: ·      It all starts with a risk assessment. ·      The importance of culture. ·      Continuous testing and continuous improvement. ·      The role of monitors. ·      CCO certification going forward.    Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 May 2022 04:00:00 -0000 DOJ Expectations for Compliance & CCOs full 277 Tom Fox Tom and Matt take a deep dive into a recent DOJ speech on what the DOJ expects in compliance programs and CCOs involved in enforcement actions. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recent speech by Kenneth Polite, the Assistant Attorney General for the Criminal Division. Every compliance professional needs to read his remarks in depth as they give significant insight into what the DOJ expects in compliance programs and CCOs involved in enforcement actions. Highlights include: ·      It all starts with a risk assessment. ·      The importance of culture. ·      Continuous testing and continuous improvement. ·      The role of monitors. ·      CCO certification going forward.    Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recent speech by Kenneth Polite, the Assistant Attorney General for the Criminal Division. Every compliance professional needs to read his remarks in depth as they give significant insight into what the DOJ expects in compliance programs and CCOs involved in enforcement actions. Highlights include:

·      It all starts with a risk assessment.

·      The importance of culture.

·      Continuous testing and continuous improvement.

·      The role of monitors.

·      CCO certification going forward.   

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1448 no ComEd Compliance Report Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recently released Commonewealth Edison report on the current state of its compliance program. Highlights include: Why is ComEd publicly filing a compliance report? How did Compliance Domains replace specific risks? The use of Design Thinking concepts in the Risk Assessment process. A direct line from Risk Assessments -> continuous monitoring-> continuous improvement-> reporting. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 May 2022 04:00:00 -0000 ComEd Compliance Report full 276 Tom Fox In this episode, Tom and Matt take a deep dive into the recently released Commonewealth Edison report on the current state of its compliance program. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recently released Commonewealth Edison report on the current state of its compliance program. Highlights include: Why is ComEd publicly filing a compliance report? How did Compliance Domains replace specific risks? The use of Design Thinking concepts in the Risk Assessment process. A direct line from Risk Assessments -> continuous monitoring-> continuous improvement-> reporting. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recently released Commonewealth Edison report on the current state of its compliance program. Highlights include:

  • Why is ComEd publicly filing a compliance report?
  • How did Compliance Domains replace specific risks?
  • The use of Design Thinking concepts in the Risk Assessment process.
  • A direct line from Risk Assessments -> continuous monitoring-> continuous improvement-> reporting.

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1313 no JPMorgan Responds to Whistleblower Claims Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recent response of JPMorgan to the whistleblower termination allegations of Shaqualla Williams. Highlights include: What does whistleblower protection actually mean? Can a company fire an employee for other conduct if they have filed a whistleblower report? Will this become the template for getting rid of whistleblowers? Do the substance of whistleblower reports matter? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 May 2022 04:00:00 -0000 JPMorgan Responds to Whistleblower Claims full 275 Tom Fox Tom and Matt take a deep dive into the JPMorgan response to the whistleblower allegations of Shaqualla Williams. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recent response of JPMorgan to the whistleblower termination allegations of Shaqualla Williams. Highlights include: What does whistleblower protection actually mean? Can a company fire an employee for other conduct if they have filed a whistleblower report? Will this become the template for getting rid of whistleblowers? Do the substance of whistleblower reports matter? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recent response of JPMorgan to the whistleblower termination allegations of Shaqualla Williams. Highlights include:

  • What does whistleblower protection actually mean?
  • Can a company fire an employee for other conduct if they have filed a whistleblower report?
  • Will this become the template for getting rid of whistleblowers?
  • Do the substance of whistleblower reports matter?

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1493 no Impacts on Compliance of Russian Invasion of Ukraine Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into some of the impacts on compliance from the Russian invasion of Ukraine. Highlights include: ·      How will the invasion impact your Supply Chain? ·      What are the attributes of a compliance program that can lead your corporate response? ·      What about cyber? ·      Will all this lead to a more holistic ERM response?   Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 May 2022 04:00:00 -0000 Impacts on Compliance of Russian Invasion of Ukraine full 274 Tom Fox Matt and Tom take a deep dive into some of the impacts on compliance from the Russian invasion of Ukraine on supply chain and cyber security. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into some of the impacts on compliance from the Russian invasion of Ukraine. Highlights include: ·      How will the invasion impact your Supply Chain? ·      What are the attributes of a compliance program that can lead your corporate response? ·      What about cyber? ·      Will all this lead to a more holistic ERM response?   Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into some of the impacts on compliance from the Russian invasion of Ukraine. Highlights include:

·      How will the invasion impact your Supply Chain?

·      What are the attributes of a compliance program that can lead your corporate response?

·      What about cyber?

·      Will all this lead to a more holistic ERM response?  

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1482 no Stericycle FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recently released Stericycle FCPA enforcement action. Highlights include: ·      What is a business strategy based upon corruption? ·      Over-expansion and under due diligence in M&A. ·      Document Document Document ·      The Monaco Doctrine at work.   ·      Lessons learned going forward. Resources DPA SEC Order Matt in Radical Compliance Tom in FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 Apr 2022 04:00:00 -0000 Stericycle FCPA Enforcement Action full 273 Tom Fox This week, Matt and Tom take a deep dive into the recently released Stericycle FCPA enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recently released Stericycle FCPA enforcement action. Highlights include: ·      What is a business strategy based upon corruption? ·      Over-expansion and under due diligence in M&A. ·      Document Document Document ·      The Monaco Doctrine at work.   ·      Lessons learned going forward. Resources DPA SEC Order Matt in Radical Compliance Tom in FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a deep dive into the recently released Stericycle FCPA enforcement action. Highlights include:

·      What is a business strategy based upon corruption?

·      Over-expansion and under due diligence in M&A.

·      Document Document Document

·      The Monaco Doctrine at work.  

·      Lessons learned going forward.

Resources

DPA

SEC Order

Matt in Radical Compliance

Tom in FCPA Compliance and Ethics Blog


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1387 no SEC Proposed Rules on Disclosure of Cyber Breaches Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom are joined by Karen Woody and Jonathan Marks to consider the SEC’s recent proposed rules for disclosure of cyber breaches. Highlights include: ·      What was in the proposals? The 60-day comment period is running. ·      The 4-day disclosure requirement for material breaches. ·      The corporate governance issues around Board reporting. ·      What is the SEC trying to accomplish?   ·      Should your company have a cyber-risk committee? If so, who should be on it.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Apr 2022 04:00:00 -0000 SEC Proposed Rules on Disclosure of Cyber Breaches full 272 Tom Fox In this episode, Matt and Tom are joined by Karen Woody and Jonathan Marks to consider the SEC’s recent proposed rules for disclosure of cyber breaches. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom are joined by Karen Woody and Jonathan Marks to consider the SEC’s recent proposed rules for disclosure of cyber breaches. Highlights include: ·      What was in the proposals? The 60-day comment period is running. ·      The 4-day disclosure requirement for material breaches. ·      The corporate governance issues around Board reporting. ·      What is the SEC trying to accomplish?   ·      Should your company have a cyber-risk committee? If so, who should be on it.  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom are joined by Karen Woody and Jonathan Marks to consider the SEC’s recent proposed rules for disclosure of cyber breaches. Highlights include:

·      What was in the proposals? The 60-day comment period is running.

·      The 4-day disclosure requirement for material breaches.

·      The corporate governance issues around Board reporting.

·      What is the SEC trying to accomplish?  

·      Should your company have a cyber-risk committee? If so, who should be on it. 

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1276 no Musk Pulls U-Turn on Twitter Board Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take on strange comings and goings of Elon Musk and his participation on the Twitter Board of Directors. Highlights include: ·      When and how did Musk become Twitter’s largest shareholder? ·      Why was he asked to come on to the Board? ·      SEC filing requirement issues? ·      What role did the various stakeholder groups, including employees have in Musk turning down the Twitter Board seat?   ·      What are the compliance and governance issues to be learned? Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Apr 2022 04:00:00 -0000 Musk Pulls U-Turn on Twitter Board full 271 Tom Fox Tom and Matt look at the abortive Elon Musk to Twitter Board saga. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take on strange comings and goings of Elon Musk and his participation on the Twitter Board of Directors. Highlights include: ·      When and how did Musk become Twitter’s largest shareholder? ·      Why was he asked to come on to the Board? ·      SEC filing requirement issues? ·      What role did the various stakeholder groups, including employees have in Musk turning down the Twitter Board seat?   ·      What are the compliance and governance issues to be learned? Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take on strange comings and goings of Elon Musk and his participation on the Twitter Board of Directors. Highlights include:

·      When and how did Musk become Twitter’s largest shareholder?

·      Why was he asked to come on to the Board?

·      SEC filing requirement issues?

·      What role did the various stakeholder groups, including employees have in Musk turning down the Twitter Board seat?  

·      What are the compliance and governance issues to be learned?

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1509 no Company Size and State of Their Compliance Programs Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a look at the recent ECI report on the Differences Between Small, Medium And Large Enterprises E&C Programs. Highlights include: ·      Where did this ECI report derive its data? ·      Why are middle sized companies in such bad condition regarding compliance program? ·      Why are middle sized companies having the most issues? ·       When is the time for compliance SME at a company?   ·      When should a company institute robust internal controls? Resources  Matt in Radical Compliance ECI Report - Differences Between Small, Medium And Large Enterprises E&C Programs Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Apr 2022 04:00:00 -0000 Company Size and State of Their Compliance Programs full 270 Tom Fox In this episode, Matt and Tom take a look at the recent ECI report on the Differences Between Small, Medium And Large Enterprises E&C Programs. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a look at the recent ECI report on the Differences Between Small, Medium And Large Enterprises E&C Programs. Highlights include: ·      Where did this ECI report derive its data? ·      Why are middle sized companies in such bad condition regarding compliance program? ·      Why are middle sized companies having the most issues? ·       When is the time for compliance SME at a company?   ·      When should a company institute robust internal controls? Resources  Matt in Radical Compliance ECI Report - Differences Between Small, Medium And Large Enterprises E&C Programs Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a look at the recent ECI report on the Differences Between Small, Medium And Large Enterprises E&C Programs. Highlights include:

·      Where did this ECI report derive its data?

·      Why are middle sized companies in such bad condition regarding compliance program?

·      Why are middle sized companies having the most issues?

·       When is the time for compliance SME at a company?  

·      When should a company institute robust internal controls?

Resources 

Matt in Radical Compliance

ECI Report - Differences Between Small, Medium And Large Enterprises E&C Programs

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1398 no CCO Certification of Compliance Programs Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take at the recent remarks by DOJ Assistant Attorney General Kenneth Polite on CCO certifications of compliance programs after the conclusion of a DPA. Highlights include: ·      Where did this issue come from? ·      Is its implementation looming? ·      What are the implications for individual CCO liability? ·       What about CEO liability for recidivism?   ·      What are the corporate governance implications? Resources  Text of Kenneth Polite speech Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 30 Mar 2022 04:00:00 -0000 CCO Certification of Compliance Programs full Tom Fox Matt and Tom consider remarks by Kennth Polite about CCO certifications of compliance programs. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take at the recent remarks by DOJ Assistant Attorney General Kenneth Polite on CCO certifications of compliance programs after the conclusion of a DPA. Highlights include: ·      Where did this issue come from? ·      Is its implementation looming? ·      What are the implications for individual CCO liability? ·       What about CEO liability for recidivism?   ·      What are the corporate governance implications? Resources  Text of Kenneth Polite speech Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take at the recent remarks by DOJ Assistant Attorney General Kenneth Polite on CCO certifications of compliance programs after the conclusion of a DPA. Highlights include:

·      Where did this issue come from?

·      Is its implementation looming?

·      What are the implications for individual CCO liability?

·       What about CEO liability for recidivism?  

·      What are the corporate governance implications?

Resources 

Text of Kenneth Polite speech

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]]> 1412 Proposed SEC Climate Change Risk Disclosure Regulations Released Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a look at the proposed SEC climate change risk disclosure regulations released on Monday. Highlights include: The history of this issue. Is the SEC over-reaching? Why climate change regulations only? What about a broader set on ESG? The role of internal controls, audit and oversight.  What does all this mean for the compliance function? Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Mar 2022 04:00:00 -0000 Proposed SEC Climate Change Risk Disclosure Regulations Released full 268 Tom Fox Matt and Tom review the recently released proposed SEC climate change risk disclosure regs released. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a look at the proposed SEC climate change risk disclosure regulations released on Monday. Highlights include: The history of this issue. Is the SEC over-reaching? Why climate change regulations only? What about a broader set on ESG? The role of internal controls, audit and oversight.  What does all this mean for the compliance function? Resources Matt Kelly in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a look at the proposed SEC climate change risk disclosure regulations released on Monday. Highlights include:

  • The history of this issue.
  • Is the SEC over-reaching?
  • Why climate change regulations only? What about a broader set on ESG?
  • The role of internal controls, audit and oversight. 
  • What does all this mean for the compliance function?

Resources

Matt Kelly in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1259 no A Ukrainian Compliance Professional-Tim Khashinov-Batirov Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom visit with our Ukrainian colleague Tim Khashinov-Batirov. Tim is well-known in the worldwide compliance community as Compliance Man. He is currently a refugee in The Netherlands at the time of this recording. In this episode, Tim talks about his escape from Ukraine, what life has been like as a displaced person in Europe, the current and burgeoning refugee crisis and some things that we in America can do right now to help those still in Ukraine and those who are refugees. Other topics we consider include: ·      How the bonds of brotherhood between Russia, Belarus and Ukraine may have been permanently destroyed? ·      What do ordinary Russians think about the invasion? ·      Armies like companies run on culture. Why and how has the corruption in the Russian Army hollowed out its culture from the inside? ·       The leadership of President Zelensky and his impact on the Ukrainian people.   ·      The negative leadership of Russia President Putin. Resources for Donations for Ukraine and Ukrainians UNICEF Salvation Army Red Cross Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Mar 2022 04:00:00 -0000 A Ukrainian Compliance Professional-Tim Khashinov-Batirov full Tom Fox Tim Khashinov-Batirov. joins Tom & Matt to discuss his escape from Ukraine, what life has been like as a displaced person in Europe, the current and burgeoning refugee crisis and some things that we in America can do right now to help those still in Ukraine and its refugees. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom visit with our Ukrainian colleague Tim Khashinov-Batirov. Tim is well-known in the worldwide compliance community as Compliance Man. He is currently a refugee in The Netherlands at the time of this recording. In this episode, Tim talks about his escape from Ukraine, what life has been like as a displaced person in Europe, the current and burgeoning refugee crisis and some things that we in America can do right now to help those still in Ukraine and those who are refugees. Other topics we consider include: ·      How the bonds of brotherhood between Russia, Belarus and Ukraine may have been permanently destroyed? ·      What do ordinary Russians think about the invasion? ·      Armies like companies run on culture. Why and how has the corruption in the Russian Army hollowed out its culture from the inside? ·       The leadership of President Zelensky and his impact on the Ukrainian people.   ·      The negative leadership of Russia President Putin. Resources for Donations for Ukraine and Ukrainians UNICEF Salvation Army Red Cross Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom visit with our Ukrainian colleague Tim Khashinov-Batirov. Tim is well-known in the worldwide compliance community as Compliance Man. He is currently a refugee in The Netherlands at the time of this recording. In this episode, Tim talks about his escape from Ukraine, what life has been like as a displaced person in Europe, the current and burgeoning refugee crisis and some things that we in America can do right now to help those still in Ukraine and those who are refugees. Other topics we consider include:

·      How the bonds of brotherhood between Russia, Belarus and Ukraine may have been permanently destroyed?

·      What do ordinary Russians think about the invasion?

·      Armies like companies run on culture. Why and how has the corruption in the Russian Army hollowed out its culture from the inside?

·       The leadership of President Zelensky and his impact on the Ukrainian people.  

·      The negative leadership of Russia President Putin.

Resources for Donations for Ukraine and Ukrainians

UNICEF

Salvation Army

Red Cross

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1552 First We Kill All the Lawyers Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take look at a recent speech by SEC Commissioner Alison Herron Lee where she considered the role of lawyers as gatekeepers under SOX 307. Some of the issues we consider  ·      Who do lawyers represent? ·      What is the difference between lawyers and gatekeepers? ·      How can or should lawyers represent multiple interests on SOX issues? ·       How does this comport with state bar requirements?  ·      How, if at all, does SOX 307 impact compliance professionals? ·      Was the speech a policy change announcement, trial balloon or something else.  Resources Matt in Radical Compliance SOX 307 Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Mar 2022 05:00:00 -0000 First We Kill All the Lawyers full 266 Tom Fox Tom and Matt are back to review a speech by SEC Commissioner Lee on lawyers and their gatekeeper obligations under SOX, Sec. 307. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take look at a recent speech by SEC Commissioner Alison Herron Lee where she considered the role of lawyers as gatekeepers under SOX 307. Some of the issues we consider  ·      Who do lawyers represent? ·      What is the difference between lawyers and gatekeepers? ·      How can or should lawyers represent multiple interests on SOX issues? ·       How does this comport with state bar requirements?  ·      How, if at all, does SOX 307 impact compliance professionals? ·      Was the speech a policy change announcement, trial balloon or something else.  Resources Matt in Radical Compliance SOX 307 Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take look at a recent speech by SEC Commissioner Alison Herron Lee where she considered the role of lawyers as gatekeepers under SOX 307. Some of the issues we consider 

·      Who do lawyers represent?

·      What is the difference between lawyers and gatekeepers?

·      How can or should lawyers represent multiple interests on SOX issues?

·       How does this comport with state bar requirements? 

·      How, if at all, does SOX 307 impact compliance professionals?

·      Was the speech a policy change announcement, trial balloon or something else. 

Resources


Matt in Radical Compliance

SOX 307

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]]> 1631 no Compliance Issues from the Russia Invasion of Ukraine Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a somewhat somber view on the Russia invasion of Ukraine. Some of the issues we consider: Discussion of sanctions. What do sanctions mean for US, UK and EU countries? How companies should think about doing business in Russia going forward. What about energy production and consumption? US company employees in Ukraine and Russia. The role of China in a potential resolution. Resources Tom in the FCPA Compliance and Ethics Blog Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Mar 2022 05:00:00 -0000 Compliance Issues from the Russia Invasion of Ukraine full 265 Tom Fox Matt and Tom look at compliance issues from the Russia invasion of Ukraine. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a somewhat somber view on the Russia invasion of Ukraine. Some of the issues we consider: Discussion of sanctions. What do sanctions mean for US, UK and EU countries? How companies should think about doing business in Russia going forward. What about energy production and consumption? US company employees in Ukraine and Russia. The role of China in a potential resolution. Resources Tom in the FCPA Compliance and Ethics Blog Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a somewhat somber view on the Russia invasion of Ukraine. Some of the issues we consider:

  • Discussion of sanctions.
  • What do sanctions mean for US, UK and EU countries?
  • How companies should think about doing business in Russia going forward.
  • What about energy production and consumption?
  • US company employees in Ukraine and Russia.
  • The role of China in a potential resolution.

Resources

Tom in the FCPA Compliance and Ethics Blog

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1687 no Corrupt Culture and Bags of Cash-the KT Corp. FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom turn to the recent FCPA enforcement action brought by the SEC involving the Korean company KT Corp. Some of the issues we consider Background facts and a corrupt culture, literally from the top. How does the SEC have jurisdiction over KT Corp? Why you need a flow chart of the bribery schemes and a scorecard of the players. Corruption leading to the Korean Blue House. Bags of cash delivered and kept in office safes. Was the resolution an interim step before a monitor is employed? Resources Tom with a 3-part series in the FCPA Compliance and Ethics Blog Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Feb 2022 05:00:00 -0000 Corrupt Culture and Bags of Cash-the KT Corp. FCPA Enforcement Action full 264 Tom Fox Tom and Matt are back to look at the recent FCPA enforcement action brought by the SEC involving the Korean company KT Corp. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom turn to the recent FCPA enforcement action brought by the SEC involving the Korean company KT Corp. Some of the issues we consider Background facts and a corrupt culture, literally from the top. How does the SEC have jurisdiction over KT Corp? Why you need a flow chart of the bribery schemes and a scorecard of the players. Corruption leading to the Korean Blue House. Bags of cash delivered and kept in office safes. Was the resolution an interim step before a monitor is employed? Resources Tom with a 3-part series in the FCPA Compliance and Ethics Blog Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom turn to the recent FCPA enforcement action brought by the SEC involving the Korean company KT Corp. Some of the issues we consider

  • Background facts and a corrupt culture, literally from the top.
  • How does the SEC have jurisdiction over KT Corp?
  • Why you need a flow chart of the bribery schemes and a scorecard of the players.
  • Corruption leading to the Korean Blue House.
  • Bags of cash delivered and kept in office safes.
  • Was the resolution an interim step before a monitor is employed?

Resources

Tom with a 3-part series in the FCPA Compliance and Ethics Blog

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1509 no Elon Musk and Tesla Redux Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom return to one of Matt’s favorite topics Elon Musk/Tesla. Some of the issues we consider: ·      What happens when a business is lead by a runaway CEO? ·      Implications of new SEC investigation. ·       State of California investigation into racial discrimination.  ·      Where has the Board been all this time? ·      Will the attitude of the SEC regarding enforcement change?  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Feb 2022 05:00:00 -0000 Elon Musk and Tesla Redux full Tom Fox Matt and Tom return to Elon Musk and Tesla for questions about corporate governance. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom return to one of Matt’s favorite topics Elon Musk/Tesla. Some of the issues we consider: ·      What happens when a business is lead by a runaway CEO? ·      Implications of new SEC investigation. ·       State of California investigation into racial discrimination.  ·      Where has the Board been all this time? ·      Will the attitude of the SEC regarding enforcement change?  Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom return to one of Matt’s favorite topics Elon Musk/Tesla. Some of the issues we consider:

·      What happens when a business is lead by a runaway CEO?

·      Implications of new SEC investigation.

·       State of California investigation into racial discrimination. 

·      Where has the Board been all this time?

·      Will the attitude of the SEC regarding enforcement change? 


Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1210 Two Obscure Academic Papers and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take up two recent academic papers which every compliance practitioner should study as they provide insight about how communications can impact both fraud prevention and compliance. Some of the issues we consider Berger and Lee on state FCA claims cutting overall accounting fraud. Jinjie Lin on SEC tweeting and reduction of SEC violations. What do these communication strategies portend? How can they be used by the compliance professional? Why whistleblowing does more than simply prevent fraud, waste and abuse. If improves the bottom line. Investment in communications strategies pays off? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Feb 2022 05:00:00 -0000 Two Obscure Academic Papers and Compliance full 262 Tom Fox Matt and and Tom take up two recent academic papers which provide insight about how communications can impact both fraud prevention and compliance. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take up two recent academic papers which every compliance practitioner should study as they provide insight about how communications can impact both fraud prevention and compliance. Some of the issues we consider Berger and Lee on state FCA claims cutting overall accounting fraud. Jinjie Lin on SEC tweeting and reduction of SEC violations. What do these communication strategies portend? How can they be used by the compliance professional? Why whistleblowing does more than simply prevent fraud, waste and abuse. If improves the bottom line. Investment in communications strategies pays off? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take up two recent academic papers which every compliance practitioner should study as they provide insight about how communications can impact both fraud prevention and compliance. Some of the issues we consider

  • Berger and Lee on state FCA claims cutting overall accounting fraud.
  • Jinjie Lin on SEC tweeting and reduction of SEC violations.
  • What do these communication strategies portend?
  • How can they be used by the compliance professional?
  • Why whistleblowing does more than simply prevent fraud, waste and abuse. If improves the bottom line.
  • Investment in communications strategies pays off?

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1338 no Mike Volkov on Antitrust Issues in Microsoft Acquisition of Activision Blizzard Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom are pleased to host Mike Volkov, host of the Corruption Crime and Compliance podcast on the Compliance Podcast Network. Mike formerly worked in the DOJ, Antitrust Division. We consider the current evolution of antitrust enforcement by the DOJ and FTC and how it might impact the Microsoft acquisition of Activision Blizzard. Some of the issues we consider include: ·      Is the focus of antitrust enforcement changing from consumers to others? ·      What is a Section 2 Sherman Act claim? ·       What are structural v. behavioral remedies?  ·      Have partial divestitures fallen out of favor? ·      How might all this play out in the Microsoft acquisition of Activision Blizzard? ·      What is the role of compliance going forward? Resources Matt in Radical Compliance Mike Volkov in  Corruption Crime and Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Feb 2022 05:00:00 -0000 Mike Volkov on Antitrust Issues in Microsoft Acquisition of Activision Blizzard full Tom Fox Matt and Tom welcome Mike Volkov to discuss anti-trust enforcement evolution and how it might impact the Microsoft acquisition of Activision Blizzard. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom are pleased to host Mike Volkov, host of the Corruption Crime and Compliance podcast on the Compliance Podcast Network. Mike formerly worked in the DOJ, Antitrust Division. We consider the current evolution of antitrust enforcement by the DOJ and FTC and how it might impact the Microsoft acquisition of Activision Blizzard. Some of the issues we consider include: ·      Is the focus of antitrust enforcement changing from consumers to others? ·      What is a Section 2 Sherman Act claim? ·       What are structural v. behavioral remedies?  ·      Have partial divestitures fallen out of favor? ·      How might all this play out in the Microsoft acquisition of Activision Blizzard? ·      What is the role of compliance going forward? Resources Matt in Radical Compliance Mike Volkov in  Corruption Crime and Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom are pleased to host Mike Volkov, host of the Corruption Crime and Compliance podcast on the Compliance Podcast Network. Mike formerly worked in the DOJ, Antitrust Division. We consider the current evolution of antitrust enforcement by the DOJ and FTC and how it might impact the Microsoft acquisition of Activision Blizzard. Some of the issues we consider include:

·      Is the focus of antitrust enforcement changing from consumers to others?

·      What is a Section 2 Sherman Act claim?

·       What are structural v. behavioral remedies? 

·      Have partial divestitures fallen out of favor?

·      How might all this play out in the Microsoft acquisition of Activision Blizzard?

·      What is the role of compliance going forward?

Resources

Matt in Radical Compliance

Mike Volkov in  Corruption Crime and Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2494 Log4j-the Merger of Cyber, 3rd Party and Operational Risk Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take up the Log4j imbroglio. Some of the issues we consider: ·      Why is this matter of such importance to compliance and audit? ·      Is your IT security out-sourced? If so how do you perform 3rd party due diligence on these companies? ·       What is the intersection of 3rd party, cyber and operational risk?  ·      How can you implement at 3rd party risk management program in cyber? ·      Have you audited a 3rd party in the cyber realm? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Jan 2022 05:00:00 -0000 Log4j-the Merger of Cyber, 3rd Party and Operational Risk full 260 Tom Fox Matt and Tom take a look at a cyber breach which has merged the areas of cyber, 3rd party and operational risk. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take up the Log4j imbroglio. Some of the issues we consider: ·      Why is this matter of such importance to compliance and audit? ·      Is your IT security out-sourced? If so how do you perform 3rd party due diligence on these companies? ·       What is the intersection of 3rd party, cyber and operational risk?  ·      How can you implement at 3rd party risk management program in cyber? ·      Have you audited a 3rd party in the cyber realm? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take up the Log4j imbroglio. Some of the issues we consider:

·      Why is this matter of such importance to compliance and audit?

·      Is your IT security out-sourced? If so how do you perform 3rd party due diligence on these companies?

·       What is the intersection of 3rd party, cyber and operational risk? 

·      How can you implement at 3rd party risk management program in cyber?

·      Have you audited a 3rd party in the cyber realm?

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1667 no Aspirational Compliance Training and Messaging Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take up compliance training and messages insights Matt had from the book, Get It Done, a newly released book by business professor Ayelet Fishbach. Some of the issues we consider  ·      How has compliance training evolved? ·      The differences in values-based training and rules-based training. ·       How can you build aspirational goal setting into your compliance training and compliance messaging?  ·      Incorporation of aspirational goal setting into your internal controls. ·      What is the bottom line on your compliance goal setting? Resources Matt in Radical Compliance  Get It Done by Ayelet Fishbach Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Jan 2022 05:00:00 -0000 Aspirational Compliance Training and Messaging full 259 Tom Fox Matt and Tom take up compliance training and messages insights the book, Get It Done. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take up compliance training and messages insights Matt had from the book, Get It Done, a newly released book by business professor Ayelet Fishbach. Some of the issues we consider  ·      How has compliance training evolved? ·      The differences in values-based training and rules-based training. ·       How can you build aspirational goal setting into your compliance training and compliance messaging?  ·      Incorporation of aspirational goal setting into your internal controls. ·      What is the bottom line on your compliance goal setting? Resources Matt in Radical Compliance  Get It Done by Ayelet Fishbach Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take up compliance training and messages insights Matt had from the book, Get It Done, a newly released book by business professor Ayelet Fishbach. Some of the issues we consider 

·      How has compliance training evolved?

·      The differences in values-based training and rules-based training.

·       How can you build aspirational goal setting into your compliance training and compliance messaging? 

·      Incorporation of aspirational goal setting into your internal controls.

·      What is the bottom line on your compliance goal setting?

Resources

Matt in Radical Compliance

 Get It Done by Ayelet Fishbach

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1324 no Issue and Trends for 2022, Part 2 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom conclude a special two-part podcast series of several topics they will be following in 2022. Today in our concluding Part 2, we consider: ·      The time of reckoning is coming for SPACs funded in 2021 as their 18 month-deadline is fast approaching. Is the SEC looking at SPACs as an alternative form of IPO? What will the regulatory landscape look like going forward? ·       CCO pay. Will it go up after several years of remaining flat? How did the Great Resignation impact compliance, if at all? What skills sets might a CCO need into 2025 and beyond?  ·      The SEC investigation into Facebook. Are a company’s public statements about having an ethical culture mere puffery or are they actionable for failing to live up to their public statements. Also, what does the Francis Haugen testimony mean for whistleblowers going forward.   ·      The SEC investigation into Activision’s toxic workplace and culture of misogyny. Are these new areas the SEC will be looking at in addition to its traditional role of financial reporting watchdog. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Jan 2022 05:00:00 -0000 Issue and Trends for 2022, Part 2 full 258 Tom Fox Matt and Tom conclude a special two-part podcast series of several topics they will be following in 2022. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom conclude a special two-part podcast series of several topics they will be following in 2022. Today in our concluding Part 2, we consider: ·      The time of reckoning is coming for SPACs funded in 2021 as their 18 month-deadline is fast approaching. Is the SEC looking at SPACs as an alternative form of IPO? What will the regulatory landscape look like going forward? ·       CCO pay. Will it go up after several years of remaining flat? How did the Great Resignation impact compliance, if at all? What skills sets might a CCO need into 2025 and beyond?  ·      The SEC investigation into Facebook. Are a company’s public statements about having an ethical culture mere puffery or are they actionable for failing to live up to their public statements. Also, what does the Francis Haugen testimony mean for whistleblowers going forward.   ·      The SEC investigation into Activision’s toxic workplace and culture of misogyny. Are these new areas the SEC will be looking at in addition to its traditional role of financial reporting watchdog. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom conclude a special two-part podcast series of several topics they will be following in 2022. Today in our concluding Part 2, we consider:

·      The time of reckoning is coming for SPACs funded in 2021 as their 18 month-deadline is fast approaching. Is the SEC looking at SPACs as an alternative form of IPO? What will the regulatory landscape look like going forward?

·       CCO pay. Will it go up after several years of remaining flat? How did the Great Resignation impact compliance, if at all? What skills sets might a CCO need into 2025 and beyond? 

·      The SEC investigation into Facebook. Are a company’s public statements about having an ethical culture mere puffery or are they actionable for failing to live up to their public statements. Also, what does the Francis Haugen testimony mean for whistleblowers going forward.  

·      The SEC investigation into Activision’s toxic workplace and culture of misogyny. Are these new areas the SEC will be looking at in addition to its traditional role of financial reporting watchdog.

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2038 no Issue and Trends for 2022, Part 1 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom begin a special two-part podcast series of several topics they will be following in 2022. Today in Part 1, we consider The Biden Administration’s Strategy on Countering Corruption, specifically around FinCEN and AML enforcement and how it may impact FCPA enforcement. The PCAOB was long dysfunctional before the Trump Administration eviscerated it. How will it change under the Biden Administration? The SEC plans for the regulation of and reporting on ESG. FCPA enforcement for recidivist corporations after DAG Lisa Monaco’s speech in October 2021. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Jan 2022 05:00:00 -0000 Issue and Trends for 2022, Part 1 full 257 Tom Fox Tom and Matt begin a special two-part podcast series of several topics they will be following in 2022. Topics include FCPA recidivists, SEC & ESG, the PCAOB, FinCEN & AML impacting FCPA enforcement. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom begin a special two-part podcast series of several topics they will be following in 2022. Today in Part 1, we consider The Biden Administration’s Strategy on Countering Corruption, specifically around FinCEN and AML enforcement and how it may impact FCPA enforcement. The PCAOB was long dysfunctional before the Trump Administration eviscerated it. How will it change under the Biden Administration? The SEC plans for the regulation of and reporting on ESG. FCPA enforcement for recidivist corporations after DAG Lisa Monaco’s speech in October 2021. Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom begin a special two-part podcast series of several topics they will be following in 2022. Today in Part 1, we consider

  • The Biden Administration’s Strategy on Countering Corruption, specifically around FinCEN and AML enforcement and how it may impact FCPA enforcement.
  • The PCAOB was long dysfunctional before the Trump Administration eviscerated it. How will it change under the Biden Administration?
  • The SEC plans for the regulation of and reporting on ESG.
  • FCPA enforcement for recidivist corporations after DAG Lisa Monaco’s speech in October 2021.

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2295 no Year End Review, Part 2 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. On Tuesday, Matt and Tom began a special two-part year-end review of six topics which they saw as significant in 2021 and believe will be so into 2022 as well. They looked at SPACs, the Robinhood/GameStop phenomena and the new hybrid working environment and what is means for the compliance professional. Today in Part 2 we consider the Biden Administration’s Strategy on Countering Corruption, in conjunction with DAG Lisa Monaco's speech on the refocus of the Department of Justice on FCPA enforcement and other white collar prosecutions, the continuing evolution of ransomware attacks and ESG in 2021 and beyond. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 30 Dec 2021 05:00:00 -0000 Year End Review, Part 2 full 256 Tom Fox Tom and Matt return for Part 2 of a special year-end review. In this episode they review the Strategy on Countering Corruption, DAG Lisa Monaco's speech on the refocus of the DOJ on FCPA enforcement, the continuing evolution of ransomware attacks and ESG. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. On Tuesday, Matt and Tom began a special two-part year-end review of six topics which they saw as significant in 2021 and believe will be so into 2022 as well. They looked at SPACs, the Robinhood/GameStop phenomena and the new hybrid working environment and what is means for the compliance professional. Today in Part 2 we consider the Biden Administration’s Strategy on Countering Corruption, in conjunction with DAG Lisa Monaco's speech on the refocus of the Department of Justice on FCPA enforcement and other white collar prosecutions, the continuing evolution of ransomware attacks and ESG in 2021 and beyond. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. On Tuesday, Matt and Tom began a special two-part year-end review of six topics which they saw as significant in 2021 and believe will be so into 2022 as well. They looked at SPACs, the Robinhood/GameStop phenomena and the new hybrid working environment and what is means for the compliance professional. Today in Part 2 we consider the Biden Administration’s Strategy on Countering Corruption, in conjunction with DAG Lisa Monaco's speech on the refocus of the Department of Justice on FCPA enforcement and other white collar prosecutions, the continuing evolution of ransomware attacks and ESG in 2021 and beyond.

Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2283 no Year End Review, Part 1 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom begin a special two-part year-end review of six topics which they saw as significant in 2021 and believe will be so into 2022 as well. In this episode we discuss SPACs, the Robinhood/GameStop phenomena and the new hybrid working environment and what is means for the compliance professional. Join us on Thursday of this week as we post Part 2 and look at the Biden Administration’s Strategy on Countering Corruption, the continuing evolution of ransomware attacks and ESG in 2021 and beyond.  Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 28 Dec 2021 11:11:00 -0000 Year End Review, Part 1 full 255 Tom Fox Tom and Matt begin a special 2-part year end review. Today they look at SPACs, Robinhood/GameStop and hybrid work environments. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom begin a special two-part year-end review of six topics which they saw as significant in 2021 and believe will be so into 2022 as well. In this episode we discuss SPACs, the Robinhood/GameStop phenomena and the new hybrid working environment and what is means for the compliance professional. Join us on Thursday of this week as we post Part 2 and look at the Biden Administration’s Strategy on Countering Corruption, the continuing evolution of ransomware attacks and ESG in 2021 and beyond.  Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom begin a special two-part year-end review of six topics which they saw as significant in 2021 and believe will be so into 2022 as well. In this episode we discuss SPACs, the Robinhood/GameStop phenomena and the new hybrid working environment and what is means for the compliance professional. Join us on Thursday of this week as we post Part 2 and look at the Biden Administration’s Strategy on Countering Corruption, the continuing evolution of ransomware attacks and ESG in 2021 and beyond. 

Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2062 no Compliance into the Weeds: On the Naughty List-JPMorgan $200 Settlement Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into the JPMorgan settlement with the SEC and CFTC for faulty electronic record-keeping. Some of the issues we consider are: ·      Why does Matt ‘almost feel bad' for JPMorgan? ·      There was a paucity of facts. So why is the fine so high? ·      Is it a ‘Compliance Consultant’ or a Monitor?  ·      The remediation agreed to by JPMorgan. ·      Lessons learned for the compliance professional and ephemeral communications. ·      Focus on consistent and even-handed discipline for JPMorgan employees going forward. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Dec 2021 05:00:00 -0000 Compliance into the Weeds: On the Naughty List-JPMorgan $200 Settlement full 254 Tom Fox Tom and Matt take a deep dive into the JPMorgan $200MM settlement with the SEC and CFTC. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into the JPMorgan settlement with the SEC and CFTC for faulty electronic record-keeping. Some of the issues we consider are: ·      Why does Matt ‘almost feel bad' for JPMorgan? ·      There was a paucity of facts. So why is the fine so high? ·      Is it a ‘Compliance Consultant’ or a Monitor?  ·      The remediation agreed to by JPMorgan. ·      Lessons learned for the compliance professional and ephemeral communications. ·      Focus on consistent and even-handed discipline for JPMorgan employees going forward. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into the JPMorgan settlement with the SEC and CFTC for faulty electronic record-keeping. Some of the issues we consider are:

·      Why does Matt ‘almost feel bad' for JPMorgan?

·      There was a paucity of facts. So why is the fine so high?

·      Is it a ‘Compliance Consultant’ or a Monitor? 

·      The remediation agreed to by JPMorgan.

·      Lessons learned for the compliance professional and ephemeral communications.

·      Focus on consistent and even-handed discipline for JPMorgan employees going forward.

Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2108 no US Strategy on Countering Corruption Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into the recently released US Strategy on Countering Corruption. After beginning with a debate on whether the document is simply a nice to have or something more significant, some of the issues we consider are: What is the significance domestically v. internationally? What new data will be collected and analyzed? What new agencies and departments in the US government will be involved? What additional international NGOs will be involved? Enhanced whistleblower protections? New focus on government procurement and in the Department of Defense. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Dec 2021 05:00:00 -0000 US Strategy on Countering Corruption full 253 Tom Fox Is the recently released US Strategy on Countering Corruption a big deal? Tom and Matt debate on this episode. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into the recently released US Strategy on Countering Corruption. After beginning with a debate on whether the document is simply a nice to have or something more significant, some of the issues we consider are: What is the significance domestically v. internationally? What new data will be collected and analyzed? What new agencies and departments in the US government will be involved? What additional international NGOs will be involved? Enhanced whistleblower protections? New focus on government procurement and in the Department of Defense. Resources Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into the recently released US Strategy on Countering Corruption. After beginning with a debate on whether the document is simply a nice to have or something more significant, some of the issues we consider are:

  • What is the significance domestically v. internationally?
  • What new data will be collected and analyzed?
  • What new agencies and departments in the US government will be involved?
  • What additional international NGOs will be involved?
  • Enhanced whistleblower protections?
  • New focus on government procurement and in the Department of Defense.

Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1435 no Ransomware Attacks and Internal Controls Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into the difference between a privacy breach and a ransomware attack. Some of the issues we consider are: Why are privacy breaches different from ransomware attacks? What is an authenticated v. unauthenticated cyber-attack? Why would the SEC get involved? What are the internal controls need to prevent and detect a ransomware attack? How will they be audited? How can a material weakness in internal controls around ransomware lead to a financial restatement? What will the SEC look at from an enforcement angle? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Dec 2021 05:00:00 -0000 Ransomware Attacks and Internal Controls full 252 Tom Fox Tom and Matt take a deep dive into ransomware attacks and internal controls. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into the difference between a privacy breach and a ransomware attack. Some of the issues we consider are: Why are privacy breaches different from ransomware attacks? What is an authenticated v. unauthenticated cyber-attack? Why would the SEC get involved? What are the internal controls need to prevent and detect a ransomware attack? How will they be audited? How can a material weakness in internal controls around ransomware lead to a financial restatement? What will the SEC look at from an enforcement angle? Resources Matt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into the difference between a privacy breach and a ransomware attack.

Some of the issues we consider are:

  • Why are privacy breaches different from ransomware attacks?
  • What is an authenticated v. unauthenticated cyber-attack?
  • Why would the SEC get involved?
  • What are the internal controls need to prevent and detect a ransomware attack? How will they be audited?
  • How can a material weakness in internal controls around ransomware lead to a financial restatement?
  • What will the SEC look at from an enforcement angle?

Resources

Matt in Radical Compliance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1530 no Red Flags and SPACs Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into several issues regarding Special Purpose Acquisition Companies (SPACs). Some of the issues we consider are: What did the Klausner and Olhrogge Research Paper show about conflicts of interest? What did Calcbench analysis show about not only the number of SPAC filings but how they are driving the dramatic increase in M&A activity. What are the corporate governance issues involved in with SPACs? What are the internal controls issues involved with SPACs? What has (or will) the Delaware Supreme Court have to say. What have been the pronouncements from the SEC? Resources Matt in Radical Compliance, Paper Raises Red Flags on SPACs Governance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Dec 2021 05:00:00 -0000 Red Flags and SPACs full 251 Tom Fox Tom and Matt go into the weeds on red flags surrounding SPACs. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into several issues regarding Special Purpose Acquisition Companies (SPACs). Some of the issues we consider are: What did the Klausner and Olhrogge Research Paper show about conflicts of interest? What did Calcbench analysis show about not only the number of SPAC filings but how they are driving the dramatic increase in M&A activity. What are the corporate governance issues involved in with SPACs? What are the internal controls issues involved with SPACs? What has (or will) the Delaware Supreme Court have to say. What have been the pronouncements from the SEC? Resources Matt in Radical Compliance, Paper Raises Red Flags on SPACs Governance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a deep dive into several issues regarding Special Purpose Acquisition Companies (SPACs).

Some of the issues we consider are:

  • What did the Klausner and Olhrogge Research Paper show about conflicts of interest?
  • What did Calcbench analysis show about not only the number of SPAC filings but how they are driving the dramatic increase in M&A activity.
  • What are the corporate governance issues involved in with SPACs?
  • What are the internal controls issues involved with SPACs?
  • What has (or will) the Delaware Supreme Court have to say.
  • What have been the pronouncements from the SEC?

Resources

Matt in Radical Compliance, Paper Raises Red Flags on SPACs Governance

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1570 no A Single Source of Truth Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a the recently filed lawsuit by Shaquala Williams against JPMorgan for alleged retaliation for her internal whistleblowing. Williams was in a compliance function at the bank and claimed she was terminated for raising the issues that JPMorgan was not living up to its reporting requirements under a DPA.Some of the issues we consider are: Facts of the claim? Made in the context of an ongoing DPA. The lack of lack of documented policies and procedures. Siloed nature of compliance functions. Inconsistency in risk assessments. Why is a single source of truth so critical? Resources Matt in Radical Compliance, That Lawsuit Against JP Morgan Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Nov 2021 05:00:00 -0000 A Single Source of Truth full 250 Tom Fox Matt and Tom take a the recently filed lawsuit by Shaquala Williams against JPMorgan for alleged retaliation for her internal whistleblowing. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a the recently filed lawsuit by Shaquala Williams against JPMorgan for alleged retaliation for her internal whistleblowing. Williams was in a compliance function at the bank and claimed she was terminated for raising the issues that JPMorgan was not living up to its reporting requirements under a DPA.Some of the issues we consider are: Facts of the claim? Made in the context of an ongoing DPA. The lack of lack of documented policies and procedures. Siloed nature of compliance functions. Inconsistency in risk assessments. Why is a single source of truth so critical? Resources Matt in Radical Compliance, That Lawsuit Against JP Morgan Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a the recently filed lawsuit by Shaquala Williams against JPMorgan for alleged retaliation for her internal whistleblowing. Williams was in a compliance function at the bank and claimed she was terminated for raising the issues that JPMorgan was not living up to its reporting requirements under a DPA.Some of the issues we consider are:

  • Facts of the claim?
  • Made in the context of an ongoing DPA.
  • The lack of lack of documented policies and procedures.
  • Siloed nature of compliance functions.
  • Inconsistency in risk assessments.
  • Why is a single source of truth so critical?

Resources

Matt in Radical Compliance, That Lawsuit Against JP Morgan

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1552 no Retreat on DoD Cybersecurity for Contractors Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a look at the Department of Defense retreat on its cybersecurity initiative for contractors, from the original CMMC to the new standard of CMMC 2.0. Some of the issues we consider are: ·      What is CMMC and what morphed into CMMC 2.0? ·      Who led the charge to make these changes? ·      Do these changes help or hurt federal government overall cybersecurity?  ·      Will self-assessments work? ·      New FCA claims coming? ·      What about compliance? Resources Matt in Radical Compliance, Pentagon Sounds Retreat on CMMC Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Nov 2021 05:00:00 -0000 Retreat on DoD Cybersecurity for Contractors full 249 Tom Fox Matt and Tom take a look at the DoD retreat on its cybersecurity initiative for contractors, from the original CMMC to the new standard of CMMC 2.0. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a look at the Department of Defense retreat on its cybersecurity initiative for contractors, from the original CMMC to the new standard of CMMC 2.0. Some of the issues we consider are: ·      What is CMMC and what morphed into CMMC 2.0? ·      Who led the charge to make these changes? ·      Do these changes help or hurt federal government overall cybersecurity?  ·      Will self-assessments work? ·      New FCA claims coming? ·      What about compliance? Resources Matt in Radical Compliance, Pentagon Sounds Retreat on CMMC Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom take a look at the Department of Defense retreat on its cybersecurity initiative for contractors, from the original CMMC to the new standard of CMMC 2.0.

Some of the issues we consider are:

·      What is CMMC and what morphed into CMMC 2.0?

·      Who led the charge to make these changes?

·      Do these changes help or hurt federal government overall cybersecurity? 

·      Will self-assessments work?

·      New FCA claims coming?

·      What about compliance?

Resources

Matt in Radical Compliance, Pentagon Sounds Retreat on CMMC Compliance

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]]> 1264 no More on DAG Monaco Speech-DPAs and NPAs  Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom continue their look at the recent speech by DAG Lisa Monaco to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Today we consider potential changes to DPAs and NPAs and other settlement mechanisms. Some of the issues we consider are: ·      Are DPAs and NPAs simply the cost of doing business? ·      Is the Wells Fargo growth cap a valid model? ·      What about greater DOJ or Monitor oversight?  ·      Longer terms for DPAs? ·      New enforcement tools coming? ·      New review of DPAs and NPAs. Resources Matt in Radical Compliance So What Happens Next with DPAs Tom in the FCPA Compliance and Ethics Blog Monaco Speech - Individual Accountability Monaco Speech - Monitors Text of DAG Monaco Speech Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Nov 2021 04:00:00 -0000 More on DAG Monaco Speech-DPAs and NPAs full 248 Tom Fox Tom and Matt return to the Monaco speech to consider DPAs and NPAs going forward.  Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom continue their look at the recent speech by DAG Lisa Monaco to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Today we consider potential changes to DPAs and NPAs and other settlement mechanisms. Some of the issues we consider are: ·      Are DPAs and NPAs simply the cost of doing business? ·      Is the Wells Fargo growth cap a valid model? ·      What about greater DOJ or Monitor oversight?  ·      Longer terms for DPAs? ·      New enforcement tools coming? ·      New review of DPAs and NPAs. Resources Matt in Radical Compliance So What Happens Next with DPAs Tom in the FCPA Compliance and Ethics Blog Monaco Speech - Individual Accountability Monaco Speech - Monitors Text of DAG Monaco Speech Learn more about your ad choices. Visit megaphone.fm/adchoices  Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom continue their look at the recent speech by DAG Lisa Monaco to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Today we consider potential changes to DPAs and NPAs and other settlement mechanisms.

Some of the issues we consider are:

·      Are DPAs and NPAs simply the cost of doing business?

·      Is the Wells Fargo growth cap a valid model?

·      What about greater DOJ or Monitor oversight? 

·      Longer terms for DPAs?

·      New enforcement tools coming?

·      New review of DPAs and NPAs.

Resources

Matt in Radical Compliance

So What Happens Next with DPAs

Tom in the FCPA Compliance and Ethics Blog

Monaco Speech - Individual Accountability

Monaco Speech - Monitors

Text of DAG Monaco Speech

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]]> 1389 no DAG Announces Changes in Enforcement Priorities Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom have a rare emergency podcast on DAG Lisa Monaco’s speech to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Some of the issues we consider are: Return to the Yates Memo. Disavowal of the Benczkowski Memo. Change in the FCPA Corporate Enforcement Policy? Whither recidivists? New enforcement tools coming? New review of DPAs and NPAs? Resources Matt in Radical Compliance, Justice Dept. Unveils Big Compliance Shifts Text of DAG Monaco Speec Learn more about your ad choices. Visit megaphone.fm/adchoices Fri, 29 Oct 2021 15:46:00 -0000 DAG Announces Changes in Enforcement Priorities full 247 Tom Fox Matt and Tom have a rare emergency podcast on DAG Lisa Monaco’s speech announcing some very significant change to white collar, including FCPA enforcement. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom have a rare emergency podcast on DAG Lisa Monaco’s speech to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Some of the issues we consider are: Return to the Yates Memo. Disavowal of the Benczkowski Memo. Change in the FCPA Corporate Enforcement Policy? Whither recidivists? New enforcement tools coming? New review of DPAs and NPAs? Resources Matt in Radical Compliance, Justice Dept. Unveils Big Compliance Shifts Text of DAG Monaco Speec Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today, Matt and Tom have a rare emergency podcast on DAG Lisa Monaco’s speech to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Some of the issues we consider are:

  • Return to the Yates Memo.
  • Disavowal of the Benczkowski Memo.
  • Change in the FCPA Corporate Enforcement Policy?
  • Whither recidivists?
  • New enforcement tools coming?
  • New review of DPAs and NPAs?

Resources

Matt in Radical Compliance, Justice Dept. Unveils Big Compliance Shifts

Text of DAG Monaco Speec

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]]> 1628 no Credit Suisse and Holistic Risk Management Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deeper dive into the recent Credit Suisse enforcement action. Some of the issues we consider are: Is a broader view of risk needed? If so, who would perform that review? Too many silos? Public companies v. investment banks? What is under escalated risk? What is conduct risk? Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 Oct 2021 04:00:00 -0000 Credit Suisse and Holistic Risk Management full 246 Tom Fox Tom and Matt take a deeer dive into the Credit Suisse matter to consider a more holistic approach to risk. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deeper dive into the recent Credit Suisse enforcement action. Some of the issues we consider are: Is a broader view of risk needed? If so, who would perform that review? Too many silos? Public companies v. investment banks? What is under escalated risk? What is conduct risk? Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deeper dive into the recent Credit Suisse enforcement action. Some of the issues we consider are:

  • Is a broader view of risk needed?
  • If so, who would perform that review?
  • Too many silos?
  • Public companies v. investment banks?
  • What is under escalated risk?
  • What is conduct risk?

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1484 no Compliance and AI Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the issue of compliance and artificial intelligence. Some of the issues we consider are: What are the AI risks for compliance? What guidance does the COSO Framework provide? What are some of the top areas of AI failure? Are we governing AI in the right manner? What about the audit of AI tools? Compliance, governance, ethics and AI.  Resources Matt in Radical Compliance Thoughts on AI From the Audit Perspective Grappling With Artificial Intelligence  Tom in the FCPA Compliance and Ethics Blog Compliance Communications: Using an AI Marketing Strategy – Part 1 Compliance Communications: Using an AI Marketing Strategy – Part 2 Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Oct 2021 04:00:00 -0000 Compliance and AI full 245 Tom Fox Tom and Matt take a deep dive into Compliance and AI. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the issue of compliance and artificial intelligence. Some of the issues we consider are: What are the AI risks for compliance? What guidance does the COSO Framework provide? What are some of the top areas of AI failure? Are we governing AI in the right manner? What about the audit of AI tools? Compliance, governance, ethics and AI.  Resources Matt in Radical Compliance Thoughts on AI From the Audit Perspective Grappling With Artificial Intelligence  Tom in the FCPA Compliance and Ethics Blog Compliance Communications: Using an AI Marketing Strategy – Part 1 Compliance Communications: Using an AI Marketing Strategy – Part 2 Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the issue of compliance and artificial intelligence. Some of the issues we consider are:

  • What are the AI risks for compliance?
  • What guidance does the COSO Framework provide?
  • What are some of the top areas of AI failure?
  • Are we governing AI in the right manner?
  • What about the audit of AI tools?
  • Compliance, governance, ethics and AI.

 Resources

Matt in Radical Compliance

Thoughts on AI From the Audit Perspective

Grappling With Artificial Intelligence

 Tom in the FCPA Compliance and Ethics Blog

Compliance Communications: Using an AI Marketing Strategy – Part 1

Compliance Communications: Using an AI Marketing Strategy – Part 2

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]]> 1832 no Expansive SEC Enforcement in the Wind Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a recent speech by SEC Director of Enforcement Gurbir Grewal and the likely increase in a more expansive use of SEC enforcement. Some of the issues we consider are: What is the purpose of SEC penalties; to penalize or to deter others? How did SEC Commissioner Crenshaw presage this talk? What about a potential change in DOJ penalties? Its approach and focus? Are monitorships back on the table? What about the CFPB? Will Directors and Officers be held accountable or just the low level minions?  Resources Matt in Radical Compliance More on SEC Penalties Policy Shift Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Oct 2021 04:00:00 -0000 Expansive SEC Enforcement in the Wind full 242 Tom Fox Tom and Matt look at potential increase in SEC enforcement penalties. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a recent speech by SEC Director of Enforcement Gurbir Grewal and the likely increase in a more expansive use of SEC enforcement. Some of the issues we consider are: What is the purpose of SEC penalties; to penalize or to deter others? How did SEC Commissioner Crenshaw presage this talk? What about a potential change in DOJ penalties? Its approach and focus? Are monitorships back on the table? What about the CFPB? Will Directors and Officers be held accountable or just the low level minions?  Resources Matt in Radical Compliance More on SEC Penalties Policy Shift Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a recent speech by SEC Director of Enforcement Gurbir Grewal and the likely increase in a more expansive use of SEC enforcement.

Some of the issues we consider are:

  • What is the purpose of SEC penalties; to penalize or to deter others?
  • How did SEC Commissioner Crenshaw presage this talk?
  • What about a potential change in DOJ penalties? Its approach and focus?
  • Are monitorships back on the table?
  • What about the CFPB? Will Directors and Officers be held accountable or just the low level minions?

 Resources

Matt in Radical Compliance

More on SEC Penalties Policy Shift

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1781 no Ozy Media and Culture Failure Bingo Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into collapse (and perhaps rebirth) of Ozy Media and have our first round of culture failure bingo.  Some of the issues we consider are: What is an Ozy and why does its collapse matter to compliance? Who is Ozzie Osbourne and what does he have to do with Ozy? What is culture failure bingo and why is it on Compliance into the Weeds? Who were the bingo winning companies this week? Why all this matter to compliance? Resources Matt in Radical Compliance  Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 05 Oct 2021 04:00:00 -0000 Ozy Media and Culture Failure Bingo full 243 Tom Fox What is an Ozy and why does its collapse matter to compliance? Matt and Tom explore. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into collapse (and perhaps rebirth) of Ozy Media and have our first round of culture failure bingo.  Some of the issues we consider are: What is an Ozy and why does its collapse matter to compliance? Who is Ozzie Osbourne and what does he have to do with Ozy? What is culture failure bingo and why is it on Compliance into the Weeds? Who were the bingo winning companies this week? Why all this matter to compliance? Resources Matt in Radical Compliance  Tom in the FCPA Compliance and Ethics Blog Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into collapse (and perhaps rebirth) of Ozy Media and have our first round of culture failure bingo. 

Some of the issues we consider are:

  • What is an Ozy and why does its collapse matter to compliance?
  • Who is Ozzie Osbourne and what does he have to do with Ozy?
  • What is culture failure bingo and why is it on Compliance into the Weeds?
  • Who were the bingo winning companies this week?
  • Why all this matter to compliance?

Resources

Matt in Radical Compliance 

Tom in the FCPA Compliance and Ethics Blog

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1828 no The WPP Foreign Corrupt Practices Act Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the second FCPA enforcement action of 2021, involving the UK entity, WPP. Some of the issues we consider are: Why does a $15bn, 100K employee worldwide, multination not have a compliance function? What does that say about its culture? What is the role of compliance in M&A? When does a financial incentive become perverse? Where is the DOJ? Where is the SFO? How did WPP avoid a monitor?  Resources Matt in Radical Compliance WPP Pays $19M on FCPA: An Analysis  Tom in the FCPA Compliance and Ethics Blog Part 1-Background Part 2-Structural Compliance Deficiencies Part 3-Bribery Schemes Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Sep 2021 04:00:00 -0000 The WPP Foreign Corrupt Practices Act Enforcement Action full 242 Tom Fox Tom and Matt deep into the WPP FCPA enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the second FCPA enforcement action of 2021, involving the UK entity, WPP. Some of the issues we consider are: Why does a $15bn, 100K employee worldwide, multination not have a compliance function? What does that say about its culture? What is the role of compliance in M&A? When does a financial incentive become perverse? Where is the DOJ? Where is the SFO? How did WPP avoid a monitor?  Resources Matt in Radical Compliance WPP Pays $19M on FCPA: An Analysis  Tom in the FCPA Compliance and Ethics Blog Part 1-Background Part 2-Structural Compliance Deficiencies Part 3-Bribery Schemes Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the second FCPA enforcement action of 2021, involving the UK entity, WPP.

Some of the issues we consider are:

  • Why does a $15bn, 100K employee worldwide, multination not have a compliance function? What does that say about its culture?
  • What is the role of compliance in M&A?
  • When does a financial incentive become perverse?
  • Where is the DOJ? Where is the SFO?
  • How did WPP avoid a monitor? 

Resources

Matt in Radical Compliance

WPP Pays $19M on FCPA: An Analysis

 Tom in the FCPA Compliance and Ethics Blog

Part 1-Background

Part 2-Structural Compliance Deficiencies

Part 3-Bribery Schemes

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]]> 1861 no Lax Anti-Vax Policies Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive a recent survey around employee attitudes towards employer vaccination policies and enforcement of those policies.   Some of the issues we consider are: ·      What are employee attitudes toward employer vaccination policies? ·      Why is there a split between White Collar response v. Blue Collar responses? ·      What will be government enforcement?  ·      Will there be increased whistleblower reporting? ·      What could be the social media impact on corporate reputations?  Resources Matt in Radical Compliance Poll: 46% Would Report Lax Vax Policies Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Sep 2021 04:00:00 -0000 Lax Anti-Vax Policies full Tom Fox What will be the impact of employer vaccination policies? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive a recent survey around employee attitudes towards employer vaccination policies and enforcement of those policies.   Some of the issues we consider are: ·      What are employee attitudes toward employer vaccination policies? ·      Why is there a split between White Collar response v. Blue Collar responses? ·      What will be government enforcement?  ·      Will there be increased whistleblower reporting? ·      What could be the social media impact on corporate reputations?  Resources Matt in Radical Compliance Poll: 46% Would Report Lax Vax Policies Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive a recent survey around employee attitudes towards employer vaccination policies and enforcement of those policies.  

Some of the issues we consider are:

·      What are employee attitudes toward employer vaccination policies?

·      Why is there a split between White Collar response v. Blue Collar responses?

·      What will be government enforcement? 

·      Will there be increased whistleblower reporting?

·      What could be the social media impact on corporate reputations?

 Resources

Matt in Radical Compliance

Poll: 46% Would Report Lax Vax Policies

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]]> 1525 Listening is a Conversation Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into why an internal reporting system is not enough. Indeed having a speak up culture is not enough. Your company must have a listen up culture.   Some of the issues we consider are: ·      What is a speak up culture? ·      What is a listen up culture? ·      What are some of the benefits of a true listen up culture?  ·      How do you training middle managers to be speak up portals? ·      Why is having a conversation so powerful?  Resources Matt in Radical Compliance Corporate Culture: Speak Up v. Listen Up Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Sep 2021 04:00:00 -0000 Listening is a Conversation full 240 Tom Fox Today we look at a speak up v. listen up culture. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into why an internal reporting system is not enough. Indeed having a speak up culture is not enough. Your company must have a listen up culture.   Some of the issues we consider are: ·      What is a speak up culture? ·      What is a listen up culture? ·      What are some of the benefits of a true listen up culture?  ·      How do you training middle managers to be speak up portals? ·      Why is having a conversation so powerful?  Resources Matt in Radical Compliance Corporate Culture: Speak Up v. Listen Up Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into why an internal reporting system is not enough. Indeed having a speak up culture is not enough. Your company must have a listen up culture.  

Some of the issues we consider are:

·      What is a speak up culture?

·      What is a listen up culture?

·      What are some of the benefits of a true listen up culture? 

·      How do you training middle managers to be speak up portals?

·      Why is having a conversation so powerful?

 Resources

Matt in Radical Compliance

Corporate Culture: Speak Up v. Listen Up

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]]> 1525 no High Calorie Compliance Lessons from Kraft Foods Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive the recent SEC enforcement action involving Kraft Foods. While the subject matter of the enforcement action was fraudulent expense recognition, it turns out the real culprit was a corrupt culture. Some of the issues we consider are: ·      What were the underlying facts? ·      What does tone at the top really mean? ·      How does management cost cutting mantra lead to corruption?  ·      Why is incentive based comp so deterius? ·      What did SEC Commissioner Crenshaw say about this enforcement action? Resources Matt in Radical Compliance Food For Thought From Kraft Foods Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Sep 2021 04:00:00 -0000 High Calorie Compliance Lessons from Kraft Foods full 239 Tom Fox What are the compliance lessons from Kraft Foods SEC enforcement action? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive the recent SEC enforcement action involving Kraft Foods. While the subject matter of the enforcement action was fraudulent expense recognition, it turns out the real culprit was a corrupt culture. Some of the issues we consider are: ·      What were the underlying facts? ·      What does tone at the top really mean? ·      How does management cost cutting mantra lead to corruption?  ·      Why is incentive based comp so deterius? ·      What did SEC Commissioner Crenshaw say about this enforcement action? Resources Matt in Radical Compliance Food For Thought From Kraft Foods Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive the recent SEC enforcement action involving Kraft Foods. While the subject matter of the enforcement action was fraudulent expense recognition, it turns out the real culprit was a corrupt culture. Some of the issues we consider are:


·      What were the underlying facts?

·      What does tone at the top really mean?

·      How does management cost cutting mantra lead to corruption? 

·      Why is incentive based comp so deterius?

·      What did SEC Commissioner Crenshaw say about this enforcement action?

Resources

Matt in Radical Compliance

Food For Thought From Kraft Foods

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1675 no Delta Airlines Responds to the Delta Variant Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive the recent move by Delta Airlines to require employees who refuse to be vaccinated to pay a special health care insurance surcharge of $200 to cover the increased health care costs associated with unvaccinated employees who contract Covid-19.  Some of the issues we consider are: ·      What were the underlying facts? ·      How did Delta Airline’s actions follow a risk management protocol? ·      How did Delta’s actions demonstrate a commitment to compliance?  ·      How about the data? ·      How about Document Document Document?  Resources Matt in Radical Compliance Delta’s Smart Approach on Delta Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Sep 2021 04:00:00 -0000 Delta Airlines Responds to the Delta Variant full 238 Tom Fox Matt and Tom look at the Delta Airline response to unvaccinated employees? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive the recent move by Delta Airlines to require employees who refuse to be vaccinated to pay a special health care insurance surcharge of $200 to cover the increased health care costs associated with unvaccinated employees who contract Covid-19.  Some of the issues we consider are: ·      What were the underlying facts? ·      How did Delta Airline’s actions follow a risk management protocol? ·      How did Delta’s actions demonstrate a commitment to compliance?  ·      How about the data? ·      How about Document Document Document?  Resources Matt in Radical Compliance Delta’s Smart Approach on Delta Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive the recent move by Delta Airlines to require employees who refuse to be vaccinated to pay a special health care insurance surcharge of $200 to cover the increased health care costs associated with unvaccinated employees who contract Covid-19. 

Some of the issues we consider are:

·      What were the underlying facts?

·      How did Delta Airline’s actions follow a risk management protocol?

·      How did Delta’s actions demonstrate a commitment to compliance? 

·      How about the data?

·      How about Document Document Document? 

Resources

Matt in Radical Compliance

Delta’s Smart Approach on Delta


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1211 no Matt Miner Makes 3-Point Pivot into the Walmart CCO Chair Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent announcement by Walmart that former DOJ Deputy Attorney General, Criminal Matthew Miner had joined the company as CCO.   Resources Matt in Radical Compliance Walmart Names ex-DOJ Boss CCO Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Aug 2021 04:00:00 -0000 Matt Miner Makes 3-Point Pivot into the Walmart CCO Chair full 237 Tom Fox Matt and Tom consider ex-DOJer Matt Miner moving to the Walmart CCO chair. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent announcement by Walmart that former DOJ Deputy Attorney General, Criminal Matthew Miner had joined the company as CCO.   Resources Matt in Radical Compliance Walmart Names ex-DOJ Boss CCO Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent announcement by Walmart that former DOJ Deputy Attorney General, Criminal Matthew Miner had joined the company as CCO.  

Resources

Matt in Radical Compliance

Walmart Names ex-DOJ Boss CCO


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1519 no Pearson SEC Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the SEC enforcement involving Pearson. Some of the issues we consider are: How can a failure to disclose lead to a SEC violation? What were the disclosure controls and procedures failures? How is patch management a critical part of cybersecurity? What were the misleading statements made by Pearson? What are the lessons learned? What is the role of compliance?  Resources Matt in Radical Compliance SEC Schools Pearson on Cyber Disclosure Failures Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Aug 2021 04:00:00 -0000 Pearson SEC Enforcement Action full 236 Tom Fox Matt and Tom take a deep dive into the Pearson SEC Enforcement Action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the SEC enforcement involving Pearson. Some of the issues we consider are: How can a failure to disclose lead to a SEC violation? What were the disclosure controls and procedures failures? How is patch management a critical part of cybersecurity? What were the misleading statements made by Pearson? What are the lessons learned? What is the role of compliance?  Resources Matt in Radical Compliance SEC Schools Pearson on Cyber Disclosure Failures Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the SEC enforcement involving Pearson. Some of the issues we consider are:

  • How can a failure to disclose lead to a SEC violation?
  • What were the disclosure controls and procedures failures?
  • How is patch management a critical part of cybersecurity?
  • What were the misleading statements made by Pearson?
  • What are the lessons learned?
  • What is the role of compliance? 

Resources

Matt in Radical Compliance

SEC Schools Pearson on Cyber Disclosure Failures

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]]> 1484 no Who Controls Corporate Values? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into Venn Diagrams to consider the questions of who sets corporate values. Some of the issues we consider are: What happens when management dictates a corp value? What happens when that value is disputed by employees? What happens when the regulators come knocking? How does social media play into all this? How can you assess your risk? What is the role of compliance? Resources Matt in Radical Compliance Mapping the Pressures on Corporate Values, Priorities Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Aug 2021 04:00:00 -0000 Who Controls Corporate Values? full 234 Tom Fox What happens when management values conflict with employee values? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into Venn Diagrams to consider the questions of who sets corporate values. Some of the issues we consider are: What happens when management dictates a corp value? What happens when that value is disputed by employees? What happens when the regulators come knocking? How does social media play into all this? How can you assess your risk? What is the role of compliance? Resources Matt in Radical Compliance Mapping the Pressures on Corporate Values, Priorities Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into Venn Diagrams to consider the questions of who sets corporate values. Some of the issues we consider are:

  • What happens when management dictates a corp value?
  • What happens when that value is disputed by employees?
  • What happens when the regulators come knocking?
  • How does social media play into all this?
  • How can you assess your risk?
  • What is the role of compliance?

Resources

Matt in Radical Compliance

Mapping the Pressures on Corporate Values, Priorities

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1484 no What Happens When a CCO Goes off the Deep End? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the actions of Activision CCO Frances Townsend who when faced with a claim by the state of California of sexual harassment by the company in the workplace, went off the deep end. Some of the issues we consider are: ·      What happens when a CCO attacks internal whistleblowers? ·      How is the role of the CCO different from that of the GC?? ·      What happens when a company starts attacking its own employees?  ·      What happens when a CCO closes their door to employees? ·      The over/under on Townsend’s continued employment.   Resources Matt in Radical Compliance More Activison CCO Drama Activision CCO Steps Into a Mess Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Aug 2021 11:08:52 -0000 What Happens When a CCO Goes off the Deep End? full 233 Tom Fox Matt and Tom explore why a CCO should not also be the GC. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the actions of Activision CCO Frances Townsend who when faced with a claim by the state of California of sexual harassment by the company in the workplace, went off the deep end. Some of the issues we consider are: ·      What happens when a CCO attacks internal whistleblowers? ·      How is the role of the CCO different from that of the GC?? ·      What happens when a company starts attacking its own employees?  ·      What happens when a CCO closes their door to employees? ·      The over/under on Townsend’s continued employment.   Resources Matt in Radical Compliance More Activison CCO Drama Activision CCO Steps Into a Mess Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the actions of Activision CCO Frances Townsend who when faced with a claim by the state of California of sexual harassment by the company in the workplace, went off the deep end. Some of the issues we consider are:


·      What happens when a CCO attacks internal whistleblowers?

·      How is the role of the CCO different from that of the GC??

·      What happens when a company starts attacking its own employees? 

·      What happens when a CCO closes their door to employees?

·      The over/under on Townsend’s continued employment.

 

Resources

Matt in Radical Compliance

More Activison CCO Drama

Activision CCO Steps Into a Mess


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]]> 1420 no First Energy Corruption Settlement Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the Deferred Prosecution Agreement entered into by First Energy company for its bribery of certain state officials in the state of Ohio, including the former Speaker of the House in Ohio. Some of the issues we consider are: What were the underlying facts? What were the bribery schemes involved? How did the tax code facilitate the bribery? What are the compliance program implications? How does this fit into ESG?  Resources Matt in Radical Compliance First Energy and Domestic Corruption Woes Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Jul 2021 04:00:00 -0000 First Energy Corruption Settlement full 232 Tom Fox Matt and Tom take a deep dive into the First Energy domestic corruption enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the Deferred Prosecution Agreement entered into by First Energy company for its bribery of certain state officials in the state of Ohio, including the former Speaker of the House in Ohio. Some of the issues we consider are: What were the underlying facts? What were the bribery schemes involved? How did the tax code facilitate the bribery? What are the compliance program implications? How does this fit into ESG?  Resources Matt in Radical Compliance First Energy and Domestic Corruption Woes Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the Deferred Prosecution Agreement entered into by First Energy company for its bribery of certain state officials in the state of Ohio, including the former Speaker of the House in Ohio.

Some of the issues we consider are:

  • What were the underlying facts?
  • What were the bribery schemes involved?
  • How did the tax code facilitate the bribery?
  • What are the compliance program implications?
  • How does this fit into ESG? 

Resources

Matt in Radical Compliance

First Energy and Domestic Corruption Woes

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1366 no SEC-SPAC Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent SEC enforcement action regarding the SPAC Stable Road Acquisition Corp. and its acquisition of the space technology company Momentus.  Some of the issues we consider are: What were the underlying facts? Were red flags missed, consciously avoided or outright ignored? Where was compliance due diligence? Bill Ackerman, Pershing Square Tontine Holdings and the proposed Universal Music acquisition? Diamond Acquisition Corp and its acquisition of Lordstown Motors.  Resources Matt in Radical Compliance The Second Act of SPAC Enforcement Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Jul 2021 04:00:00 -0000 SEC-SPAC Enforcement Action full 231 Tom Fox Tom and Matt look at the SEC enforcement action involving the SPAC Stable Road Acquisition Corp. and its acquisition of Momentus. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent SEC enforcement action regarding the SPAC Stable Road Acquisition Corp. and its acquisition of the space technology company Momentus.  Some of the issues we consider are: What were the underlying facts? Were red flags missed, consciously avoided or outright ignored? Where was compliance due diligence? Bill Ackerman, Pershing Square Tontine Holdings and the proposed Universal Music acquisition? Diamond Acquisition Corp and its acquisition of Lordstown Motors.  Resources Matt in Radical Compliance The Second Act of SPAC Enforcement Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent SEC enforcement action regarding the SPAC Stable Road Acquisition Corp. and its acquisition of the space technology company Momentus.

 Some of the issues we consider are:

  • What were the underlying facts?
  • Were red flags missed, consciously avoided or outright ignored?
  • Where was compliance due diligence?
  • Bill Ackerman, Pershing Square Tontine Holdings and the proposed Universal Music acquisition?
  • Diamond Acquisition Corp and its acquisition of Lordstown Motors.

 Resources

Matt in Radical Compliance

The Second Act of SPAC Enforcement

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]]> 1100 no FINRA Enforcement Actions involving Robinhood Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the two recent FINRA enforcement actions involving the trading platform Robinhood.  Some of the issues we consider are: What were the underlying facts? Were red flags missed, consciously avoided or outright ignored? Where was compliance? Why must the human element always be present in compliance? Why business continuity is really a compliance issues. What about the IPO?  Resources Matt in Radical Compliance Lessons from Robinhood Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Jul 2021 04:00:00 -0000 FINRA Enforcement Actions involving Robinhood full 230 Tom Fox Matt and Tom review 2 recent FINRA enforcement actions involving Robinhood. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the two recent FINRA enforcement actions involving the trading platform Robinhood.  Some of the issues we consider are: What were the underlying facts? Were red flags missed, consciously avoided or outright ignored? Where was compliance? Why must the human element always be present in compliance? Why business continuity is really a compliance issues. What about the IPO?  Resources Matt in Radical Compliance Lessons from Robinhood Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the two recent FINRA enforcement actions involving the trading platform Robinhood. 

Some of the issues we consider are:

  • What were the underlying facts?
  • Were red flags missed, consciously avoided or outright ignored?
  • Where was compliance?
  • Why must the human element always be present in compliance?
  • Why business continuity is really a compliance issues.
  • What about the IPO? 

Resources

Matt in Radical Compliance

Lessons from Robinhood

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]]> 1270 no The Amec Foster Wheeler FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the first FCPA enforcement action involving a company in 2021, the Amec Foster Wheeler global anti-corruption enforcement action. Some of the issues we consider are: What were the underlying facts? Were red flags missed, consciously avoided or outright ignored? Where was compliance? How corrupt was the culture of Foster Wheeler? What does this mean for compliance going forward?   Resources Matt in Radical Compliance Foster Wheeler’s FCPA Lessons Tom in the FCPA Compliance and Ethics Blog Not a Siren’s Song Silk Shirts and Corruption Ba-da-Bing; Ba-Da-Bing Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 30 Jun 2021 04:00:00 -0000 The Amec Foster Wheeler FCPA Enforcement Action full 228 Tom Fox Compliance lessons from the Amec Foster Wheeler FCPA enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the first FCPA enforcement action involving a company in 2021, the Amec Foster Wheeler global anti-corruption enforcement action. Some of the issues we consider are: What were the underlying facts? Were red flags missed, consciously avoided or outright ignored? Where was compliance? How corrupt was the culture of Foster Wheeler? What does this mean for compliance going forward?   Resources Matt in Radical Compliance Foster Wheeler’s FCPA Lessons Tom in the FCPA Compliance and Ethics Blog Not a Siren’s Song Silk Shirts and Corruption Ba-da-Bing; Ba-Da-Bing Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the first FCPA enforcement action involving a company in 2021, the Amec Foster Wheeler global anti-corruption enforcement action. Some of the issues we consider are:

  • What were the underlying facts?
  • Were red flags missed, consciously avoided or outright ignored?
  • Where was compliance?
  • How corrupt was the culture of Foster Wheeler?
  • What does this mean for compliance going forward?

 

Resources

Matt in Radical Compliance

Foster Wheeler’s FCPA Lessons

Tom in the FCPA Compliance and Ethics Blog

Not a Siren’s Song

Silk Shirts and Corruption

Ba-da-Bing; Ba-Da-Bing

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1665 no Disclosures of Cyber Security Disclosure Failures Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a lesson learned long ago by the Nixon Administration, adapted for 21st century cybersecurity. It’s not just the breach, it is not disclosing the breach to authorities and investors for which companies get in hot water. Some of the issues we consider are: What are your reporting obligations after a breach? Why is the SEC interested in how you inform investors? Why does the legal department want to hide any breaches? What are the costs for failure to disclose? What does this mean for compliance going forward? Resources Matt in Radical Compliance Example of Cybersecurity Disclosure Failures Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Jun 2021 04:00:00 -0000 Disclosures of Cyber Security Disclosure Failures full 228 Tom Fox Why can the failure to disclose a cyber breach be just as bad as the breach itself? Tom and Matt explore. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a lesson learned long ago by the Nixon Administration, adapted for 21st century cybersecurity. It’s not just the breach, it is not disclosing the breach to authorities and investors for which companies get in hot water. Some of the issues we consider are: What are your reporting obligations after a breach? Why is the SEC interested in how you inform investors? Why does the legal department want to hide any breaches? What are the costs for failure to disclose? What does this mean for compliance going forward? Resources Matt in Radical Compliance Example of Cybersecurity Disclosure Failures Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a lesson learned long ago by the Nixon Administration, adapted for 21st century cybersecurity. It’s not just the breach, it is not disclosing the breach to authorities and investors for which companies get in hot water. Some of the issues we consider are:

  • What are your reporting obligations after a breach?
  • Why is the SEC interested in how you inform investors?
  • Why does the legal department want to hide any breaches?
  • What are the costs for failure to disclose?
  • What does this mean for compliance going forward?

Resources

Matt in Radical Compliance

Example of Cybersecurity Disclosure Failures

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]]> 984 no Financial Crimes Compliance Costs Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent report from LexisNexis Risk Solutions about the costs of financial crimes compliance and its implications for ABC compliance professionals.  Some of the issues we consider are: What costs have gone up? Why have the costs for financial crimes compliance increased? What areas are the costs centered? Did the costs increase due to the pandemic? What does this mean for other compliance disciplines going forward?  Resources Matt in Radical Compliance Financial Crimes Compliance Cost Keeps Going Up  LexisNexis Report - True Cost of Financial Crime Compliance Global Report Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Jun 2021 04:00:00 -0000 Financial Crimes Compliance Costs full 227 Tom Fox In this episode Matt and Tom look at a recent report on the increasing costs of financial crimes compliance. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent report from LexisNexis Risk Solutions about the costs of financial crimes compliance and its implications for ABC compliance professionals.  Some of the issues we consider are: What costs have gone up? Why have the costs for financial crimes compliance increased? What areas are the costs centered? Did the costs increase due to the pandemic? What does this mean for other compliance disciplines going forward?  Resources Matt in Radical Compliance Financial Crimes Compliance Cost Keeps Going Up  LexisNexis Report - True Cost of Financial Crime Compliance Global Report Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent report from LexisNexis Risk Solutions about the costs of financial crimes compliance and its implications for ABC compliance professionals. 

Some of the issues we consider are:

  • What costs have gone up?
  • Why have the costs for financial crimes compliance increased?
  • What areas are the costs centered?
  • Did the costs increase due to the pandemic?
  • What does this mean for other compliance disciplines going forward?

 Resources

Matt in Radical Compliance

Financial Crimes Compliance Cost Keeps Going Up 

LexisNexis Report - True Cost of Financial Crime Compliance Global Report

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1189 no PCAOB Clean Sweep Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the SEC Chairman Gary Gensler’s firing of the entire PCAOB Board, including Board Chair William Duhnke.  Some of the issues we consider are: What does this mean for internal audit? What does this mean for compliance? What was the legal basis for these terminations? How did Duhnke create such a toxic culture at the PCAOB? What does this mean for ESG, cybersecurity and data analytics going forward? Resources Matt in Radical Compliance The PCAOB House-Cleaning and You Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Jun 2021 04:02:00 -0000 PCAOB Clean Sweep full 226 Tom Fox What does the clean sweep of the PCAOB mean for compliance? Tom and Matt explore in this episode. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the SEC Chairman Gary Gensler’s firing of the entire PCAOB Board, including Board Chair William Duhnke.  Some of the issues we consider are: What does this mean for internal audit? What does this mean for compliance? What was the legal basis for these terminations? How did Duhnke create such a toxic culture at the PCAOB? What does this mean for ESG, cybersecurity and data analytics going forward? Resources Matt in Radical Compliance The PCAOB House-Cleaning and You Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the SEC Chairman Gary Gensler’s firing of the entire PCAOB Board, including Board Chair William Duhnke.

 Some of the issues we consider are:

  • What does this mean for internal audit?
  • What does this mean for compliance?
  • What was the legal basis for these terminations?
  • How did Duhnke create such a toxic culture at the PCAOB?
  • What does this mean for ESG, cybersecurity and data analytics going forward?

Resources

Matt in Radical Compliance

The PCAOB House-Cleaning and You

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1445 no Compliance and ESG Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the role(s) of compliance for ESG. Some of the issues we consider are: How compliance is most suited to lead a corporate ESG effort. Why compliance must do so or be relegated to a technical function? How does government, the courts and investors drive ESG? What is the role in asymmetrical regulations in driving ESG? Why was last week such a wakeup call for corporations around ESG?  Resources Matt in Radical Compliance Resources to Assess ESG Materiality Tom in the FCPA Compliance and Ethics Blog The Role of Compliance in ESG Leading the ESG Effort-Steps for Compliance Compliance, Data Analytics and ESG Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Jun 2021 04:08:00 -0000 Compliance and ESG full 225 Tom Fox In this episode, we look at the role of compliance in ESG. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the role(s) of compliance for ESG. Some of the issues we consider are: How compliance is most suited to lead a corporate ESG effort. Why compliance must do so or be relegated to a technical function? How does government, the courts and investors drive ESG? What is the role in asymmetrical regulations in driving ESG? Why was last week such a wakeup call for corporations around ESG?  Resources Matt in Radical Compliance Resources to Assess ESG Materiality Tom in the FCPA Compliance and Ethics Blog The Role of Compliance in ESG Leading the ESG Effort-Steps for Compliance Compliance, Data Analytics and ESG Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the role(s) of compliance for ESG. Some of the issues we consider are:

  • How compliance is most suited to lead a corporate ESG effort.
  • Why compliance must do so or be relegated to a technical function?
  • How does government, the courts and investors drive ESG?
  • What is the role in asymmetrical regulations in driving ESG?
  • Why was last week such a wakeup call for corporations around ESG? 

Resources

Matt in Radical Compliance

Resources to Assess ESG Materiality

Tom in the FCPA Compliance and Ethics Blog

The Role of Compliance in ESG

Leading the ESG Effort-Steps for Compliance

Compliance, Data Analytics and ESG

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1578 no Compliance Lessons from the Super League Fiasco Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the fiasco around the formation of the Super League in European Football (soccer), focusing on the role of John Henry, American owner of the Liverpool Football Club and the lessons for the (American) compliance professional.  Some of the issues we consider are: How do you make a cultural change? Why it is mandatory to engage stakeholder in any discussions around cultural change? What makes stakeholder want to follow a corp leader? Why empathy is a mandatory leadership trait for any successful CEO. Why understanding corporate subcultures outside the US is mandatory for the CCO.  Resources Read WSJ article Liverpool and the Red Sox Won on His Watch. For Fans, That’s Not Enough by Joshua Robinson Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 27 May 2021 17:40:12 -0000 Compliance Lessons from the Super League Fiasco full 224 Tom Fox This week Matt and Tom take a deep dive into the fiasco around the formation of the Super League . Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the fiasco around the formation of the Super League in European Football (soccer), focusing on the role of John Henry, American owner of the Liverpool Football Club and the lessons for the (American) compliance professional.  Some of the issues we consider are: How do you make a cultural change? Why it is mandatory to engage stakeholder in any discussions around cultural change? What makes stakeholder want to follow a corp leader? Why empathy is a mandatory leadership trait for any successful CEO. Why understanding corporate subcultures outside the US is mandatory for the CCO.  Resources Read WSJ article Liverpool and the Red Sox Won on His Watch. For Fans, That’s Not Enough by Joshua Robinson Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the fiasco around the formation of the Super League in European Football (soccer), focusing on the role of John Henry, American owner of the Liverpool Football Club and the lessons for the (American) compliance professional.  Some of the issues we consider are:

  • How do you make a cultural change?
  • Why it is mandatory to engage stakeholder in any discussions around cultural change?
  • What makes stakeholder want to follow a corp leader?
  • Why empathy is a mandatory leadership trait for any successful CEO.
  • Why understanding corporate subcultures outside the US is mandatory for the CCO. 

Resources

Read WSJ article Liverpool and the Red Sox Won on His Watch. For Fans, That’s Not Enough by Joshua Robinson

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1076 no Biden Administration Executive Order on Cybersecurity Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the Biden Administration’s recently released Executive Order on cybersecurity for both the federal government but also contractors who do work for the US government and their subcontractors.  Some of the issues we consider are: How will there be more and better sharing of threat information? How will we achieve stronger cybersecurity within the government? Why will contractors will need to have stronger oversight of their SW supply chain? What will be the role of compliance? What will be the role of internal audit?  Resources Matt’s blog post on Radical Compliance:  Parsing Biden’s Cybersecurity Order Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 May 2021 04:04:00 -0000 Biden Administration Executive Order on Cybersecurity full 223 Tom Fox Matt and Tom take a deep dive into the Biden Administration Executive Order on Cybersecurity Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the Biden Administration’s recently released Executive Order on cybersecurity for both the federal government but also contractors who do work for the US government and their subcontractors.  Some of the issues we consider are: How will there be more and better sharing of threat information? How will we achieve stronger cybersecurity within the government? Why will contractors will need to have stronger oversight of their SW supply chain? What will be the role of compliance? What will be the role of internal audit?  Resources Matt’s blog post on Radical Compliance:  Parsing Biden’s Cybersecurity Order Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the Biden Administration’s recently released Executive Order on cybersecurity for both the federal government but also contractors who do work for the US government and their subcontractors.

 Some of the issues we consider are:

  • How will there be more and better sharing of threat information?
  • How will we achieve stronger cybersecurity within the government?
  • Why will contractors will need to have stronger oversight of their SW supply chain?
  • What will be the role of compliance?
  • What will be the role of internal audit? 

Resources

Matt’s blog post on Radical Compliance: 

Parsing Biden’s Cybersecurity Order

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1678 no Elon Musk, Cryptocurrency and the SEC Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the intersection of Elon Musk, cryptocurrencies and the SEC. Some of the issues we consider are: What do make of Musk’s SLN performance? What does the SEC have to say about all this? What is the MicroStrategy, strategy? What does the market think about all this? Where is compliance?  Resources Matt’s blog post on Radical Compliance:  Bitcoin We Have a Problem Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 May 2021 04:02:00 -0000 Elon Musk, Cryptocurrency and the SEC full 222 Tom Fox Tom & Matt take a deep dive into the intersection of Elon Musk, cryptocurrencies and the SEC. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the intersection of Elon Musk, cryptocurrencies and the SEC. Some of the issues we consider are: What do make of Musk’s SLN performance? What does the SEC have to say about all this? What is the MicroStrategy, strategy? What does the market think about all this? Where is compliance?  Resources Matt’s blog post on Radical Compliance:  Bitcoin We Have a Problem Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the intersection of Elon Musk, cryptocurrencies and the SEC. Some of the issues we consider are:

  • What do make of Musk’s SLN performance?
  • What does the SEC have to say about all this?
  • What is the MicroStrategy, strategy?
  • What does the market think about all this?
  • Where is compliance? 

Resources

Matt’s blog post on Radical Compliance: 

Bitcoin We Have a Problem

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]]> 1268 no SAP Trade Sanctions Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into SAP trade sanction enforcement action. Some of the issues we consider are: What were the underlying facts? How did SAP allow products to get to Iran for so long? How did SAP achieve a NPA even with aggrieved factors? How was the financial penalty calculated? What were the remedial steps SAP engaged in? Why does this enforcement action point towards the need for a more holistic approach to risk?  Resources Matt’s blog post on Radical Compliance:  SAP Nailed on Sanctions Violations Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 May 2021 04:00:00 -0000 SAP Trade Sanctions Enforcement Action full 221 Tom Fox Matt and Tom take a deep dive into SAP trade sanction enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into SAP trade sanction enforcement action. Some of the issues we consider are: What were the underlying facts? How did SAP allow products to get to Iran for so long? How did SAP achieve a NPA even with aggrieved factors? How was the financial penalty calculated? What were the remedial steps SAP engaged in? Why does this enforcement action point towards the need for a more holistic approach to risk?  Resources Matt’s blog post on Radical Compliance:  SAP Nailed on Sanctions Violations Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into SAP trade sanction enforcement action. Some of the issues we consider are:

  • What were the underlying facts?
  • How did SAP allow products to get to Iran for so long?
  • How did SAP achieve a NPA even with aggrieved factors?
  • How was the financial penalty calculated?
  • What were the remedial steps SAP engaged in?
  • Why does this enforcement action point towards the need for a more holistic approach to risk?

 Resources

Matt’s blog post on Radical Compliance:

 SAP Nailed on Sanctions Violations

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]]> 1387 Compliance Lessons from the Cuban Missile Crisis Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a different area; their joint love of history. Matt is reading Nuclear Folly, a new chronicle of the Cuban Missile Crisis by Ukrainian history professor Serhii Plokhy. We use this as a starting point to explore how both the Soviets and Americans used different types of internal debate and information to eventually steer clear of nuclear war.  Some of the issues we consider are: What was the Soviet model for information gathering, analysis and debate, both before and during the Missile Crisis? How was the American model of Ex-Comm so different? How do these models inform a speak up culture? How and more importantly why are leadership, corporate culture, speaking up, ethical values all connected.? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance: Culture and the Cuban Missile Crisis Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Apr 2021 04:02:00 -0000 Compliance Lessons from the Cuban Missile Crisis full 220 Tom Fox What was the role of culture in the events leading to and resolution of the Cuban Missile Crisis? Tom and Matt take a dip into history to explore. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a different area; their joint love of history. Matt is reading Nuclear Folly, a new chronicle of the Cuban Missile Crisis by Ukrainian history professor Serhii Plokhy. We use this as a starting point to explore how both the Soviets and Americans used different types of internal debate and information to eventually steer clear of nuclear war.  Some of the issues we consider are: What was the Soviet model for information gathering, analysis and debate, both before and during the Missile Crisis? How was the American model of Ex-Comm so different? How do these models inform a speak up culture? How and more importantly why are leadership, corporate culture, speaking up, ethical values all connected.? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance: Culture and the Cuban Missile Crisis Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a different area; their joint love of history. Matt is reading Nuclear Folly, a new chronicle of the Cuban Missile Crisis by Ukrainian history professor Serhii Plokhy. We use this as a starting point to explore how both the Soviets and Americans used different types of internal debate and information to eventually steer clear of nuclear war. 

Some of the issues we consider are:

  • What was the Soviet model for information gathering, analysis and debate, both before and during the Missile Crisis?
  • How was the American model of Ex-Comm so different?
  • How do these models inform a speak up culture?
  • How and more importantly why are leadership, corporate culture, speaking up, ethical values all connected.?
  • What does this mean for compliance officers?

 Resources

Matt’s blog post on Radical Compliance:

Culture and the Cuban Missile Crisis

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]]> 1494 no What is risk? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into different types of risk including cybersecurity and anti-corruption to lead a broader discuss about the nature of risk, risk management and the future of compliance. Some of the issues we consider are: What is risk? What are the roles of the CISO and CCO for risk management? Who owns risk? What does a BOD want to see around risk management? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance: The Cracks in Third Party Risk Management Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Apr 2021 04:01:00 -0000 What is risk? full 219 Tom Fox In this episode, Tom Fox and Matt Kelly take a deep dive into the questions of what is risk and what is risk management. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into different types of risk including cybersecurity and anti-corruption to lead a broader discuss about the nature of risk, risk management and the future of compliance. Some of the issues we consider are: What is risk? What are the roles of the CISO and CCO for risk management? Who owns risk? What does a BOD want to see around risk management? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance: The Cracks in Third Party Risk Management Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into different types of risk including cybersecurity and anti-corruption to lead a broader discuss about the nature of risk, risk management and the future of compliance. Some of the issues we consider are:

  • What is risk?
  • What are the roles of the CISO and CCO for risk management?
  • Who owns risk?
  • What does a BOD want to see around risk management?
  • What does this mean for compliance officers?

 Resources

Matt’s blog post on Radical Compliance:

The Cracks in Third Party Risk Management

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]]> 1244 no Cybersecurity, ERP and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the type of cybersecurity risk where ERP software is compromised due to a bug or other vulnerability.  Some of the issues we consider are: ·      What are two types of cybersecurity risk? ·      How does this second type of risk impact ERP systems? ·      What are the compliance implications? Internal Audit?  Crop Governance?  ·      What steps can a CISO take? ·      What does this mean for compliance officers? Resources Matt’s blog post on Radical Compliance:  More on Cybersecurity, Compliance Risk Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 13 Apr 2021 04:04:00 -0000 Cybersecurity, ERP and Compliance full 218 Tom Fox This week Matt and Tom take a deep dive into the type of cybersecurity risk where ERP software is compromised due to a bug or other vulnerability. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the type of cybersecurity risk where ERP software is compromised due to a bug or other vulnerability.  Some of the issues we consider are: ·      What are two types of cybersecurity risk? ·      How does this second type of risk impact ERP systems? ·      What are the compliance implications? Internal Audit?  Crop Governance?  ·      What steps can a CISO take? ·      What does this mean for compliance officers? Resources Matt’s blog post on Radical Compliance:  More on Cybersecurity, Compliance Risk Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the type of cybersecurity risk where ERP software is compromised due to a bug or other vulnerability. 

Some of the issues we consider are:

·      What are two types of cybersecurity risk?

·      How does this second type of risk impact ERP systems?

·      What are the compliance implications? Internal Audit?  Crop Governance? 

·      What steps can a CISO take?

·      What does this mean for compliance officers?

Resources

Matt’s blog post on Radical Compliance: 

More on Cybersecurity, Compliance Risk


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]]> 1569 no SPACs and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent spate of SPACs which have formed and are gobbling up companies through acquisition. What does it mean from the internal control, risk management and compliance perspective?  Some of the issues we consider are: What are SPACs? Do SPACs render controls ineffective? What are the requirements under SOX 404b for SPACs? Do SPACs create an inherent conflict of interest between management and shareholders? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance:  SPACs Draw Internal Control, Governance Concerns Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 Apr 2021 04:02:00 -0000 SPACs and Compliance full 217 Tom Fox In this episode, Matt and Tom take a deep dive into the recent spate of SPACs which have formed. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent spate of SPACs which have formed and are gobbling up companies through acquisition. What does it mean from the internal control, risk management and compliance perspective?  Some of the issues we consider are: What are SPACs? Do SPACs render controls ineffective? What are the requirements under SOX 404b for SPACs? Do SPACs create an inherent conflict of interest between management and shareholders? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance:  SPACs Draw Internal Control, Governance Concerns Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent spate of SPACs which have formed and are gobbling up companies through acquisition. What does it mean from the internal control, risk management and compliance perspective?

 Some of the issues we consider are:

  • What are SPACs?
  • Do SPACs render controls ineffective?
  • What are the requirements under SOX 404b for SPACs?
  • Do SPACs create an inherent conflict of interest between management and shareholders?
  • What does this mean for compliance officers? 

Resources

Matt’s blog post on Radical Compliance: 

SPACs Draw Internal Control, Governance Concerns

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]]> 1418 no Boaty McBoat, Risk and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent grounding of the Ever Given in the Suez Canal, which has now been floated free. What does it mean from the risk management and compliance perspective? Some of the issues we consider are: What were the controls in place to stop this failure? What changed which rendered these controls ineffective and even obsolete? What is your risk program around supply chain disruption? Was this a Black Swan event? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance:  Less Ever Given on Risk and Control The bank effect and the big boat blocking the Suez, Brendan Greely in the FT Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 31 Mar 2021 04:02:00 -0000 Boaty McBoat, Risk and Compliance full 216 Tom Fox What does the Ever Given grounding mean from the risk management and compliance perspective? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent grounding of the Ever Given in the Suez Canal, which has now been floated free. What does it mean from the risk management and compliance perspective? Some of the issues we consider are: What were the controls in place to stop this failure? What changed which rendered these controls ineffective and even obsolete? What is your risk program around supply chain disruption? Was this a Black Swan event? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance:  Less Ever Given on Risk and Control The bank effect and the big boat blocking the Suez, Brendan Greely in the FT Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent grounding of the Ever Given in the Suez Canal, which has now been floated free. What does it mean from the risk management and compliance perspective? Some of the issues we consider are:

  • What were the controls in place to stop this failure?
  • What changed which rendered these controls ineffective and even obsolete?
  • What is your risk program around supply chain disruption?
  • Was this a Black Swan event?
  • What does this mean for compliance officers? 

Resources

Matt’s blog post on Radical Compliance: 

Less Ever Given on Risk and Control

The bank effect and the big boat blocking the Suez, Brendan Greely in the FT

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]]> 1406 no CEOs Perception of Risk, Impact on Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the 2021 PwC Global CEO Survey, including its findings about digital transformation of business processes and risk management. Some of the issues we consider are: What are the top risks CEOs are worried about in 2021? How has that list changed since 2020? What is the digital transformation of business process and risk management? How will compliance response to these new risks? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance:  Thoughts from CEOs Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Mar 2021 04:01:00 -0000 CEOs Perception of Risk, Impact on Compliance full 215 Tom Fox In this episode, take a deep dive into the 2021 PwC Global CEO Survey, including its findings about digital transformation of business processes and risk management to discuss. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the 2021 PwC Global CEO Survey, including its findings about digital transformation of business processes and risk management. Some of the issues we consider are: What are the top risks CEOs are worried about in 2021? How has that list changed since 2020? What is the digital transformation of business process and risk management? How will compliance response to these new risks? What does this mean for compliance officers?  Resources Matt’s blog post on Radical Compliance:  Thoughts from CEOs Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the 2021 PwC Global CEO Survey, including its findings about digital transformation of business processes and risk management.

Some of the issues we consider are:

  • What are the top risks CEOs are worried about in 2021?
  • How has that list changed since 2020?
  • What is the digital transformation of business process and risk management?
  • How will compliance response to these new risks?
  • What does this mean for compliance officers? 

Resources

Matt’s blog post on Radical Compliance: 

Thoughts from CEOs

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]]> 1422 no A Punch in the Face to SEC Enforcement? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a recent speech by SEC Commissioner Caroline Crenshaw on a new philosophy in SEC financial penalty enforcement.   Some of the issues we consider are: Who is SEC Commissioner Caroline Crenshaw? What was the 2006 policy regarding enforcement priorities? What changes did Commissioner Crenshaw propose? What about the timing of the remarks? Is this a response to the Supreme Court decision in Lui? What does this mean for compliance officers? Resources Matt’s blog post on Radical Compliance: SEC Enforcement Speech, Umm Wow  2006 SEC Enforcement Policy Statement Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Mar 2021 04:02:00 -0000 A Punch in the Face to SEC Enforcement? full 214 Tom Fox SEC Commissioner Caroline Crenshaw recently challenged SEC enforcement theory with a 'punch in the face' Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a recent speech by SEC Commissioner Caroline Crenshaw on a new philosophy in SEC financial penalty enforcement.   Some of the issues we consider are: Who is SEC Commissioner Caroline Crenshaw? What was the 2006 policy regarding enforcement priorities? What changes did Commissioner Crenshaw propose? What about the timing of the remarks? Is this a response to the Supreme Court decision in Lui? What does this mean for compliance officers? Resources Matt’s blog post on Radical Compliance: SEC Enforcement Speech, Umm Wow  2006 SEC Enforcement Policy Statement Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into a recent speech by SEC Commissioner Caroline Crenshaw on a new philosophy in SEC financial penalty enforcement.  

Some of the issues we consider are:

  • Who is SEC Commissioner Caroline Crenshaw?
  • What was the 2006 policy regarding enforcement priorities?
  • What changes did Commissioner Crenshaw propose?
  • What about the timing of the remarks?
  • Is this a response to the Supreme Court decision in Lui?
  • What does this mean for compliance officers?

Resources

Matt’s blog post on Radical Compliance:

SEC Enforcement Speech, Umm Wow 

2006 SEC Enforcement Policy Statement

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]]> 1388 no The ECI 2021 Global Business Ethics Survey Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into findings, conclusions and recommendations in the ECI 2021 GBES.   Some of the issues we consider are: What were the key findings of the GBES? What pressure are employees under? What were the findings on observed misconduct and the reported misconduct? Troubling findings on retaliation. What has been the impact of Covid-19 on compliance and ethics? What were the conclusions and recommendations?  Resources Matt’s blog post on Radical Compliance: Report: Ethics Pressures Mounting on Employees ECI 2021 Global Business Ethics Survey Next week, Tom will have a 5-part podcast series on the FCPA Compliance Report, featuring ECI President Pat Harned discussing the 2021 GBES. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Mar 2021 05:01:00 -0000 The ECI 2021 Global Business Ethics Survey full 213 Tom Fox Matt and Tom take a deep dive into findings, conclusions and recommendations in the ECI 2021 GBES. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into findings, conclusions and recommendations in the ECI 2021 GBES.   Some of the issues we consider are: What were the key findings of the GBES? What pressure are employees under? What were the findings on observed misconduct and the reported misconduct? Troubling findings on retaliation. What has been the impact of Covid-19 on compliance and ethics? What were the conclusions and recommendations?  Resources Matt’s blog post on Radical Compliance: Report: Ethics Pressures Mounting on Employees ECI 2021 Global Business Ethics Survey Next week, Tom will have a 5-part podcast series on the FCPA Compliance Report, featuring ECI President Pat Harned discussing the 2021 GBES. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into findings, conclusions and recommendations in the ECI 2021 GBES.  

Some of the issues we consider are:

  • What were the key findings of the GBES?
  • What pressure are employees under?
  • What were the findings on observed misconduct and the reported misconduct?
  • Troubling findings on retaliation.
  • What has been the impact of Covid-19 on compliance and ethics?
  • What were the conclusions and recommendations? 

Resources

Matt’s blog post on Radical Compliance:

Report: Ethics Pressures Mounting on Employees

ECI

2021 Global Business Ethics Survey

Next week, Tom will have a 5-part podcast series on the FCPA Compliance Report, featuring ECI President Pat Harned discussing the 2021 GBES.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1724 no The SEC and Climate Disclosures Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent announcement by the SEC that it would start paying more attention to companies’ climate change disclosures.   Some of the issues we consider are: What did acting Chairman Allison Herren Lee announce? A review of the 2010 Climate Guidance What changes might be in the offing? What will the SEC process be going forward? What frameworks might the SEC use as a guide? What does this mean for the compliance function? What are the compliance lessons?  Resources Matt’s blog post on Radical Compliance: SEC Fires Warning Shot on Climate Disclosure Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Mar 2021 05:05:00 -0000 The SEC and Climate Disclosures full 212 Tom Fox In this episode, we take a deep dive into the recent announcement by the SEC that it would start paying more attention to companies’ climate change disclosures. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent announcement by the SEC that it would start paying more attention to companies’ climate change disclosures.   Some of the issues we consider are: What did acting Chairman Allison Herren Lee announce? A review of the 2010 Climate Guidance What changes might be in the offing? What will the SEC process be going forward? What frameworks might the SEC use as a guide? What does this mean for the compliance function? What are the compliance lessons?  Resources Matt’s blog post on Radical Compliance: SEC Fires Warning Shot on Climate Disclosure Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into the recent announcement by the SEC that it would start paying more attention to companies’ climate change disclosures.  

Some of the issues we consider are:

  • What did acting Chairman Allison Herren Lee announce?
  • A review of the 2010 Climate Guidance
  • What changes might be in the offing?
  • What will the SEC process be going forward?
  • What frameworks might the SEC use as a guide?
  • What does this mean for the compliance function?
  • What are the compliance lessons? 

Resources

Matt’s blog post on Radical Compliance:

SEC Fires Warning Shot on Climate Disclosure

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1168 no Compliance Lessons from Citibank’s $900MM Erroneous Wire Transfer Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into one of the most delicious legal decisions recently seen: the attempt by Citibank to recoup $500MM of the $900MM it erroneously wired out on behalf of Revlon.   Some of the issues we consider are: ·      How did this Fubar occur? ·      What was the role of complexity? ·      Why did the employees make this mistake? ·      What about training? ·      Where were internal controls? ·      What is the ‘value for discharge’ defense? ·      Does this all just come down to finders keepers? ·      What are the compliance lessons?  Resources Tom’s blog posts on the FCPA Compliance and Ethics Blog: Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 1 - The Facts Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 2 – Lessons Learned  The Citibank decision Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Feb 2021 05:01:00 -0000 Compliance Lessons from Citibank’s $900MM Erroneous Wire Transfer full 211 Tom Fox What are the compliance lessons from Citibank's erroneous $900 wire transfer? Plenty it turns out. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into one of the most delicious legal decisions recently seen: the attempt by Citibank to recoup $500MM of the $900MM it erroneously wired out on behalf of Revlon.   Some of the issues we consider are: ·      How did this Fubar occur? ·      What was the role of complexity? ·      Why did the employees make this mistake? ·      What about training? ·      Where were internal controls? ·      What is the ‘value for discharge’ defense? ·      Does this all just come down to finders keepers? ·      What are the compliance lessons?  Resources Tom’s blog posts on the FCPA Compliance and Ethics Blog: Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 1 - The Facts Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 2 – Lessons Learned  The Citibank decision Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week Matt and Tom take a deep dive into one of the most delicious legal decisions recently seen: the attempt by Citibank to recoup $500MM of the $900MM it erroneously wired out on behalf of Revlon.  

Some of the issues we consider are:

·      How did this Fubar occur?

·      What was the role of complexity?

·      Why did the employees make this mistake?

·      What about training?

·      Where were internal controls?

·      What is the ‘value for discharge’ defense?

·      Does this all just come down to finders keepers?

·      What are the compliance lessons? 

Resources

Tom’s blog posts on the FCPA Compliance and Ethics Blog:

Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 1 - The Facts

Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 2 – Lessons Learned 

The Citibank decision

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2125 no Employee Trust and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Last week we considered the SEC regulations requiring companies to detail human capital issues in their annual reports and what it meant for compliance. This led to a week-long dialogue between Matt and myself about the current state of employee trust and its role in corporate culture and a best practices compliance and ethics program.    Some of the issues we consider are: Trust is down. The now former UK KPMG Chairman who told employees to ‘quit whining’ about the Coronavirus health crisis issue. Employees are under more pressure to deliver results. What does this do to trust? Employee to employee trust issues in WFH. Trust issues around RTW, both employee to employee and management response to employee health and safety issues at the workplace. Benjamin Moore getting rid of legal department and then restricting employee access to legal assistance. Greater fear toward retaliation stopping whistleblowers from coming forward.  Resources Matt’s blog post in Radical Compliance: Corporate Culture and Human Capital Disclosures  Tom’s blog posts on the FCPA Compliance and Ethics Blog: A Macro Approach for Human Capital Compliance Hal Holbrook, Mark Twain and Employee Trust How to Destroy Employee Trust Leadership Lessons from Abraham Lincoln Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Feb 2021 05:01:00 -0000 Employee Trust and Compliance full 210 Tom Fox In this episode, Matt & Tom This continue their dialogue about the current state of employee trust and its role in corporate culture and a best practices compliance and ethics program. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Last week we considered the SEC regulations requiring companies to detail human capital issues in their annual reports and what it meant for compliance. This led to a week-long dialogue between Matt and myself about the current state of employee trust and its role in corporate culture and a best practices compliance and ethics program.    Some of the issues we consider are: Trust is down. The now former UK KPMG Chairman who told employees to ‘quit whining’ about the Coronavirus health crisis issue. Employees are under more pressure to deliver results. What does this do to trust? Employee to employee trust issues in WFH. Trust issues around RTW, both employee to employee and management response to employee health and safety issues at the workplace. Benjamin Moore getting rid of legal department and then restricting employee access to legal assistance. Greater fear toward retaliation stopping whistleblowers from coming forward.  Resources Matt’s blog post in Radical Compliance: Corporate Culture and Human Capital Disclosures  Tom’s blog posts on the FCPA Compliance and Ethics Blog: A Macro Approach for Human Capital Compliance Hal Holbrook, Mark Twain and Employee Trust How to Destroy Employee Trust Leadership Lessons from Abraham Lincoln Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Last week we considered the SEC regulations requiring companies to detail human capital issues in their annual reports and what it meant for compliance. This led to a week-long dialogue between Matt and myself about the current state of employee trust and its role in corporate culture and a best practices compliance and ethics program. 

 

Some of the issues we consider are:

  • Trust is down.
  • The now former UK KPMG Chairman who told employees to ‘quit whining’ about the Coronavirus health crisis issue.
  • Employees are under more pressure to deliver results. What does this do to trust?
  • Employee to employee trust issues in WFH.
  • Trust issues around RTW, both employee to employee and management response to employee health and safety issues at the workplace.
  • Benjamin Moore getting rid of legal department and then restricting employee access to legal assistance.
  • Greater fear toward retaliation stopping whistleblowers from coming forward. 

Resources

Matt’s blog post in Radical Compliance:

Corporate Culture and Human Capital Disclosures 

Tom’s blog posts on the FCPA Compliance and Ethics Blog:

A Macro Approach for Human Capital Compliance

Hal Holbrook, Mark Twain and Employee Trust

How to Destroy Employee Trust

Leadership Lessons from Abraham Lincoln

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]]> 1768 no Human Capital Disclosures and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the SEC regulations requiring companies to detail human capital issues in their annual reports. What have some of the initial disclosures revealed? What does it mean for compliance?  Some of the issues we consider are: Why is this issue so important? What are the SEC reporting rules? How did companies report their human capital issues? What does all this mean for corporate culture? Resources Matt’s blog post in Radical Compliance: Corporate Culture and Human Capital Disclosures Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Feb 2021 05:02:00 -0000 Human Capital Disclosures and Compliance full Tom Fox In this episode, we consider the SEC regulations requiring companies to detail human capital issues in their annual reports. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the SEC regulations requiring companies to detail human capital issues in their annual reports. What have some of the initial disclosures revealed? What does it mean for compliance?  Some of the issues we consider are: Why is this issue so important? What are the SEC reporting rules? How did companies report their human capital issues? What does all this mean for corporate culture? Resources Matt’s blog post in Radical Compliance: Corporate Culture and Human Capital Disclosures Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the SEC regulations requiring companies to detail human capital issues in their annual reports. What have some of the initial disclosures revealed? What does it mean for compliance? 

Some of the issues we consider are:

  • Why is this issue so important?
  • What are the SEC reporting rules?
  • How did companies report their human capital issues?
  • What does all this mean for corporate culture?

Resources

Matt’s blog post in Radical Compliance:

Corporate Culture and Human Capital Disclosures

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]]> 1608 no GameStop and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the GameStop matter through the lens of the compliance profession.   Some of the issues we consider are: ·      What is the background? ·      What are the compliance implications of this matter?  ·      Is this a black swan event or just ‘business as usual?  ·      Short sellers in the bulls-eye?  ·      The role of the regulators? ·      Who are Robinhood’s stakeholders? ·      What is the more relevant precedent; Long Term Capital or the Panic of 1907? ·      What is the role (or responsibility) of social media? Resources Check out Tom’s 5-part blog post series on GameStop and Compliance: GameStop and Compliance-Introduction GameStop and Compliance-The Shorts GameStop and Compliance-The Squeeze and Social Media GameStop and Compliance-The Regulatory Response GameStop and Compliance-Lessons for the Compliance Professional Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Feb 2021 05:03:00 -0000 GameStop and Compliance full 208 Tom Fox In this episode, we consider the GameStop matter through the lens of the compliance profession. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the GameStop matter through the lens of the compliance profession.   Some of the issues we consider are: ·      What is the background? ·      What are the compliance implications of this matter?  ·      Is this a black swan event or just ‘business as usual?  ·      Short sellers in the bulls-eye?  ·      The role of the regulators? ·      Who are Robinhood’s stakeholders? ·      What is the more relevant precedent; Long Term Capital or the Panic of 1907? ·      What is the role (or responsibility) of social media? Resources Check out Tom’s 5-part blog post series on GameStop and Compliance: GameStop and Compliance-Introduction GameStop and Compliance-The Shorts GameStop and Compliance-The Squeeze and Social Media GameStop and Compliance-The Regulatory Response GameStop and Compliance-Lessons for the Compliance Professional Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the GameStop matter through the lens of the compliance profession.  

Some of the issues we consider are:

·      What is the background?

·      What are the compliance implications of this matter? 

·      Is this a black swan event or just ‘business as usual? 

·      Short sellers in the bulls-eye? 

·      The role of the regulators?

·      Who are Robinhood’s stakeholders?

·      What is the more relevant precedent; Long Term Capital or the Panic of 1907?

·      What is the role (or responsibility) of social media?

Resources

Check out Tom’s 5-part blog post series on GameStop and Compliance:

GameStop and Compliance-Introduction

GameStop and Compliance-The Shorts

GameStop and Compliance-The Squeeze and Social Media

GameStop and Compliance-The Regulatory Response

GameStop and Compliance-Lessons for the Compliance Professional


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]]> 1746 no WFH, RTW or Something Else Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider what will be the implications of our working environments post-pandemic. Will we be permanently working from home, returning to the office, a mix of both or something else?  Some of the issues we consider are: What are the compliance implications of a distributed workforce? How to maintain culture? Is WFH communications too much like social media? What about cyber-bullying from co-workers? Resources Matt’s blog post in Radical Compliance: Thoughts on Return to Work Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 Jan 2021 05:08:00 -0000 WFH, RTW or Something Else full 207 Tom Fox In this episode we consider will we be permanently working from home, returning to the office, a mix of both or something else? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider what will be the implications of our working environments post-pandemic. Will we be permanently working from home, returning to the office, a mix of both or something else?  Some of the issues we consider are: What are the compliance implications of a distributed workforce? How to maintain culture? Is WFH communications too much like social media? What about cyber-bullying from co-workers? Resources Matt’s blog post in Radical Compliance: Thoughts on Return to Work Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider what will be the implications of our working environments post-pandemic. Will we be permanently working from home, returning to the office, a mix of both or something else? 

Some of the issues we consider are:

  • What are the compliance implications of a distributed workforce?
  • How to maintain culture?
  • Is WFH communications too much like social media?
  • What about cyber-bullying from co-workers?

Resources

Matt’s blog post in Radical Compliance: Thoughts on Return to Work

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1537 no FinCEN Enforcement Action involving Capital One Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the Capital One resolution of the FinCEN enforcement action. We look at the compliance program; red flags missed, and how the bank was faulted as its compliance program was found to be not effective. Resources: See Matt's blog post Capital One Whacked on AML Failures See Tom's blog post the Capital One FinCEN Enforcement Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Jan 2021 05:05:00 -0000 FinCEN Enforcement Action involving Capital One full 206 Tom Fox In this episode, we consider the Capital One resolution of the FinCEN enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the Capital One resolution of the FinCEN enforcement action. We look at the compliance program; red flags missed, and how the bank was faulted as its compliance program was found to be not effective. Resources: See Matt's blog post Capital One Whacked on AML Failures See Tom's blog post the Capital One FinCEN Enforcement Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the Capital One resolution of the FinCEN enforcement action. We look at the compliance program; red flags missed, and how the bank was faulted as its compliance program was found to be not effective.

Resources:

See Matt's blog post Capital One Whacked on AML Failures

See Tom's blog post the Capital One FinCEN Enforcement

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]]> 1681 no The Deutsche Bank FCPA Settlement Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the Deutsche Bank Foreign Corrupt Practices Act resolution. We look at the compliance program; red flags missed, overlooked or avoided and internal control failures.  Some of the issues we consider are: The Bank’s compliance program was a paper program only. Where was compliance? What Red Flags were missed? Internal Audit did its job but was ignored. Actual Knowledge of corruption? What about the DFS? Resources Tom is running a 5-part blog post series on the FCPA Compliance and Ethics Blog: Part 1-Introduction Part 2- The Bribery Schemes Part 3- Overlooked Red Flags and Internal Control Failures Part 4-Recivist Penalty Part 5-Final Thoughts Matt’s blog post in Radical Compliance: Deutsche Bank Control Failures Cost $130 million Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Jan 2021 05:02:00 -0000 The Deutsche Bank FCPA Settlement full 205 Tom Fox In this episode, Matt Kelly and Tom Fox take a deep dive into the Deutsche Bank FCPA resolution. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the Deutsche Bank Foreign Corrupt Practices Act resolution. We look at the compliance program; red flags missed, overlooked or avoided and internal control failures.  Some of the issues we consider are: The Bank’s compliance program was a paper program only. Where was compliance? What Red Flags were missed? Internal Audit did its job but was ignored. Actual Knowledge of corruption? What about the DFS? Resources Tom is running a 5-part blog post series on the FCPA Compliance and Ethics Blog: Part 1-Introduction Part 2- The Bribery Schemes Part 3- Overlooked Red Flags and Internal Control Failures Part 4-Recivist Penalty Part 5-Final Thoughts Matt’s blog post in Radical Compliance: Deutsche Bank Control Failures Cost $130 million Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the Deutsche Bank Foreign Corrupt Practices Act resolution. We look at the compliance program; red flags missed, overlooked or avoided and internal control failures.

 Some of the issues we consider are:

  • The Bank’s compliance program was a paper program only.
  • Where was compliance?
  • What Red Flags were missed?
  • Internal Audit did its job but was ignored.
  • Actual Knowledge of corruption?
  • What about the DFS?

Resources

Tom is running a 5-part blog post series on the FCPA Compliance and Ethics Blog:

Part 1-Introduction

Part 2- The Bribery Schemes

Part 3- Overlooked Red Flags and Internal Control Failures

Part 4-Recivist Penalty

Part 5-Final Thoughts

Matt’s blog post in Radical Compliance:

Deutsche Bank Control Failures Cost $130 million

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]]> 1621 no 5 Issues for Compliance Professionals in 2021 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider five issues that compliance practitioners need to watch in 2021. We also talk about the second five which did not make the Top 5 but you still need to watch.  Some of the issues we consider are: What will be the implications of the Covid-19 vaccine and RTW? The Anti-Money Laundering Law of 2020. The first Biden Administration announcement. Climate Change Disclosures. The SolarWind Cybersecurity Disaster. A special bonus from Matt. Resources For more information see Matt’s blog post in Radical Compliance: Five Compliance Events to Watch in 2021 Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Jan 2021 05:03:00 -0000 5 Issues for Compliance Professionals in 2021 full Tom Fox In this episode, Jay Rosen and Tom Fox consider what can influence an organization’s ethical culture, starting at the top with senior leadership. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider five issues that compliance practitioners need to watch in 2021. We also talk about the second five which did not make the Top 5 but you still need to watch.  Some of the issues we consider are: What will be the implications of the Covid-19 vaccine and RTW? The Anti-Money Laundering Law of 2020. The first Biden Administration announcement. Climate Change Disclosures. The SolarWind Cybersecurity Disaster. A special bonus from Matt. Resources For more information see Matt’s blog post in Radical Compliance: Five Compliance Events to Watch in 2021 Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider five issues that compliance practitioners need to watch in 2021. We also talk about the second five which did not make the Top 5 but you still need to watch. 

Some of the issues we consider are:

  • What will be the implications of the Covid-19 vaccine and RTW?
  • The Anti-Money Laundering Law of 2020.
  • The first Biden Administration announcement.
  • Climate Change Disclosures.
  • The SolarWind Cybersecurity Disaster.
  • A special bonus from Matt.

Resources

For more information see Matt’s blog post in Radical Compliance:

Five Compliance Events to Watch in 2021

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2036 no Who Should Oversee and Manage the Hotline Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the question of who in an organization should oversee a hotline. Once that decision is made, who should manage the hotline.  Some of the issues we consider are: Why the Audit Committee on the Board should oversee the hotline. It should be written into the Audit Committee’s Charter. The hotline manager must have the independence to investigate any issues raised and they must have the competence to do so. Why the Compliance Function should oversee management of the hotline. Resources For more information see Matt’s blog post in Radical Compliance: Who Should Run the Hotline? Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 30 Dec 2020 05:02:00 -0000 Who Should Oversee and Manage the Hotline full 203 Tom Fox In this episode, we take a deep dive into who should oversee and manage a hotline. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the question of who in an organization should oversee a hotline. Once that decision is made, who should manage the hotline.  Some of the issues we consider are: Why the Audit Committee on the Board should oversee the hotline. It should be written into the Audit Committee’s Charter. The hotline manager must have the independence to investigate any issues raised and they must have the competence to do so. Why the Compliance Function should oversee management of the hotline. Resources For more information see Matt’s blog post in Radical Compliance: Who Should Run the Hotline? Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider the question of who in an organization should oversee a hotline. Once that decision is made, who should manage the hotline.

 Some of the issues we consider are:

  • Why the Audit Committee on the Board should oversee the hotline.
  • It should be written into the Audit Committee’s Charter.
  • The hotline manager must have the independence to investigate any issues raised and they must have the competence to do so.
  • Why the Compliance Function should oversee management of the hotline.

Resources

For more information see Matt’s blog post in Radical Compliance:

Who Should Run the Hotline?

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1346 no Algorithm Failures in Ethics and Equity at Stanford Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider how badly Stanford University Health Systems botched it decision on whom in the organization would receive its allotted Covid-19 vaccinations. Stanford used a faulty algorithm which mandated that only seven of the Health Systems 1300 medical residents would receive the vaccine. As you might guess these front-line health workers were up in arms over Stanford’s incompetence on this issue. Some of the issues we consider are: The plan had been for the algorithm to assign vaccination slots for the first 5,000 employees, who would begin receiving the Covid vaccine on Dec. 18. What were the parameters of the algorithm? Why was there so little ethics in the process? Why was there so little equity in the result? What are the implications for the compliance professional of the use of the algorithm to make such a critical decision? What does the EEOC decision allowing companies to mandate vaccines for employees mean for compliance? Resources For more information see Matt’s blog post in Radical Compliance: Lessons on Algorithms, Ethics and Equity Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Dec 2020 05:05:00 -0000 Algorithm Failures in Ethics and Equity at Stanford full 202 Tom Fox In this episode, we consider how badly Stanford University Health Systems botched it decision on whom in the organization would receive its allotted Covid-19 vaccinations Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider how badly Stanford University Health Systems botched it decision on whom in the organization would receive its allotted Covid-19 vaccinations. Stanford used a faulty algorithm which mandated that only seven of the Health Systems 1300 medical residents would receive the vaccine. As you might guess these front-line health workers were up in arms over Stanford’s incompetence on this issue. Some of the issues we consider are: The plan had been for the algorithm to assign vaccination slots for the first 5,000 employees, who would begin receiving the Covid vaccine on Dec. 18. What were the parameters of the algorithm? Why was there so little ethics in the process? Why was there so little equity in the result? What are the implications for the compliance professional of the use of the algorithm to make such a critical decision? What does the EEOC decision allowing companies to mandate vaccines for employees mean for compliance? Resources For more information see Matt’s blog post in Radical Compliance: Lessons on Algorithms, Ethics and Equity Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we consider how badly Stanford University Health Systems botched it decision on whom in the organization would receive its allotted Covid-19 vaccinations. Stanford used a faulty algorithm which mandated that only seven of the Health Systems 1300 medical residents would receive the vaccine. As you might guess these front-line health workers were up in arms over Stanford’s incompetence on this issue.

Some of the issues we consider are:

  • The plan had been for the algorithm to assign vaccination slots for the first 5,000 employees, who would begin receiving the Covid vaccine on Dec. 18.
  • What were the parameters of the algorithm?
  • Why was there so little ethics in the process?
  • Why was there so little equity in the result?
  • What are the implications for the compliance professional of the use of the algorithm to make such a critical decision?
  • What does the EEOC decision allowing companies to mandate vaccines for employees mean for compliance?

Resources

For more information see Matt’s blog post in Radical Compliance:

Lessons on Algorithms, Ethics and Equity

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1326 no Leadership Failures at Ft. Hood, with Special Guest Diane St. Ives Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we take on a much more somber topic and set of facts in this, our 201st episode. We have our first guest, Diane St. Ives, a retired US Army officer now practicing law in Houston. Diane is also a Director of the State Bar of Texas.  Matt, Tom and Diane consider the recent US Special Commission Report on leadership and culture failures in the areas of sexual harassment and assault which have occurred at Ft. Hood. These issues were brought to a head with the sexual assault and brutal murder of Specialist Vanessa Guillén, who disappeared on April 22. She was murdered by a fellow soldier, who killed himself in June when he escaped Army investigators taking him into custody. Some of the issues we consider are: What were and are the continuing failures of leadership at Ft. Hood in these areas? Why is the SHARP program simply window dressing? What will it take to make a change? Our Guest Diane St. Ives relates her personal experience of being sexually harassed over 40 years ago while a Private at Ft. Hood. She talks about the retaliation she received for reporting the crime and how it all still affects her today. What can be some of the solutions for this situation and how can compliance principles help turn around a continuing culture of misogyny in the Army. Resources For more information see Matt’s blog post in Radical Compliance: Leadership Failures at Ft. Hood Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Dec 2020 12:55:06 -0000 Leadership Failures at Ft. Hood, with Special Guest Diane St. Ives full 201 Tom Fox In this episode, Matt,Tom and special guest Diane St. Ives consider the recent US Special Commission Report on leadership and culture failures in the areas of sexual harassment and assault which have occurred at Ft. Hood. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we take on a much more somber topic and set of facts in this, our 201st episode. We have our first guest, Diane St. Ives, a retired US Army officer now practicing law in Houston. Diane is also a Director of the State Bar of Texas.  Matt, Tom and Diane consider the recent US Special Commission Report on leadership and culture failures in the areas of sexual harassment and assault which have occurred at Ft. Hood. These issues were brought to a head with the sexual assault and brutal murder of Specialist Vanessa Guillén, who disappeared on April 22. She was murdered by a fellow soldier, who killed himself in June when he escaped Army investigators taking him into custody. Some of the issues we consider are: What were and are the continuing failures of leadership at Ft. Hood in these areas? Why is the SHARP program simply window dressing? What will it take to make a change? Our Guest Diane St. Ives relates her personal experience of being sexually harassed over 40 years ago while a Private at Ft. Hood. She talks about the retaliation she received for reporting the crime and how it all still affects her today. What can be some of the solutions for this situation and how can compliance principles help turn around a continuing culture of misogyny in the Army. Resources For more information see Matt’s blog post in Radical Compliance: Leadership Failures at Ft. Hood Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we take on a much more somber topic and set of facts in this, our 201st episode. We have our first guest, Diane St. Ives, a retired US Army officer now practicing law in Houston. Diane is also a Director of the State Bar of Texas.

 Matt, Tom and Diane consider the recent US Special Commission Report on leadership and culture failures in the areas of sexual harassment and assault which have occurred at Ft. Hood. These issues were brought to a head with the sexual assault and brutal murder of Specialist Vanessa Guillén, who disappeared on April 22. She was murdered by a fellow soldier, who killed himself in June when he escaped Army investigators taking him into custody.

Some of the issues we consider are:

  • What were and are the continuing failures of leadership at Ft. Hood in these areas?
  • Why is the SHARP program simply window dressing?
  • What will it take to make a change?
  • Our Guest Diane St. Ives relates her personal experience of being sexually harassed over 40 years ago while a Private at Ft. Hood. She talks about the retaliation she received for reporting the crime and how it all still affects her today.
  • What can be some of the solutions for this situation and how can compliance principles help turn around a continuing culture of misogyny in the Army.

Resources

For more information see Matt’s blog post in Radical Compliance:

Leadership Failures at Ft. Hood

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1502 no NDAA Creates New Whistleblower Law   Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this, our 200th episode Matt and Tom go into the weeds to look at the new anti-money launder whistleblower law (AMLA) which is part for the updated Bank Secrecy Act legislation, included in the National Defense Authorization Act authorization of 2012 (get all that). It significantly expands whistleblower protections for those who come forward with AML or other similar allegations. Some of the issues we consider are: ·      Why has this been created for the Department of the Treasury? ·      Who will administer the whistleblower program? ·      What lessons has Congress learned about protecting whistleblowers? ·      Can a CCO be a whistleblower under this new law? How about a GC?  Resources For more information see Mengqi Sun’s article in the WSJ Risk & Compliance: Defense Bill Proposes Anti-Money-Laundering Whistleblower Program  For an excellent breakdown of the legislation, see the Zuckerman Law Firm’s Whistleblower Protection Law and SEC Whistleblower Awards Blog:  Anti-Money Laundering Act Establishes Whistleblower Reward Program and Protects Whistleblowers from Retaliation Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Dec 2020 05:03:00 -0000 NDAA Creates New Whistleblower Law full 200 Tom Fox In this, our 200th episode of Compliance into the Weeds, Matt and Tom go into the weeds to look at the new anti-money launder whistleblower law.   Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this, our 200th episode Matt and Tom go into the weeds to look at the new anti-money launder whistleblower law (AMLA) which is part for the updated Bank Secrecy Act legislation, included in the National Defense Authorization Act authorization of 2012 (get all that). It significantly expands whistleblower protections for those who come forward with AML or other similar allegations. Some of the issues we consider are: ·      Why has this been created for the Department of the Treasury? ·      Who will administer the whistleblower program? ·      What lessons has Congress learned about protecting whistleblowers? ·      Can a CCO be a whistleblower under this new law? How about a GC?  Resources For more information see Mengqi Sun’s article in the WSJ Risk & Compliance: Defense Bill Proposes Anti-Money-Laundering Whistleblower Program  For an excellent breakdown of the legislation, see the Zuckerman Law Firm’s Whistleblower Protection Law and SEC Whistleblower Awards Blog:  Anti-Money Laundering Act Establishes Whistleblower Reward Program and Protects Whistleblowers from Retaliation Learn more about your ad choices. Visit megaphone.fm/adchoices  

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this, our 200th episode Matt and Tom go into the weeds to look at the new anti-money launder whistleblower law (AMLA) which is part for the updated Bank Secrecy Act legislation, included in the National Defense Authorization Act authorization of 2012 (get all that). It significantly expands whistleblower protections for those who come forward with AML or other similar allegations. Some of the issues we consider are:

·      Why has this been created for the Department of the Treasury?

·      Who will administer the whistleblower program?

·      What lessons has Congress learned about protecting whistleblowers?

·      Can a CCO be a whistleblower under this new law? How about a GC? 

Resources

For more information see Mengqi Sun’s article in the WSJ Risk & Compliance:

Defense Bill Proposes Anti-Money-Laundering Whistleblower Program 

For an excellent breakdown of the legislation, see the Zuckerman Law Firm’s Whistleblower Protection Law and SEC Whistleblower Awards Blog: 

Anti-Money Laundering Act Establishes Whistleblower Reward Program and Protects Whistleblowers from Retaliation


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]]> 1342 no A Mayor, Covid-19 and Leadership Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the actions of Denver Mayor, Michael Hancock. Just before Thanksgiving he told folks to stay at home to avoid Covid-19 transmission and then promptly traveled to Mississippi for the Thanksgiving holidays. Some of the issues we consider are:  Is there always an inherent conflict in a human leader? How do leaders rationalize misconduct? What are the dangers when they do so? Do as I say, not as I do. Are we all simply our parents? What is the role of compliance? How do Hancock’s actions fit into the Fraud Pentagon? Resources For more information see Matt’s blog post: More Misadventures in Leadership  For more information on the Fraud Triangle see Jonathan Marks’ blog post: Fraud Pentagon Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Dec 2020 05:04:00 -0000 A Mayor, Covid-19 and Leadership full 199 Tom Fox What is a leader's responsibility to follow his own prescriptions around ethical conduct? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the actions of Denver Mayor, Michael Hancock. Just before Thanksgiving he told folks to stay at home to avoid Covid-19 transmission and then promptly traveled to Mississippi for the Thanksgiving holidays. Some of the issues we consider are:  Is there always an inherent conflict in a human leader? How do leaders rationalize misconduct? What are the dangers when they do so? Do as I say, not as I do. Are we all simply our parents? What is the role of compliance? How do Hancock’s actions fit into the Fraud Pentagon? Resources For more information see Matt’s blog post: More Misadventures in Leadership  For more information on the Fraud Triangle see Jonathan Marks’ blog post: Fraud Pentagon Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the actions of Denver Mayor, Michael Hancock. Just before Thanksgiving he told folks to stay at home to avoid Covid-19 transmission and then promptly traveled to Mississippi for the Thanksgiving holidays. Some of the issues we consider are: 

  • Is there always an inherent conflict in a human leader?
  • How do leaders rationalize misconduct?
  • What are the dangers when they do so?
  • Do as I say, not as I do. Are we all simply our parents?
  • What is the role of compliance?
  • How do Hancock’s actions fit into the Fraud Pentagon?

Resources

For more information see Matt’s blog post:

More Misadventures in Leadership 

For more information on the Fraud Triangle see Jonathan Marks’ blog post:

Fraud Pentagon

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]]> 1342 no Insider Trading Compliance and Former Apple CCO Indicted on Bribery Charges Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at recent remarks by SEC Chairman Jay Clayton and Bill Hinman, director of the Division of Corporation Finance, on issues around insider trading compliance programs. Some of the issues we consider are:  Why would two high ranking SEC officials publicly address insider trading and compliance in the same week? What are the rules around 10(b)5-1? What about Albert Bourla, the CEO of Pfizer, who sold $5.6 million worth of Pfizer shares on Nov. 9, the day the company announced stellar results of its Covid vaccine trials. Who owns insider trading compliance in a corporation? Values based ethics v. rules based ethics. Tom Moyer, former CCO and now head of Global Security at Apple indicted for alleged offering bribes to obtain concealed carry permits in Santa Clara County CA. Resources For more information see Matt’s blog posts: SEC Warning on Insider Trading Sales Apple Exec Indicted on Bribery Charge Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Nov 2020 05:03:00 -0000 Insider Trading Compliance and Former Apple CCO Indicted on Bribery Charges full 198 Tom Fox In this episode Matt and Tom go into the weeds to look at recent SEC remarks on issues around insider trading compliance programs. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at recent remarks by SEC Chairman Jay Clayton and Bill Hinman, director of the Division of Corporation Finance, on issues around insider trading compliance programs. Some of the issues we consider are:  Why would two high ranking SEC officials publicly address insider trading and compliance in the same week? What are the rules around 10(b)5-1? What about Albert Bourla, the CEO of Pfizer, who sold $5.6 million worth of Pfizer shares on Nov. 9, the day the company announced stellar results of its Covid vaccine trials. Who owns insider trading compliance in a corporation? Values based ethics v. rules based ethics. Tom Moyer, former CCO and now head of Global Security at Apple indicted for alleged offering bribes to obtain concealed carry permits in Santa Clara County CA. Resources For more information see Matt’s blog posts: SEC Warning on Insider Trading Sales Apple Exec Indicted on Bribery Charge Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at recent remarks by SEC Chairman Jay Clayton and Bill Hinman, director of the Division of Corporation Finance, on issues around insider trading compliance programs. Some of the issues we consider are: 

  • Why would two high ranking SEC officials publicly address insider trading and compliance in the same week?
  • What are the rules around 10(b)5-1?
  • What about Albert Bourla, the CEO of Pfizer, who sold $5.6 million worth of Pfizer shares on Nov. 9, the day the company announced stellar results of its Covid vaccine trials.
  • Who owns insider trading compliance in a corporation?
  • Values based ethics v. rules based ethics.
  • Tom Moyer, former CCO and now head of Global Security at Apple indicted for alleged offering bribes to obtain concealed carry permits in Santa Clara County CA.

Resources

For more information see Matt’s blog posts:

SEC Warning on Insider Trading Sales

Apple Exec Indicted on Bribery Charge

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]]> 1419 no The SEC Tenure of Jay Clayton Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the SEC Chairmanship of Jay Clayton who announced he was stepping down at the end of the year. Some of the issues we consider are: ·      Tom call it a mixed bag and Matt had mixed views? ·      His first 12 to 18 had a series of crisis including a cyber breach at the SEC itself, the PCAOB scandal with KPMG and Crypto-currency issues. ·      Matt felt Clayton did a good job of listening. ·      He worked to open non-capital markets for investment. ·      In the SEC enforcement action, he basically said Elon Musk was too important to Tesla to punish. ·      His abortive move to head the SDNY was reputational disaster. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Nov 2020 05:06:00 -0000 The SEC Tenure of Jay Clayton full Tom Fox In this episode Matt and Tom go into the weeds to look at the SEC Chairmanship of Jay Clayton who announced he was stepping down at the end of the year. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the SEC Chairmanship of Jay Clayton who announced he was stepping down at the end of the year. Some of the issues we consider are: ·      Tom call it a mixed bag and Matt had mixed views? ·      His first 12 to 18 had a series of crisis including a cyber breach at the SEC itself, the PCAOB scandal with KPMG and Crypto-currency issues. ·      Matt felt Clayton did a good job of listening. ·      He worked to open non-capital markets for investment. ·      In the SEC enforcement action, he basically said Elon Musk was too important to Tesla to punish. ·      His abortive move to head the SDNY was reputational disaster. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the SEC Chairmanship of Jay Clayton who announced he was stepping down at the end of the year. Some of the issues we consider are:

·      Tom call it a mixed bag and Matt had mixed views?

·      His first 12 to 18 had a series of crisis including a cyber breach at the SEC itself, the PCAOB scandal with KPMG and Crypto-currency issues.

·      Matt felt Clayton did a good job of listening.

·      He worked to open non-capital markets for investment.

·      In the SEC enforcement action, he basically said Elon Musk was too important to Tesla to punish.

·      His abortive move to head the SDNY was reputational disaster.


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]]> 1360 no Compliance Under the Biden Administration Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at compliance issues relevant to the next administration. Some of the issues we consider are:  What are some of the key appointments to follow? Where will FCPA enforcement go? Will use of monitors increase? How might the tone of SEC initiative and enforcement change under the Biden Administration? There has been increased scrutiny by the OCC and Fed on financial institutions compliance program. Will it continue? The Trump Administration attacks on Diversity and Inclusion training will end.  Resources See Matt’s blog posts on Radical Compliance- The Biden Administration and Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Nov 2020 05:04:00 -0000 Compliance Under the Biden Administration full 196 Tom Fox In this episode Matt and Tom go into the weeds to look at compliance issues relevant to the next administration Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at compliance issues relevant to the next administration. Some of the issues we consider are:  What are some of the key appointments to follow? Where will FCPA enforcement go? Will use of monitors increase? How might the tone of SEC initiative and enforcement change under the Biden Administration? There has been increased scrutiny by the OCC and Fed on financial institutions compliance program. Will it continue? The Trump Administration attacks on Diversity and Inclusion training will end.  Resources See Matt’s blog posts on Radical Compliance- The Biden Administration and Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at compliance issues relevant to the next administration. Some of the issues we consider are: 

  • What are some of the key appointments to follow?
  • Where will FCPA enforcement go?
  • Will use of monitors increase?
  • How might the tone of SEC initiative and enforcement change under the Biden Administration?
  • There has been increased scrutiny by the OCC and Fed on financial institutions compliance program. Will it continue?
  • The Trump Administration attacks on Diversity and Inclusion training will end.

 Resources

See Matt’s blog posts on Radical Compliance- The Biden Administration and Compliance

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]]> 1991 no Turbulence in the Compliance Profession Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the turbulence brought to the compliance profession and compliance job market. Some of the issues we consider are:  How Working From Home has brought a material change to the practice of compliance. How to follow the money in the age of Coronavirus? Has the pandemic made compliance more relevant? Why is there such turbulence in the compliance job market? How has the pandemic transformed one traditional risk into something that manifests quite differently.? How is the compliance profession evolving?  Resources See Matt’s blog posts on Radical Compliance- Compliance and Career Turbulence Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Nov 2020 14:14:06 -0000 Turbulence in the Compliance Profession full 195 Tom Fox In this episode Matt and Tom go into the weeds to look at the turbulence brought to the compliance profession and compliance job market. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the turbulence brought to the compliance profession and compliance job market. Some of the issues we consider are:  How Working From Home has brought a material change to the practice of compliance. How to follow the money in the age of Coronavirus? Has the pandemic made compliance more relevant? Why is there such turbulence in the compliance job market? How has the pandemic transformed one traditional risk into something that manifests quite differently.? How is the compliance profession evolving?  Resources See Matt’s blog posts on Radical Compliance- Compliance and Career Turbulence Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the turbulence brought to the compliance profession and compliance job market. Some of the issues we consider are: 

  • How Working From Home has brought a material change to the practice of compliance.
  • How to follow the money in the age of Coronavirus?
  • Has the pandemic made compliance more relevant?
  • Why is there such turbulence in the compliance job market?
  • How has the pandemic transformed one traditional risk into something that manifests quite differently.?
  • How is the compliance profession evolving? 

Resources

See Matt’s blog posts on Radical Compliance- Compliance and Career Turbulence

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]]> 1348 no The Goldman Sachs FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the US banking and finance entity Goldman Sachs. Some of the issues we consider are:  One of the most bold, audacious bribery schemes ever. Complete total and utter failure of compliance? Or something worse? Blatant assistance in money-laundering. How watches the watchers? Has Goldman really done anything different? Largest FCPA fine ever.  Resources See Matt’s blog posts on Radical Compliance- Goldman Sachs, FCPA and Internal Controls See Tom’s exploration on the FCPA Compliance and Ethics Blog Part 1-Introduction Part 2-Control Failures Part 3-Fines and Penalties Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Oct 2020 04:03:00 -0000 The Goldman Sachs FCPA Enforcement Action full 194 Tom Fox In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the US banking and finance entity Goldman Sachs. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the US banking and finance entity Goldman Sachs. Some of the issues we consider are:  One of the most bold, audacious bribery schemes ever. Complete total and utter failure of compliance? Or something worse? Blatant assistance in money-laundering. How watches the watchers? Has Goldman really done anything different? Largest FCPA fine ever.  Resources See Matt’s blog posts on Radical Compliance- Goldman Sachs, FCPA and Internal Controls See Tom’s exploration on the FCPA Compliance and Ethics Blog Part 1-Introduction Part 2-Control Failures Part 3-Fines and Penalties Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the US banking and finance entity Goldman Sachs. Some of the issues we consider are: 

  • One of the most bold, audacious bribery schemes ever.
  • Complete total and utter failure of compliance? Or something worse?
  • Blatant assistance in money-laundering.
  • How watches the watchers?
  • Has Goldman really done anything different?
  • Largest FCPA fine ever. 

Resources

See Matt’s blog posts on Radical Compliance- Goldman Sachs, FCPA and Internal Controls

See Tom’s exploration on the FCPA Compliance and Ethics Blog

Part 1-Introduction

Part 2-Control Failures

Part 3-Fines and Penalties

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]]> 1421 no The J&F FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the Brazilian megalith, J&F Investments. Some of the issues we consider are:  It was one of the most bold, audacious bribery schemes ever. Follow on from Brazil’s largest anti-corruption enforcement action, JBS. What happens when an acquirer of a US listed company is the corrupt entity? Is a target required to perform due diligence on the source of the money used in a M&A deal? Did Pilgrim’s Pride have any responsibility? Are there any US individuals involved? Is Pilgrim’s Pride a victim, entitled to compensation?  Resources See Matt’s blog posts on Radical Compliance-JBS, Internal Controls and the FPCA See Tom’s exploration the FCPA Compliance and Ethics Blog Part 1-Introduction Part 2-The Bribery Schemes Part 3-The SEC Order Part 4-The Plea Agreement Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Oct 2020 04:03:00 -0000 The J&F FCPA Enforcement Action full 193 Tom Fox In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the Brazilian megalith, J&F Investments. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the Brazilian megalith, J&F Investments. Some of the issues we consider are:  It was one of the most bold, audacious bribery schemes ever. Follow on from Brazil’s largest anti-corruption enforcement action, JBS. What happens when an acquirer of a US listed company is the corrupt entity? Is a target required to perform due diligence on the source of the money used in a M&A deal? Did Pilgrim’s Pride have any responsibility? Are there any US individuals involved? Is Pilgrim’s Pride a victim, entitled to compensation?  Resources See Matt’s blog posts on Radical Compliance-JBS, Internal Controls and the FPCA See Tom’s exploration the FCPA Compliance and Ethics Blog Part 1-Introduction Part 2-The Bribery Schemes Part 3-The SEC Order Part 4-The Plea Agreement Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the Brazilian megalith, J&F Investments. Some of the issues we consider are: 

  • It was one of the most bold, audacious bribery schemes ever.
  • Follow on from Brazil’s largest anti-corruption enforcement action, JBS.
  • What happens when an acquirer of a US listed company is the corrupt entity?
  • Is a target required to perform due diligence on the source of the money used in a M&A deal?
  • Did Pilgrim’s Pride have any responsibility?
  • Are there any US individuals involved?
  • Is Pilgrim’s Pride a victim, entitled to compensation?

 Resources

See Matt’s blog posts on Radical Compliance-JBS, Internal Controls and the FPCA

See Tom’s exploration the FCPA Compliance and Ethics Blog

Part 1-Introduction

Part 2-The Bribery Schemes

Part 3-The SEC Order

Part 4-The Plea Agreement

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]]> 1384 no Citibank Failures in Risk Management Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent fine of $400 million against Citibank for its poor risk management processes. Some of the issues we consider are: ·      Four areas of concern(1) Poor ERM; (2) Poor compliance; (3) Poor internal controls; and (4) Data governance. ·      How the OCC Order is an audit road map. ·      What does that mean for compliance on the Board? ·      Did the OCC push out Michael Corbat? ·      Focus on the ERM Blueprint.   Resources See Matt’s blog posts on Radical Compliance-Citigroup’s Governance Issues, Part 1 and Citigroup, Part 2-Better ERM Program Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Oct 2020 04:02:00 -0000 Citibank Failures in Risk Management full 192 Tom Fox In this episode Matt and Tom go into the weeds to look at the recent fine of $400 million against Citibank for its poor risk management processes. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent fine of $400 million against Citibank for its poor risk management processes. Some of the issues we consider are: ·      Four areas of concern(1) Poor ERM; (2) Poor compliance; (3) Poor internal controls; and (4) Data governance. ·      How the OCC Order is an audit road map. ·      What does that mean for compliance on the Board? ·      Did the OCC push out Michael Corbat? ·      Focus on the ERM Blueprint.   Resources See Matt’s blog posts on Radical Compliance-Citigroup’s Governance Issues, Part 1 and Citigroup, Part 2-Better ERM Program Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent fine of $400 million against Citibank for its poor risk management processes. Some of the issues we consider are:

·      Four areas of concern(1) Poor ERM; (2) Poor compliance; (3) Poor internal controls; and (4) Data governance.

·      How the OCC Order is an audit road map.

·      What does that mean for compliance on the Board?

·      Did the OCC push out Michael Corbat?

·      Focus on the ERM Blueprint.  

Resources

See Matt’s blog posts on Radical Compliance-Citigroup’s Governance Issues, Part 1 and Citigroup, Part 2-Better ERM Program


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]]> 1321 no The JPMorgan Fine and Penalty Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent fine of $920 million against JPMorgan for spoofing. Some of the issues we consider are: What is spoofing? How did the CFTC use data analytics to build their case? What does that mean for compliance professionals? How did the JPMorgan remediation of its compliance function reduce ? Once again, the DOJ demonstrates that robust remediation will pay great dividends in the form of a significant penalty reduction.  Resources See Matt’s blog posts on Radical Compliance-JPMorgan’s Compliance Benefit See also, David Michaels piece in the Wall Street Journal, JPMorgan’s Probe Revived by Regulators Data Mining Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 Oct 2020 04:05:00 -0000 The JPMorgan Fine and Penalty full 191 Tom Fox In this episode Matt and Tom go into the weeds to look at the recent fine of $920 million against JPMorgan for spoofing. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent fine of $920 million against JPMorgan for spoofing. Some of the issues we consider are: What is spoofing? How did the CFTC use data analytics to build their case? What does that mean for compliance professionals? How did the JPMorgan remediation of its compliance function reduce ? Once again, the DOJ demonstrates that robust remediation will pay great dividends in the form of a significant penalty reduction.  Resources See Matt’s blog posts on Radical Compliance-JPMorgan’s Compliance Benefit See also, David Michaels piece in the Wall Street Journal, JPMorgan’s Probe Revived by Regulators Data Mining Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent fine of $920 million against JPMorgan for spoofing. Some of the issues we consider are:

  • What is spoofing?
  • How did the CFTC use data analytics to build their case?
  • What does that mean for compliance professionals?
  • How did the JPMorgan remediation of its compliance function reduce ?
  • Once again, the DOJ demonstrates that robust remediation will pay great dividends in the form of a significant penalty reduction. 

Resources

See Matt’s blog posts on Radical Compliance-JPMorgan’s Compliance Benefit

See also, David Michaels piece in the Wall Street Journal, JPMorgan’s Probe Revived by Regulators Data Mining

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1296 no What are the compliance issues from WFH collaboration tools? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at some of the compliance issues that collaboration tools raise in the WFH era. Some of the issues we consider are: How do you assess the risks of collaboration tools? Does it matter only to regulated industries or all commercial operations? What can compliance do to manage the risk? When is training a better risk management tool than internal controls? Do you know your archiving status? Resources See Matt’s blog posts on Radical Compliance-Compliance Risks and Collaboration Tools Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 30 Sep 2020 04:03:00 -0000 What are the compliance issues from WFH collaboration tools? full 190 Tom Fox In this episode, Matt Kelly and Tom Fox consider some of the compliance issues that collaboration tools raise in the WFH era. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at some of the compliance issues that collaboration tools raise in the WFH era. Some of the issues we consider are: How do you assess the risks of collaboration tools? Does it matter only to regulated industries or all commercial operations? What can compliance do to manage the risk? When is training a better risk management tool than internal controls? Do you know your archiving status? Resources See Matt’s blog posts on Radical Compliance-Compliance Risks and Collaboration Tools Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at some of the compliance issues that collaboration tools raise in the WFH era. Some of the issues we consider are:

  • How do you assess the risks of collaboration tools?
  • Does it matter only to regulated industries or all commercial operations?
  • What can compliance do to manage the risk?
  • When is training a better risk management tool than internal controls?
  • Do you know your archiving status?

Resources

See Matt’s blog posts on Radical Compliance-Compliance Risks and Collaboration Tools

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1089 no Compliance into the Weeds: When is Diversity Training Anti-American Propaganda/the FinCen Files? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent initiative of the Department of Education to go after Princeton University for diversity training which Trump says is “Anti-American propaganda” and the release of the FinCen papers. Some of the issues we consider are:  What is the Trump Administration up to? Will white nationalism be the order of the day if Trump wins? Why does impact compliance professionals? What are the FinCen papers? Why was their release so devastating to the Administration? Resources See Matt’s blog posts on Radical Compliance Boom: The FinCen Files are Here Trump Administration Targets Princeton for Diversity Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Sep 2020 04:07:00 -0000 Compliance into the Weeds: When is Diversity Training Anti-American Propaganda/the FinCen Files? full 189 Tom Fox In this episode Matt and Tom go into the weeds to look at the recent initiative of the Department of Education to go after Princeton University for diversity training which Trump says is “Anti-American propaganda” and the release of the FinCen papers. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent initiative of the Department of Education to go after Princeton University for diversity training which Trump says is “Anti-American propaganda” and the release of the FinCen papers. Some of the issues we consider are:  What is the Trump Administration up to? Will white nationalism be the order of the day if Trump wins? Why does impact compliance professionals? What are the FinCen papers? Why was their release so devastating to the Administration? Resources See Matt’s blog posts on Radical Compliance Boom: The FinCen Files are Here Trump Administration Targets Princeton for Diversity Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent initiative of the Department of Education to go after Princeton University for diversity training which Trump says is “Anti-American propaganda” and the release of the FinCen papers. Some of the issues we consider are: 

  • What is the Trump Administration up to?
  • Will white nationalism be the order of the day if Trump wins?
  • Why does impact compliance professionals?
  • What are the FinCen papers?
  • Why was their release so devastating to the Administration?

Resources

See Matt’s blog posts on Radical Compliance

Boom: The FinCen Files are Here

Trump Administration Targets Princeton for Diversity

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]]> 1343 no Herbalife FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look the recently announced Herbalife FCPA enforcement action. Some of the issues we consider are:  Why were the facts so egregious? How high up in the organization did the corruption scheme go? Why was the Board’s performance so abysmal? Was the head of Internal Audit in on the bribery scheme? What was the role of short-sellers in bringing this massive fraud to light? Resources See Matt’s blog posts on Radical Compliance Herbalife Pays $123M on FCPA Charges  See Tom’s 3-part blog post series on the FCPA Compliance and Ethics Blog The Herbalife FCPA Enforcement Action, Part 1 The Herbalife FCPA Enforcement Action, Part 2 The Herbalife FCPA Enforcement Action, Part 3 Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Sep 2020 04:04:00 -0000 Herbalife FCPA Enforcement Action full 188 Tom Fox In this episode Matt and Tom go into the weeds to look the recently announced Herbalife FCPA enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look the recently announced Herbalife FCPA enforcement action. Some of the issues we consider are:  Why were the facts so egregious? How high up in the organization did the corruption scheme go? Why was the Board’s performance so abysmal? Was the head of Internal Audit in on the bribery scheme? What was the role of short-sellers in bringing this massive fraud to light? Resources See Matt’s blog posts on Radical Compliance Herbalife Pays $123M on FCPA Charges  See Tom’s 3-part blog post series on the FCPA Compliance and Ethics Blog The Herbalife FCPA Enforcement Action, Part 1 The Herbalife FCPA Enforcement Action, Part 2 The Herbalife FCPA Enforcement Action, Part 3 Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look the recently announced Herbalife FCPA enforcement action. Some of the issues we consider are: 

  • Why were the facts so egregious?
  • How high up in the organization did the corruption scheme go?
  • Why was the Board’s performance so abysmal?
  • Was the head of Internal Audit in on the bribery scheme?
  • What was the role of short-sellers in bringing this massive fraud to light?

Resources

See Matt’s blog posts on Radical Compliance

Herbalife Pays $123M on FCPA Charges 

See Tom’s 3-part blog post series on the FCPA Compliance and Ethics Blog

The Herbalife FCPA Enforcement Action, Part 1

The Herbalife FCPA Enforcement Action, Part 2

The Herbalife FCPA Enforcement Action, Part 3

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]]> 1369 no FinCen DD Pronouncements-Did they Hurt More than Help? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at two recent pronouncements by FinCen on customer and PEP due diligence. We ask the question: Is the Guidance so vague as to actually hurt the efforts of a compliance practitioner.   Resources See Matt’s blog posts on Radical Compliance Regulators Talk PEPs and Due Diligence FinCen Gives Guidance, Says Little Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Sep 2020 04:03:00 -0000 FinCen DD Pronouncements-Did they Hurt More than Help? full Tom Fox In this episode Matt and Tom go into the weeds to look at two recent pronouncements by FinCen on customer and PEP due diligence. We ask the question: Is the Guidance so vague as to actually hurt the efforts of a compliance practitioner. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at two recent pronouncements by FinCen on customer and PEP due diligence. We ask the question: Is the Guidance so vague as to actually hurt the efforts of a compliance practitioner.   Resources See Matt’s blog posts on Radical Compliance Regulators Talk PEPs and Due Diligence FinCen Gives Guidance, Says Little Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at two recent pronouncements by FinCen on customer and PEP due diligence. We ask the question: Is the Guidance so vague as to actually hurt the efforts of a compliance practitioner.  

Resources

See Matt’s blog posts on Radical Compliance

Regulators Talk PEPs and Due Diligence

FinCen Gives Guidance, Says Little

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 910 no DFS First Cyber Case-First American Title Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the first Cybersecurity breach case brought by the state of New York’s Department of Financial Services.  Some of the highlights include: What is the DFS? What is Reg 500, Cyber Rules? What were the First American comedy of errors? CISO disavowed ownership of the issue, stating, among other reasons, that such controls were not the responsibility of respondent’s information security department. No training for new employee charged with remediation. First American said it did nothing wrong.  Resources See Matt’s blog post, Parsing DFS’ First Cybersecurity Case on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Aug 2020 04:05:00 -0000 DFS First Cyber Case-First American Title full 168 Tom Fox In this episode Matt and Tom go into the weeds to look at the first Cybersecurity breach case brought by the state of New York’s Department of Financial Services. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the first Cybersecurity breach case brought by the state of New York’s Department of Financial Services.  Some of the highlights include: What is the DFS? What is Reg 500, Cyber Rules? What were the First American comedy of errors? CISO disavowed ownership of the issue, stating, among other reasons, that such controls were not the responsibility of respondent’s information security department. No training for new employee charged with remediation. First American said it did nothing wrong.  Resources See Matt’s blog post, Parsing DFS’ First Cybersecurity Case on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the first Cybersecurity breach case brought by the state of New York’s Department of Financial Services. 

Some of the highlights include:

  • What is the DFS?
  • What is Reg 500, Cyber Rules?
  • What were the First American comedy of errors?
  • CISO disavowed ownership of the issue, stating, among other reasons, that such controls were not the responsibility of respondent’s information security department.
  • No training for new employee charged with remediation.
  • First American said it did nothing wrong.

 Resources

See Matt’s blog post, Parsing DFS’ First Cybersecurity Case on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1700 no Governance Lessons from the Postal Service Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt comes in smoking hot over the Trump Administration’s attempted evisceration of the US Postal Service. He cools down to present multiple lessons for the compliance professional. Some of the highlights include: What is the controversy? What happens when the CEO has a conflict of interest with his own organization? What happens when business objectives conflict with business priorities? How the amplification of social media can create undue pressures.  Resources See Matt’s blog post, Governance Lessons from the Postal Service on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Aug 2020 04:05:00 -0000 Governance Lessons from the Post Service full 185 Tom Fox In this episode Matt comes in smoking hot over the Trump Administration’s attempted evisceration of the US Postal Service. He cools down to present multiple lessons for the compliance professional. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt comes in smoking hot over the Trump Administration’s attempted evisceration of the US Postal Service. He cools down to present multiple lessons for the compliance professional. Some of the highlights include: What is the controversy? What happens when the CEO has a conflict of interest with his own organization? What happens when business objectives conflict with business priorities? How the amplification of social media can create undue pressures.  Resources See Matt’s blog post, Governance Lessons from the Postal Service on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt comes in smoking hot over the Trump Administration’s attempted evisceration of the US Postal Service. He cools down to present multiple lessons for the compliance professional.

Some of the highlights include:

  • What is the controversy?
  • What happens when the CEO has a conflict of interest with his own organization?
  • What happens when business objectives conflict with business priorities?
  • How the amplification of social media can create undue pressures.

 Resources

See Matt’s blog post, Governance Lessons from the Postal Service on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1199 no Wells WAC-O Spending Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox consider the $20+ billion spend by Wells Fargo for its various regulatory fines and penalties, investigative and remediation costs since the initial announcement of its fraudulent accounts scandal back in 2016. Some of the highlights include: How can you spend over $1bn on compliance remediation in one quarter? Just how bad was the Wells Fargo culture? Can the bank ever get it right? How much is a functioning corporate culture worth?  Resources See Matt’s blog post, Wells Fargo’s Staggering Compliance Costs on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Aug 2020 13:40:23 -0000 Wells WAC-O Spending full Tom Fox n this episode Matt Kelly and Tom Fox consider the $20+ billion spend by Wells Fargo since the initial announcement of its fraudulent accounts scandal back in 2016. WAC-O Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox consider the $20+ billion spend by Wells Fargo for its various regulatory fines and penalties, investigative and remediation costs since the initial announcement of its fraudulent accounts scandal back in 2016. Some of the highlights include: How can you spend over $1bn on compliance remediation in one quarter? Just how bad was the Wells Fargo culture? Can the bank ever get it right? How much is a functioning corporate culture worth?  Resources See Matt’s blog post, Wells Fargo’s Staggering Compliance Costs on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox consider the $20+ billion spend by Wells Fargo for its various regulatory fines and penalties, investigative and remediation costs since the initial announcement of its fraudulent accounts scandal back in 2016.

Some of the highlights include:

  • How can you spend over $1bn on compliance remediation in one quarter?
  • Just how bad was the Wells Fargo culture?
  • Can the bank ever get it right?
  • How much is a functioning corporate culture worth? 

Resources

See Matt’s blog post, Wells Fargo’s Staggering Compliance Costs on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1574 no Vindman and Whistleblowers Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look at an Op-Ed piece penned by Alexander Vindman in the Washington Post where detailed his experiences as a whistleblower in the Trump White House. Some of the highlights include: What is the psychology for a whistleblower? What is the role of senior management in a speak up culture? What is the role of a CCO after a whistleblower speaks up? What are the ethical values of a whistleblower? Resources See Matt’s blog post, A Must Read on Whistleblower Retaliation on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Aug 2020 04:08:00 -0000 Vindman and Whistleblowers full Tom Fox In this episode Matt Kelly and Tom Fox take a look at an Op-Ed piece penned by Alexander Vindman in the Washington Post where detailed his experiences as a whistleblower in the Trump White House. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look at an Op-Ed piece penned by Alexander Vindman in the Washington Post where detailed his experiences as a whistleblower in the Trump White House. Some of the highlights include: What is the psychology for a whistleblower? What is the role of senior management in a speak up culture? What is the role of a CCO after a whistleblower speaks up? What are the ethical values of a whistleblower? Resources See Matt’s blog post, A Must Read on Whistleblower Retaliation on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look at an Op-Ed piece penned by Alexander Vindman in the Washington Post where detailed his experiences as a whistleblower in the Trump White House.

Some of the highlights include:

  • What is the psychology for a whistleblower?
  • What is the role of senior management in a speak up culture?
  • What is the role of a CCO after a whistleblower speaks up?
  • What are the ethical values of a whistleblower?

Resources

See Matt’s blog post, A Must Read on Whistleblower Retaliation on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1189 no Compliance Conference Economics 101 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the economics of compliance conferences. Who will be the winners and losers with conferences going virtual through the rest of 2020 and beyond?  Some of the highlights include: Compliance conference economic basics. How does this change in the age of virtual events? What about compliance conferences that do not need to make money? What are the differences in live and virtual conferences and do those differences make a difference in the experience?  Resources See Matt’s blog post, SCCE Conference Going Virtual on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Jul 2020 04:02:00 -0000 Compliance Conference Economics 101 full Tom Fox What are the economics of compliance conferences? How has Covid-19 changed those numbers? What are the new realities going forward? Find out in Compliance Conference Economics 101. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the economics of compliance conferences. Who will be the winners and losers with conferences going virtual through the rest of 2020 and beyond?  Some of the highlights include: Compliance conference economic basics. How does this change in the age of virtual events? What about compliance conferences that do not need to make money? What are the differences in live and virtual conferences and do those differences make a difference in the experience?  Resources See Matt’s blog post, SCCE Conference Going Virtual on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the economics of compliance conferences. Who will be the winners and losers with conferences going virtual through the rest of 2020 and beyond?

 Some of the highlights include:

  • Compliance conference economic basics.
  • How does this change in the age of virtual events?
  • What about compliance conferences that do not need to make money?
  • What are the differences in live and virtual conferences and do those differences make a difference in the experience?

 Resources

See Matt’s blog post, SCCE Conference Going Virtual on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 997 no CPA In America-the ComEd Bribery Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recent domestic bribery and corruption enforcement action involving ComEd, a subsidiary of energy giant Exelon Corp. and the largest utility in the state of Illinois, agreeing to pay $200 million to settle federal corruption charges that also involve one of the state’s most powerful politicians.   Some of the highlights include: Compliance practitioners need to remember domestic bribery and corruption as well as international. The bribes were offering lucrative lobbying contracts and no-show jobs to associates of Illinois House Speaker Michael Madigan. How did compliance save the day for ComEd? What about the Board of ComEd and Exelon? Is there a real commitment from the top?  Resources See Matt’s blog post, ComEd Pays $200 Million on Domestic Bribery on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Jul 2020 04:08:00 -0000 CPA In America-the ComEd Bribery Action full 181 Tom Fox n this episode Matt Kelly and Tom Fox take a look the recent domestic bribery and corruption enforcement action involving ComEd. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recent domestic bribery and corruption enforcement action involving ComEd, a subsidiary of energy giant Exelon Corp. and the largest utility in the state of Illinois, agreeing to pay $200 million to settle federal corruption charges that also involve one of the state’s most powerful politicians.   Some of the highlights include: Compliance practitioners need to remember domestic bribery and corruption as well as international. The bribes were offering lucrative lobbying contracts and no-show jobs to associates of Illinois House Speaker Michael Madigan. How did compliance save the day for ComEd? What about the Board of ComEd and Exelon? Is there a real commitment from the top?  Resources See Matt’s blog post, ComEd Pays $200 Million on Domestic Bribery on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recent domestic bribery and corruption enforcement action involving ComEd, a subsidiary of energy giant Exelon Corp. and the largest utility in the state of Illinois, agreeing to pay $200 million to settle federal corruption charges that also involve one of the state’s most powerful politicians.

 

Some of the highlights include:

  • Compliance practitioners need to remember domestic bribery and corruption as well as international.
  • The bribes were offering lucrative lobbying contracts and no-show jobs to associates of Illinois House Speaker Michael Madigan.
  • How did compliance save the day for ComEd?
  • What about the Board of ComEd and Exelon?
  • Is there a real commitment from the top?

 Resources

See Matt’s blog post, ComEd Pays $200 Million on Domestic Bribery on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1164 no Deutsche Bank Fined Over Epstein Accounts Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recent enforcement action by New York banking regulators against Deutsche Bank, which resulted in a $150 million penalty for its business dealings with Jeffrey Epstein. The matter is full of corporate miss-steps, compliance failures, corporate governance disasters and presents a cautionary tale for every compliance professional.  Resources See Matt’s blog post, Deutsche Bank’s Many Epstein Failures on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Jul 2020 04:02:00 -0000 Deutsche Bank Fined Over Epstein Accounts full 180 Tom Fox In this episode Matt Kelly and Tom Fox take a look the recent enforcement action by New York banking regulators against Deutsche Bank, which resulted in a $150 million penalty for its business dealings with Jeffrey Epstein. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recent enforcement action by New York banking regulators against Deutsche Bank, which resulted in a $150 million penalty for its business dealings with Jeffrey Epstein. The matter is full of corporate miss-steps, compliance failures, corporate governance disasters and presents a cautionary tale for every compliance professional.  Resources See Matt’s blog post, Deutsche Bank’s Many Epstein Failures on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recent enforcement action by New York banking regulators against Deutsche Bank, which resulted in a $150 million penalty for its business dealings with Jeffrey Epstein. The matter is full of corporate miss-steps, compliance failures, corporate governance disasters and presents a cautionary tale for every compliance professional.

 Resources

See Matt’s blog post, Deutsche Bank’s Many Epstein Failures on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1293 no FCPA Resource Guide, 2nd edition Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recently released FCPA Resource Guide, 2nd edition; released jointly last week by the Department of Justice and Securities and Exchange Commission. Resources From Tom, check out his five part blog post series on the new FCPA Resource Guide on the FCPA Compliance and Ethics Blog. For a copy of the FCPA Resource Guide, 2nd edition, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Jul 2020 04:07:00 -0000 FCPA Resource Guide, 2nd edition full 179 Tom Fox In this episode Matt Kelly and Tom Fox take a look the recently released FCPA Resource Guide, 2nd edition; released jointly last week by the Department of Justice and Securities and Exchange Commission. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recently released FCPA Resource Guide, 2nd edition; released jointly last week by the Department of Justice and Securities and Exchange Commission. Resources From Tom, check out his five part blog post series on the new FCPA Resource Guide on the FCPA Compliance and Ethics Blog. For a copy of the FCPA Resource Guide, 2nd edition, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recently released FCPA Resource Guide, 2nd edition; released jointly last week by the Department of Justice and Securities and Exchange Commission.

Resources

From Tom, check out his five part blog post series on the new FCPA Resource Guide on the FCPA Compliance and Ethics Blog.

For a copy of the FCPA Resource Guide, 2nd edition, click here.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1309 no Novartis FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recently announced Novartis FCPA enforcement action. We discuss the background facts, bribery schemes, fines and penalties, data analytics approach and conclude with lessons learned.   Resources From Matt, Novartis Settles FCPA Case for $345 Million From Tom Part 1-Introduction Part 2-the Bribery Schemes Part 3-Internal Controls Part 4-Fines, Penalties and Recidivism Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Jul 2020 10:43:55 -0000 Novartis FCPA Enforcement Action full 178 Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and Tom Fox take a look the recently announced Novartis FCPA enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recently announced Novartis FCPA enforcement action. We discuss the background facts, bribery schemes, fines and penalties, data analytics approach and conclude with lessons learned.   Resources From Matt, Novartis Settles FCPA Case for $345 Million From Tom Part 1-Introduction Part 2-the Bribery Schemes Part 3-Internal Controls Part 4-Fines, Penalties and Recidivism Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look the recently announced Novartis FCPA enforcement action. We discuss the background facts, bribery schemes, fines and penalties, data analytics approach and conclude with lessons learned.

 

Resources

From Matt, Novartis Settles FCPA Case for $345 Million

From Tom

Part 1-Introduction

Part 2-the Bribery Schemes

Part 3-Internal Controls

Part 4-Fines, Penalties and Recidivism

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1743 no Supreme Court Upholds Profit Disgorgement Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look this week’s United States Supreme Court decision in Liu v. Securities and Exchange Commission, which upheld the SEC remedy of profit disgorgement. We consider the background facts of the case and how the Court reached its decision. We also consider what the decision might mean for FCPA enforcement and compliance professionals going forward.  For a copy of the decision in Liu v. SEC, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Jun 2020 04:06:00 -0000 Supreme Court Upholds Profit Disgorgement full 177 Tom Fox In this episode Matt Kelly and Tom Fox take a look this week’s United States Supreme Court decision in Liu v. SEC. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look this week’s United States Supreme Court decision in Liu v. Securities and Exchange Commission, which upheld the SEC remedy of profit disgorgement. We consider the background facts of the case and how the Court reached its decision. We also consider what the decision might mean for FCPA enforcement and compliance professionals going forward.  For a copy of the decision in Liu v. SEC, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look this week’s United States Supreme Court decision in Liu v. Securities and Exchange Commission, which upheld the SEC remedy of profit disgorgement. We consider the background facts of the case and how the Court reached its decision. We also consider what the decision might mean for FCPA enforcement and compliance professionals going forward. 

For a copy of the decision in Liu v. SEC, click here.


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1427 no Emergency Weekend Podcast-Barr Tries to Oust Berman In this special emergency weekend episode (our first) Matt Kelly and Tom Fox take a deep dive into the attempt by AG William Barr to fire the US Attorney for the Southern District of New York, late on the evening of June 19. We consider its legality, what it means for both the SDNY, SEC and white-collar law enforcement going forward.   Resources  See Matt Kelly blog post on Radical Compliance, Turmoil for SEC, SDNY Leadership Barr tries to fire US Attorney for SDNY. (NYT) Jay Clayton nominated as new Attorney for SDNY. (CoinDesk) Berman says will not step down. (WaPo) Barr does not have authority to fire Berman under Court order appointing him. (Law and Crime) Learn more about your ad choices. Visit megaphone.fm/adchoices Sat, 20 Jun 2020 15:31:50 -0000 Emergency Weekend Podcast-Barr Tries to Oust Berman full 176 Tom Fox In this special emergency weekend episode, Matt Kelly and Tom Fox take a deep dive into the attempt by AG William Barr to fire the US Attorney for the Southern District of New York In this special emergency weekend episode (our first) Matt Kelly and Tom Fox take a deep dive into the attempt by AG William Barr to fire the US Attorney for the Southern District of New York, late on the evening of June 19. We consider its legality, what it means for both the SDNY, SEC and white-collar law enforcement going forward.   Resources  See Matt Kelly blog post on Radical Compliance, Turmoil for SEC, SDNY Leadership Barr tries to fire US Attorney for SDNY. (NYT) Jay Clayton nominated as new Attorney for SDNY. (CoinDesk) Berman says will not step down. (WaPo) Barr does not have authority to fire Berman under Court order appointing him. (Law and Crime) Learn more about your ad choices. Visit megaphone.fm/adchoices In this special emergency weekend episode (our first) Matt Kelly and Tom Fox take a deep dive into the attempt by AG William Barr to fire the US Attorney for the Southern District of New York, late on the evening of June 19. We consider its legality, what it means for both the SDNY, SEC and white-collar law enforcement going forward. 

 Resources

 See Matt Kelly blog post on Radical Compliance, Turmoil for SEC, SDNY Leadership

Barr tries to fire US Attorney for SDNY. (NYT)

Jay Clayton nominated as new Attorney for SDNY. (CoinDesk)

Berman says will not step down. (WaPo)

Barr does not have authority to fire Berman under Court order appointing him. (Law and Crime)

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1664 no Wynn Monitor Report-3rd Parties Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take another deep dive into the Wynn Monitor report. Today we consider the issues around third parties; including vendors in the Supply Chain and the rigor of the approval process and role of the corporate compliance function and CCO. We also discuss how customers and especially high rollers are treated.   Resources See Matt Kelly blog post, Wynn Part 2: Third-Party Oversight Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Jun 2020 04:03:00 -0000 Wynn Monitor Report-3rd Parties full 40 Tom Fox In this episode Matt Kelly and Tom Fox take another deep dive into the Wynn Monitor report, today focusing on the issues around third parties Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take another deep dive into the Wynn Monitor report. Today we consider the issues around third parties; including vendors in the Supply Chain and the rigor of the approval process and role of the corporate compliance function and CCO. We also discuss how customers and especially high rollers are treated.   Resources See Matt Kelly blog post, Wynn Part 2: Third-Party Oversight Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take another deep dive into the Wynn Monitor report. Today we consider the issues around third parties; including vendors in the Supply Chain and the rigor of the approval process and role of the corporate compliance function and CCO. We also discuss how customers and especially high rollers are treated.  


Resources


See Matt Kelly blog post, Wynn Part 2: Third-Party Oversight

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1242 no Ham-fisted Leadership Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look at two examples of ham-fisted leadership; one by Facebook CEO Mark Zuckerberg and the second by NFL Commissioner Roger Goodell. Both also had to respond to employee near revolts over their poor leadership. For Zuckerberg it was his refusal to stop President Trump’s incendiary and race-bait tweeting. For Goodell, it was lack of acknowledge of the racist murder of George Floyd. Resources See Matt Kelly blog post, Two Tales of Ham-Fisted Leadership Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Jun 2020 04:08:00 -0000 Ham-fisted Leadership full 174 Tom Fox In this episode Matt Kelly and Tom Fox take a look at two examples of ham-fisted leadership; one by Facebook CEO Mark Zuckerberg and the second by NFL Commissioner Roger Goodell. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look at two examples of ham-fisted leadership; one by Facebook CEO Mark Zuckerberg and the second by NFL Commissioner Roger Goodell. Both also had to respond to employee near revolts over their poor leadership. For Zuckerberg it was his refusal to stop President Trump’s incendiary and race-bait tweeting. For Goodell, it was lack of acknowledge of the racist murder of George Floyd. Resources See Matt Kelly blog post, Two Tales of Ham-Fisted Leadership Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt Kelly and Tom Fox take a look at two examples of ham-fisted leadership; one by Facebook CEO Mark Zuckerberg and the second by NFL Commissioner Roger Goodell. Both also had to respond to employee near revolts over their poor leadership. For Zuckerberg it was his refusal to stop President Trump’s incendiary and race-bait tweeting. For Goodell, it was lack of acknowledge of the racist murder of George Floyd.

Resources

See Matt Kelly blog post, Two Tales of Ham-Fisted Leadership

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1485 no Compliance and Leadership Lessons from the Floyd Protests  Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This past weekend saw some of the largest protests and violence this country has seen in 50+ years in the wake of the killing of George Floyd. In a very somber episode, in this podcast Matt Kelly and Tom Fox try to make some sense of leadership responses to the protests over the Floyd killing and explore if there is a compliance-based approach to remedying the institutional racism which led to his killing. Resources A good general summary of anti-racism resources: https://docs.google.com/document/d/1BRlF2_zhNe86SGgHa6-VlBO-QgirITwCTugSfKie5Fs/preview?pru=AAABcnb5mB8*DxXs7K_umbRHlS1kzEln3g A website that gives you specific bail funds for your city: The Bail Project, a nonprofit that aims to mitigate incarceration rates through bail reform. https://bailproject.org Other places to donate: Black Visions Collective, a black, trans, and queer-led social justice organization and legal fund based in Minneapolis-St. Paul. https://www.blackvisionsmn.org/about The Minnesota Freedom Fund, which pays criminal and immigration bail and bond for people who cannot afford it. https://minnesotafreedomfund.org/bailbondfaq The Brooklyn Bail Fund, which helps pay bail for those who cannot afford it. https://brooklynbailfund.org/donation-form The NAACP Legal Defense Fund, which supports racial justice through advocacy, litigation, and education. https://www.naacpldf.org/about-us/ Communities United Against Police Brutality, which operates a crisis hotline where people can report abuse; offers legal, medical, and psychological resource referrals; and engages in political action against police brutality. https://www.cuapb.org/what_we_do Northstar Health Collective, a St. Paul–based organization that provides health services and support at protests. https://northstarhealth.wordpress.com/about-us/ The ACLU, which provides legal services and support for a broad range of people with civil rights complaints. https://www.aclu.org/issues/racial-justice Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Jun 2020 04:05:00 -0000 Compliance and Leadership Lessons from the Floyd Protests full Tom Fox What are the leadership compliance lessons from the George Floyd tragedy? Matt Kelly and Tom Fox take a deep dive into the weeds to explore on this week's episode.  Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This past weekend saw some of the largest protests and violence this country has seen in 50+ years in the wake of the killing of George Floyd. In a very somber episode, in this podcast Matt Kelly and Tom Fox try to make some sense of leadership responses to the protests over the Floyd killing and explore if there is a compliance-based approach to remedying the institutional racism which led to his killing. Resources A good general summary of anti-racism resources: https://docs.google.com/document/d/1BRlF2_zhNe86SGgHa6-VlBO-QgirITwCTugSfKie5Fs/preview?pru=AAABcnb5mB8*DxXs7K_umbRHlS1kzEln3g A website that gives you specific bail funds for your city: The Bail Project, a nonprofit that aims to mitigate incarceration rates through bail reform. https://bailproject.org Other places to donate: Black Visions Collective, a black, trans, and queer-led social justice organization and legal fund based in Minneapolis-St. Paul. https://www.blackvisionsmn.org/about The Minnesota Freedom Fund, which pays criminal and immigration bail and bond for people who cannot afford it. https://minnesotafreedomfund.org/bailbondfaq The Brooklyn Bail Fund, which helps pay bail for those who cannot afford it. https://brooklynbailfund.org/donation-form The NAACP Legal Defense Fund, which supports racial justice through advocacy, litigation, and education. https://www.naacpldf.org/about-us/ Communities United Against Police Brutality, which operates a crisis hotline where people can report abuse; offers legal, medical, and psychological resource referrals; and engages in political action against police brutality. https://www.cuapb.org/what_we_do Northstar Health Collective, a St. Paul–based organization that provides health services and support at protests. https://northstarhealth.wordpress.com/about-us/ The ACLU, which provides legal services and support for a broad range of people with civil rights complaints. https://www.aclu.org/issues/racial-justice Learn more about your ad choices. Visit megaphone.fm/adchoices  Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This past weekend saw some of the largest protests and violence this country has seen in 50+ years in the wake of the killing of George Floyd. In a very somber episode, in this podcast Matt Kelly and Tom Fox try to make some sense of leadership responses to the protests over the Floyd killing and explore if there is a compliance-based approach to remedying the institutional racism which led to his killing.

Resources

A good general summary of anti-racism resources:

https://docs.google.com/document/d/1BRlF2_zhNe86SGgHa6-VlBO-QgirITwCTugSfKie5Fs/preview?pru=AAABcnb5mB8*DxXs7K_umbRHlS1kzEln3g

A website that gives you specific bail funds for your city: The Bail Project, a nonprofit that aims to mitigate incarceration rates through bail reform.

https://bailproject.org

Other places to donate:

  • Black Visions Collective, a black, trans, and queer-led social justice organization and legal fund based in Minneapolis-St. Paul.

https://www.blackvisionsmn.org/about

  • The Minnesota Freedom Fund, which pays criminal and immigration bail and bond for people who cannot afford it.

https://minnesotafreedomfund.org/bailbondfaq

  • The Brooklyn Bail Fund, which helps pay bail for those who cannot afford it.

https://brooklynbailfund.org/donation-form

  • The NAACP Legal Defense Fund, which supports racial justice through advocacy, litigation, and education.

https://www.naacpldf.org/about-us/

  • Communities United Against Police Brutality, which operates a crisis hotline where people can report abuse; offers legal, medical, and psychological resource referrals; and engages in political action against police brutality.

https://www.cuapb.org/what_we_do

  • Northstar Health Collective, a St. Paul–based organization that provides health services and support at protests.

https://northstarhealth.wordpress.com/about-us/

  • The ACLU, which provides legal services and support for a broad range of people with civil rights complaints.

https://www.aclu.org/issues/racial-justice

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1445 Demonstrating Corporate Values in the Time of Economic Downturn Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into how business leaders can demonstrate values during times of difficulty, specifically when the CEO of Airbnb was required to layoff nearly 25% of the company’s workforce. Some of the highlights include: How can tone at the top be so critical during the coronavirus health crisis and economic dislocation? Airbnb’s CEO Brian Chesky’s communication to employees. How does clarity and certainty in Brian Chesky’s letter help make the layoffs more palatable? Why are personal meetings so critical? Why is dignity to a RIF’d employee so critical? What can the compliance professional learn from this experience? How (and why) was the Weight Watchers massive layoff so different? See Matt Kelly blog post Demonstrating Values During Difficulties on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 May 2020 04:07:00 -0000 Demonstrating Corporate Values in the Time of Economic Downturn full 172 Tom Fox In this podcast Matt Kelly and Tom Fox take a deep dive into how business leaders can demonstrate values during times of difficulty, specifically when the CEO of Airbnb was required to layoff nearly 25% of the company’s workforce. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into how business leaders can demonstrate values during times of difficulty, specifically when the CEO of Airbnb was required to layoff nearly 25% of the company’s workforce. Some of the highlights include: How can tone at the top be so critical during the coronavirus health crisis and economic dislocation? Airbnb’s CEO Brian Chesky’s communication to employees. How does clarity and certainty in Brian Chesky’s letter help make the layoffs more palatable? Why are personal meetings so critical? Why is dignity to a RIF’d employee so critical? What can the compliance professional learn from this experience? How (and why) was the Weight Watchers massive layoff so different? See Matt Kelly blog post Demonstrating Values During Difficulties on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into how business leaders can demonstrate values during times of difficulty, specifically when the CEO of Airbnb was required to layoff nearly 25% of the company’s workforce.

Some of the highlights include:

  • How can tone at the top be so critical during the coronavirus health crisis and economic dislocation?
  • Airbnb’s CEO Brian Chesky’s communication to employees.
  • How does clarity and certainty in Brian Chesky’s letter help make the layoffs more palatable?
  • Why are personal meetings so critical?
  • Why is dignity to a RIF’d employee so critical?
  • What can the compliance professional learn from this experience?
  • How (and why) was the Weight Watchers massive layoff so different?


See Matt Kelly blog post Demonstrating Values During Difficulties on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1445 no Covid-19 Attestation in Massachusetts Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the attestation required by the Commonwealth of Massachusetts for businesses eligible to reopen in response to Covid-19. Some of the highlights include: What is the attestation requirement? What policies and procedures are a company mandated to have to reopen? What training must a company give its employees? What is the four-phase plan that Massachusetts will implement to effect reopening? What has been the decision-making process of the Massachusetts Governor Charlie Baker? When will sports reopen in Boston? See Matt Kelly blog post Massachusetts Covid-19 Attestation on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 May 2020 04:05:00 -0000 Covid-19 Attestation in Massachusetts full 171 Tom Fox In this episode, Matt Kelly and Tom Fox take a deep dive into the attestation required by the Commonwealth of Massachusetts for businesses eligible to reopen in response to Covid-19. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the attestation required by the Commonwealth of Massachusetts for businesses eligible to reopen in response to Covid-19. Some of the highlights include: What is the attestation requirement? What policies and procedures are a company mandated to have to reopen? What training must a company give its employees? What is the four-phase plan that Massachusetts will implement to effect reopening? What has been the decision-making process of the Massachusetts Governor Charlie Baker? When will sports reopen in Boston? See Matt Kelly blog post Massachusetts Covid-19 Attestation on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the attestation required by the Commonwealth of Massachusetts for businesses eligible to reopen in response to Covid-19.

Some of the highlights include:

  • What is the attestation requirement?
  • What policies and procedures are a company mandated to have to reopen?
  • What training must a company give its employees?
  • What is the four-phase plan that Massachusetts will implement to effect reopening?
  • What has been the decision-making process of the Massachusetts Governor Charlie Baker?
  • When will sports reopen in Boston?

See Matt Kelly blog post Massachusetts Covid-19 Attestation on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1445 no The Compliance Job Market, Frozen Not Wrecked Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the compliance job market, during the middle of Covid-19 health crisis and into the rest of 2020 and beyond. Some of the highlights include: The Radical Compliance Job Report is growing not lessening. Why is the market for CCO types frozen and wrecked? Will a thaw come in the second half of the year? WWill the Big Brother interview appear? Does Covid-19 hasten the move to more tech solutions in the AML compliance world and beyond? What is happening with salaries? What industries are bullish on compliance hiring? Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 May 2020 04:04:00 -0000 The Compliance Job Market, Frozen Not Wrecked full Tom Fox What does the compliance job and hiring market look like about now? Will it change in 2020? Find out on this episode of Compliance into the Weeds. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the compliance job market, during the middle of Covid-19 health crisis and into the rest of 2020 and beyond. Some of the highlights include: The Radical Compliance Job Report is growing not lessening. Why is the market for CCO types frozen and wrecked? Will a thaw come in the second half of the year? WWill the Big Brother interview appear? Does Covid-19 hasten the move to more tech solutions in the AML compliance world and beyond? What is happening with salaries? What industries are bullish on compliance hiring? Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the compliance job market, during the middle of Covid-19 health crisis and into the rest of 2020 and beyond.

Some of the highlights include:

  • The Radical Compliance Job Report is growing not lessening.
  • Why is the market for CCO types frozen and wrecked?
  • Will a thaw come in the second half of the year?
  • WWill the Big Brother interview appear?
  • Does Covid-19 hasten the move to more tech solutions in the AML compliance world and beyond?
  • What is happening with salaries?
  • What industries are bullish on compliance hiring?

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1373 no Rough Waters Ahead for Cruise Line CCOs Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recent mandate from the CDC that CEOs, CCOs and CFOs certify and attest that each employee who disembarks from a cruise ship has met the CDC requirements to do so, under potential criminal penalty. Three cruise lines, Royal Caribbean, Carnival Cruises, and Norwegian Cruise Line have over 100,000 employees cooped up on ships in US ports. The CDC wants to make certain that when they come on land, it is safe for everyone. Some of the highlights include: What are the CDC requirements? Why does the CDC want CEO, CCO and CFO attestation? Should these corporate leaders agree to do so? What is about the employees on the ships? Given that at least 100 cruise ships that set sail after March 4, the first day that a passenger died of Covid-19 while on a cruise stopping in the United States, is this warranted? What does it mean for potential liability going forward? Resources Matt Kelly blog post, Cruise Lines Face Covid-19 Compliance Squeeze Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 May 2020 04:03:00 -0000 Rough Waters Ahead for Cruise Line CCOs full Tom Fox The CDC wants cruise lines CEOs, CCOs and CFOs to certify adherence to CDC requirements before their crews can disembark. What possibly could go wrong? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recent mandate from the CDC that CEOs, CCOs and CFOs certify and attest that each employee who disembarks from a cruise ship has met the CDC requirements to do so, under potential criminal penalty. Three cruise lines, Royal Caribbean, Carnival Cruises, and Norwegian Cruise Line have over 100,000 employees cooped up on ships in US ports. The CDC wants to make certain that when they come on land, it is safe for everyone. Some of the highlights include: What are the CDC requirements? Why does the CDC want CEO, CCO and CFO attestation? Should these corporate leaders agree to do so? What is about the employees on the ships? Given that at least 100 cruise ships that set sail after March 4, the first day that a passenger died of Covid-19 while on a cruise stopping in the United States, is this warranted? What does it mean for potential liability going forward? Resources Matt Kelly blog post, Cruise Lines Face Covid-19 Compliance Squeeze Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recent mandate from the CDC that CEOs, CCOs and CFOs certify and attest that each employee who disembarks from a cruise ship has met the CDC requirements to do so, under potential criminal penalty. Three cruise lines, Royal Caribbean, Carnival Cruises, and Norwegian Cruise Line have over 100,000 employees cooped up on ships in US ports. The CDC wants to make certain that when they come on land, it is safe for everyone.

Some of the highlights include:

  • What are the CDC requirements?
  • Why does the CDC want CEO, CCO and CFO attestation?
  • Should these corporate leaders agree to do so?
  • What is about the employees on the ships?
  • Given that at least 100 cruise ships that set sail after March 4, the first day that a passenger died of Covid-19 while on a cruise stopping in the United States, is this warranted?
  • What does it mean for potential liability going forward?

Resources

Matt Kelly blog post, Cruise Lines Face Covid-19 Compliance Squeeze

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1076 Compliance Lessons from Smithfield Foods Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recently released CDC Inspection Report for the Smithfield Foods’ South Dakota meat packing facility. Last week, the CDC published a report that recommended more than 100 remediation steps Smithfield should implement so it can reopen the plant as soon as possible. We explore them from the compliance perspective. Some of the highlights include: What are the CDC services which led to the Report? Smithfield Foods was not designed to prevent the spread of infectious diseases. What must it do now? What are some of the key elements needed for a successful reopening? What is the role of the CCO in reopening? How can physical layout be a control? What are the potential legal liabilities to Smithfield Foods? Resources Matt Kelly blog post, Smithfield Foods and Covid-19 Controls Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Apr 2020 04:01:00 -0000 Compliance Lessons from Smithfield Foods full 168 Tom Fox In this podcast Matt Kelly and Tom Fox take a deep dive into the recently released CDC Inspection Report for the Smithfield Foods’ South Dakota meat packing facility. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recently released CDC Inspection Report for the Smithfield Foods’ South Dakota meat packing facility. Last week, the CDC published a report that recommended more than 100 remediation steps Smithfield should implement so it can reopen the plant as soon as possible. We explore them from the compliance perspective. Some of the highlights include: What are the CDC services which led to the Report? Smithfield Foods was not designed to prevent the spread of infectious diseases. What must it do now? What are some of the key elements needed for a successful reopening? What is the role of the CCO in reopening? How can physical layout be a control? What are the potential legal liabilities to Smithfield Foods? Resources Matt Kelly blog post, Smithfield Foods and Covid-19 Controls Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recently released CDC Inspection Report for the Smithfield Foods’ South Dakota meat packing facility. Last week, the CDC published a report that recommended more than 100 remediation steps Smithfield should implement so it can reopen the plant as soon as possible. We explore them from the compliance perspective.

Some of the highlights include:

  • What are the CDC services which led to the Report?
  • Smithfield Foods was not designed to prevent the spread of infectious diseases. What must it do now?
  • What are some of the key elements needed for a successful reopening?
  • What is the role of the CCO in reopening?
  • How can physical layout be a control?
  • What are the potential legal liabilities to Smithfield Foods?

Resources

Matt Kelly blog post, Smithfield Foods and Covid-19 Controls

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1097 no Happy Hour FCPA Enforcement Action Involving ENI Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recently released SEC enforcement action against ENI involving FCPA violations, which was released just before 5 PM on Friday April 17. Some of the highlights include: What were the background facts? What is the standard a parent has over a subsidiary for FCPA violations? What were the internal controls violations? What were the books and records violations? What are the lessons learned for the compliance professional? Did the fact that ENI was a recidivist make any difference? Resources Matt Kelly blog post, ENI Settles FCPA Case for $24.5 Million Tom Fox blog post, Recidivist ENI Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Apr 2020 04:03:00 -0000 Happy Hour FCPA Enforcement Action Involving ENI full 167 Tom Fox The ENI Foreign Corrupt Practices Act enforcement action presents several lessons learned for the compliance professional. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recently released SEC enforcement action against ENI involving FCPA violations, which was released just before 5 PM on Friday April 17. Some of the highlights include: What were the background facts? What is the standard a parent has over a subsidiary for FCPA violations? What were the internal controls violations? What were the books and records violations? What are the lessons learned for the compliance professional? Did the fact that ENI was a recidivist make any difference? Resources Matt Kelly blog post, ENI Settles FCPA Case for $24.5 Million Tom Fox blog post, Recidivist ENI Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recently released SEC enforcement action against ENI involving FCPA violations, which was released just before 5 PM on Friday April 17.

Some of the highlights include:

  • What were the background facts?
  • What is the standard a parent has over a subsidiary for FCPA violations?
  • What were the internal controls violations?
  • What were the books and records violations?
  • What are the lessons learned for the compliance professional?
  • Did the fact that ENI was a recidivist make any difference?

Resources

Matt Kelly blog post, ENI Settles FCPA Case for $24.5 Million

Tom Fox blog post, Recidivist ENI

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1279 no Hotline Benchmark Report Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the hotline benchmark report from Navex Global which was previewed on a recent webinar Matt attended. Some of the data was quite interesting and perhaps even troubling. Some of the highlights include: Case closure times are longer this year. Why are they lengthening? The five top categories of cases reported. Reports via online reporting v. telephone call nearly doubled. Reports of violations of business integrity violations are on the uptick. The #MeToo movement is over two years old, what do the numbers reveal? Resources Matt Kelly blog post, Report: Hotline Cases Taking More Time Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Apr 2020 04:08:00 -0000 Hotline Benchmark Report full 166 Tom Fox In this episode of Compliance int the Weeds, Matt Kelly and Tom Fox take a look at a new hotline benchmarking study. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the hotline benchmark report from Navex Global which was previewed on a recent webinar Matt attended. Some of the data was quite interesting and perhaps even troubling. Some of the highlights include: Case closure times are longer this year. Why are they lengthening? The five top categories of cases reported. Reports via online reporting v. telephone call nearly doubled. Reports of violations of business integrity violations are on the uptick. The #MeToo movement is over two years old, what do the numbers reveal? Resources Matt Kelly blog post, Report: Hotline Cases Taking More Time Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the hotline benchmark report from Navex Global which was previewed on a recent webinar Matt attended. Some of the data was quite interesting and perhaps even troubling.

Some of the highlights include:

  • Case closure times are longer this year. Why are they lengthening?
  • The five top categories of cases reported.
  • Reports via online reporting v. telephone call nearly doubled.
  • Reports of violations of business integrity violations are on the uptick.
  • The #MeToo movement is over two years old, what do the numbers reveal?

Resources

Matt Kelly blog post, Report: Hotline Cases Taking More Time

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1135 no Covidiocy Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. While we have both written and spoken about companies who are responding positively during the COVID-19 crisis, today we take up companies who are not doing so and are thereby engaging in covidiocy.  Some of the highlights include: What is the tale of the Boston Sports Club? What were its governance failures? Its policy failures? What is the FINRA Guidance on Pandemic Risks? Why is liquidity so critical now? Corporate governance failures by the parent. Resources Matt Kelly blog posts , When Covidiocy Strikes Corporate Governance and New FINRA on Pandemic Risks Tom Fox blog post, Navigating the Coronavirus Crisis for Compliance Professionals -Company Responses Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Apr 2020 04:08:00 -0000 Covidiocy full 165 Tom Fox What is covidiocy and how does it relate to compliance and corporate governance. Find out in this episode of Compliance into the Weeds. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. While we have both written and spoken about companies who are responding positively during the COVID-19 crisis, today we take up companies who are not doing so and are thereby engaging in covidiocy.  Some of the highlights include: What is the tale of the Boston Sports Club? What were its governance failures? Its policy failures? What is the FINRA Guidance on Pandemic Risks? Why is liquidity so critical now? Corporate governance failures by the parent. Resources Matt Kelly blog posts , When Covidiocy Strikes Corporate Governance and New FINRA on Pandemic Risks Tom Fox blog post, Navigating the Coronavirus Crisis for Compliance Professionals -Company Responses Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. While we have both written and spoken about companies who are responding positively during the COVID-19 crisis, today we take up companies who are not doing so and are thereby engaging in covidiocy.

 Some of the highlights include:

  • What is the tale of the Boston Sports Club?
  • What were its governance failures? Its policy failures?
  • What is the FINRA Guidance on Pandemic Risks?
  • Why is liquidity so critical now?
  • Corporate governance failures by the parent.

Resources

Matt Kelly blog posts , When Covidiocy Strikes Corporate Governance and New FINRA on Pandemic Risks

Tom Fox blog post, Navigating the Coronavirus Crisis for Compliance Professionals -Company Responses

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]]> 1005 no Compliance Officer as Whistleblower Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recent whistleblower award issued to an anonymous whistleblower, who happened to be a compliance professional. Some of the highlights include: What are the requirements for a compliance professional to be eligible for a Dodd-Frank Whistleblower award? How many CCOs or internal audit types have been awarded Dodd-Frank Whistleblower awards? The SEC was previously investigating the company, how (or why) was there an award in this case? With nearly $400MM paid out in whistleblower awards, the program is clearly working. Is Jay Clayton’s attempt to eviscerate the Whistleblower Awards? Resources Matt Kelly blog post, Whistleblower Award to Compliance Professional SEC Press Release Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Apr 2020 04:03:00 -0000 Compliance Officer as Whistleblower full 164 Tom Fox In this podcast Matt Kelly and Tom Fox take a deep dive into the recent whistleblower award issued to an anonymous whistleblower, who happened to be a compliance officer. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recent whistleblower award issued to an anonymous whistleblower, who happened to be a compliance professional. Some of the highlights include: What are the requirements for a compliance professional to be eligible for a Dodd-Frank Whistleblower award? How many CCOs or internal audit types have been awarded Dodd-Frank Whistleblower awards? The SEC was previously investigating the company, how (or why) was there an award in this case? With nearly $400MM paid out in whistleblower awards, the program is clearly working. Is Jay Clayton’s attempt to eviscerate the Whistleblower Awards? Resources Matt Kelly blog post, Whistleblower Award to Compliance Professional SEC Press Release Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this podcast Matt Kelly and Tom Fox take a deep dive into the recent whistleblower award issued to an anonymous whistleblower, who happened to be a compliance professional.

Some of the highlights include:

  • What are the requirements for a compliance professional to be eligible for a Dodd-Frank Whistleblower award?
  • How many CCOs or internal audit types have been awarded Dodd-Frank Whistleblower awards?
  • The SEC was previously investigating the company, how (or why) was there an award in this case?
  • With nearly $400MM paid out in whistleblower awards, the program is clearly working.
  • Is Jay Clayton’s attempt to eviscerate the Whistleblower Awards?

Resources

Matt Kelly blog post, Whistleblower Award to Compliance Professional

SEC Press Release

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]]> 1024 no According to Frank...A Tale of Compliance and COVID-19 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. As with many of you, we are overwhelmed with COVID-19 information. Matt and I want to bring some clarity, if not sanity to the conversation. In this podcast we continue our exploration of the parameters and impacts of COVID-19, by taking a look at one compliance tale in the time of coronavirus…according to Frank. Some of the highlights include: What is being Frank in the time of COVID-19? Have your underlying assumptions on risk changed? Why must you look at risk not simply with another set of eyes but also with a different eye? With COVID-19, the risk is not only different but also unknown. Why are isolation and quarantine key? Why is focus on your risk management process so critical now? Are you revamping your engines at 40,000 ft at 480 mph? Stay tuned to after the outro for a special bonus piece on the phrase According to Hoyle… Resources Matt Kelly blog post, One Compliance Tale in the Time of COVID Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Mar 2020 04:03:00 -0000 According to Frank...A Tale of Compliance and COVID-19 full 163 Tom Fox What is a tale of Frank in the time of coronavirus? Matt Kelly and Tom Fox take a deep dive into how COVID-19 is impacting one compliance professional. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. As with many of you, we are overwhelmed with COVID-19 information. Matt and I want to bring some clarity, if not sanity to the conversation. In this podcast we continue our exploration of the parameters and impacts of COVID-19, by taking a look at one compliance tale in the time of coronavirus…according to Frank. Some of the highlights include: What is being Frank in the time of COVID-19? Have your underlying assumptions on risk changed? Why must you look at risk not simply with another set of eyes but also with a different eye? With COVID-19, the risk is not only different but also unknown. Why are isolation and quarantine key? Why is focus on your risk management process so critical now? Are you revamping your engines at 40,000 ft at 480 mph? Stay tuned to after the outro for a special bonus piece on the phrase According to Hoyle… Resources Matt Kelly blog post, One Compliance Tale in the Time of COVID Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. As with many of you, we are overwhelmed with COVID-19 information. Matt and I want to bring some clarity, if not sanity to the conversation. In this podcast we continue our exploration of the parameters and impacts of COVID-19, by taking a look at one compliance tale in the time of coronavirus…according to Frank.

Some of the highlights include:

  • What is being Frank in the time of COVID-19?
  • Have your underlying assumptions on risk changed?
  • Why must you look at risk not simply with another set of eyes but also with a different eye?
  • With COVID-19, the risk is not only different but also unknown.
  • Why are isolation and quarantine key?
  • Why is focus on your risk management process so critical now?
  • Are you revamping your engines at 40,000 ft at 480 mph?
  • Stay tuned to after the outro for a special bonus piece on the phrase According to Hoyle…

Resources

Matt Kelly blog post, One Compliance Tale in the Time of COVID

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1228 no Flattening the COVID-19 Curve Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. As with many of you, we are overwhelmed with COVID-19 information. Matt and I want to bring some clarity, if not sanity to the conversation. To that end, in this episode we take a deep dive into the need to integrate public health measures into our private enterprise operations, now and for the foreseeable future. Some of the highlights include: What is some of the positive news coming out of China? How did China’s lockdown help slow the virus? Why do we need to use the time to integrate public health measures into private sector operations? What are some of these public health measures? Why are isolation and quarantine key? If we get it under control, how do we prevent another outbreak? What are some practical starting points for businesses to think through at this time? What should businesses be thinking about 30, 60, 90 days out? Resources Matt Kelly blog post, The Downslope Risks of COVID-19 Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Mar 2020 04:03:00 -0000 Episode 162-Flattening the Curve full Tom Fox In this episode we take a deep dive into the need to integrate public health measures into our private enterprise operations, now and for the foreseeable future. And of course why we must flatten the curve now. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. As with many of you, we are overwhelmed with COVID-19 information. Matt and I want to bring some clarity, if not sanity to the conversation. To that end, in this episode we take a deep dive into the need to integrate public health measures into our private enterprise operations, now and for the foreseeable future. Some of the highlights include: What is some of the positive news coming out of China? How did China’s lockdown help slow the virus? Why do we need to use the time to integrate public health measures into private sector operations? What are some of these public health measures? Why are isolation and quarantine key? If we get it under control, how do we prevent another outbreak? What are some practical starting points for businesses to think through at this time? What should businesses be thinking about 30, 60, 90 days out? Resources Matt Kelly blog post, The Downslope Risks of COVID-19 Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. As with many of you, we are overwhelmed with COVID-19 information. Matt and I want to bring some clarity, if not sanity to the conversation. To that end, in this episode we take a deep dive into the need to integrate public health measures into our private enterprise operations, now and for the foreseeable future.

Some of the highlights include:

  • What is some of the positive news coming out of China?
  • How did China’s lockdown help slow the virus?
  • Why do we need to use the time to integrate public health measures into private sector operations?
  • What are some of these public health measures?
  • Why are isolation and quarantine key?
  • If we get it under control, how do we prevent another outbreak?
  • What are some practical starting points for businesses to think through at this time?
  • What should businesses be thinking about 30, 60, 90 days out?

Resources

Matt Kelly blog post, The Downslope Risks of COVID-19

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1208 no OCC Guidance on 3rd Party Risk Management Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into recent OCC Guidance on managing 3rd party risk. Some of the highlights include: What was the Office of the Comptroller of the Currency, guidance published the on March 5? Why is 3rd party risk still a chronic issue? What is the role of due diligence? What are sustainable business models for 3rd party risk management? What are 4th party risks? What is Kelly’s Law of 3rd Party Risk Management? A short discussion of FINRA’s new bulletin on pandemic risk? Resources Matt Kelly blog post, Some Good Guidance on 3rd Party Risk Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Mar 2020 04:06:00 -0000 OCC Guidance on 3rd Party Risk Management full Tom Fox The OCC recently released guidance on third-party risk management. Matt Kelly and Tom Fox take a deep dive into it on this episode of Compliance into the Weeds. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into recent OCC Guidance on managing 3rd party risk. Some of the highlights include: What was the Office of the Comptroller of the Currency, guidance published the on March 5? Why is 3rd party risk still a chronic issue? What is the role of due diligence? What are sustainable business models for 3rd party risk management? What are 4th party risks? What is Kelly’s Law of 3rd Party Risk Management? A short discussion of FINRA’s new bulletin on pandemic risk? Resources Matt Kelly blog post, Some Good Guidance on 3rd Party Risk Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into recent OCC Guidance on managing 3rd party risk.

Some of the highlights include:

  • What was the Office of the Comptroller of the Currency, guidance published the on March 5?
  • Why is 3rd party risk still a chronic issue?
  • What is the role of due diligence?
  • What are sustainable business models for 3rd party risk management?
  • What are 4th party risks?
  • What is Kelly’s Law of 3rd Party Risk Management?
  • A short discussion of FINRA’s new bulletin on pandemic risk?

Resources

Matt Kelly blog post, Some Good Guidance on 3rd Party Risk

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1330 no Cardinal Health FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into Cardinal Health FCPA enforcement action brought by the SEC. Some of the highlights include: What is the background to the matter? How did a Chinese acquisition cause so much FCPA grief? What were the types of business relationships involved? How did the corporate office respond? What red flags were spotted or missed? Why didn’t the corporate office take stronger action? What was the SEC’s response in the fine and penalty phase? Resources Matt Kelly blog post, Cardinal Health Pays $8.8 Million on FCPA Issues Tom Fox blog post, Cardinal Health FCPA Enforcement Action: High Risk Business Relationships Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Mar 2020 05:03:00 -0000 Cardinal Health FCPA Enforcement Action full Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and I take a deep dive into the Cardinal Health FCPA enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into Cardinal Health FCPA enforcement action brought by the SEC. Some of the highlights include: What is the background to the matter? How did a Chinese acquisition cause so much FCPA grief? What were the types of business relationships involved? How did the corporate office respond? What red flags were spotted or missed? Why didn’t the corporate office take stronger action? What was the SEC’s response in the fine and penalty phase? Resources Matt Kelly blog post, Cardinal Health Pays $8.8 Million on FCPA Issues Tom Fox blog post, Cardinal Health FCPA Enforcement Action: High Risk Business Relationships Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into Cardinal Health FCPA enforcement action brought by the SEC.

Some of the highlights include:

  • What is the background to the matter?
  • How did a Chinese acquisition cause so much FCPA grief?
  • What were the types of business relationships involved?
  • How did the corporate office respond?
  • What red flags were spotted or missed?
  • Why didn’t the corporate office take stronger action?
  • What was the SEC’s response in the fine and penalty phase?

Resources

Matt Kelly blog post, Cardinal Health Pays $8.8 Million on FCPA Issues

Tom Fox blog post, Cardinal Health FCPA Enforcement Action: High Risk Business Relationships

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1187 no Barr Sentencing Memo and Trump Pardons Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into Donald Trump ordering (via Twitter) the AG to reduce the length of sentence requested for Roger Stone and his pardons of 13 convicted white-collar criminals. Some of the highlights include: What is the background to the Barr Sentencing Memo? Can white collar defense lawyers use the DOJ reasoning to decouple of the sentencing guidelines? What does all this mean for corporate culture? When will Trump start attacking companies for doing business ethically? What are the implications for the compliance discipline and CCO? What tensions does all this create for the corporate compliance and corporate legal functions? What happens when arbitrary behavior emanates from the top of an organization? Resources Matt Kelly blog post, Lessons from Justice Department Meltdown Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Feb 2020 05:09:00 -0000 Barr Sentencing Memo and Trump Pardons full 159 Tom Fox What do the Barr Sentencing Memo for Roger Stone and Trump pardons of white collar criminals mean for compliance? Nothing but trouble. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into Donald Trump ordering (via Twitter) the AG to reduce the length of sentence requested for Roger Stone and his pardons of 13 convicted white-collar criminals. Some of the highlights include: What is the background to the Barr Sentencing Memo? Can white collar defense lawyers use the DOJ reasoning to decouple of the sentencing guidelines? What does all this mean for corporate culture? When will Trump start attacking companies for doing business ethically? What are the implications for the compliance discipline and CCO? What tensions does all this create for the corporate compliance and corporate legal functions? What happens when arbitrary behavior emanates from the top of an organization? Resources Matt Kelly blog post, Lessons from Justice Department Meltdown Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into Donald Trump ordering (via Twitter) the AG to reduce the length of sentence requested for Roger Stone and his pardons of 13 convicted white-collar criminals.

Some of the highlights include:

  • What is the background to the Barr Sentencing Memo?
  • Can white collar defense lawyers use the DOJ reasoning to decouple of the sentencing guidelines?
  • What does all this mean for corporate culture?
  • When will Trump start attacking companies for doing business ethically?
  • What are the implications for the compliance discipline and CCO?
  • What tensions does all this create for the corporate compliance and corporate legal functions?
  • What happens when arbitrary behavior emanates from the top of an organization?

Resources

Matt Kelly blog post, Lessons from Justice Department Meltdown

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1511 no Hogan Lovells Report on Compliance Budgets Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into recent Hogan Lovell’s report High Seas: Steering the Course II Navigating bribery and corruption risk in 2020. We conclude with a special tribute to Bernie Ebbers and his role in creating the modern compliance professional.  Some of the highlights include: What do the survey results say about the direction of compliance function spending? Can companies manage risks in emerging markets when compliance spending is decelerating? Technology can improve compliance efficiency but it can also improve compliance evasion. Will CCOs be able to interpret data from ComTech tools? What are the implications for the compliance discipline and CCO? Resources Hogan Lovell’s report High Seas: Steering the Course II Navigating bribery and corruption risk in 2020, click here. Matt Kelly blog post, Compliance Resources Getting Tighter Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Feb 2020 05:02:00 -0000 Hogan Lovells Report on Compliance Budgets full 158 Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and I go into the weeds to explore the reported decrease in compliance budgets and headcount.   Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into recent Hogan Lovell’s report High Seas: Steering the Course II Navigating bribery and corruption risk in 2020. We conclude with a special tribute to Bernie Ebbers and his role in creating the modern compliance professional.  Some of the highlights include: What do the survey results say about the direction of compliance function spending? Can companies manage risks in emerging markets when compliance spending is decelerating? Technology can improve compliance efficiency but it can also improve compliance evasion. Will CCOs be able to interpret data from ComTech tools? What are the implications for the compliance discipline and CCO? Resources Hogan Lovell’s report High Seas: Steering the Course II Navigating bribery and corruption risk in 2020, click here. Matt Kelly blog post, Compliance Resources Getting Tighter Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into recent Hogan Lovell’s report High Seas: Steering the Course II Navigating bribery and corruption risk in 2020. We conclude with a special tribute to Bernie Ebbers and his role in creating the modern compliance professional.  Some of the highlights include:

  • What do the survey results say about the direction of compliance function spending?
  • Can companies manage risks in emerging markets when compliance spending is decelerating?
  • Technology can improve compliance efficiency but it can also improve compliance evasion.
  • Will CCOs be able to interpret data from ComTech tools?
  • What are the implications for the compliance discipline and CCO?

Resources

Hogan Lovell’s report High Seas: Steering the Course II Navigating bribery and corruption risk in 2020, click here.

Matt Kelly blog post, Compliance Resources Getting Tighter

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1330 no Wells Fargo Risk Assurance Execs Under Scrutiny Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into the Office of Comptroller and Currency’s proposed Cease and Desist Order against former high-ranking Wells Fargo risk assurance executives. Some of the highlights include: Are risk assurance executives now under more scrutiny by regulators? Were the facts of Wells Fargo’s fraudulent accounts scandal so bad to raise a new level of liability? Should we expect new regulatory guidance? If the first line of defense performs it function, but the second and third do now; what are the implications? What are the implications for the compliance discipline and CCO? Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Feb 2020 05:01:00 -0000 Wells Fargo Risk Assurance Execs Under Scrutiny full 157 Tom Fox In this episode we take a deep dive into the Office of Comptroller and Currency’s proposed Cease and Desist Order against former high-ranking Wells Fargo risk assurance executives. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into the Office of Comptroller and Currency’s proposed Cease and Desist Order against former high-ranking Wells Fargo risk assurance executives. Some of the highlights include: Are risk assurance executives now under more scrutiny by regulators? Were the facts of Wells Fargo’s fraudulent accounts scandal so bad to raise a new level of liability? Should we expect new regulatory guidance? If the first line of defense performs it function, but the second and third do now; what are the implications? What are the implications for the compliance discipline and CCO? Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode we take a deep dive into the Office of Comptroller and Currency’s proposed Cease and Desist Order against former high-ranking Wells Fargo risk assurance executives.

Some of the highlights include:

  • Are risk assurance executives now under more scrutiny by regulators?
  • Were the facts of Wells Fargo’s fraudulent accounts scandal so bad to raise a new level of liability?
  • Should we expect new regulatory guidance?
  • If the first line of defense performs it function, but the second and third do now; what are the implications?
  • What are the implications for the compliance discipline and CCO?

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1308 no The 2020 Edelman Trust Barometer Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt indulges me as we take a deep dive into 2020 Edelman Trust Barometer and its implications for the CCO and corporate compliance function.  Some of the highlights include: Why is trust down so much in developed countries while going up in under-developed countries? Why is the trust gap widening between the well-educated and others? While respondents tend to trust their employers, why is business in general seen as untrustworthy? What does the growing gap in executive pay portend for employee trust? What are the implications for the compliance discipline and CCO? Resources Download the Edelman Trust Barometer here. Read Matt’s blog post, Edelman Trust Report Gets Grim Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 Jan 2020 05:03:00 -0000 The 2020 Edelman Trust Barometer full 156 Tom Fox What are some of the top findings from the 2020 Edelman Trust Barometer? What are the implication for compliance. Join Matt Kelly and Tom Fox to take a deep dive into the weeds of this provocative report. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt indulges me as we take a deep dive into 2020 Edelman Trust Barometer and its implications for the CCO and corporate compliance function.  Some of the highlights include: Why is trust down so much in developed countries while going up in under-developed countries? Why is the trust gap widening between the well-educated and others? While respondents tend to trust their employers, why is business in general seen as untrustworthy? What does the growing gap in executive pay portend for employee trust? What are the implications for the compliance discipline and CCO? Resources Download the Edelman Trust Barometer here. Read Matt’s blog post, Edelman Trust Report Gets Grim Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt indulges me as we take a deep dive into 2020 Edelman Trust Barometer and its implications for the CCO and corporate compliance function.

 Some of the highlights include:

  • Why is trust down so much in developed countries while going up in under-developed countries?
  • Why is the trust gap widening between the well-educated and others?
  • While respondents tend to trust their employers, why is business in general seen as untrustworthy?
  • What does the growing gap in executive pay portend for employee trust?
  • What are the implications for the compliance discipline and CCO?

Resources

Download the Edelman Trust Barometer here.

Read Matt’s blog post, Edelman Trust Report Gets Grim

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1225 no Lessons from the Astros Sign Stealing Scandal Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt indulges me as we take a deep dive into the Houston Astros sign stealing scandal. We mine the episode for compliance and ethics lessons. It turns out there are quite a few.  Some of the highlights include: Ø  What was the role amnesty to the players played in both the speed of the MLB Report and its thoroughness?  Ø  Does the MLB sanctions against Luhnow and Hinch send a clear (enough) signal?  Ø  It was a technology innovation which led to the scandal. How does that inform a compliance professional?  Ø  Houston’s culture was broken. How can it be fixed? Ø  Did the Mets and Red Sox both actually consider keeping Alex Cora and Carlos Beltran? If so why?   Resources Tom’s five blog posts (to date) in the FCPA Compliance and Ethics Blog.  Part 1-The Scandal Part 2-Luhnow and Hinch Part 3-Compliance Lessons Part 4-Ethics and The Truth of the Game Part 5-the Whistleblower and Amnesty Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 22 Jan 2020 05:05:00 -0000 Lessons from the Astros Sign Stealing Scandal full 155 Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and Tom Fox take a deep dive into the Astros sign stealing scandal and the lessons a compliance professional can take away from it. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt indulges me as we take a deep dive into the Houston Astros sign stealing scandal. We mine the episode for compliance and ethics lessons. It turns out there are quite a few.  Some of the highlights include: Ø  What was the role amnesty to the players played in both the speed of the MLB Report and its thoroughness?  Ø  Does the MLB sanctions against Luhnow and Hinch send a clear (enough) signal?  Ø  It was a technology innovation which led to the scandal. How does that inform a compliance professional?  Ø  Houston’s culture was broken. How can it be fixed? Ø  Did the Mets and Red Sox both actually consider keeping Alex Cora and Carlos Beltran? If so why?   Resources Tom’s five blog posts (to date) in the FCPA Compliance and Ethics Blog.  Part 1-The Scandal Part 2-Luhnow and Hinch Part 3-Compliance Lessons Part 4-Ethics and The Truth of the Game Part 5-the Whistleblower and Amnesty Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt indulges me as we take a deep dive into the Houston Astros sign stealing scandal. We mine the episode for compliance and ethics lessons. It turns out there are quite a few. 

Some of the highlights include:

Ø  What was the role amnesty to the players played in both the speed of the MLB Report and its thoroughness? 

Ø  Does the MLB sanctions against Luhnow and Hinch send a clear (enough) signal? 

Ø  It was a technology innovation which led to the scandal. How does that inform a compliance professional? 

Ø  Houston’s culture was broken. How can it be fixed?

Ø  Did the Mets and Red Sox both actually consider keeping Alex Cora and Carlos Beltran? If so why?  

Resources

Tom’s five blog posts (to date) in the FCPA Compliance and Ethics Blog.

 Part 1-The Scandal

Part 2-Luhnow and Hinch

Part 3-Compliance Lessons

Part 4-Ethics and The Truth of the Game

Part 5-the Whistleblower and Amnesty


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]]> 2379 no Compliance Issues in 2020, Part 2 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Welcome to the first Into the Weeds podcast of the new decade and the new year. In this Part 2 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year.   Some of the highlights include: The Institutional Shareholder Services lawsuit against the SEC. What will this and other court cases against the Trump Administration’s attempt to gut shareholder protects by the SEC? Effective sanctions compliance programs. Will there be congruity or discrepancies in the interpretation of what constitutes a best practices compliance program by the DOJ and OFAC. Compliance convergence. We are moving to do away with anti-corruption compliance, trade sanction and export control compliance, AML compliance to a role which is simply compliance. Data, data and more data. Regulators now expect data analytics, continuous monitoring and continuous improvement in your compliance program. The ethical edge. How more effective compliance creates more efficient business process equating to greater profitability. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Jan 2020 12:11:46 -0000 Compliance Issues in 2020, Part 2 full 154 Tom Fox In this Part 2 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Welcome to the first Into the Weeds podcast of the new decade and the new year. In this Part 2 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year.   Some of the highlights include: The Institutional Shareholder Services lawsuit against the SEC. What will this and other court cases against the Trump Administration’s attempt to gut shareholder protects by the SEC? Effective sanctions compliance programs. Will there be congruity or discrepancies in the interpretation of what constitutes a best practices compliance program by the DOJ and OFAC. Compliance convergence. We are moving to do away with anti-corruption compliance, trade sanction and export control compliance, AML compliance to a role which is simply compliance. Data, data and more data. Regulators now expect data analytics, continuous monitoring and continuous improvement in your compliance program. The ethical edge. How more effective compliance creates more efficient business process equating to greater profitability. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Welcome to the first Into the Weeds podcast of the new decade and the new year. In this Part 2 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year.

 

Some of the highlights include:

  • The Institutional Shareholder Services lawsuit against the SEC. What will this and other court cases against the Trump Administration’s attempt to gut shareholder protects by the SEC?
  • Effective sanctions compliance programs. Will there be congruity or discrepancies in the interpretation of what constitutes a best practices compliance program by the DOJ and OFAC.
  • Compliance convergence. We are moving to do away with anti-corruption compliance, trade sanction and export control compliance, AML compliance to a role which is simply compliance.
  • Data, data and more data. Regulators now expect data analytics, continuous monitoring and continuous improvement in your compliance program.
  • The ethical edge. How more effective compliance creates more efficient business process equating to greater profitability.


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1615 no Compliance Issues in 2020, Part 1 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Welcome to the first Into the Weeds podcast of the new decade and the new year. In this Part 1 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year. Some of the highlights include: A legislative fix to the Supreme Court’s Digital Realty Trust decision? Can Congress do anything, including overturning this anti-compliance ruling. The Fed will take a look at technological service providers? How this will impact compliance. Climate change disclosures. We use this topic to consider the impact on corporate governance, Boards and mandated disclosures. Disgorgement at the Supreme Court. Will the SCt allow fraudsters to keep their ill-gotten gains? Critical audit matters. Will companies move make controls more data based and less subjective? Check in next week, where Matt and Tom continue the discussion. Resources Matt’s blog post 7 Compliance Items to Watch in 2020 in Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Jan 2020 11:00:00 -0000 Compliance Issues in 2020, Part 1 full 153 Tom Fox In this Part 1 of a two-part series, Matt and Tom consider the first five of their top ten issues for compliance professionals in 2020. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Welcome to the first Into the Weeds podcast of the new decade and the new year. In this Part 1 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year. Some of the highlights include: A legislative fix to the Supreme Court’s Digital Realty Trust decision? Can Congress do anything, including overturning this anti-compliance ruling. The Fed will take a look at technological service providers? How this will impact compliance. Climate change disclosures. We use this topic to consider the impact on corporate governance, Boards and mandated disclosures. Disgorgement at the Supreme Court. Will the SCt allow fraudsters to keep their ill-gotten gains? Critical audit matters. Will companies move make controls more data based and less subjective? Check in next week, where Matt and Tom continue the discussion. Resources Matt’s blog post 7 Compliance Items to Watch in 2020 in Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Welcome to the first Into the Weeds podcast of the new decade and the new year. In this Part 1 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year.

Some of the highlights include:

  • A legislative fix to the Supreme Court’s Digital Realty Trust decision? Can Congress do anything, including overturning this anti-compliance ruling.
  • The Fed will take a look at technological service providers? How this will impact compliance.
  • Climate change disclosures. We use this topic to consider the impact on corporate governance, Boards and mandated disclosures.
  • Disgorgement at the Supreme Court. Will the SCt allow fraudsters to keep their ill-gotten gains?
  • Critical audit matters. Will companies move make controls more data based and less subjective?

Check in next week, where Matt and Tom continue the discussion.

Resources

Matt’s blog post 7 Compliance Items to Watch in 2020 in Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2070 no Continued Missteps and Misadventures in Ethics by Boeing Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weed over the ethical failings and missteps made by the now former Boeing CEO Dennis Muilenburg which led to his firing. Some of the highlights include: Ø  What are the three steps in cooperating with the government after a failure? Ø  Why did Boeing fail to reveal negative information it uncovered in its internal investigation? Ø  What is the role of a CEO around ethics? Ø  What is the role of the Board of Directors? Ø  What is the only control for a CEO around ethics? Ø  What are the lessons learned for a corporate compliance program? Ø  What does all this mean for compliance professionals going forward? Resources Matt’s blog post More Misadventures in Ethics From Boeing in Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 24 Dec 2019 05:00:00 -0000 Continued Missteps and Misadventures in Ethics by Boeing full 152 Tom Fox In this episode Matt Kelly and Tom Fox take a deep dive into the ethical failures of the now former Boeing CEO Dennis Muilenburg which led to his firing on December 23, 2019. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weed over the ethical failings and missteps made by the now former Boeing CEO Dennis Muilenburg which led to his firing. Some of the highlights include: Ø  What are the three steps in cooperating with the government after a failure? Ø  Why did Boeing fail to reveal negative information it uncovered in its internal investigation? Ø  What is the role of a CEO around ethics? Ø  What is the role of the Board of Directors? Ø  What is the only control for a CEO around ethics? Ø  What are the lessons learned for a corporate compliance program? Ø  What does all this mean for compliance professionals going forward? Resources Matt’s blog post More Misadventures in Ethics From Boeing in Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weed over the ethical failings and missteps made by the now former Boeing CEO Dennis Muilenburg which led to his firing.

Some of the highlights include:

Ø  What are the three steps in cooperating with the government after a failure?

Ø  Why did Boeing fail to reveal negative information it uncovered in its internal investigation?

Ø  What is the role of a CEO around ethics?

Ø  What is the role of the Board of Directors?

Ø  What is the only control for a CEO around ethics?

Ø  What are the lessons learned for a corporate compliance program?

Ø  What does all this mean for compliance professionals going forward?

Resources

Matt’s blog post More Misadventures in Ethics From Boeing in Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1681 no New DOJ Cooperation Guidance on Trade Sanctions and Export Controls Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the new DOJ, National Security Division’s Export Controls and Sanctions Enforcement Policy for Business Organizations.  Some of the highlights include: Why is there no declination available? What aggravating factors are different between this policy and the FCPA policy? What is an effective compliance program under this Policy and the OFAC Compliance Framework? Who do you self-disclose to first if you uncover a trade sanctions violation? Is this policy coordinated with other cooperation agreements? What are the lessons learned for a corporate compliance program? What does all this mean for compliance professionals going forward? Resources Matt’s blog post Cooperation for Sanctions Violations in Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Dec 2019 05:00:00 -0000 New DOJ Cooperation Guidance on Trade Sanctions and Export Controls full Tom Fox In this episode Matt Kelly and I consider the new New DOJ Cooperation Guidance on Trade Sanctions and Export Controls. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the new DOJ, National Security Division’s Export Controls and Sanctions Enforcement Policy for Business Organizations.  Some of the highlights include: Why is there no declination available? What aggravating factors are different between this policy and the FCPA policy? What is an effective compliance program under this Policy and the OFAC Compliance Framework? Who do you self-disclose to first if you uncover a trade sanctions violation? Is this policy coordinated with other cooperation agreements? What are the lessons learned for a corporate compliance program? What does all this mean for compliance professionals going forward? Resources Matt’s blog post Cooperation for Sanctions Violations in Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the new DOJ, National Security Division’s Export Controls and Sanctions Enforcement Policy for Business Organizations.

 Some of the highlights include:

  • Why is there no declination available?
  • What aggravating factors are different between this policy and the FCPA policy?
  • What is an effective compliance program under this Policy and the OFAC Compliance Framework?
  • Who do you self-disclose to first if you uncover a trade sanctions violation?
  • Is this policy coordinated with other cooperation agreements?
  • What are the lessons learned for a corporate compliance program?
  • What does all this mean for compliance professionals going forward?

Resources

Matt’s blog post Cooperation for Sanctions Violations in Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1384 no Ericsson from the Internal Controls Perspective Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the Ericsson FCPA enforcement action from the internal controls perspective.  Some of the highlights include: Ø  What does this enforcement action tell up about internal controls? Ø  How were the business units able to evade internal controls for so long? Ø  Was there control override? Ø  What is the role of ERP systems such as Oracle and SAP in compliance? Ø  If a company refuses to use standard ERP systems, is that a control failure under the FCPA? Ø  What are the lessons learned for a corporate compliance program? Ø  What does all this mean for compliance professionals going forward? Resources Tom’s blog posts, both the FCPA Compliance and Ethics Blog. Part 1-Overview Part 2-The Bribery Schemes Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Dec 2019 05:00:00 -0000 Ericsson from the Internal Controls Perspective full Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and I take a deep dive into the internal controls aspects of the Ericsson FCPA enforcement action. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the Ericsson FCPA enforcement action from the internal controls perspective.  Some of the highlights include: Ø  What does this enforcement action tell up about internal controls? Ø  How were the business units able to evade internal controls for so long? Ø  Was there control override? Ø  What is the role of ERP systems such as Oracle and SAP in compliance? Ø  If a company refuses to use standard ERP systems, is that a control failure under the FCPA? Ø  What are the lessons learned for a corporate compliance program? Ø  What does all this mean for compliance professionals going forward? Resources Tom’s blog posts, both the FCPA Compliance and Ethics Blog. Part 1-Overview Part 2-The Bribery Schemes Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the Ericsson FCPA enforcement action from the internal controls perspective. 


Some of the highlights include:


Ø  What does this enforcement action tell up about internal controls?

Ø  How were the business units able to evade internal controls for so long?

Ø  Was there control override?

Ø  What is the role of ERP systems such as Oracle and SAP in compliance?

Ø  If a company refuses to use standard ERP systems, is that a control failure under the FCPA?

Ø  What are the lessons learned for a corporate compliance program?

Ø  What does all this mean for compliance professionals going forward?


Resources


Tom’s blog posts, both the FCPA Compliance and Ethics Blog.

Part 1-Overview

Part 2-The Bribery Schemes


Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1202 no Episode 149- Operational Resiliency Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about operational resiliency.  Some of the highlights include: What is operational resiliency? Why is technology so critical in this area? What is the intersection of operational resiliency and compliance? Should compliance and risk management be merged? From the headlines (1)-What did the Fed say? From the headlines (2) moving past financial services-Virtual Care Provider. What does all this mean for compliance professionals going forward? Resources Matt’s blog posts, both on Radical Compliance. Compliance Role in Operational Resiliency, Operational Resiliency Part II Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Dec 2019 05:20:00 -0000 Episode 149- Operational Resiliency full Tom Fox In this episode Matt Kelly and I consider the intersection of operational resiliency and compliance. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about operational resiliency.  Some of the highlights include: What is operational resiliency? Why is technology so critical in this area? What is the intersection of operational resiliency and compliance? Should compliance and risk management be merged? From the headlines (1)-What did the Fed say? From the headlines (2) moving past financial services-Virtual Care Provider. What does all this mean for compliance professionals going forward? Resources Matt’s blog posts, both on Radical Compliance. Compliance Role in Operational Resiliency, Operational Resiliency Part II Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about operational resiliency. 

Some of the highlights include:

  • What is operational resiliency?
  • Why is technology so critical in this area?
  • What is the intersection of operational resiliency and compliance?
  • Should compliance and risk management be merged?
  • From the headlines (1)-What did the Fed say?
  • From the headlines (2) moving past financial services-Virtual Care Provider.
  • What does all this mean for compliance professionals going forward?


Resources

Matt’s blog posts, both on Radical Compliance.

Compliance Role in Operational Resiliency,

Operational Resiliency Part II

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1584 no Procurement Collusion Strike Force Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the recent DOJ announcement of the Procurement Collusion Strike Force (PCSF).  Some of the highlights include.  Some of the highlights include: Ø  Why was the PCSF created? Ø  What will it focus on? Ø  Why does the funding (or lack thereof) matter? Ø  What do the twin DOJ announcements of the PCFS portend? Ø  Why are analytics more critical for compliance going forward? Ø  What are procurement red flags? Ø  What does all this mean for compliance professionals going forward? Resources Matt’s blog post, Brace for Procurement Compliance, on Radical Compliance. DOJ Press Release on PCSF PCSF website Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Nov 2019 05:00:00 -0000 Procurement Collusion Strike Force full 148 Tom Fox In this episode, Matt Kelly and I go into the weeds to explore the recent announcement of the creation of the Procurement Collusion Strike Force by the Department of Justice. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the recent DOJ announcement of the Procurement Collusion Strike Force (PCSF).  Some of the highlights include.  Some of the highlights include: Ø  Why was the PCSF created? Ø  What will it focus on? Ø  Why does the funding (or lack thereof) matter? Ø  What do the twin DOJ announcements of the PCFS portend? Ø  Why are analytics more critical for compliance going forward? Ø  What are procurement red flags? Ø  What does all this mean for compliance professionals going forward? Resources Matt’s blog post, Brace for Procurement Compliance, on Radical Compliance. DOJ Press Release on PCSF PCSF website Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the recent DOJ announcement of the Procurement Collusion Strike Force (PCSF).  Some of the highlights include. 

Some of the highlights include:

Ø  Why was the PCSF created?

Ø  What will it focus on?

Ø  Why does the funding (or lack thereof) matter?

Ø  What do the twin DOJ announcements of the PCFS portend?

Ø  Why are analytics more critical for compliance going forward?

Ø  What are procurement red flags?

Ø  What does all this mean for compliance professionals going forward?

Resources

Matt’s blog post, Brace for Procurement Compliance, on Radical Compliance.

DOJ Press Release on PCSF

PCSF website

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1324 no Episode 147-Secondhand Whistleblower Reporting Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds on a recent academic paper by Stubben and Welch entitled, Are Secondhand Whistleblowing Reports More Credible. The authors reviewed data from the Navex Global data base of 2 million whistleblower reports from more than 1,000 companies from 2004 through 2017. Their findings have significant implications for CCO, GCs and Boards of Directors. Some of the highlights include: Why is this the first international podcast of Compliance Into the Weeds? What are the key differences between a first-hand whistleblower report and a secondhand report? Why are over 47% more second-hand reports substantiated than first-hand reports? Why do first-hand reports tend to be about actions against a person and secondhand reports be about things which happened to the organization? What are the implications for triage/investigations of first and secondhand reports? Is confirmation bias at work here? For additional reading see the following: Matt’s blog post, Study-Second Hand Reports More Reliable, on Radical Compliance. Stubben and Welch, Are Secondhand Internal Whistleblowing Reports Credible? Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Nov 2019 05:00:00 -0000 Episode 147-Secondhand Whistleblower Reporting full 147 Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and I take a deep dive into the differences in first-hand and secondhand whistleblowers. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds on a recent academic paper by Stubben and Welch entitled, Are Secondhand Whistleblowing Reports More Credible. The authors reviewed data from the Navex Global data base of 2 million whistleblower reports from more than 1,000 companies from 2004 through 2017. Their findings have significant implications for CCO, GCs and Boards of Directors. Some of the highlights include: Why is this the first international podcast of Compliance Into the Weeds? What are the key differences between a first-hand whistleblower report and a secondhand report? Why are over 47% more second-hand reports substantiated than first-hand reports? Why do first-hand reports tend to be about actions against a person and secondhand reports be about things which happened to the organization? What are the implications for triage/investigations of first and secondhand reports? Is confirmation bias at work here? For additional reading see the following: Matt’s blog post, Study-Second Hand Reports More Reliable, on Radical Compliance. Stubben and Welch, Are Secondhand Internal Whistleblowing Reports Credible? Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds on a recent academic paper by Stubben and Welch entitled, Are Secondhand Whistleblowing Reports More Credible. The authors reviewed data from the Navex Global data base of 2 million whistleblower reports from more than 1,000 companies from 2004 through 2017. Their findings have significant implications for CCO, GCs and Boards of Directors.

Some of the highlights include:

  • Why is this the first international podcast of Compliance Into the Weeds?
  • What are the key differences between a first-hand whistleblower report and a secondhand report?
  • Why are over 47% more second-hand reports substantiated than first-hand reports?
  • Why do first-hand reports tend to be about actions against a person and secondhand reports be about things which happened to the organization?
  • What are the implications for triage/investigations of first and secondhand reports?
  • Is confirmation bias at work here?

For additional reading see the following:

Matt’s blog post, Study-Second Hand Reports More Reliable, on Radical Compliance.

Stubben and Welch, Are Secondhand Internal Whistleblowing Reports Credible?

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1151 no SOX Compliance-Slow Poking Along Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds on issues raised around SOX compliance by internal audit functions in corporations and the use of tech solutions to improve things by a recent report of the SOX Professional Group.  Some of the highlights include: Why is SOX compliance still ‘a big hassle’? A recent report by the SOX Professional Group found that internal audit is taking over more SOX reporting. Why has internal audit been asked to take over more of this role? Why would the SEC want to reduce award levels at the high end? What is the constituency for this position? The SOX Professional Group report noted that SOX compliance costs are increasing; why did an earlier Protiviti report show costs were ‘drifting downward’? Where are companies on the use of new tech solutions to facilitate SOX Compliance? Why are 73% of all companies still using Excel spreadsheet to report on SOX compliance? What role, if any, does internal audit have in cyber security? Why is cybersecurity not seen as a high risk from SOX reporting perspective? For additional reading see the following: Matt’s blog post, Report: SOX Compliance Still a Pain, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 30 Oct 2019 04:00:00 -0000 SOX Compliance-Slow Poking Along full 146 Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and I go into the weeds to explore the ongoing slog of SOX compliance reporting.   Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds on issues raised around SOX compliance by internal audit functions in corporations and the use of tech solutions to improve things by a recent report of the SOX Professional Group.  Some of the highlights include: Why is SOX compliance still ‘a big hassle’? A recent report by the SOX Professional Group found that internal audit is taking over more SOX reporting. Why has internal audit been asked to take over more of this role? Why would the SEC want to reduce award levels at the high end? What is the constituency for this position? The SOX Professional Group report noted that SOX compliance costs are increasing; why did an earlier Protiviti report show costs were ‘drifting downward’? Where are companies on the use of new tech solutions to facilitate SOX Compliance? Why are 73% of all companies still using Excel spreadsheet to report on SOX compliance? What role, if any, does internal audit have in cyber security? Why is cybersecurity not seen as a high risk from SOX reporting perspective? For additional reading see the following: Matt’s blog post, Report: SOX Compliance Still a Pain, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds on issues raised around SOX compliance by internal audit functions in corporations and the use of tech solutions to improve things by a recent report of the SOX Professional Group.

 Some of the highlights include:

  • Why is SOX compliance still ‘a big hassle’?
  • A recent report by the SOX Professional Group found that internal audit is taking over more SOX reporting.
  • Why has internal audit been asked to take over more of this role?
  • Why would the SEC want to reduce award levels at the high end? What is the constituency for this position?
  • The SOX Professional Group report noted that SOX compliance costs are increasing; why did an earlier Protiviti report show costs were ‘drifting downward’?
  • Where are companies on the use of new tech solutions to facilitate SOX Compliance?
  • Why are 73% of all companies still using Excel spreadsheet to report on SOX compliance?
  • What role, if any, does internal audit have in cyber security?
  • Why is cybersecurity not seen as a high risk from SOX reporting perspective?

For additional reading see the following:

Matt’s blog post, Report: SOX Compliance Still a Pain, on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1540 no Proposed SEC Whistleblower Reform Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the SEC’s proposed changes to its whistleblower program.  Some of the highlights include: The reforms were originally announced 18 moths ago. Why is the SEC just now getting to public discussion? What if anything will be the cap on high end awards? Conversely, will the expansion of low-end awards beget better whistleblower tips? Why would the SEC want to reduce award levels at the high end? What is the constituency for this position? Why (or why not) should a whistleblower tip be in writing? Why was the SEC Open Meeting to discuss these reforms postponed until November? Will the meeting be postponed again? Who benefits from a postponement? For additional reading see the following: Matt’s blog post, SEC Tees Up Whistleblower Reform, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Oct 2019 04:00:00 -0000 Proposed SEC Whistleblower Reform full 145 Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and I go into the weeds to explore the SEC’s proposed changes to its whistleblower program.   Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the SEC’s proposed changes to its whistleblower program.  Some of the highlights include: The reforms were originally announced 18 moths ago. Why is the SEC just now getting to public discussion? What if anything will be the cap on high end awards? Conversely, will the expansion of low-end awards beget better whistleblower tips? Why would the SEC want to reduce award levels at the high end? What is the constituency for this position? Why (or why not) should a whistleblower tip be in writing? Why was the SEC Open Meeting to discuss these reforms postponed until November? Will the meeting be postponed again? Who benefits from a postponement? For additional reading see the following: Matt’s blog post, SEC Tees Up Whistleblower Reform, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the SEC’s proposed changes to its whistleblower program. 

Some of the highlights include:

  • The reforms were originally announced 18 moths ago. Why is the SEC just now getting to public discussion?
  • What if anything will be the cap on high end awards?
  • Conversely, will the expansion of low-end awards beget better whistleblower tips?
  • Why would the SEC want to reduce award levels at the high end? What is the constituency for this position?
  • Why (or why not) should a whistleblower tip be in writing?
  • Why was the SEC Open Meeting to discuss these reforms postponed until November?
  • Will the meeting be postponed again? Who benefits from a postponement?

For additional reading see the following:

Matt’s blog post, SEC Tees Up Whistleblower Reform, on Radical Compliance.

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]]> 1152 no Changes at the PCAOB Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent changes at the PCAOB made by SEC Chairman Jay Clayton.   Some of the highlights include: Ø  Why were the changes announced in a manner to hide them? Ø  Why were they such unusual personnel moves? Ø  Why would the SEC put someone on the PCAOB with no discernible qualifications for the role? Ø  Is the goal of Jay Clayton to do away with SOX 404 protection for investors? Ø  Does going public under SOX mandate investor protection? Ø  What else will Clayton pull to ram through his changes at the PCAOB and SEC? Ø  Why is WeWork such a power example right now? For additional reading see the following: Matt’s blog post, PCAOB Shakeup-What it Means for You, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Oct 2019 04:00:00 -0000 Changes at the PCAOB full 144 Tom Fox In this episode, Matt Kelly and I go into the weeds to explore the recent changes at the PCAOB made by SEC Chairman Jay Clayton. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent changes at the PCAOB made by SEC Chairman Jay Clayton.   Some of the highlights include: Ø  Why were the changes announced in a manner to hide them? Ø  Why were they such unusual personnel moves? Ø  Why would the SEC put someone on the PCAOB with no discernible qualifications for the role? Ø  Is the goal of Jay Clayton to do away with SOX 404 protection for investors? Ø  Does going public under SOX mandate investor protection? Ø  What else will Clayton pull to ram through his changes at the PCAOB and SEC? Ø  Why is WeWork such a power example right now? For additional reading see the following: Matt’s blog post, PCAOB Shakeup-What it Means for You, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent changes at the PCAOB made by SEC Chairman Jay Clayton.  

Some of the highlights include:

Ø  Why were the changes announced in a manner to hide them?

Ø  Why were they such unusual personnel moves?

Ø  Why would the SEC put someone on the PCAOB with no discernible qualifications for the role?

Ø  Is the goal of Jay Clayton to do away with SOX 404 protection for investors?

Ø  Does going public under SOX mandate investor protection?

Ø  What else will Clayton pull to ram through his changes at the PCAOB and SEC?

Ø  Why is WeWork such a power example right now?

For additional reading see the following:

Matt’s blog post, PCAOB Shakeup-What it Means for You, on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1324 no Mylan and Silos Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against Mylan and its mischaracterization of the drug EpiPen as a generic drug. This mischaracterization cost the federal government millions of dollars and led the SEC to fine Mylan $30MM.   Some of the highlights include: Ø  How can one event have multiple risk scenarios?Ø  How risks can ripple across an organization?Ø  Who oversees risk for a company in a holistic manner?Ø  How can internal controls help to break down silos?Ø  Where was compliance?Ø  Why do internal controls need to cut across silos to provide (at least) internal transparency? For additional reading see the following: Matt’s blog post, Mylan’s Lessons on Silos & Risks, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Fri, 11 Oct 2019 14:32:00 -0000 Mylan and Silos full Tom Fox In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against Mylan and its mischaracterization of the drug EpiPen as a generic drug. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against Mylan and its mischaracterization of the drug EpiPen as a generic drug. This mischaracterization cost the federal government millions of dollars and led the SEC to fine Mylan $30MM.   Some of the highlights include: Ø  How can one event have multiple risk scenarios?Ø  How risks can ripple across an organization?Ø  Who oversees risk for a company in a holistic manner?Ø  How can internal controls help to break down silos?Ø  Where was compliance?Ø  Why do internal controls need to cut across silos to provide (at least) internal transparency? For additional reading see the following: Matt’s blog post, Mylan’s Lessons on Silos & Risks, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against Mylan and its mischaracterization of the drug EpiPen as a generic drug. This mischaracterization cost the federal government millions of dollars and led the SEC to fine Mylan $30MM.   Some of the highlights include: Ø  How can one event have multiple risk scenarios?Ø  How risks can ripple across an organization?Ø  Who oversees risk for a company in a holistic manner?Ø  How can internal controls help to break down silos?Ø  Where was compliance?Ø  Why do internal controls need to cut across silos to provide (at least) internal transparency? For additional reading see the following: Matt’s blog post, Mylan’s Lessons on Silos & Risks, on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1043 no Quad/Graphics FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we have a special live and in person podcast recording from Converge19. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against Quad/Graphics and its Peruvian subsidiary. Matt comes in smoking on the egregious conduct of the company and the lack of criminal sanctions against the company.   Some of the highlights include: How did the company garner credit for prompt disclosure when it knew about the conduct for 3 years?Why have there been no criminal indictments against individuals?How many sham vendors, invoices and payments does a company need to take notice?Where was compliance?Why is it the sham-ness of it all?For additional reading see the following: Matt’s blog post, Graphics Firm Draws $10 FCPA Settlement, on Radical Compliance. Tom’s blog post, Quad/Graphics-the Sham-ness of it all, on the FCPA Compliance Report. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Oct 2019 04:00:00 -0000 Quad/Graphics FCPA Enforcement Action full 142 Tom Fox In this episode of Compliance into the Weeds, Matt comes in hot on the Quad/Graphics FCPA settlement. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we have a special live and in person podcast recording from Converge19. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against Quad/Graphics and its Peruvian subsidiary. Matt comes in smoking on the egregious conduct of the company and the lack of criminal sanctions against the company.   Some of the highlights include: How did the company garner credit for prompt disclosure when it knew about the conduct for 3 years?Why have there been no criminal indictments against individuals?How many sham vendors, invoices and payments does a company need to take notice?Where was compliance?Why is it the sham-ness of it all?For additional reading see the following: Matt’s blog post, Graphics Firm Draws $10 FCPA Settlement, on Radical Compliance. Tom’s blog post, Quad/Graphics-the Sham-ness of it all, on the FCPA Compliance Report. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Today we have a special live and in person podcast recording from Converge19. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against Quad/Graphics and its Peruvian subsidiary. Matt comes in smoking on the egregious conduct of the company and the lack of criminal sanctions against the company.  

Some of the highlights include:

How did the company garner credit for prompt disclosure when it knew about the conduct for 3 years?Why have there been no criminal indictments against individuals?How many sham vendors, invoices and payments does a company need to take notice?Where was compliance?Why is it the sham-ness of it all?For additional reading see the following:

Matt’s blog post, Graphics Firm Draws $10 FCPA Settlement, on Radical Compliance.

Tom’s blog post, Quad/Graphics-the Sham-ness of it all, on the FCPA Compliance Report.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1149 yes PwC Spanked Edition  Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against PwC and its partner Brandon Sprankle for  violating audit firm independence rules,  including PwC implementing a GRC software system for one of its audit clients. Some of the highlights include:What was the conduct which led to the $8.9MM fine against PwC?Why do audit firm independence rules exist?Why ethical norms did PwC partner Brandon Sprankle violate?Should an audit partner who engages in material misrepresentations be trusted to perform an audit?What internal controls at PwC were violated by Sprankle’s actions?What does a CCO need to pay attention to audit firm independence rules?For additional reading see the following: Matt’s blog post, SEC Dings PwC on GRC Deal, on Radical Compliance. For more information on Converge19, click here.   Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Sep 2019 04:00:00 -0000 PwC Spanked Edition full Tom Fox In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against PwC and its partner Brandon Sprankle for violating audit firm independence rules.  Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against PwC and its partner Brandon Sprankle for  violating audit firm independence rules,  including PwC implementing a GRC software system for one of its audit clients. Some of the highlights include:What was the conduct which led to the $8.9MM fine against PwC?Why do audit firm independence rules exist?Why ethical norms did PwC partner Brandon Sprankle violate?Should an audit partner who engages in material misrepresentations be trusted to perform an audit?What internal controls at PwC were violated by Sprankle’s actions?What does a CCO need to pay attention to audit firm independence rules?For additional reading see the following: Matt’s blog post, SEC Dings PwC on GRC Deal, on Radical Compliance. For more information on Converge19, click here.   Learn more about your ad choices. Visit megaphone.fm/adchoices  Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recent SEC enforcement action against PwC and its partner Brandon Sprankle for  violating audit firm independence rules,  including PwC implementing a GRC software system for one of its audit clients.

Some of the highlights include:What was the conduct which led to the $8.9MM fine against PwC?Why do audit firm independence rules exist?Why ethical norms did PwC partner Brandon Sprankle violate?Should an audit partner who engages in material misrepresentations be trusted to perform an audit?What internal controls at PwC were violated by Sprankle’s actions?What does a CCO need to pay attention to audit firm independence rules?For additional reading see the following:

Matt’s blog post, SEC Dings PwC on GRC Deal, on Radical Compliance.

For more information on Converge19, click here.

 

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1210 no Some of My Best Friends Are Lawyers Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore what additional educational degrees or certifications  a mid-career compliance professional should consider obtaining to further their career.   Some of the highlights include: Ø How did Matt become interested in this question?Ø What types of additional university degrees will assist the compliance professional?Ø Why a law degree will not help the mid-career compliance professional?Ø Does legal training apply to compliance any longer?Ø Why you should assess your skill set and then move to fill any gaps to become a more well-rounded compliance professional.Ø Why other university disciplines such as behavioral phycology, Human Resources and Risk Management are more valuable than law degrees for the compliance professional. For additional reading see the following: Matt’s blog post, Study Law to Advance Compliance Career?,on Radical Compliance.For more information on Converge19, click here.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Sep 2019 04:00:00 -0000 Some of My Best Friends Are Lawyers full 140 Tom Fox In this podcast, Matt Kelly and I take a deep dive into the weeds to consider what additional education degrees a mid-career compliance professional would benefit from going forward. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore what additional educational degrees or certifications  a mid-career compliance professional should consider obtaining to further their career.   Some of the highlights include: Ø How did Matt become interested in this question?Ø What types of additional university degrees will assist the compliance professional?Ø Why a law degree will not help the mid-career compliance professional?Ø Does legal training apply to compliance any longer?Ø Why you should assess your skill set and then move to fill any gaps to become a more well-rounded compliance professional.Ø Why other university disciplines such as behavioral phycology, Human Resources and Risk Management are more valuable than law degrees for the compliance professional. For additional reading see the following: Matt’s blog post, Study Law to Advance Compliance Career?,on Radical Compliance.For more information on Converge19, click here.  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore what additional educational degrees or certifications  a mid-career compliance professional should consider obtaining to further their career.   Some of the highlights include: Ø How did Matt become interested in this question?Ø What types of additional university degrees will assist the compliance professional?Ø Why a law degree will not help the mid-career compliance professional?Ø Does legal training apply to compliance any longer?Ø Why you should assess your skill set and then move to fill any gaps to become a more well-rounded compliance professional.Ø Why other university disciplines such as behavioral phycology, Human Resources and Risk Management are more valuable than law degrees for the compliance professional. For additional reading see the following: Matt’s blog post, Study Law to Advance Compliance Career?,on Radical Compliance.For more information on Converge19, click here. 

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1337 no Sharpies, Leadership and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the President’s recent imbroglio regarding Hurricane Dorian, Alabama and sharpies.   Some of the highlights include:Why was this episode so creepy?What is a Level 5 business leader and why are those traits so valued in business?What would happen if a business leader intentionally misrepresented his company’s products?If you threaten to fire all who disagree with the Leader’s comments, what will it do for the future of the organization?What was the failure of compensating controls?What should a Board of Directors do if a CEO engages in material misrepresentations?For additional reading see Matt’s blog post, Sharp(ie) Insights in Speak Up Culture, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Sep 2019 04:00:00 -0000 Sharpies, Leadership and Compliance full 139 Tom Fox How does the President’s recent imbroglio regarding Hurricane Dorian, Alabama and sharpies inform compliance? Find out on this episode of Compliance into the Weeds. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the President’s recent imbroglio regarding Hurricane Dorian, Alabama and sharpies.   Some of the highlights include:Why was this episode so creepy?What is a Level 5 business leader and why are those traits so valued in business?What would happen if a business leader intentionally misrepresented his company’s products?If you threaten to fire all who disagree with the Leader’s comments, what will it do for the future of the organization?What was the failure of compensating controls?What should a Board of Directors do if a CEO engages in material misrepresentations?For additional reading see Matt’s blog post, Sharp(ie) Insights in Speak Up Culture, on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the President’s recent imbroglio regarding Hurricane Dorian, Alabama and sharpies.  

Some of the highlights include:Why was this episode so creepy?What is a Level 5 business leader and why are those traits so valued in business?What would happen if a business leader intentionally misrepresented his company’s products?If you threaten to fire all who disagree with the Leader’s comments, what will it do for the future of the organization?What was the failure of compensating controls?What should a Board of Directors do if a CEO engages in material misrepresentations?For additional reading see Matt’s blog post, Sharp(ie) Insights in Speak Up Culture, on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1416 no Juniper Networks FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recently released FCPA enforcement action by the SEC involving Juniper Networks.  Some of the highlights include: Ø Who is responsible for the continued violations after initial discovery, the subsidiaries or the parent?Ø What happens when a grandparent ‘speaks sternly’ to a grandchild?Ø Why does a decentralized compliance structure allow for internal abuse? Ø Do your policies and procedures actually support your compliance efforts? Ø As CCO do you have visibility into where customer discounts are going?Ø Should lawyers ever review expense reports from foreign business units? For additional reading see the following: Tom’s blog post, Juniper Network FCPA Enforcement Action, on the FCPA Compliance & Ethics Blog. Matt’s blog post, Juniper Networks Hit on FCPA Charge, on Radical Compliance. Jonathan Marks considers these points as well as the Board of Directors role in his blog post, Slush Funds and the Juniper Networks FCPA Settlement, on his always great Board and Fraud blog.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 04 Sep 2019 04:04:00 -0000 Juniper Networks FCPA Enforcement Action full 138 Tom Fox In this episode, Matt Kelly and I go into the weeds to explore the recently released FCPA enforcement action by the SEC involving Juniper Networks. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recently released FCPA enforcement action by the SEC involving Juniper Networks.  Some of the highlights include: Ø Who is responsible for the continued violations after initial discovery, the subsidiaries or the parent?Ø What happens when a grandparent ‘speaks sternly’ to a grandchild?Ø Why does a decentralized compliance structure allow for internal abuse? Ø Do your policies and procedures actually support your compliance efforts? Ø As CCO do you have visibility into where customer discounts are going?Ø Should lawyers ever review expense reports from foreign business units? For additional reading see the following: Tom’s blog post, Juniper Network FCPA Enforcement Action, on the FCPA Compliance & Ethics Blog. Matt’s blog post, Juniper Networks Hit on FCPA Charge, on Radical Compliance. Jonathan Marks considers these points as well as the Board of Directors role in his blog post, Slush Funds and the Juniper Networks FCPA Settlement, on his always great Board and Fraud blog.  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds to explore the recently released FCPA enforcement action by the SEC involving Juniper Networks.  Some of the highlights include: Ø Who is responsible for the continued violations after initial discovery, the subsidiaries or the parent?Ø What happens when a grandparent ‘speaks sternly’ to a grandchild?Ø Why does a decentralized compliance structure allow for internal abuse? Ø Do your policies and procedures actually support your compliance efforts? Ø As CCO do you have visibility into where customer discounts are going?Ø Should lawyers ever review expense reports from foreign business units? For additional reading see the following: Tom’s blog post, Juniper Network FCPA Enforcement Action, on the FCPA Compliance & Ethics Blog. Matt’s blog post, Juniper Networks Hit on FCPA Charge, on Radical Compliance. Jonathan Marks considers these points as well as the Board of Directors role in his blog post, Slush Funds and the Juniper Networks FCPA Settlement, on his always great Board and Fraud blog. 

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1745 no Episode 137- Debating the Statement on the Purpose of a Corporation Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly  and I go into the weeds to discuss our views on the Business Roundtable’s recently released Statement on the Purpose of a Corporation.   Some of the highlights include: Ø Tom believes it is an important first step to consider the various stakeholders in a business enterprise.Ø Matt has a bit more cynical view of the document. Ø Matt is concerned that the Statement does not have the force of law and indeed may be antithetical to corporate law. Ø Matt is suspicious of the timing of the Statement. Ø Tom believes it provides a playbook for both corporations and lawmakers in the debate going forward. For additional reading see Tom’s blog post Statement on the Purpose of a Corporation and What it Means for the Compliance Professionalon the FCPA Compliance Report. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Aug 2019 04:00:00 -0000 Debating the Statement on the Purpose of a Corporation full 137 Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and I take a deep dive into Business Roundtable's recently released Statement on the Purpose of a Corporation. . Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly  and I go into the weeds to discuss our views on the Business Roundtable’s recently released Statement on the Purpose of a Corporation.   Some of the highlights include: Ø Tom believes it is an important first step to consider the various stakeholders in a business enterprise.Ø Matt has a bit more cynical view of the document. Ø Matt is concerned that the Statement does not have the force of law and indeed may be antithetical to corporate law. Ø Matt is suspicious of the timing of the Statement. Ø Tom believes it provides a playbook for both corporations and lawmakers in the debate going forward. For additional reading see Tom’s blog post Statement on the Purpose of a Corporation and What it Means for the Compliance Professionalon the FCPA Compliance Report. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly  and I go into the weeds to discuss our views on the Business Roundtable’s recently released Statement on the Purpose of a Corporation.   Some of the highlights include: Ø Tom believes it is an important first step to consider the various stakeholders in a business enterprise.Ø Matt has a bit more cynical view of the document. Ø Matt is concerned that the Statement does not have the force of law and indeed may be antithetical to corporate law. Ø Matt is suspicious of the timing of the Statement. Ø Tom believes it provides a playbook for both corporations and lawmakers in the debate going forward. For additional reading see Tom’s blog post Statement on the Purpose of a Corporation and What it Means for the Compliance Professionalon the FCPA Compliance Report.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1754 no Compliance into the Weeds: Episode 136- Scoping the Size of Compliance Workforce Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly  and I go into the weeds to explore size of the compliance workforce in secondary markets in the US and how that will impact compliance program enhancements going forward. Some of the highlights include:Do FASB accounting standard changes mandate new skill/talents?Why are the new FASB lease accounting standards being delayed?Is the role of compliance is to build better systems to govern ourselves around risk management?Is the BLS definition of compliance professional still relevant or is it stuck in 1998?Why is there such a divergence in secondary markets in the hiring of compliance professionals?How would all this play out for compliance professionals in a recession?For additional reading see Matt’s blog post Scoping the Size of Compliance Workforce on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Aug 2019 04:00:00 -0000 Scoping the Size of Compliance Workforce full 136 Tom Fox Matt Kelly and I are back to dive into the weeds on another compliance topic. This week we consider the size of the compliance workforce in secondary markets. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly  and I go into the weeds to explore size of the compliance workforce in secondary markets in the US and how that will impact compliance program enhancements going forward. Some of the highlights include:Do FASB accounting standard changes mandate new skill/talents?Why are the new FASB lease accounting standards being delayed?Is the role of compliance is to build better systems to govern ourselves around risk management?Is the BLS definition of compliance professional still relevant or is it stuck in 1998?Why is there such a divergence in secondary markets in the hiring of compliance professionals?How would all this play out for compliance professionals in a recession?For additional reading see Matt’s blog post Scoping the Size of Compliance Workforce on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly  and I go into the weeds to explore size of the compliance workforce in secondary markets in the US and how that will impact compliance program enhancements going forward.

Some of the highlights include:Do FASB accounting standard changes mandate new skill/talents?Why are the new FASB lease accounting standards being delayed?Is the role of compliance is to build better systems to govern ourselves around risk management?Is the BLS definition of compliance professional still relevant or is it stuck in 1998?Why is there such a divergence in secondary markets in the hiring of compliance professionals?How would all this play out for compliance professionals in a recession?For additional reading see Matt’s blog post Scoping the Size of Compliance Workforce on Radical Compliance.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1497 no Compliance into the Weeds: Episode 135-CEOs Modeling Corporate Values Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly  and I go into the weeds to explore the actions by Delta CEO in not going to a meeting at the White House because of previously scheduled vacation plans. Is this modeling of corporate values useful to improve employee morale?   Some of the highlights include:Why did Delta CEO Ed Bastain ditch a White House meeting?Does a CEO cancelling a meeting to go on previously scheduled vacation model your corporate values?If a CEO will not attend a meeting what does that say about a company?Does the CEO’s help or hurt employee morale?How was Delta accountable in its ferrying of stranded 5thgraders to DC?How has Lowe’s damaged employee trust?For additional reading see Matt’s blog post Great Example of CEO Setting the Tone on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Aug 2019 04:00:00 -0000 CEOs Modeling Corporate Values full 135 Tom Fox In this episode, Matt Kelly and I explore the actions by Delta CEO in not going to a meeting at the White House because of previously scheduled vacation plans. Is this modeling of corporate values useful to improve employee morale? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly  and I go into the weeds to explore the actions by Delta CEO in not going to a meeting at the White House because of previously scheduled vacation plans. Is this modeling of corporate values useful to improve employee morale?   Some of the highlights include:Why did Delta CEO Ed Bastain ditch a White House meeting?Does a CEO cancelling a meeting to go on previously scheduled vacation model your corporate values?If a CEO will not attend a meeting what does that say about a company?Does the CEO’s help or hurt employee morale?How was Delta accountable in its ferrying of stranded 5thgraders to DC?How has Lowe’s damaged employee trust?For additional reading see Matt’s blog post Great Example of CEO Setting the Tone on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly  and I go into the weeds to explore the actions by Delta CEO in not going to a meeting at the White House because of previously scheduled vacation plans. Is this modeling of corporate values useful to improve employee morale?  

Some of the highlights include:Why did Delta CEO Ed Bastain ditch a White House meeting?Does a CEO cancelling a meeting to go on previously scheduled vacation model your corporate values?If a CEO will not attend a meeting what does that say about a company?Does the CEO’s help or hurt employee morale?How was Delta accountable in its ferrying of stranded 5thgraders to DC?How has Lowe’s damaged employee trust?For additional reading see Matt’s blog post Great Example of CEO Setting the Tone on Radical Compliance.

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]]> 1804 no Episode 134-Compliance Responses to El Paso and Dayton Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this most somber episode, Matt Kelly  and I go into the weeds to explore what are some of the compliance responses to the twin tragedies of El Paso and Dayton.   Some of the highlights include: Ø How the lack of safety at the workplace impacts employee trust.Ø How should a company monitor hate and racist speech by employees online? Ø What is your company policy around firearms at the workplace? What if your state allows it? Ø What actions should Walmart take for the safety of its employees and customers?Ø What red flags on employee hate speech are actionable? Ø What employee hate speech puts a company on actual knowledge of an impending or even possible attack?Ø What is a company’s liability in such a situation? Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 07 Aug 2019 04:00:00 -0000 Compliance Responses to El Paso and Dayton full 134 Tom Fox In this most somber episode, Matt Kelly and I go into the weeds to explore what are some of the compliance responses to the twin tragedies of El Paso and Dayton. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this most somber episode, Matt Kelly  and I go into the weeds to explore what are some of the compliance responses to the twin tragedies of El Paso and Dayton.   Some of the highlights include: Ø How the lack of safety at the workplace impacts employee trust.Ø How should a company monitor hate and racist speech by employees online? Ø What is your company policy around firearms at the workplace? What if your state allows it? Ø What actions should Walmart take for the safety of its employees and customers?Ø What red flags on employee hate speech are actionable? Ø What employee hate speech puts a company on actual knowledge of an impending or even possible attack?Ø What is a company’s liability in such a situation? Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this most somber episode, Matt Kelly  and I go into the weeds to explore what are some of the compliance responses to the twin tragedies of El Paso and Dayton.   Some of the highlights include: Ø How the lack of safety at the workplace impacts employee trust.Ø How should a company monitor hate and racist speech by employees online? Ø What is your company policy around firearms at the workplace? What if your state allows it? Ø What actions should Walmart take for the safety of its employees and customers?Ø What red flags on employee hate speech are actionable? Ø What employee hate speech puts a company on actual knowledge of an impending or even possible attack?Ø What is a company’s liability in such a situation?

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1721 no Compliance into the Weeds: Episode 133-Facebook Settlement Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore recent Facebook settlement with the SEC and the FTC. We also explore what the new DOJ antitrust investigation may portend going forward.   Some of the highlights include: This is now the second SEC settlement under this fact pattern.The SEC settlement was three times the amount of the Yahoo settlement.Did the FTC settle too low (or too high)?Is Facebook prevented from doing anything going forward?What is the impact if any on the stock price? Does the market even care?Is the DOJ antitrust investigation simply a politically motivated attack?Has the administration thought through the implications of its antitrust investigations?For further reading on Conn’s see Matt’s blog posts: Facebook, Power and Antitrust Issues  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 31 Jul 2019 04:05:00 -0000 Episode 133-Facebook Settlement full 133 Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and I take a deep dive into Facebook's settlements with the SEC and FTC plus a preview of the DOJ antitrust investigation. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore recent Facebook settlement with the SEC and the FTC. We also explore what the new DOJ antitrust investigation may portend going forward.   Some of the highlights include: This is now the second SEC settlement under this fact pattern.The SEC settlement was three times the amount of the Yahoo settlement.Did the FTC settle too low (or too high)?Is Facebook prevented from doing anything going forward?What is the impact if any on the stock price? Does the market even care?Is the DOJ antitrust investigation simply a politically motivated attack?Has the administration thought through the implications of its antitrust investigations?For further reading on Conn’s see Matt’s blog posts: Facebook, Power and Antitrust Issues  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore recent Facebook settlement with the SEC and the FTC. We also explore what the new DOJ antitrust investigation may portend going forward.  

Some of the highlights include:

This is now the second SEC settlement under this fact pattern.The SEC settlement was three times the amount of the Yahoo settlement.Did the FTC settle too low (or too high)?Is Facebook prevented from doing anything going forward?What is the impact if any on the stock price? Does the market even care?Is the DOJ antitrust investigation simply a politically motivated attack?Has the administration thought through the implications of its antitrust investigations?For further reading on Conn’s see Matt’s blog posts: Facebook, Power and Antitrust Issues 

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]]> 1550 no Compliance into the Weeds: Episode 132-Internal Control Palooza Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore recent SEC enforcement actions which Matt characterized as an “internal control Palooza”. We explore what went askance, how to learn from it and how to prevent it going forward.   Some of the highlights include: Ø The SEC recently had an “Internal Controls Palooza” of enforcement actions. Ø Microsoft demonstrated poor controls over third parties.Ø Why do does units need a ‘second set of eyes’ for non-standard discounts?Ø What is earnings management and why is it so risky? Ø Why do you need robust internal controls when engaging in earnings management? Ø Why must internal controls have an auditable trail? For further reading on Conn’s see Matt’s blog posts:Conn’s Lessons on Management EstimatesandMore on Embedding, Automating ControlsFor further reading on Microsoft see Matt’s blog post:FCPA Issues Nick Microsoft $25 MillionFinally see Tom’s blog postsPart 1-Microsoft FCPA Enforcement Actionand Part 2-the Bribery Schemes Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Jul 2019 04:05:00 -0000 Episode 132-Internal Control Palooza full 132 Tom Fox What is an Internal Control Palooza and what can you learn from it as a compliance professional? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore recent SEC enforcement actions which Matt characterized as an “internal control Palooza”. We explore what went askance, how to learn from it and how to prevent it going forward.   Some of the highlights include: Ø The SEC recently had an “Internal Controls Palooza” of enforcement actions. Ø Microsoft demonstrated poor controls over third parties.Ø Why do does units need a ‘second set of eyes’ for non-standard discounts?Ø What is earnings management and why is it so risky? Ø Why do you need robust internal controls when engaging in earnings management? Ø Why must internal controls have an auditable trail? For further reading on Conn’s see Matt’s blog posts:Conn’s Lessons on Management EstimatesandMore on Embedding, Automating ControlsFor further reading on Microsoft see Matt’s blog post:FCPA Issues Nick Microsoft $25 MillionFinally see Tom’s blog postsPart 1-Microsoft FCPA Enforcement Actionand Part 2-the Bribery Schemes Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore recent SEC enforcement actions which Matt characterized as an “internal control Palooza”. We explore what went askance, how to learn from it and how to prevent it going forward.   Some of the highlights include: Ø The SEC recently had an “Internal Controls Palooza” of enforcement actions. Ø Microsoft demonstrated poor controls over third parties.Ø Why do does units need a ‘second set of eyes’ for non-standard discounts?Ø What is earnings management and why is it so risky? Ø Why do you need robust internal controls when engaging in earnings management? Ø Why must internal controls have an auditable trail? For further reading on Conn’s see Matt’s blog posts:Conn’s Lessons on Management EstimatesandMore on Embedding, Automating ControlsFor further reading on Microsoft see Matt’s blog post:FCPA Issues Nick Microsoft $25 MillionFinally see Tom’s blog postsPart 1-Microsoft FCPA Enforcement Actionand Part 2-the Bribery Schemes

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]]> 1666 no Compliance into the Weeds: Episode 131-Compliance Training Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore Matt’s observations on compliance training. While traveling cross-country with the family for a well-earned vacation he paid close attention to the safety training video. We used that as a starting point for a deep dive into compliance training and communications.     Some of the highlights include: What are some fresh takes on compliance training?How do you implement both effective and tailored training?Is your training procedural? Ethical? Systemic?Do you want your employees to follow procedures or standards of behavior?Employees need to feel like there is someone listening.What is the role of ongoing communications in training?For further reading see Matt’s blog post-How Good Training Finds its Wings Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Jul 2019 04:00:00 -0000 Episode 131-Compliance Training full 131 Tom Fox How can your compliance training take wings of effectiveness? Matt Kelly and Tom Fox explore on this episode of Compliance into the Weeds. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore Matt’s observations on compliance training. While traveling cross-country with the family for a well-earned vacation he paid close attention to the safety training video. We used that as a starting point for a deep dive into compliance training and communications.     Some of the highlights include: What are some fresh takes on compliance training?How do you implement both effective and tailored training?Is your training procedural? Ethical? Systemic?Do you want your employees to follow procedures or standards of behavior?Employees need to feel like there is someone listening.What is the role of ongoing communications in training?For further reading see Matt’s blog post-How Good Training Finds its Wings Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore Matt’s observations on compliance training. While traveling cross-country with the family for a well-earned vacation he paid close attention to the safety training video. We used that as a starting point for a deep dive into compliance training and communications.    

Some of the highlights include:

What are some fresh takes on compliance training?How do you implement both effective and tailored training?Is your training procedural? Ethical? Systemic?Do you want your employees to follow procedures or standards of behavior?Employees need to feel like there is someone listening.What is the role of ongoing communications in training?For further reading see Matt’s blog post-How Good Training Finds its Wings

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1413 no Compliance into the Weeds: Episode 130- Corrosive Subcultures Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into employees of the U.S. Customs and Border Protection who operated a closed Facebook group, replete with racist, sexist posts about migrants and Democratic politicians. For corporate compliance and governance professionals who think about the challenges of building a strong corporate culture, the mess at CBP offers a cautionary tale about the corrosive nature of subcultures.    Some of the highlights include: Ø Why are subcultures so corrosive?Ø What is Metcalfe’s Law and how does it apply here?Ø What is corporate culture v. subcultures?Ø How does an organization fight the growth of subcultures?Ø What is the role of the CCO?Ø Is all this simply protected speech? For additional reading see Matt’s blog post What CBP Tells Us About Subcultures Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Jul 2019 04:00:00 -0000 Episode 130- Corrosive Subcultures full 130 Tom Fox In this episode of Compliance into the Weeds, Matt Kelly and I take a deep dive into the corrosive nature of subcultures. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into employees of the U.S. Customs and Border Protection who operated a closed Facebook group, replete with racist, sexist posts about migrants and Democratic politicians. For corporate compliance and governance professionals who think about the challenges of building a strong corporate culture, the mess at CBP offers a cautionary tale about the corrosive nature of subcultures.    Some of the highlights include: Ø Why are subcultures so corrosive?Ø What is Metcalfe’s Law and how does it apply here?Ø What is corporate culture v. subcultures?Ø How does an organization fight the growth of subcultures?Ø What is the role of the CCO?Ø Is all this simply protected speech? For additional reading see Matt’s blog post What CBP Tells Us About Subcultures Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into employees of the U.S. Customs and Border Protection who operated a closed Facebook group, replete with racist, sexist posts about migrants and Democratic politicians. For corporate compliance and governance professionals who think about the challenges of building a strong corporate culture, the mess at CBP offers a cautionary tale about the corrosive nature of subcultures.    Some of the highlights include: Ø Why are subcultures so corrosive?Ø What is Metcalfe’s Law and how does it apply here?Ø What is corporate culture v. subcultures?Ø How does an organization fight the growth of subcultures?Ø What is the role of the CCO?Ø Is all this simply protected speech? For additional reading see Matt’s blog post What CBP Tells Us About Subcultures

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1290 no Compliance into the Weeds: Episode 129-Open Secrets Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore Matt’s recent interview of Theranos whistleblower Tyler Schultz. We use this as a starting point to discuss what a company can do when everyone knows that fraud is going on but no one says anything about it.    Some of the highlights include: Tyler Schultz tells his story.What was the conversation inside Theranos?Was it an open secret the company was engaged in fraud?Why do employees take baby steps to whistleblowing?Employees need to feel like there is someone listening.Are there any alternative areas of power in a company, such as the Board of Directors?For further reading see Matt’s blog post-What Drives Open Secrets Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Jul 2019 04:00:00 -0000 Episode 129-Open Secrets full 129 Tom Fox IN this episode Matt Kelly and I use the experience of Tyler Schultz as a whistleblower at Theranos to explore the concept of open secrets in an organization. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore Matt’s recent interview of Theranos whistleblower Tyler Schultz. We use this as a starting point to discuss what a company can do when everyone knows that fraud is going on but no one says anything about it.    Some of the highlights include: Tyler Schultz tells his story.What was the conversation inside Theranos?Was it an open secret the company was engaged in fraud?Why do employees take baby steps to whistleblowing?Employees need to feel like there is someone listening.Are there any alternative areas of power in a company, such as the Board of Directors?For further reading see Matt’s blog post-What Drives Open Secrets Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore Matt’s recent interview of Theranos whistleblower Tyler Schultz. We use this as a starting point to discuss what a company can do when everyone knows that fraud is going on but no one says anything about it.  

 Some of the highlights include:

Tyler Schultz tells his story.What was the conversation inside Theranos?Was it an open secret the company was engaged in fraud?Why do employees take baby steps to whistleblowing?Employees need to feel like there is someone listening.Are there any alternative areas of power in a company, such as the Board of Directors?For further reading see Matt’s blog post-What Drives Open Secrets

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]]> 1278 no Compliance into the Weeds: Bonus Episode-Reflections on KPMG with Francine McKenna Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take things in a different direction as we welcome Francine McKenna, reporter at MarketWatch. And blogger extraordinaire at Re: The Auditors. After one full week of writing, thinking and talking about the SEC enforcement action against KPMG, we provide our initial reflections.    For additional reading,  check out the following resources: You should start with McKenna’s great piece on the scandal in MarketWatch, “The KPMG cheating scandal was much more widespread than originally thought” Matt’s blog post-Questions on the KPMG Ethics Fiasco Tom’s blog post-Day of Reckoning for KPMG-Failures in Ethics Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Jun 2019 04:02:00 -0000 Reflections on KPMG with Francine McKenna bonus Tom Fox In tis episode, Matt Kelly and I are joined by MarketWatch's Francine McKenna to reflect upon the first week's news and fallout from the SEC enforcement Order involving KPMG. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take things in a different direction as we welcome Francine McKenna, reporter at MarketWatch. And blogger extraordinaire at Re: The Auditors. After one full week of writing, thinking and talking about the SEC enforcement action against KPMG, we provide our initial reflections.    For additional reading,  check out the following resources: You should start with McKenna’s great piece on the scandal in MarketWatch, “The KPMG cheating scandal was much more widespread than originally thought” Matt’s blog post-Questions on the KPMG Ethics Fiasco Tom’s blog post-Day of Reckoning for KPMG-Failures in Ethics Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take things in a different direction as we welcome Francine McKenna, reporter at MarketWatch. And blogger extraordinaire at Re: The Auditors. After one full week of writing, thinking and talking about the SEC enforcement action against KPMG, we provide our initial reflections.   

For additional reading,  check out the following resources:

You should start with McKenna’s great piece on the scandal in MarketWatch, “The KPMG cheating scandal was much more widespread than originally thought”

Matt’s blog post-Questions on the KPMG Ethics Fiasco

Tom’s blog post-Day of Reckoning for KPMG-Failures in Ethics

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 2654 no Compliance into the Weeds: Episode 128- KPMG Scandal Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into SEC enforcement action announced against KPMG this week.    Some of the highlights include: Which part of the scandal is worse-bribery/corruption or falsifying standards?Can KPMG be trusted going forward?What led to the Board investigation of the educational scandal?Is this the end of KPMG? The Big Four?How could the firm create a culture so antithetical to integrity?Where does KPMG go from here?Who is qualified to be the Monitor?Will there be an additional SEC enforcement action?For additional reading see Tom’s blog post Day of Reckoning for KPMG-Failures in Ethics Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Jun 2019 04:00:00 -0000 Episode 128- KPMG Scandal full 128 Tom Fox In this episode, Matt Kelly and I take a deep dive into he SEC enforcement action against KPMG and the surrounding ethics scandal the firms finds itself embroiled in. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into SEC enforcement action announced against KPMG this week.    Some of the highlights include: Which part of the scandal is worse-bribery/corruption or falsifying standards?Can KPMG be trusted going forward?What led to the Board investigation of the educational scandal?Is this the end of KPMG? The Big Four?How could the firm create a culture so antithetical to integrity?Where does KPMG go from here?Who is qualified to be the Monitor?Will there be an additional SEC enforcement action?For additional reading see Tom’s blog post Day of Reckoning for KPMG-Failures in Ethics Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into SEC enforcement action announced against KPMG this week.   

Some of the highlights include:

Which part of the scandal is worse-bribery/corruption or falsifying standards?Can KPMG be trusted going forward?What led to the Board investigation of the educational scandal?Is this the end of KPMG? The Big Four?How could the firm create a culture so antithetical to integrity?Where does KPMG go from here?Who is qualified to be the Monitor?Will there be an additional SEC enforcement action?For additional reading see Tom’s blog post Day of Reckoning for KPMG-Failures in Ethics

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1584 no Compliance into the Weeds: Episode 127- Robotic Process Automation Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into Robotic Process Automation.    Some of the highlights include:What is robotic process automation (RPA)?How does it differ from AI?How could a compliance professional use RPA?Why is does it pose unique risks to a corporate compliance function?For additional reading see Matt’s blog post Thoughts on RPA, Compliance and You Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Jun 2019 04:00:00 -0000 Episode 127- Robotic Process Automation full 127 Tom Fox In this episode Matt Kelly and I take a deep dive into the weeds on robotic process automation in a special on location recording. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into Robotic Process Automation.    Some of the highlights include:What is robotic process automation (RPA)?How does it differ from AI?How could a compliance professional use RPA?Why is does it pose unique risks to a corporate compliance function?For additional reading see Matt’s blog post Thoughts on RPA, Compliance and You Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into Robotic Process Automation.   

Some of the highlights include:What is robotic process automation (RPA)?How does it differ from AI?How could a compliance professional use RPA?Why is does it pose unique risks to a corporate compliance function?For additional reading see Matt’s blog post Thoughts on RPA, Compliance and You

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1288 no Compliance into the Weeds: Episode 126-Compliance and Complexity Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore how the complexity of modern-day corporations can lead to catastrophic failures such as the two crashes of the Boeing 737 Max.  Some of the highlights include: Ø Our podcast today was based upon two blog posts we both wrote this week based upon the NYT article The Late Change, and Fatal Flaws in Boeing’s Plane. Ø Why and how can complexity lead to catastrophic failre?Ø The modern corporation is very siloed. How does this contribute to risk?Ø Why every compliance professional should read the NYT article.Ø How should you think about systemic risk in your organization’s ecosystem?Ø How does the COSO 2013 Internal Controls Framework consider the issue of communication across an organization? In addition to the great NYT piece check out the following resources: Matt’s blog post-Another Lesson from Boeing-SilosTom’s blog post-Boeing and More Compliance Lessons Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Jun 2019 04:02:00 -0000 Episode 126-Compliance and Complexity full 126 Tom Fox In this episode, Matt Kelly and I take a deep dive into corporate complexity which caused or contributed to the Boeing 737 Max disaster. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore how the complexity of modern-day corporations can lead to catastrophic failures such as the two crashes of the Boeing 737 Max.  Some of the highlights include: Ø Our podcast today was based upon two blog posts we both wrote this week based upon the NYT article The Late Change, and Fatal Flaws in Boeing’s Plane. Ø Why and how can complexity lead to catastrophic failre?Ø The modern corporation is very siloed. How does this contribute to risk?Ø Why every compliance professional should read the NYT article.Ø How should you think about systemic risk in your organization’s ecosystem?Ø How does the COSO 2013 Internal Controls Framework consider the issue of communication across an organization? In addition to the great NYT piece check out the following resources: Matt’s blog post-Another Lesson from Boeing-SilosTom’s blog post-Boeing and More Compliance Lessons Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore how the complexity of modern-day corporations can lead to catastrophic failures such as the two crashes of the Boeing 737 Max.  Some of the highlights include: Ø Our podcast today was based upon two blog posts we both wrote this week based upon the NYT article The Late Change, and Fatal Flaws in Boeing’s Plane. Ø Why and how can complexity lead to catastrophic failre?Ø The modern corporation is very siloed. How does this contribute to risk?Ø Why every compliance professional should read the NYT article.Ø How should you think about systemic risk in your organization’s ecosystem?Ø How does the COSO 2013 Internal Controls Framework consider the issue of communication across an organization? In addition to the great NYT piece check out the following resources: Matt’s blog post-Another Lesson from Boeing-SilosTom’s blog post-Boeing and More Compliance Lessons

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]]> 1326 no Compliance into the Weeds: Episode 125-It’s Just Paper Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore what exactly is sub-regulatory guidance and why the debate around it by the current administration is seemingly against not only the government’s interest but also business’ interest. Be sure and listen all the way through as Matt goes on a rant at the end of the podcast.  Some of the highlights include: Ø What were the remarks of Claire Murray that got Matt so riled up?Ø Is the Evaluation of Corporate Compliance Programs, 2019 Guidance just paper?Ø What would happen to a company which does not use the 2019 Guidance as a roadmap?Ø Why business’ support sub-regulatory guidance?Ø Why documentation is critical for multiple parts of a compliance program?Ø What do Murray’s remarks mean for the compliance practitioner? For the full text of the remarks of Principal Deputy Associate Attorney General Claire Murray at the Compliance Week 2019 Annual Conference, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 29 May 2019 04:00:00 -0000 Episode 125-It’s Just Paper full 125 Tom Fox In this episode, Matt Kelly and I take a deep dive into remarks made by Claire Murray at a Compliance Week 2019 Keynote and ask, is the recently released DOJ Evaluation of Corporate Compliance Programs, 2019 Guidance just paper or is it real? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore what exactly is sub-regulatory guidance and why the debate around it by the current administration is seemingly against not only the government’s interest but also business’ interest. Be sure and listen all the way through as Matt goes on a rant at the end of the podcast.  Some of the highlights include: Ø What were the remarks of Claire Murray that got Matt so riled up?Ø Is the Evaluation of Corporate Compliance Programs, 2019 Guidance just paper?Ø What would happen to a company which does not use the 2019 Guidance as a roadmap?Ø Why business’ support sub-regulatory guidance?Ø Why documentation is critical for multiple parts of a compliance program?Ø What do Murray’s remarks mean for the compliance practitioner? For the full text of the remarks of Principal Deputy Associate Attorney General Claire Murray at the Compliance Week 2019 Annual Conference, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore what exactly is sub-regulatory guidance and why the debate around it by the current administration is seemingly against not only the government’s interest but also business’ interest. Be sure and listen all the way through as Matt goes on a rant at the end of the podcast.  Some of the highlights include: Ø What were the remarks of Claire Murray that got Matt so riled up?Ø Is the Evaluation of Corporate Compliance Programs, 2019 Guidance just paper?Ø What would happen to a company which does not use the 2019 Guidance as a roadmap?Ø Why business’ support sub-regulatory guidance?Ø Why documentation is critical for multiple parts of a compliance program?Ø What do Murray’s remarks mean for the compliance practitioner? For the full text of the remarks of Principal Deputy Associate Attorney General Claire Murray at the Compliance Week 2019 Annual Conference, click here.

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]]> 1370 no Compliance into the Weeds: Episode 124-Food Fight This is a special Friday edition of Compliance into the Weeds, the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I channel our inner Bluto and Flounder to consider a recent imbroglio around food in a cafeteria led to some powerful compliance lessons. Some of the highlights include: What are the ethical values of your organization?Why a company must give employees on the ground the flexibility to over-ride rules when ethics demands it?If you fire someone publicly, you need to list the true reasons?How does a company empower its employees?Why documentation is critical for multiple parts of a compliance program?Why an efficient and accurate investigations must be done before termination?How an ethical misstep can significantly harm any sized organization.For more reading check out Matt’s two blog post  on this topic “When Ethics and Policy Collide” and “More Lessons from the Lunch Lady” Learn more about your ad choices. Visit megaphone.fm/adchoices Fri, 24 May 2019 04:00:00 -0000 Episode 124-Food Fight full 124 Tom Fox In this episode, Matt Kelly and I channel our inner Bluto and Flounder to consider a recent imbroglio around food fight in a cafeteria led to some powerful compliance lessons. This is a special Friday edition of Compliance into the Weeds, the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I channel our inner Bluto and Flounder to consider a recent imbroglio around food in a cafeteria led to some powerful compliance lessons. Some of the highlights include: What are the ethical values of your organization?Why a company must give employees on the ground the flexibility to over-ride rules when ethics demands it?If you fire someone publicly, you need to list the true reasons?How does a company empower its employees?Why documentation is critical for multiple parts of a compliance program?Why an efficient and accurate investigations must be done before termination?How an ethical misstep can significantly harm any sized organization.For more reading check out Matt’s two blog post  on this topic “When Ethics and Policy Collide” and “More Lessons from the Lunch Lady” Learn more about your ad choices. Visit megaphone.fm/adchoices This is a special Friday edition of Compliance into the Weeds, the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I channel our inner Bluto and Flounder to consider a recent imbroglio around food in a cafeteria led to some powerful compliance lessons.

Some of the highlights include:

What are the ethical values of your organization?Why a company must give employees on the ground the flexibility to over-ride rules when ethics demands it?If you fire someone publicly, you need to list the true reasons?How does a company empower its employees?Why documentation is critical for multiple parts of a compliance program?Why an efficient and accurate investigations must be done before termination?How an ethical misstep can significantly harm any sized organization.For more reading check out Matt’s two blog post  on this topic “When Ethics and Policy Collide” and “More Lessons from the Lunch Lady”

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]]> 1422 no Compliance into the Weeds: Episode 123-Whistleblower Protection Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the House Financial Services bill, HR 2515, which amends the Dodd-Frank Act to clarify that whistleblowers who report misconduct to their employers and not to the SEC also have protections against retaliation under the law. This bill fixes the US Supreme Court decision in Digital Realty Trust which mandated that whistleblowers had to go to the SEC to obtain Dodd-Frank anti-retaliation protection. Some of the highlights include: Some of the highlights include: Ø What was the ruling in Digital Realty Trust?Ø Why did it negatively impact whistleblowers, companies and the SEC?Ø What has made whistleblowers and internal reporting so significant?Ø How does the proposed fix benefit whistleblowers, companies and the SEC?Ø Why should businesses get behind this proposed fix?Ø What are the chances it actually is signed into law? For more reading check out Matt’s blog post “Progress on Whistleblower Fix”  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 May 2019 04:05:00 -0000 Episode 123-Whistleblower Protection full 123 Tom Fox In this episode, Matt and I take a deep dive into the House Financial Services bill, HR 2515, which amends the Dodd-Frank Act to clarify that whistleblowers who report misconduct to their employers and not to the SEC also have protections against retaliation under the law. Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the House Financial Services bill, HR 2515, which amends the Dodd-Frank Act to clarify that whistleblowers who report misconduct to their employers and not to the SEC also have protections against retaliation under the law. This bill fixes the US Supreme Court decision in Digital Realty Trust which mandated that whistleblowers had to go to the SEC to obtain Dodd-Frank anti-retaliation protection. Some of the highlights include: Some of the highlights include: Ø What was the ruling in Digital Realty Trust?Ø Why did it negatively impact whistleblowers, companies and the SEC?Ø What has made whistleblowers and internal reporting so significant?Ø How does the proposed fix benefit whistleblowers, companies and the SEC?Ø Why should businesses get behind this proposed fix?Ø What are the chances it actually is signed into law? For more reading check out Matt’s blog post “Progress on Whistleblower Fix”  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the House Financial Services bill, HR 2515, which amends the Dodd-Frank Act to clarify that whistleblowers who report misconduct to their employers and not to the SEC also have protections against retaliation under the law. This bill fixes the US Supreme Court decision in Digital Realty Trust which mandated that whistleblowers had to go to the SEC to obtain Dodd-Frank anti-retaliation protection. Some of the highlights include: Some of the highlights include: Ø What was the ruling in Digital Realty Trust?Ø Why did it negatively impact whistleblowers, companies and the SEC?Ø What has made whistleblowers and internal reporting so significant?Ø How does the proposed fix benefit whistleblowers, companies and the SEC?Ø Why should businesses get behind this proposed fix?Ø What are the chances it actually is signed into law? For more reading check out Matt’s blog post “Progress on Whistleblower Fix” 

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]]> 1605 no Compliance into the Weeds: Episode 121-The Role of the CRO in ERM Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive intothe role of the Chief Risk Officer in overall Enterprise Risk Management. Some of the highlights include: Some of the highlights include: Ø Why  is effective ERM is more than simply operationalization of ethics and compliance?Ø Why the Board and senior management must take a holistic approach to ERM? Ø Why is it even more important for Boards and senior management to have better risk governance?Ø How do you define the role of Chief Risk Officer?Ø What is the role of internal audit in today’s analytical world of risk management?Ø Could or even should the role of the Chief Audit Officer evolve into the role of a Chief Risk Officer? For more reading check out Matt’s blog post “The Chief Risk Officer Role”. Also listen to the Radical Compliance podcast here. Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 30 Apr 2019 23:26:46 -0000 Compliance into the Weeds: Episode 121-The Role of the CRO in ERM full 121 Tom Fox Compliance into the Weeds: Episode 121-The Role of the CRO in ERM Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive intothe role of the Chief Risk Officer in overall Enterprise Risk Management. Some of the highlights include: Some of the highlights include: Ø Why  is effective ERM is more than simply operationalization of ethics and compliance?Ø Why the Board and senior management must take a holistic approach to ERM? Ø Why is it even more important for Boards and senior management to have better risk governance?Ø How do you define the role of Chief Risk Officer?Ø What is the role of internal audit in today’s analytical world of risk management?Ø Could or even should the role of the Chief Audit Officer evolve into the role of a Chief Risk Officer? For more reading check out Matt’s blog post “The Chief Risk Officer Role”. Also listen to the Radical Compliance podcast here. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive intothe role of the Chief Risk Officer in overall Enterprise Risk Management. Some of the highlights include: Some of the highlights include: Ø Why  is effective ERM is more than simply operationalization of ethics and compliance?Ø Why the Board and senior management must take a holistic approach to ERM? Ø Why is it even more important for Boards and senior management to have better risk governance?Ø How do you define the role of Chief Risk Officer?Ø What is the role of internal audit in today’s analytical world of risk management?Ø Could or even should the role of the Chief Audit Officer evolve into the role of a Chief Risk Officer? For more reading check out Matt’s blog post “The Chief Risk Officer Role”. Also listen to the Radical Compliance podcast here.

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]]> 1605 no Compliance into the Weeds: Episode 120-On the Ethical Tarmac Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into continued ethical, reputational and business imbroglio which Boeing finds itself in around the 737 MAX airliner, as the company finds itself on the ethical tarmac.  Some of the highlights include:Where does compliance come into a sales strategy?Who is responsible for entailing safety - the buyer or seller?What does it mean from the compliance perspective is a safety upgrade is optional?How does regulatory capture affect overseas sales?What is the legal analysis around safety and options for safety upgrade on products?Who should regulate the supply side-the government or the market?For more reading check out Matt’s blog post “More on Boeing and Business Ethics” Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Apr 2019 05:03:00 -0000 Compliance into the Weeds: Episode 120-On the Ethical Tarmac full 120 Tom Fox Compliance into the Weeds: Episode 120-On the Ethical Tarmac Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into continued ethical, reputational and business imbroglio which Boeing finds itself in around the 737 MAX airliner, as the company finds itself on the ethical tarmac.  Some of the highlights include:Where does compliance come into a sales strategy?Who is responsible for entailing safety - the buyer or seller?What does it mean from the compliance perspective is a safety upgrade is optional?How does regulatory capture affect overseas sales?What is the legal analysis around safety and options for safety upgrade on products?Who should regulate the supply side-the government or the market?For more reading check out Matt’s blog post “More on Boeing and Business Ethics” Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into continued ethical, reputational and business imbroglio which Boeing finds itself in around the 737 MAX airliner, as the company finds itself on the ethical tarmac. 

Some of the highlights include:Where does compliance come into a sales strategy?Who is responsible for entailing safety - the buyer or seller?What does it mean from the compliance perspective is a safety upgrade is optional?How does regulatory capture affect overseas sales?What is the legal analysis around safety and options for safety upgrade on products?Who should regulate the supply side-the government or the market?For more reading check out Matt’s blog post “More on Boeing and Business Ethics”

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]]> 1605 no Compliance into the Weeds: Episode 119-Rule Making Power Grab Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recently announced policy by the Trump White House that all regulatory rules and guidance must be submitted to the White House for review before it goes through Congressional review. Some of the highlights include: Some of the highlights include: Ø This is a significant power grab by the White House.Ø What is OIRA and can the White House force all new regs and guidance go through it before Congress considers them? Ø Will regulatory guidance be treated as regulations? What about SEC No-Action Letters? DOJ declinations?. Ø Will regulatory reduction continue under this new policy?Ø This is an example of how political instability negatively impacts businesses.Ø What does this mean for the Democratic nominee to the SEC? For more reading check out Matt’s blog post “Trump Grabs at Rulemaking" Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Apr 2019 05:00:00 -0000 Compliance into the Weeds: Episode 119-Rule Making Power Grab full 119 Tom Fox Compliance into the Weeds: Episode 119-Rule Making Power Grab Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recently announced policy by the Trump White House that all regulatory rules and guidance must be submitted to the White House for review before it goes through Congressional review. Some of the highlights include: Some of the highlights include: Ø This is a significant power grab by the White House.Ø What is OIRA and can the White House force all new regs and guidance go through it before Congress considers them? Ø Will regulatory guidance be treated as regulations? What about SEC No-Action Letters? DOJ declinations?. Ø Will regulatory reduction continue under this new policy?Ø This is an example of how political instability negatively impacts businesses.Ø What does this mean for the Democratic nominee to the SEC? For more reading check out Matt’s blog post “Trump Grabs at Rulemaking" Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recently announced policy by the Trump White House that all regulatory rules and guidance must be submitted to the White House for review before it goes through Congressional review. Some of the highlights include: Some of the highlights include: Ø This is a significant power grab by the White House.Ø What is OIRA and can the White House force all new regs and guidance go through it before Congress considers them? Ø Will regulatory guidance be treated as regulations? What about SEC No-Action Letters? DOJ declinations?. Ø Will regulatory reduction continue under this new policy?Ø This is an example of how political instability negatively impacts businesses.Ø What does this mean for the Democratic nominee to the SEC? For more reading check out Matt’s blog post “Trump Grabs at Rulemaking"

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]]> 1605 no Compliance into the Weeds: Episode 118-Hotline Metrics Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recently released NAVEX Global 2019 Ethics & Compliance Hotline Benchmark Report. We consider the details from the report and ask the following question “are you using all the right intake channels to capture a true sense of misconduct and corporate culture at your organization?” Some of the highlights include: Some of the highlights include: Ø What are the intake channels available to your organization?Ø If you are only tracking complaints through a formal system, you may well be missing a wider variety and rich source of information. Ø Moving your intake past simply what the law requires will give you a much better accounting of your organization’s culture.Ø How can you improve your intake?Ø Has closure time for reported increase or decrease?Ø What has been the continued impact of #MeToo? For more reading check out Matt’s blog post “Hotline Metrics-are you missing any?”To read the full NAVEX Global 2019 Ethics & Compliance Hotline Benchmark Report, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 11 Apr 2019 05:00:00 -0000 Compliance into the Weeds: Episode 118-Hotline Metrics full 118 Tom Fox Compliance into the Weeds: Episode 118-Hotline Metrics Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recently released NAVEX Global 2019 Ethics & Compliance Hotline Benchmark Report. We consider the details from the report and ask the following question “are you using all the right intake channels to capture a true sense of misconduct and corporate culture at your organization?” Some of the highlights include: Some of the highlights include: Ø What are the intake channels available to your organization?Ø If you are only tracking complaints through a formal system, you may well be missing a wider variety and rich source of information. Ø Moving your intake past simply what the law requires will give you a much better accounting of your organization’s culture.Ø How can you improve your intake?Ø Has closure time for reported increase or decrease?Ø What has been the continued impact of #MeToo? For more reading check out Matt’s blog post “Hotline Metrics-are you missing any?”To read the full NAVEX Global 2019 Ethics & Compliance Hotline Benchmark Report, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recently released NAVEX Global 2019 Ethics & Compliance Hotline Benchmark Report. We consider the details from the report and ask the following question “are you using all the right intake channels to capture a true sense of misconduct and corporate culture at your organization?” Some of the highlights include: Some of the highlights include: Ø What are the intake channels available to your organization?Ø If you are only tracking complaints through a formal system, you may well be missing a wider variety and rich source of information. Ø Moving your intake past simply what the law requires will give you a much better accounting of your organization’s culture.Ø How can you improve your intake?Ø Has closure time for reported increase or decrease?Ø What has been the continued impact of #MeToo? For more reading check out Matt’s blog post “Hotline Metrics-are you missing any?”To read the full NAVEX Global 2019 Ethics & Compliance Hotline Benchmark Report, click here.

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]]> 1342 no Compliance into the Weeds: Episode 117-Wells Fargo Update Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into resignation of now former Wells Fargo CEO Tim Sloan. We use his departure as a starting point to discuss some of the issues which continue to bedevil the organization some three years after the original fraudulent accounts scandal broke. Some of the highlights include: Ø Another tough Congressional hearing, another Wells Fargo CEO resigns. Ø Why can’t Wells Fargo turn around its culture?Ø Should an outsider (IE., non-long term Wells Fargo employee be brought in to right the ship?Ø What is the difference in high-performing and high-pressure organizations?Ø Why does Wells Fargo continue to resist whistleblower retaliation claims?Ø Does Wells Fargo treat its customers as it treats its employees?Ø What draconian sanctions are the OCC and Fed considering?Ø What can Wells Fargo do to actually change its culture? If you are in Houston on Friday, please plan to attend the South Texas College of Law 2019 Symposium on Compliance in international Corporate Legal Practices – Legal Development and the Talent Needs of the Future. Information and registration details available here. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Apr 2019 11:03:05 -0000 Compliance into the Weeds: Episode 117-Wells Fargo Update full 117 Tom Fox Episode 117-Wells Fargo Update Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into resignation of now former Wells Fargo CEO Tim Sloan. We use his departure as a starting point to discuss some of the issues which continue to bedevil the organization some three years after the original fraudulent accounts scandal broke. Some of the highlights include: Ø Another tough Congressional hearing, another Wells Fargo CEO resigns. Ø Why can’t Wells Fargo turn around its culture?Ø Should an outsider (IE., non-long term Wells Fargo employee be brought in to right the ship?Ø What is the difference in high-performing and high-pressure organizations?Ø Why does Wells Fargo continue to resist whistleblower retaliation claims?Ø Does Wells Fargo treat its customers as it treats its employees?Ø What draconian sanctions are the OCC and Fed considering?Ø What can Wells Fargo do to actually change its culture? If you are in Houston on Friday, please plan to attend the South Texas College of Law 2019 Symposium on Compliance in international Corporate Legal Practices – Legal Development and the Talent Needs of the Future. Information and registration details available here. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into resignation of now former Wells Fargo CEO Tim Sloan. We use his departure as a starting point to discuss some of the issues which continue to bedevil the organization some three years after the original fraudulent accounts scandal broke. Some of the highlights include: Ø Another tough Congressional hearing, another Wells Fargo CEO resigns. Ø Why can’t Wells Fargo turn around its culture?Ø Should an outsider (IE., non-long term Wells Fargo employee be brought in to right the ship?Ø What is the difference in high-performing and high-pressure organizations?Ø Why does Wells Fargo continue to resist whistleblower retaliation claims?Ø Does Wells Fargo treat its customers as it treats its employees?Ø What draconian sanctions are the OCC and Fed considering?Ø What can Wells Fargo do to actually change its culture? If you are in Houston on Friday, please plan to attend the South Texas College of Law 2019 Symposium on Compliance in international Corporate Legal Practices – Legal Development and the Talent Needs of the Future. Information and registration details available here.

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]]> 1342 no Compliance into the Weeds: Episode 116-Brexit Risks Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 Mar 2019 05:00:00 -0000 Compliance into the Weeds: Episode 116-Brexit Risks full 116 Tom Fox Compliance into the Weeds: Episode 116-Brexit Risks Learn more about your ad choices. Visit megaphone.fm/adchoices

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]]> 1238 no Compliance into the Weeds: Episode 115-Regulatory Capture and Regulatory Approval at the FAA Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the circumstances around the FAA approval process regarding the Boeing 737 MAX in the context of the crash in Ethiopia. Some of the highlights include: Ø What was the process by which the plane was approved by the FAA?Ø How did the Boeing CEO persuade President Trump to prevent the FAA from grounding the Boeing fleet during the investigation process?Ø Why did the Ethiopian government send the plane’s black box to France, rather than the US, for analysis?Ø How did the US lose the world’s leadership in aviation safety?Ø Where was Boeing’s compliance function during all of this?Ø What are the lessons for the compliance practitioner? For additional reading, see articles discussed in this podcast: 1.    In the Seattle Times, Flawed analysis, failed oversight: How Boeing, FAA certified the suspect 737 MAX flight control system, by Dominick Gates2.    In the Wall Street Journal, Prosecutors, Transportation Department Scrutinize Development of Boeing’s 737 MAXby Andrew Tangel, Andy Pasztor and Robert Wall3.     In Slate.com, Where Did Boeing Go Wrong?  by Jeff Wise. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Mar 2019 10:38:46 -0000 Compliance into the Weeds: Episode 115-Regulatory Capture and Regulatory Approval at the FAA full 115 Tom Fox Compliance into the Weeds: Episode 115-Regulatory Capture and Regulatory Approval at the FAA Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the circumstances around the FAA approval process regarding the Boeing 737 MAX in the context of the crash in Ethiopia. Some of the highlights include: Ø What was the process by which the plane was approved by the FAA?Ø How did the Boeing CEO persuade President Trump to prevent the FAA from grounding the Boeing fleet during the investigation process?Ø Why did the Ethiopian government send the plane’s black box to France, rather than the US, for analysis?Ø How did the US lose the world’s leadership in aviation safety?Ø Where was Boeing’s compliance function during all of this?Ø What are the lessons for the compliance practitioner? For additional reading, see articles discussed in this podcast: 1.    In the Seattle Times, Flawed analysis, failed oversight: How Boeing, FAA certified the suspect 737 MAX flight control system, by Dominick Gates2.    In the Wall Street Journal, Prosecutors, Transportation Department Scrutinize Development of Boeing’s 737 MAXby Andrew Tangel, Andy Pasztor and Robert Wall3.     In Slate.com, Where Did Boeing Go Wrong?  by Jeff Wise. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the circumstances around the FAA approval process regarding the Boeing 737 MAX in the context of the crash in Ethiopia. Some of the highlights include: Ø What was the process by which the plane was approved by the FAA?Ø How did the Boeing CEO persuade President Trump to prevent the FAA from grounding the Boeing fleet during the investigation process?Ø Why did the Ethiopian government send the plane’s black box to France, rather than the US, for analysis?Ø How did the US lose the world’s leadership in aviation safety?Ø Where was Boeing’s compliance function during all of this?Ø What are the lessons for the compliance practitioner? For additional reading, see articles discussed in this podcast: 1.    In the Seattle Times, Flawed analysis, failed oversight: How Boeing, FAA certified the suspect 737 MAX flight control system, by Dominick Gates2.    In the Wall Street Journal, Prosecutors, Transportation Department Scrutinize Development of Boeing’s 737 MAXby Andrew Tangel, Andy Pasztor and Robert Wall3.     In Slate.com, Where Did Boeing Go Wrong?  by Jeff Wise.

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]]> 1627 Compliance into the Weeds: Episode 114-Lessons on Internal Control Overrides Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent Bankrate DOJ enforcement action in which the company garnered a NPA and for which it paid a total penalty of $28.5 million. We feature a discussion of internal control overrides. Some of the highlights include: Ø What are the background facts of the matter?Ø Why should you never name a slush fund “Ed’s Cushion?Ø What is the difference between management over-ride of internal controls and abuse of management control override?Ø Why is robust accounting required when there is a single source of data?Ø What is the straight line from internal controls and accounting to the Board and the audit committee?Ø Where was the Audit Committee? For additional reading see Matt’s blog post Bankrate pays $28.5 million in fraud caseon Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Mar 2019 05:00:00 -0000 Compliance into the Weeds: Episode 114-Lessons on Internal Control Overrides full 114 Tom Fox Compliance into the Weeds: Episode 114-Lessons on Internal Control Overrides Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent Bankrate DOJ enforcement action in which the company garnered a NPA and for which it paid a total penalty of $28.5 million. We feature a discussion of internal control overrides. Some of the highlights include: Ø What are the background facts of the matter?Ø Why should you never name a slush fund “Ed’s Cushion?Ø What is the difference between management over-ride of internal controls and abuse of management control override?Ø Why is robust accounting required when there is a single source of data?Ø What is the straight line from internal controls and accounting to the Board and the audit committee?Ø Where was the Audit Committee? For additional reading see Matt’s blog post Bankrate pays $28.5 million in fraud caseon Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent Bankrate DOJ enforcement action in which the company garnered a NPA and for which it paid a total penalty of $28.5 million. We feature a discussion of internal control overrides. Some of the highlights include: Ø What are the background facts of the matter?Ø Why should you never name a slush fund “Ed’s Cushion?Ø What is the difference between management over-ride of internal controls and abuse of management control override?Ø Why is robust accounting required when there is a single source of data?Ø What is the straight line from internal controls and accounting to the Board and the audit committee?Ø Where was the Audit Committee? For additional reading see Matt’s blog post Bankrate pays $28.5 million in fraud caseon Radical Compliance.

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]]> 1308 no Compliance into the Weeds: Episode 113-Corporate Governance Nightmare Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into horrific corporate conduct engaged in by Hacienda Healthcare in Arizona over the past few months. Our discussion provides insights into failures at the Board oversight level, corporate governance, CEO, senior management and CCO position.  Some of the highlights include: Ø What are the background facts of the matter?Ø How could the facility allow the rape of an incapacitated patient who is in a permanent vegetative state?Ø Why did the professional investigator brought into to investigate the crime resign so noisily?Ø Why was there such a complete total and utter failure by the Board on oversight?Ø What, if any, are the potential criminal charges which might be filed?Ø Where was compliance? For additional reading see Matt’s blog post Governance Nightmare in Arizonaon Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Mar 2019 06:00:00 -0000 Compliance into the Weeds: Episode 113-Corporate Governance Nightmare full 113 Tom Fox Compliance into the Weeds: Episode 113-Corporate Governance Nightmare Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into horrific corporate conduct engaged in by Hacienda Healthcare in Arizona over the past few months. Our discussion provides insights into failures at the Board oversight level, corporate governance, CEO, senior management and CCO position.  Some of the highlights include: Ø What are the background facts of the matter?Ø How could the facility allow the rape of an incapacitated patient who is in a permanent vegetative state?Ø Why did the professional investigator brought into to investigate the crime resign so noisily?Ø Why was there such a complete total and utter failure by the Board on oversight?Ø What, if any, are the potential criminal charges which might be filed?Ø Where was compliance? For additional reading see Matt’s blog post Governance Nightmare in Arizonaon Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into horrific corporate conduct engaged in by Hacienda Healthcare in Arizona over the past few months. Our discussion provides insights into failures at the Board oversight level, corporate governance, CEO, senior management and CCO position.  Some of the highlights include: Ø What are the background facts of the matter?Ø How could the facility allow the rape of an incapacitated patient who is in a permanent vegetative state?Ø Why did the professional investigator brought into to investigate the crime resign so noisily?Ø Why was there such a complete total and utter failure by the Board on oversight?Ø What, if any, are the potential criminal charges which might be filed?Ø Where was compliance? For additional reading see Matt’s blog post Governance Nightmare in Arizonaon Radical Compliance.

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]]> 1170 no Compliance into the Weeds: Episode 112-Robert Kraft and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving surrounding New England Patriots owner Robert Kraft who has been charged with solicitation of prostitution, what it means for both Kraft and the NFL and the compliance response.   Some of the highlights include: Ø What are the background facts of the matter?Ø What has been the response of the NFL? Will it investigate or leave it to the public authorities?Ø What are other criminal charges involving NFL owners and what was the NFL response?Ø What are the key employee/CEO risks for an organization?Ø How much private conduct is really public in this age of social media?Ø Why is compliance the only response? For additional reading see Tom’s blog post Robert Kraft, the NFL and Complianceon the FCPA Compliance and Ethics Blog. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 27 Feb 2019 06:00:00 -0000 Compliance into the Weeds: Episode 112-Robert Kraft and Compliance full 82 Tom Fox Episode 112-Robert Kraft and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving surrounding New England Patriots owner Robert Kraft who has been charged with solicitation of prostitution, what it means for both Kraft and the NFL and the compliance response.   Some of the highlights include: Ø What are the background facts of the matter?Ø What has been the response of the NFL? Will it investigate or leave it to the public authorities?Ø What are other criminal charges involving NFL owners and what was the NFL response?Ø What are the key employee/CEO risks for an organization?Ø How much private conduct is really public in this age of social media?Ø Why is compliance the only response? For additional reading see Tom’s blog post Robert Kraft, the NFL and Complianceon the FCPA Compliance and Ethics Blog. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving surrounding New England Patriots owner Robert Kraft who has been charged with solicitation of prostitution, what it means for both Kraft and the NFL and the compliance response.   Some of the highlights include: Ø What are the background facts of the matter?Ø What has been the response of the NFL? Will it investigate or leave it to the public authorities?Ø What are other criminal charges involving NFL owners and what was the NFL response?Ø What are the key employee/CEO risks for an organization?Ø How much private conduct is really public in this age of social media?Ø Why is compliance the only response? For additional reading see Tom’s blog post Robert Kraft, the NFL and Complianceon the FCPA Compliance and Ethics Blog.

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]]> 1678 no Compliance into the Weeds: Episode 111- What is supply chain risk? Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Feb 2019 06:00:00 -0000 Compliance into the Weeds: Episode 111- What is supply chain risk? full Tom Fox Episode 111- What is supply chain risk? Learn more about your ad choices. Visit megaphone.fm/adchoices

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]]> 1437 Compliance into the Weeds: Episode 110- the Ralph Northam edition Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving (at least as of now) current Governor of Virginia, Ralph Northam and the pictures involving Northam in blackface and KKK robes.    Some of the highlights include: Ø What is ethical leadership?Ø Why is Northam following the Trump playbook?Ø How and why employees take their cues around ethics from their leaders?Ø Why are employees looking to work for companies with a culture of accountability?Ø Why should the CCO have an ethical role in an organization? For additional reading see Matt’s blog post Northam and Ethical Accountabilityin Radical Compliance.  Share Your Compliance Expertise and Help Those in Need!We need your expertise on ethics & compliance programs! If you’re involved in managing employee policies & procedures, a hotline/incident management program, training initiatives or third party risk management, please share your thoughts on your program effectiveness, success measurements, and key activities and goals for this year by taking part in NAVEX Global’s 2019 Future of Compliance Report survey.Click here to complete the survey.For every complete, $10 (USD) will be donated on your behalf to the charity of your choosing from the following charities: UNICEF, Operation Smile, St. Jude Children’s Hospital, Humane Society, Wounded Warrior Project,Médecins Sans Frontières, or Rainbow Trust Children’s Charity. Also, as a thank you for your participation in this annual study, you’ll get access to this valuable benchmark data to create a more effective compliance program.You can also copy and paste the URL below into your internet browser: https://na1se.voxco.com/SE/?st=4P4BV59nKuYZVVwz2mHGZPBTRrG4NjahAP%2FlgrTzTYE%3D&urlimport=1&questlist=source&source=4 COMMITMENT TO ANONYMITY All responses are confidential and will be reported only in aggregate form. Individual data will NEVER be shared with any other party (privacy policy). Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Feb 2019 06:00:00 -0000 Compliance into the Weeds: Episode 110- the Ralph Northam edition full 110 Tom Fox Compliance into the Weeds: Episode 110- the Ralph Northam edition Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving (at least as of now) current Governor of Virginia, Ralph Northam and the pictures involving Northam in blackface and KKK robes.    Some of the highlights include: Ø What is ethical leadership?Ø Why is Northam following the Trump playbook?Ø How and why employees take their cues around ethics from their leaders?Ø Why are employees looking to work for companies with a culture of accountability?Ø Why should the CCO have an ethical role in an organization? For additional reading see Matt’s blog post Northam and Ethical Accountabilityin Radical Compliance.  Share Your Compliance Expertise and Help Those in Need!We need your expertise on ethics & compliance programs! If you’re involved in managing employee policies & procedures, a hotline/incident management program, training initiatives or third party risk management, please share your thoughts on your program effectiveness, success measurements, and key activities and goals for this year by taking part in NAVEX Global’s 2019 Future of Compliance Report survey.Click here to complete the survey.For every complete, $10 (USD) will be donated on your behalf to the charity of your choosing from the following charities: UNICEF, Operation Smile, St. Jude Children’s Hospital, Humane Society, Wounded Warrior Project,Médecins Sans Frontières, or Rainbow Trust Children’s Charity. Also, as a thank you for your participation in this annual study, you’ll get access to this valuable benchmark data to create a more effective compliance program.You can also copy and paste the URL below into your internet browser: https://na1se.voxco.com/SE/?st=4P4BV59nKuYZVVwz2mHGZPBTRrG4NjahAP%2FlgrTzTYE%3D&urlimport=1&questlist=source&source=4 COMMITMENT TO ANONYMITY All responses are confidential and will be reported only in aggregate form. Individual data will NEVER be shared with any other party (privacy policy). Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving (at least as of now) current Governor of Virginia, Ralph Northam and the pictures involving Northam in blackface and KKK robes.    Some of the highlights include: Ø What is ethical leadership?Ø Why is Northam following the Trump playbook?Ø How and why employees take their cues around ethics from their leaders?Ø Why are employees looking to work for companies with a culture of accountability?Ø Why should the CCO have an ethical role in an organization? For additional reading see Matt’s blog post Northam and Ethical Accountabilityin Radical Compliance.  Share Your Compliance Expertise and Help Those in Need!We need your expertise on ethics & compliance programs! If you’re involved in managing employee policies & procedures, a hotline/incident management program, training initiatives or third party risk management, please share your thoughts on your program effectiveness, success measurements, and key activities and goals for this year by taking part in NAVEX Global’s 2019 Future of Compliance Report survey.Click here to complete the survey.For every complete, $10 (USD) will be donated on your behalf to the charity of your choosing from the following charities: UNICEF, Operation Smile, St. Jude Children’s Hospital, Humane Society, Wounded Warrior Project,Médecins Sans Frontières, or Rainbow Trust Children’s Charity. Also, as a thank you for your participation in this annual study, you’ll get access to this valuable benchmark data to create a more effective compliance program.You can also copy and paste the URL below into your internet browser:

https://na1se.voxco.com/SE/?st=4P4BV59nKuYZVVwz2mHGZPBTRrG4NjahAP%2FlgrTzTYE%3D&urlimport=1&questlist=source&source=4 COMMITMENT TO ANONYMITY

All responses are confidential and will be reported only in aggregate form. Individual data will NEVER be shared with any other party (privacy policy).

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]]> 1514 no Compliance into the Weeds: Episode 109- Does the NFL Even Care? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent blown call in the Saints-Rams NFC. We consider the (non) response from the NFL under the rubric of internal controls.   Some of the highlights include: Ø What is risk and how should it be considered?Ø Who are the stakeholders for professional football? Who are the stakeholders for your organization?Ø Does your risk increase the closer you get to the final goal? (IE., playing for the Super Bowl)Ø If a control failure can lead to a material adverse event, shouldn’t you have a compensating control?Ø Should an organization like the NFL even care about getting it right? For additional reading see Matt’s blog post Of Blown Calls and Internal Controlin Radical Compliance.  Share Your Compliance Expertise and Help Those in Need!We need your expertise on ethics & compliance programs! If you’re involved in managing employee policies & procedures, a hotline/incident management program, training initiatives or third party risk management, please share your thoughts on your program effectiveness, success measurements, and key activities and goals for this year by taking part in NAVEX Global’s 2019 Future of Compliance Report survey.Click here to complete the survey.For every complete, $10 (USD) will be donated on your behalf to the charity of your choosing from the following charities: UNICEF, Operation Smile, St. Jude Children’s Hospital, Humane Society, Wounded Warrior Project,Médecins Sans Frontières, or Rainbow Trust Children’s Charity. Also, as a thank you for your participation in this annual study, you’ll get access to this valuable benchmark data to create a more effective compliance program. You can also copy and paste the URL below into your internet browser: https://na1se.voxco.com/SE/?st=4P4BV59nKuYZVVwz2mHGZPBTRrG4NjahAP%2FlgrTzTYE%3D&urlimport=1&questlist=source&source=4 COMMITMENT TO ANONYMITY All responses are confidential and will be reported only in aggregate form. Individual data will NEVER be shared with any other party (privacy policy). Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 30 Jan 2019 06:00:00 -0000 Compliance into the Weeds: Episode 109- Does the NFL Even Care? full 109 Tom Fox Episode 109- Does the NFL Even Care? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent blown call in the Saints-Rams NFC. We consider the (non) response from the NFL under the rubric of internal controls.   Some of the highlights include: Ø What is risk and how should it be considered?Ø Who are the stakeholders for professional football? Who are the stakeholders for your organization?Ø Does your risk increase the closer you get to the final goal? (IE., playing for the Super Bowl)Ø If a control failure can lead to a material adverse event, shouldn’t you have a compensating control?Ø Should an organization like the NFL even care about getting it right? For additional reading see Matt’s blog post Of Blown Calls and Internal Controlin Radical Compliance.  Share Your Compliance Expertise and Help Those in Need!We need your expertise on ethics & compliance programs! If you’re involved in managing employee policies & procedures, a hotline/incident management program, training initiatives or third party risk management, please share your thoughts on your program effectiveness, success measurements, and key activities and goals for this year by taking part in NAVEX Global’s 2019 Future of Compliance Report survey.Click here to complete the survey.For every complete, $10 (USD) will be donated on your behalf to the charity of your choosing from the following charities: UNICEF, Operation Smile, St. Jude Children’s Hospital, Humane Society, Wounded Warrior Project,Médecins Sans Frontières, or Rainbow Trust Children’s Charity. Also, as a thank you for your participation in this annual study, you’ll get access to this valuable benchmark data to create a more effective compliance program. You can also copy and paste the URL below into your internet browser: https://na1se.voxco.com/SE/?st=4P4BV59nKuYZVVwz2mHGZPBTRrG4NjahAP%2FlgrTzTYE%3D&urlimport=1&questlist=source&source=4 COMMITMENT TO ANONYMITY All responses are confidential and will be reported only in aggregate form. Individual data will NEVER be shared with any other party (privacy policy). Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent blown call in the Saints-Rams NFC. We consider the (non) response from the NFL under the rubric of internal controls.   Some of the highlights include: Ø What is risk and how should it be considered?Ø Who are the stakeholders for professional football? Who are the stakeholders for your organization?Ø Does your risk increase the closer you get to the final goal? (IE., playing for the Super Bowl)Ø If a control failure can lead to a material adverse event, shouldn’t you have a compensating control?Ø Should an organization like the NFL even care about getting it right? For additional reading see Matt’s blog post Of Blown Calls and Internal Controlin Radical Compliance.  Share Your Compliance Expertise and Help Those in Need!We need your expertise on ethics & compliance programs! If you’re involved in managing employee policies & procedures, a hotline/incident management program, training initiatives or third party risk management, please share your thoughts on your program effectiveness, success measurements, and key activities and goals for this year by taking part in NAVEX Global’s 2019 Future of Compliance Report survey.Click here to complete the survey.For every complete, $10 (USD) will be donated on your behalf to the charity of your choosing from the following charities: UNICEF, Operation Smile, St. Jude Children’s Hospital, Humane Society, Wounded Warrior Project,Médecins Sans Frontières, or Rainbow Trust Children’s Charity. Also, as a thank you for your participation in this annual study, you’ll get access to this valuable benchmark data to create a more effective compliance program.

You can also copy and paste the URL below into your internet browser:

https://na1se.voxco.com/SE/?st=4P4BV59nKuYZVVwz2mHGZPBTRrG4NjahAP%2FlgrTzTYE%3D&urlimport=1&questlist=source&source=4 COMMITMENT TO ANONYMITY

All responses are confidential and will be reported only in aggregate form. Individual data will NEVER be shared with any other party (privacy policy).

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]]> 1532 no Compliance into the Weeds: Episode 108- Distributors and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into some of the difficulties around distributors in anti-corruption compliance.   Some of the highlights include: Ø The recent Polycom FCPA enforcement action highlighted several FCPA enforcement actions from 2018 involving distributors.Ø How do discounts, coupons, rebates, and sales devices circulate among your company, distributors, and end customers? Distributors present these and other issues separate from sales agents and employees.Ø What do the Sanofi and Stryker enforcement actions tell us around compliance?Ø Why does Document Document Document continue to be a mantra for anti-corruption compliance?   For additional reading see Matt’s blog posts Distributors, FCPA, and Internal Controls — Lessons for Anti-Bribery & Corruption Programsin Navex Global’s Ethics and Compliance Matters For more on the Polycom FCPA enforcement action, see Tom’s blog post, “Follow the Money Through Distributors”  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Jan 2019 06:00:00 -0000 Compliance into the Weeds: Episode 108- Distributors and Compliance full 108 Tom Fox Episode 108- Distributors and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into some of the difficulties around distributors in anti-corruption compliance.   Some of the highlights include: Ø The recent Polycom FCPA enforcement action highlighted several FCPA enforcement actions from 2018 involving distributors.Ø How do discounts, coupons, rebates, and sales devices circulate among your company, distributors, and end customers? Distributors present these and other issues separate from sales agents and employees.Ø What do the Sanofi and Stryker enforcement actions tell us around compliance?Ø Why does Document Document Document continue to be a mantra for anti-corruption compliance?   For additional reading see Matt’s blog posts Distributors, FCPA, and Internal Controls — Lessons for Anti-Bribery & Corruption Programsin Navex Global’s Ethics and Compliance Matters For more on the Polycom FCPA enforcement action, see Tom’s blog post, “Follow the Money Through Distributors”  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into some of the difficulties around distributors in anti-corruption compliance.   Some of the highlights include: Ø The recent Polycom FCPA enforcement action highlighted several FCPA enforcement actions from 2018 involving distributors.Ø How do discounts, coupons, rebates, and sales devices circulate among your company, distributors, and end customers? Distributors present these and other issues separate from sales agents and employees.Ø What do the Sanofi and Stryker enforcement actions tell us around compliance?Ø Why does Document Document Document continue to be a mantra for anti-corruption compliance?   For additional reading see Matt’s blog posts Distributors, FCPA, and Internal Controls — Lessons for Anti-Bribery & Corruption Programsin Navex Global’s Ethics and Compliance Matters For more on the Polycom FCPA enforcement action, see Tom’s blog post, “Follow the Money Through Distributors” 

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]]> 1403 no Compliance into the Weeds: Episode 107- Management Review Controls Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into management review controls.   Some of the highlights include: Ø Will the PCAOB up its game in this area?Ø When will the SEC provide updated guidance on the issue? Ø Will it be up to COSO to formulate an appropriate new standard? Ø How does all of this apply to the compliance professional?  For additional reading see Matt’s blog posts Deloitte Inspection Report ReleasedandTalking Compliance Analytics at AB-InBevin Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Jan 2019 11:55:55 -0000 Compliance into the Weeds: Episode 107- Management Review Controls full 107 Tom Fox Episode 107- Management Review Controls Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into management review controls.   Some of the highlights include: Ø Will the PCAOB up its game in this area?Ø When will the SEC provide updated guidance on the issue? Ø Will it be up to COSO to formulate an appropriate new standard? Ø How does all of this apply to the compliance professional?  For additional reading see Matt’s blog posts Deloitte Inspection Report ReleasedandTalking Compliance Analytics at AB-InBevin Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into management review controls.   Some of the highlights include: Ø Will the PCAOB up its game in this area?Ø When will the SEC provide updated guidance on the issue? Ø Will it be up to COSO to formulate an appropriate new standard? Ø How does all of this apply to the compliance professional?  For additional reading see Matt’s blog posts Deloitte Inspection Report ReleasedandTalking Compliance Analytics at AB-InBevin Radical Compliance. 

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]]> 1774 no Compliance into the Weeds: Episode 106- the Nine for 2019 Edition Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into a recent blog post by Matt on his top nine story lines for 2019. We slice and dice them and try to consider how they will impact the compliance profession going forward.   Some of the highlights include: Ø A US data privacy law and GDPR enforcement.Ø What do restive employees have to do with Adam Smith? Ø Private equity sees money to be made in the GRC vendor space. What will it mean for compliance? Ø Forgiveness seems to be the byword for the DOJ in 2018 FCPA enforcement. Will it encourage more self-disclosure?   For additional reading see Matt’s blog post “Nine Compliance Issues for 2019” in Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Jan 2019 06:00:00 -0000 Compliance into the Weeds: Episode 106- the Nine for 2019 Edition full 106 Tom Fox Episode 106- the Nine for 2019 Edition Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into a recent blog post by Matt on his top nine story lines for 2019. We slice and dice them and try to consider how they will impact the compliance profession going forward.   Some of the highlights include: Ø A US data privacy law and GDPR enforcement.Ø What do restive employees have to do with Adam Smith? Ø Private equity sees money to be made in the GRC vendor space. What will it mean for compliance? Ø Forgiveness seems to be the byword for the DOJ in 2018 FCPA enforcement. Will it encourage more self-disclosure?   For additional reading see Matt’s blog post “Nine Compliance Issues for 2019” in Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into a recent blog post by Matt on his top nine story lines for 2019. We slice and dice them and try to consider how they will impact the compliance profession going forward.   Some of the highlights include: Ø A US data privacy law and GDPR enforcement.Ø What do restive employees have to do with Adam Smith? Ø Private equity sees money to be made in the GRC vendor space. What will it mean for compliance? Ø Forgiveness seems to be the byword for the DOJ in 2018 FCPA enforcement. Will it encourage more self-disclosure?   For additional reading see Matt’s blog post “Nine Compliance Issues for 2019” in Radical Compliance. 

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]]> 1965 no Compliance into the Weeds: Episode 105- the Polycom FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent announced Polycom Inc. FCPA enforcement action. We both blogged on it and we bring two difference perspectives to this matter. I take a deep dive into the nuts and bolts lessons learned for the compliance practitioner. Matt takes a step back and considers the larger picture of corporate culture, corrupt CEOs and how these can lead to the destruction of the company.   Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø How the CEO’s corrupt nature permeated the entire organization. Ø Oversight means more than simply asking questions and accepting the proffered answers. Ø Data analytics are critical for a best practices compliance program going forward.  For additional reading see Matt’s blog post “Many Lessons in Polycom FCPA Case” in Radical Compliance.  See also Tom’s blog “Following the Money Through Distributors” in the FCPA Compliance and Ethics Blog.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Jan 2019 13:34:57 -0000 Compliance into the Weeds: Episode 105- the Polycom FCPA Enforcement Action full 105 Tom Fox The Polycom FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent announced Polycom Inc. FCPA enforcement action. We both blogged on it and we bring two difference perspectives to this matter. I take a deep dive into the nuts and bolts lessons learned for the compliance practitioner. Matt takes a step back and considers the larger picture of corporate culture, corrupt CEOs and how these can lead to the destruction of the company.   Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø How the CEO’s corrupt nature permeated the entire organization. Ø Oversight means more than simply asking questions and accepting the proffered answers. Ø Data analytics are critical for a best practices compliance program going forward.  For additional reading see Matt’s blog post “Many Lessons in Polycom FCPA Case” in Radical Compliance.  See also Tom’s blog “Following the Money Through Distributors” in the FCPA Compliance and Ethics Blog.  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent announced Polycom Inc. FCPA enforcement action. We both blogged on it and we bring two difference perspectives to this matter. I take a deep dive into the nuts and bolts lessons learned for the compliance practitioner. Matt takes a step back and considers the larger picture of corporate culture, corrupt CEOs and how these can lead to the destruction of the company.   Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø How the CEO’s corrupt nature permeated the entire organization. Ø Oversight means more than simply asking questions and accepting the proffered answers. Ø Data analytics are critical for a best practices compliance program going forward.  For additional reading see Matt’s blog post “Many Lessons in Polycom FCPA Case” in Radical Compliance.  See also Tom’s blog “Following the Money Through Distributors” in the FCPA Compliance and Ethics Blog. 

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]]> 1667 no Compliance into the Weeds: Episode 104- Culture and Compliance Structure Failures at CBS Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent report in the New York Timesabout the settlement of CBS with the actor Eliza Dushku over allegations of retaliation for reporting sexual harassment by CBS series star in the TV drama Bull, Michael Weatherly. The entire episode exposed the culture at CBS and the failure in the structure of the company’s compliance program.  After reporting unwanted and/or inappropriate behavior, Dushku’s character was literally written out of the series. She went to mediation over the retaliation for her internal reporting. In a formal mediation process, CBS’s attempted to assassinate her character but the evidence presented backfired on CBS as it proved the harassment. Worse yet the character assassination attempts were made by a CBS lawyer who is also the company’s Chief Compliance Officer.  Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø The interest of CBS legal was to attack the accuser and settle the lawsuit. Ø The interest of a CCO should have been was to prevent, detect and remediate the issue so that it would create a speak up culture. Ø When you subordinate an ethical culture to a legal position, it works to destroy employee trust and morale.  For additional reading see Matt’s blog post “CBS Compliance, Culture Under Fire” in Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Dec 2018 06:00:00 -0000 Compliance into the Weeds: Episode 104- Culture and Compliance Structure Failures at CBS full 104 Tom Fox Culture and Compliance Structure Failures at CBS Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent report in the New York Timesabout the settlement of CBS with the actor Eliza Dushku over allegations of retaliation for reporting sexual harassment by CBS series star in the TV drama Bull, Michael Weatherly. The entire episode exposed the culture at CBS and the failure in the structure of the company’s compliance program.  After reporting unwanted and/or inappropriate behavior, Dushku’s character was literally written out of the series. She went to mediation over the retaliation for her internal reporting. In a formal mediation process, CBS’s attempted to assassinate her character but the evidence presented backfired on CBS as it proved the harassment. Worse yet the character assassination attempts were made by a CBS lawyer who is also the company’s Chief Compliance Officer.  Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø The interest of CBS legal was to attack the accuser and settle the lawsuit. Ø The interest of a CCO should have been was to prevent, detect and remediate the issue so that it would create a speak up culture. Ø When you subordinate an ethical culture to a legal position, it works to destroy employee trust and morale.  For additional reading see Matt’s blog post “CBS Compliance, Culture Under Fire” in Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent report in the New York Timesabout the settlement of CBS with the actor Eliza Dushku over allegations of retaliation for reporting sexual harassment by CBS series star in the TV drama Bull, Michael Weatherly. The entire episode exposed the culture at CBS and the failure in the structure of the company’s compliance program.  After reporting unwanted and/or inappropriate behavior, Dushku’s character was literally written out of the series. She went to mediation over the retaliation for her internal reporting. In a formal mediation process, CBS’s attempted to assassinate her character but the evidence presented backfired on CBS as it proved the harassment. Worse yet the character assassination attempts were made by a CBS lawyer who is also the company’s Chief Compliance Officer.  Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø The interest of CBS legal was to attack the accuser and settle the lawsuit. Ø The interest of a CCO should have been was to prevent, detect and remediate the issue so that it would create a speak up culture. Ø When you subordinate an ethical culture to a legal position, it works to destroy employee trust and morale.  For additional reading see Matt’s blog post “CBS Compliance, Culture Under Fire” in Radical Compliance. 

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]]> 1424 no Compliance into the Weeds: Episode 103- Conspiracy or Coincidence? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into two recent announcements by SEC Chairman Jay Clayton and PCAOB Chairman Will Duhnke that their agencies will turn a more critical eye towards Chinese companies and their lack of transparency in the audit process and in financial reporting. We introduce two characters, Conspiracy Tom and Conspiracy Matt to evaluate whether these announcements, made the same week as the arrest of the Chinese CFO of Huawei in Canada,   are a part of the larger trade war the Trump Administration is waging against China (Conspiracy Tom) or just coincidence (Matt).  For additional reading see Matt’s blog post “US Regulators Warn on China” in Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Dec 2018 06:00:00 -0000 full 103 Tom Fox Conspiracy or Coincidence? Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into two recent announcements by SEC Chairman Jay Clayton and PCAOB Chairman Will Duhnke that their agencies will turn a more critical eye towards Chinese companies and their lack of transparency in the audit process and in financial reporting. We introduce two characters, Conspiracy Tom and Conspiracy Matt to evaluate whether these announcements, made the same week as the arrest of the Chinese CFO of Huawei in Canada,   are a part of the larger trade war the Trump Administration is waging against China (Conspiracy Tom) or just coincidence (Matt).  For additional reading see Matt’s blog post “US Regulators Warn on China” in Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into two recent announcements by SEC Chairman Jay Clayton and PCAOB Chairman Will Duhnke that their agencies will turn a more critical eye towards Chinese companies and their lack of transparency in the audit process and in financial reporting. We introduce two characters, Conspiracy Tom and Conspiracy Matt to evaluate whether these announcements, made the same week as the arrest of the Chinese CFO of Huawei in Canada,   are a part of the larger trade war the Trump Administration is waging against China (Conspiracy Tom) or just coincidence (Matt).  For additional reading see Matt’s blog post “US Regulators Warn on China” in Radical Compliance. 

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]]> 1688 no Compliance into the Weeds: Episode 102- a Rumination on Substantial Involvement Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive Michael Cohen’s guilty plea and DAG Rod Rosenstein’s ‘substantially responsible” amending of the Yates Memo. Since Cohen said in the plea agreement that he only lied to Congress to support what he believed Trump wanted; not at Trump’s direction. It gives us the opportunity to explore a gray area about accountability for senior execs complicit in misconduct or to use Rosenstein's language have 'substantial involvement' but not substantially responsible for it. It provides several new lessons learned for the compliance professional (and some old ones as well).  Some of the highlights from this podcast are: What does ‘substantially involved in or responsible for the misconduct’ actually mean?What does ‘substantially involved in or responsible for the misconduct’ actually mean?If the voting public, and employees; don’t see justice served, for legal distinctions they may neither appreciate nor care about, that’s going to blunt their interest in talk about ethical conduct; will it will corrode the trust they have in organizations?What if the senior executives are complicit in the misconduct by fostering a poor control environment; and yet they personally were not substantially involved in the misconduct?Will this drive up the importance of strong governance? For example, where were the auditors, inspecting the control environment? Or would this lead to shareholder lawsuits against the board?How would the Justice Department apply the Rosenstein policy to those circumstances?What were the key lessons learned for the compliance practitioner? Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 06 Dec 2018 06:00:00 -0000 full 102 Tom Fox Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive Michael Cohen’s guilty plea and DAG Rod Rosenstein’s ‘substantially responsible” amending of the Yates Memo. Since Cohen said in the plea agreement that he only lied to Congress to support what he believed Trump wanted; not at Trump’s direction. It gives us the opportunity to explore a gray area about accountability for senior execs complicit in misconduct or to use Rosenstein's language have 'substantial involvement' but not substantially responsible for it. It provides several new lessons learned for the compliance professional (and some old ones as well).  Some of the highlights from this podcast are: What does ‘substantially involved in or responsible for the misconduct’ actually mean?What does ‘substantially involved in or responsible for the misconduct’ actually mean?If the voting public, and employees; don’t see justice served, for legal distinctions they may neither appreciate nor care about, that’s going to blunt their interest in talk about ethical conduct; will it will corrode the trust they have in organizations?What if the senior executives are complicit in the misconduct by fostering a poor control environment; and yet they personally were not substantially involved in the misconduct?Will this drive up the importance of strong governance? For example, where were the auditors, inspecting the control environment? Or would this lead to shareholder lawsuits against the board?How would the Justice Department apply the Rosenstein policy to those circumstances?What were the key lessons learned for the compliance practitioner? Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive Michael Cohen’s guilty plea and DAG Rod Rosenstein’s ‘substantially responsible” amending of the Yates Memo. Since Cohen said in the plea agreement that he only lied to Congress to support what he believed Trump wanted; not at Trump’s direction. It gives us the opportunity to explore a gray area about accountability for senior execs complicit in misconduct or to use Rosenstein's language have 'substantial involvement' but not substantially responsible for it. It provides several new lessons learned for the compliance professional (and some old ones as well). 

Some of the highlights from this podcast are:

What does ‘substantially involved in or responsible for the misconduct’ actually mean?What does ‘substantially involved in or responsible for the misconduct’ actually mean?If the voting public, and employees; don’t see justice served, for legal distinctions they may neither appreciate nor care about, that’s going to blunt their interest in talk about ethical conduct; will it will corrode the trust they have in organizations?What if the senior executives are complicit in the misconduct by fostering a poor control environment; and yet they personally were not substantially involved in the misconduct?Will this drive up the importance of strong governance? For example, where were the auditors, inspecting the control environment? Or would this lead to shareholder lawsuits against the board?How would the Justice Department apply the Rosenstein policy to those circumstances?What were the key lessons learned for the compliance practitioner?

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]]> 1760 no Compliance into the Weeds: Episode 100- Michigan State University Reorganizes Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the recently announced reorganization of the Michigan State University compliance function, rolling it into the newly created Office of Audit, Risk, and Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Dec 2018 23:57:31 -0000 full 100 Tom Fox MSU Reorganizes Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the recently announced reorganization of the Michigan State University compliance function, rolling it into the newly created Office of Audit, Risk, and Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the recently announced reorganization of the Michigan State University compliance function, rolling it into the newly created Office of Audit, Risk, and Compliance.

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]]> 969 no Compliance into the Weeds: Episode 101- the Vantage Drilling FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the recent Vantage Drilling FCPA enforcement action. It is a highly unusual enforcement action with some very different facts from the standard FCPA case. It provides some new lessons learned for the compliance professional (and some old ones as well). Some of the highlights from this podcast are: What were the unusual facts of this matter?What is the role of a Board member who is also a supplier to a company?What were the key lessons learned for the compliance practitioner? For more see Matt’s blog post SEC Dings Vantage  $5M on FCPA Issues and see Tom’s blog post, The Vantage Drilling FCPA Enforcement Action. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Dec 2018 23:36:22 -0000 full 101 Tom Fox The Vantage Drilling FCPA Enforcement Action Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the recent Vantage Drilling FCPA enforcement action. It is a highly unusual enforcement action with some very different facts from the standard FCPA case. It provides some new lessons learned for the compliance professional (and some old ones as well). Some of the highlights from this podcast are: What were the unusual facts of this matter?What is the role of a Board member who is also a supplier to a company?What were the key lessons learned for the compliance practitioner? For more see Matt’s blog post SEC Dings Vantage  $5M on FCPA Issues and see Tom’s blog post, The Vantage Drilling FCPA Enforcement Action. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the recent Vantage Drilling FCPA enforcement action. It is a highly unusual enforcement action with some very different facts from the standard FCPA case. It provides some new lessons learned for the compliance professional (and some old ones as well).

Some of the highlights from this podcast are:

What were the unusual facts of this matter?What is the role of a Board member who is also a supplier to a company?What were the key lessons learned for the compliance practitioner?

For more see Matt’s blog post SEC Dings Vantage  $5M on FCPA Issues and see Tom’s blog post, The Vantage Drilling FCPA Enforcement Action.

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]]> 1055 no Compliance into the Weeds: Episode 98 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the Benczkowski  Memo and what it means for not only the monitor selection process but for compliance officers who may be in front of the Justice Department in a FCPA investigation.    Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Oct 2018 14:48:00 -0000 The Benczkowski Memo full 98 Tom Fox The Benczkowski Memo Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the Benczkowski  Memo and what it means for not only the monitor selection process but for compliance officers who may be in front of the Justice Department in a FCPA investigation.    Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the Benczkowski  Memo and what it means for not only the monitor selection process but for compliance officers who may be in front of the Justice Department in a FCPA investigation.   

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]]> 1405 no Compliance into the Weeds: Episode 97 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the continuing saga of Elon Musk, the SEC settlement, corporate governance at Tesla and his ongoing twitter feed.    Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Oct 2018 16:00:00 -0000 Elon Musk, Compliance and Controls full 97 Tom Fox Elon Musk, Compliance and Controls Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the continuing saga of Elon Musk, the SEC settlement, corporate governance at Tesla and his ongoing twitter feed.    Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the continuing saga of Elon Musk, the SEC settlement, corporate governance at Tesla and his ongoing twitter feed.   

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]]> 1447 no Compliance into the Weeds: Episode 96 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the increased prevalence of non-GAAP financial reporting.     Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Oct 2018 16:00:00 -0000 Non-GAAP Reporting full 96 Tom Fox Non-GAAP Reporting Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the increased prevalence of non-GAAP financial reporting.     Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the increased prevalence of non-GAAP financial reporting.    

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]]> 885 no Compliance into the Weeds: Episode 95 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the process surrounding the allegations made against Supreme Court nominee Brett Kavanaugh by Christina Ford. We consider these allegations from the compliance perspective  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Sep 2018 16:00:00 -0000 Kavanaugh and Compliance full 95 Tom Fox Kavanaugh and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the process surrounding the allegations made against Supreme Court nominee Brett Kavanaugh by Christina Ford. We consider these allegations from the compliance perspective  Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the process surrounding the allegations made against Supreme Court nominee Brett Kavanaugh by Christina Ford. We consider these allegations from the compliance perspective 

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]]> 1385 no Compliance into the Weeds: Episode 94 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the recent SEC whistleblower award of $54MM to two separate individuals.    Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Sep 2018 10:54:00 -0000 $54MM SEC Whistleblower Awards full 94 Tom Fox $54MM SEC Whistleblower Awards Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the recent SEC whistleblower award of $54MM to two separate individuals.    Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the recent SEC whistleblower award of $54MM to two separate individuals.   

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]]> 1006 no Compliance into the Weeds: Quarterly Reporting Discussion In this episode, Matt Kelly and I take a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive the implications from President Trump’s tweet on Friday, August 17th about quarterly financial reporting by public companies. Learn more about your ad choices. Visit megaphone.fm/adchoices Sat, 18 Aug 2018 14:25:00 -0000 Quarterly Reporting Discussion full Tom Fox Quarterly Reporting Discussion In this episode, Matt Kelly and I take a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive the implications from President Trump’s tweet on Friday, August 17th about quarterly financial reporting by public companies. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive the implications from President Trump’s tweet on Friday, August 17th about quarterly financial reporting by public companies.

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]]> 838 no Compliance into the Weeds: Episode 90 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the imbroglio Salesforce found itself in when it came out the company did work for ICE. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 25 Jul 2018 16:00:00 -0000 Salesforce, the Trump Risk & Compliance full 90 Tom Fox Salesforce, the Trump Risk & Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the imbroglio Salesforce found itself in when it came out the company did work for ICE. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive into the imbroglio Salesforce found itself in when it came out the company did work for ICE.

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]]> 1316 no Compliance into the Weeds: Episode 88 In this episode Matt Kelly and I unpack the proposed changes to the SEC Whistleblower program.  Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 05 Jul 2018 16:00:00 -0000 Proposed SEC Changes to Whistleblower Program full 88 Tom Fox Proposed SEC Changes to Whistleblower Program In this episode Matt Kelly and I unpack the proposed changes to the SEC Whistleblower program.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I unpack the proposed changes to the SEC Whistleblower program. 

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]]> 1377 no Compliance into the Weeds: Episode 87 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive back into the impact of the Trump Administration’s attack on friend and foe alike with tariffs, trade wars, embargoes and sanctions.  This is also our first live podcast from Matt’s stomping grounds in Cambridge, MA. Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 28 Jun 2018 16:00:00 -0000 Trade, Trump and Compliance full 87 Tom Fox Trade, Trump and Compliance Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive back into the impact of the Trump Administration’s attack on friend and foe alike with tariffs, trade wars, embargoes and sanctions.  This is also our first live podcast from Matt’s stomping grounds in Cambridge, MA. Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive back into the impact of the Trump Administration’s attack on friend and foe alike with tariffs, trade wars, embargoes and sanctions.  This is also our first live podcast from Matt’s stomping grounds in Cambridge, MA.

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]]> 1454 no Compliance into the Weeds: Episode 86 In this episode, Matt Kelly and I take a deep dive back into the issue of the ZTE monitorship announced recently as a part of the settlement with the Department of Commerce on the death penalty sanctions levied on the company in April.   Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Jun 2018 16:00:00 -0000 The ZTE Monitorship full 86 Tom Fox The ZTE Monitorship In this episode, Matt Kelly and I take a deep dive back into the issue of the ZTE monitorship announced recently as a part of the settlement with the Department of Commerce on the death penalty sanctions levied on the company in April.   Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive back into the issue of the ZTE monitorship announced recently as a part of the settlement with the Department of Commerce on the death penalty sanctions levied on the company in April.  

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]]> 1377 no Compliance into the Weeds-Episode 85 Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive back into the issue of the decline in Initial Public Offerings (IPOs). Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 13 Jun 2018 16:00:00 -0000 Professor Coffee on the Dearth of IPOs full 85 Tom Fox Professor Coffee on the Dearth of IPOs Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive back into the issue of the decline in Initial Public Offerings (IPOs). Learn more about your ad choices. Visit megaphone.fm/adchoices Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a deep dive back into the issue of the decline in Initial Public Offerings (IPOs).

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]]> 1382 no Compliance into the Weeds-Episode 84 In this episode, Matt Kelly and I take a deep dive into the issue of two factor authentication of cloud-based solutions and the intersection with compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Jun 2018 16:00:00 -0000 Two Factor Authentication & Compliance full 84 Tom Fox Two Factor Authentication & Compliance In this episode, Matt Kelly and I take a deep dive into the issue of two factor authentication of cloud-based solutions and the intersection with compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the issue of two factor authentication of cloud-based solutions and the intersection with compliance.

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]]> 1237 no Compliance into the Weeds-Episode 83 In this episode, Matt Kelly and I take a deep dive into the travails of Roseanne, her television network ABC and compliance over her vile and racist tweet comparing Obama advisor Valerie Jarrad to an ape. We consider the corporate response in light of corporate ethics, values and priorities. Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 31 May 2018 16:00:00 -0000 Roseanne and Compliance full 83 Tom Fox Roseanne and Compliance In this episode, Matt Kelly and I take a deep dive into the travails of Roseanne, her television network ABC and compliance over her vile and racist tweet comparing Obama advisor Valerie Jarrad to an ape. We consider the corporate response in light of corporate ethics, values and priorities. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the travails of Roseanne, her television network ABC and compliance over her vile and racist tweet comparing Obama advisor Valerie Jarrad to an ape. We consider the corporate response in light of corporate ethics, values and priorities.

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]]> 1471 no Compliance into the Weeds-Episode 80 In this episode, Matt Kelly and I take a continued deep dive the underlying assumptions around the reasons for lack of IPOs by small and mid-cap sized firms. We focus on a speech by SEC Commissioner Robert Jackson recently gave exploring possible reasons why middle market companies aren’t going public. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 May 2018 16:00:00 -0000 IPOs for Small and Mid-Cap Companies full 80 Tom Fox IPOs for Small and Mid-Cap Companies In this episode, Matt Kelly and I take a continued deep dive the underlying assumptions around the reasons for lack of IPOs by small and mid-cap sized firms. We focus on a speech by SEC Commissioner Robert Jackson recently gave exploring possible reasons why middle market companies aren’t going public. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a continued deep dive the underlying assumptions around the reasons for lack of IPOs by small and mid-cap sized firms. We focus on a speech by SEC Commissioner Robert Jackson recently gave exploring possible reasons why middle market companies aren’t going public.

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]]> 1373 no Compliance into the Weeds-Episode 78 In this episode, Matt Kelly and I go meta as we go into the weeds about Weed, in the context of the recent announcement by the administration that it would not prosecute persons or producers in states where marijuana sales are legal. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Apr 2018 16:00:00 -0000 An episode about Weed full 78 Tom Fox An episode about Weed In this episode, Matt Kelly and I go meta as we go into the weeds about Weed, in the context of the recent announcement by the administration that it would not prosecute persons or producers in states where marijuana sales are legal. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I go meta as we go into the weeds about Weed, in the context of the recent announcement by the administration that it would not prosecute persons or producers in states where marijuana sales are legal.

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]]> 1013 no Compliance into the Weeds-Episode 77 Privilege and Arrogance at the EPA Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Apr 2018 16:00:00 -0000 Privilege and Arrogance at the EPA full 77 Tom Fox Privilege and Arrogance at the EPA Privilege and Arrogance at the EPA Learn more about your ad choices. Visit megaphone.fm/adchoices Privilege and Arrogance at the EPA

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]]> 1141 no Compliance into the Weeds-Episode 76 Today we consider the plight of soon-to-be former Facebook Chief Information Security Officer Alex Stamos who was seemingly retaliated against for his actions to try and bring the data hacking of Facebook to the attention of senior management. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Mar 2018 11:02:00 -0000 Facebook CISO and Ethical Behavior full 76 Tom Fox Facebook CISO and Ethical Behavior Today we consider the plight of soon-to-be former Facebook Chief Information Security Officer Alex Stamos who was seemingly retaliated against for his actions to try and bring the data hacking of Facebook to the attention of senior management. Learn more about your ad choices. Visit megaphone.fm/adchoices Today we consider the plight of soon-to-be former Facebook Chief Information Security Officer Alex Stamos who was seemingly retaliated against for his actions to try and bring the data hacking of Facebook to the attention of senior management.

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]]> 1106 no Compliance into the Weeds-Episode 75 In this episode, Matt Kelly and I take a deep dive into the recent SEC enforcement action against Elizabeth Holmes, the disgraced founder of Theranos, for her massive fraud around the former unicorn. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Mar 2018 17:54:00 -0000 SEC Enforcement Action Against Holmes full 75 Tom Fox SEC Enforcement Action Against Holmes In this episode, Matt Kelly and I take a deep dive into the recent SEC enforcement action against Elizabeth Holmes, the disgraced founder of Theranos, for her massive fraud around the former unicorn. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the recent SEC enforcement action against Elizabeth Holmes, the disgraced founder of Theranos, for her massive fraud around the former unicorn.

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]]> 1286 no Compliance into the Weeds-Episode 74 In this episode, Matt Kelly and I continue our exploration of the fallout from the recent Supreme Court decision in Digital Realty Trust v. Somers in light of the filing by BioRad in its appeal of the whistleblower award to its former General Counsel, Sanford Wadler.  Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 13 Mar 2018 16:00:00 -0000 Continued Fallout from Somers full 74 Tom Fox Continued Fallout from Somers In this episode, Matt Kelly and I continue our exploration of the fallout from the recent Supreme Court decision in Digital Realty Trust v. Somers in light of the filing by BioRad in its appeal of the whistleblower award to its former General Counsel, Sanford Wadler.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I continue our exploration of the fallout from the recent Supreme Court decision in Digital Realty Trust v. Somers in light of the filing by BioRad in its appeal of the whistleblower award to its former General Counsel, Sanford Wadler. 

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]]> 1108 no Compliance into the Weeds-Episode 73 In this episode, Matt Kelly and I explore the recent revelations of systemic sexual harassment and abuse present in the front office of the Dallas Mavericks. The allegations were not lodged against owner Mark Cuban but against his former team CEO, Terdema Ussery, who was CEO of the Mavericks from 1997 to 2015.  Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 06 Mar 2018 17:00:00 -0000 Compliance Trouble in Dallas full 73 Tom Fox Compliance Trouble in Dallas In this episode, Matt Kelly and I explore the recent revelations of systemic sexual harassment and abuse present in the front office of the Dallas Mavericks. The allegations were not lodged against owner Mark Cuban but against his former team CEO, Terdema Ussery, who was CEO of the Mavericks from 1997 to 2015.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I explore the recent revelations of systemic sexual harassment and abuse present in the front office of the Dallas Mavericks. The allegations were not lodged against owner Mark Cuban but against his former team CEO, Terdema Ussery, who was CEO of the Mavericks from 1997 to 2015. 

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]]> 1392 no Compliance into the Weeds-Episode 72 In this episode, Matt Kelly and I take a deep dive into the implications flowing from the Supreme Court’s decision last week in the Digital Realty Trust v. Somers decision. Matt initiated a ‘tweetstorm’ in articulating his thoughts on the effects of the decision, including its effect on corporations, Chief Compliance Officers, corporate compliance functions and the Securities and Exchange Commission. Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 27 Feb 2018 14:42:00 -0000 Implications from Digital Realty Trust v. Somers full 72 Tom Fox Implications from Digital Realty Trust v. Somers In this episode, Matt Kelly and I take a deep dive into the implications flowing from the Supreme Court’s decision last week in the Digital Realty Trust v. Somers decision. Matt initiated a ‘tweetstorm’ in articulating his thoughts on the effects of the decision, including its effect on corporations, Chief Compliance Officers, corporate compliance functions and the Securities and Exchange Commission. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the implications flowing from the Supreme Court’s decision last week in the Digital Realty Trust v. Somers decision. Matt initiated a ‘tweetstorm’ in articulating his thoughts on the effects of the decision, including its effect on corporations, Chief Compliance Officers, corporate compliance functions and the Securities and Exchange Commission.

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]]> 1303 no Compliance into the Weeds-71 In this episode Matt Kelly and I go meta as we podcast about another podcast that Matt posted this week on his site, Radical Compliance, where he interviewed Paul Sobel, the incoming Chairman of COSO. We discuss how Sobel sees his new role at COSO, some of the initiatives that he has in mind for the organization and how companies can use the various COSO frameworks, including the Internal Controls and ERM frameworks to better manage risk some the strategic perspective.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 21 Feb 2018 17:00:00 -0000 The Meta Episode full 71 Tom Fox The Meta Episode In this episode Matt Kelly and I go meta as we podcast about another podcast that Matt posted this week on his site, Radical Compliance, where he interviewed Paul Sobel, the incoming Chairman of COSO. We discuss how Sobel sees his new role at COSO, some of the initiatives that he has in mind for the organization and how companies can use the various COSO frameworks, including the Internal Controls and ERM frameworks to better manage risk some the strategic perspective.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I go meta as we podcast about another podcast that Matt posted this week on his site, Radical Compliance, where he interviewed Paul Sobel, the incoming Chairman of COSO. We discuss how Sobel sees his new role at COSO, some of the initiatives that he has in mind for the organization and how companies can use the various COSO frameworks, including the Internal Controls and ERM frameworks to better manage risk some the strategic perspective. 

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]]> 1312 no Compliance into the Weeds-Episode 70 In this episode, Matt Kelly and I go into the weeds on the fascinating subject relating to the intersection of compliance and technology: AI and hotlines. We explore how this phone app can assist the compliance practitioner by using technology to overcome the inherent tension in an anonymous reporting system where the reporter may desire anonymity while the CCO wants and needs as much information as possible.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Feb 2018 17:05:00 -0000 AI in a Hotline App full 70 Tom Fox AI in a Hotline App In this episode, Matt Kelly and I go into the weeds on the fascinating subject relating to the intersection of compliance and technology: AI and hotlines. We explore how this phone app can assist the compliance practitioner by using technology to overcome the inherent tension in an anonymous reporting system where the reporter may desire anonymity while the CCO wants and needs as much information as possible.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I go into the weeds on the fascinating subject relating to the intersection of compliance and technology: AI and hotlines. We explore how this phone app can assist the compliance practitioner by using technology to overcome the inherent tension in an anonymous reporting system where the reporter may desire anonymity while the CCO wants and needs as much information as possible. 

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]]> 1014 no Compliance into the Weeds-Episode 69 In this episode, Matt Kelly and I take a deep dive into the events which led to the resignation of Steve Wynn as the CEO and Chairman of Wynn Casinos for sexual harassment and misconduct.  Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 08 Feb 2018 17:00:00 -0000 Steve Wynn, Corporate Governance and the Board of Directors full 69 Tom Fox Steve Wynn, Corporate Governance and the Board of Directors In this episode, Matt Kelly and I take a deep dive into the events which led to the resignation of Steve Wynn as the CEO and Chairman of Wynn Casinos for sexual harassment and misconduct.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the events which led to the resignation of Steve Wynn as the CEO and Chairman of Wynn Casinos for sexual harassment and misconduct. 

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]]> 1208 no Compliance into the Weeds-Episode 68 In this episode Matt Kelly and myself take a deep dive into the weeds of the recent remarks by Neomi Rao, head of the Office for Information and Regulatory Affairs (OIRA), the Administration’s top regulatory review office outlining ambitious plans for more deregulation in 2018 — including efforts to sweep independent federal agencies into her purview and to crack down on the “sub-regulatory” guidance that corporate compliance professionals consume all the time. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 31 Jan 2018 17:00:00 -0000 On the Guillotine, Waiting for Godot and Candyland full 68 Tom Fox On the Guillotine, Waiting for Godot and Candyland In this episode Matt Kelly and myself take a deep dive into the weeds of the recent remarks by Neomi Rao, head of the Office for Information and Regulatory Affairs (OIRA), the Administration’s top regulatory review office outlining ambitious plans for more deregulation in 2018 — including efforts to sweep independent federal agencies into her purview and to crack down on the “sub-regulatory” guidance that corporate compliance professionals consume all the time. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and myself take a deep dive into the weeds of the recent remarks by Neomi Rao, head of the Office for Information and Regulatory Affairs (OIRA), the Administration’s top regulatory review office outlining ambitious plans for more deregulation in 2018 — including efforts to sweep independent federal agencies into her purview and to crack down on the “sub-regulatory” guidance that corporate compliance professionals consume all the time.

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]]> 1239 no Compliance into the Weeds-Episode 67 In this episode Matt Kelly and I take a deep dive into the absolutely stunning indictment of five former partners or employees of KPMG and one former employee at the Public Company Oversight Accounting Board (PCAOB). L Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 Jan 2018 17:00:00 -0000 The KPMG Indictments full 67 Tom Fox The KPMG Indictments In this episode Matt Kelly and I take a deep dive into the absolutely stunning indictment of five former partners or employees of KPMG and one former employee at the Public Company Oversight Accounting Board (PCAOB). L Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take a deep dive into the absolutely stunning indictment of five former partners or employees of KPMG and one former employee at the Public Company Oversight Accounting Board (PCAOB). L

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]]> 1408 no Compliance into the Weeds-Episode 66 In this episode Matt Kelly and I take a deep dive into a fascinating paper from Harvard Business School. Boris Groysberg and George Serafeim, worked with a global recruitment firm to study more than 2,000 executive-level job placements from 2004 to 2011, examining a wide range of job placements and pay data since 2004. They found that the stigma of listing a discredited company on your resume, even if you had nothing to do with the misconduct there, leads recruiters at your next employer to pay you less. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 Jan 2018 20:53:00 -0000 The Salary Penalty for Misconduct full 66 Tom Fox The Salary Penalty for Misconduct In this episode Matt Kelly and I take a deep dive into a fascinating paper from Harvard Business School. Boris Groysberg and George Serafeim, worked with a global recruitment firm to study more than 2,000 executive-level job placements from 2004 to 2011, examining a wide range of job placements and pay data since 2004. They found that the stigma of listing a discredited company on your resume, even if you had nothing to do with the misconduct there, leads recruiters at your next employer to pay you less. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take a deep dive into a fascinating paper from Harvard Business School. Boris Groysberg and George Serafeim, worked with a global recruitment firm to study more than 2,000 executive-level job placements from 2004 to 2011, examining a wide range of job placements and pay data since 2004. They found that the stigma of listing a discredited company on your resume, even if you had nothing to do with the misconduct there, leads recruiters at your next employer to pay you less.

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]]> 1624 no Compliance into the Weeds-Episode 65 In this episode Matt Kelly and I take deep dive into the issue of non-GAAP metrics and its implications. We were inspired an article in this quarter's MIT Sloan Management Review entitled, "The Pitfalls of Non-GAAP Metrics". It is fascinating review of this topic, which "Lurking within the financial statements and communications of public companies is a troubling trend. Alternative metrics, once used sparingly, have become increasingly ubiquitous and more detached from reality."  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 10 Jan 2018 17:00:00 -0000 The Trouble with Non-GAAP Metrics full 65 Tom Fox The Trouble with Non-GAAP Metrics In this episode Matt Kelly and I take deep dive into the issue of non-GAAP metrics and its implications. We were inspired an article in this quarter's MIT Sloan Management Review entitled, "The Pitfalls of Non-GAAP Metrics". It is fascinating review of this topic, which "Lurking within the financial statements and communications of public companies is a troubling trend. Alternative metrics, once used sparingly, have become increasingly ubiquitous and more detached from reality."  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take deep dive into the issue of non-GAAP metrics and its implications. We were inspired an article in this quarter's MIT Sloan Management Review entitled, "The Pitfalls of Non-GAAP Metrics". It is fascinating review of this topic, which "Lurking within the financial statements and communications of public companies is a troubling trend. Alternative metrics, once used sparingly, have become increasingly ubiquitous and more detached from reality." 

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]]> 1208 no Compliance into the Weeds-Episode 64 In this episode, Matt Kelly and I take a look at some of the more intriguing issues in compliance and ethics, FCPA and greater GRC issues in the new year of 2018. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 Jan 2018 17:00:00 -0000 A look into 2018 issues full 64 Tom Fox A look into 2018 issues In this episode, Matt Kelly and I take a look at some of the more intriguing issues in compliance and ethics, FCPA and greater GRC issues in the new year of 2018. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a look at some of the more intriguing issues in compliance and ethics, FCPA and greater GRC issues in the new year of 2018.

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]]> 1517 no Compliance into the Weeds-Episode 60 In this podcast, we consider the joint role of a GC-CCO and the potential corporate governance issues involved when the roles are held by one person. Does this create an irreconcilable conflict? What are the different functions of the General Counsel and the Chief Compliance Officer. Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 14 Nov 2017 17:00:00 -0000 Cardinal Health and Joint GC-CCO Role full 60 Tom Fox Cardinal Health and Joint GC-CCO Role In this podcast, we consider the joint role of a GC-CCO and the potential corporate governance issues involved when the roles are held by one person. Does this create an irreconcilable conflict? What are the different functions of the General Counsel and the Chief Compliance Officer. Learn more about your ad choices. Visit megaphone.fm/adchoices In this podcast, we consider the joint role of a GC-CCO and the potential corporate governance issues involved when the roles are held by one person. Does this create an irreconcilable conflict? What are the different functions of the General Counsel and the Chief Compliance Officer.

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]]> 1223 no Compliance into the Weeds-Episode 59 What will be the fate of the Justice Department's Evaluation of Corporate Compliance Programs going forward under the Sessions Department of Justice.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Nov 2017 17:00:00 -0000 The Fate of the Evaluation full 59 Tom Fox The Fate of the Evaluation What will be the fate of the Justice Department's Evaluation of Corporate Compliance Programs going forward under the Sessions Department of Justice.  Learn more about your ad choices. Visit megaphone.fm/adchoices What will be the fate of the Justice Department's Evaluation of Corporate Compliance Programs going forward under the Sessions Department of Justice. 

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]]> 1283 no Compliance into the Weeds-Episode 58 In this episode, Matt Kelly and I take a deep dive into the scandal around Harvey Weinstein. We consider it from the compliance perspective, both programatic and for the CCO. We consider the different types of harassment which comes may face claims of from the fallout. We also consider the Board response by The Weinstein Company board and for the claims involving Bill O'Reilly.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Nov 2017 16:00:00 -0000 The Weinstein Affair and Compliance full 58 Tom Fox The Weinstein Affair and Compliance In this episode, Matt Kelly and I take a deep dive into the scandal around Harvey Weinstein. We consider it from the compliance perspective, both programatic and for the CCO. We consider the different types of harassment which comes may face claims of from the fallout. We also consider the Board response by The Weinstein Company board and for the claims involving Bill O'Reilly.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the scandal around Harvey Weinstein. We consider it from the compliance perspective, both programatic and for the CCO. We consider the different types of harassment which comes may face claims of from the fallout. We also consider the Board response by The Weinstein Company board and for the claims involving Bill O'Reilly. 

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]]> 1477 no Compliance into the Weeds-Episode 56 In this episode, Matt Kelly and I take a deep dive into an article by Todd Haugh, in the most recent issue of the MIT Sloan Management Review entitled, “The Trouble With Corporate Compliance Programs” that even best practices compliance program fail to take into account behavioral best practices and one important but too often overlooked key to strengthening both individual and overall corporate behavior is eliminating rationalizations.   Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 03 Oct 2017 16:00:00 -0000 The Fraud Triangle, Rationalizations and Compliance Programs full 56 Tom Fox The Fraud Triangle, Rationalizations and Compliance Programs In this episode, Matt Kelly and I take a deep dive into an article by Todd Haugh, in the most recent issue of the MIT Sloan Management Review entitled, “The Trouble With Corporate Compliance Programs” that even best practices compliance program fail to take into account behavioral best practices and one important but too often overlooked key to strengthening both individual and overall corporate behavior is eliminating rationalizations.   Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into an article by Todd Haugh, in the most recent issue of the MIT Sloan Management Review entitled, “The Trouble With Corporate Compliance Programs” that even best practices compliance program fail to take into account behavioral best practices and one important but too often overlooked key to strengthening both individual and overall corporate behavior is eliminating rationalizations.  

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]]> 1454 no Compliance into the Weeds-Episode 55 The Telia FCPA enforcement action is the Number 1 all-time for fines and penalties. What can you learn from it? Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 26 Sep 2017 12:45:00 -0000 The Telia FCPA Resolution full 55 Tom Fox The Telia FCPA Resolution The Telia FCPA enforcement action is the Number 1 all-time for fines and penalties. What can you learn from it? Learn more about your ad choices. Visit megaphone.fm/adchoices The Telia FCPA enforcement action is the Number 1 all-time for fines and penalties. What can you learn from it?

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]]> 1471 no Compliance into the Weeds-Episode 54 Matt reports live from TEC 2017, the Workiva user summit Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 20 Sep 2017 10:43:00 -0000 Report from TEC 2017 full 54 Tom Fox Report from TEC 2017 Matt reports live from TEC 2017, the Workiva user summit Learn more about your ad choices. Visit megaphone.fm/adchoices Matt reports live from TEC 2017, the Workiva user summit

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]]> 1245 no Compliance into the Weeds-Episode 52 In this episode, Matt Kelly and I take a deep dive into the good, bad and ugly of Hurricane Harvey for the compliance professional. We discuss what lessons may be drawn from the storm and its aftermath for the greater compliance, ERM and business communities and the need to take a much greater holistic approach to the consideration of your risk management strategy. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 06 Sep 2017 16:00:00 -0000 The Post Harvey Edition full 52 Tom Fox The Post Harvey Edition In this episode, Matt Kelly and I take a deep dive into the good, bad and ugly of Hurricane Harvey for the compliance professional. We discuss what lessons may be drawn from the storm and its aftermath for the greater compliance, ERM and business communities and the need to take a much greater holistic approach to the consideration of your risk management strategy. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the good, bad and ugly of Hurricane Harvey for the compliance professional. We discuss what lessons may be drawn from the storm and its aftermath for the greater compliance, ERM and business communities and the need to take a much greater holistic approach to the consideration of your risk management strategy.

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]]> 1117 no Compliance into the Weeds-Episode 51 What is the intersection of the PCAOB, auditing and compliance? Matt Kelly and I explore in this week's episode. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 23 Aug 2017 16:00:00 -0000 The PCAOB and Compliance full 51 Tom Fox The PCAOB and Compliance What is the intersection of the PCAOB, auditing and compliance? Matt Kelly and I explore in this week's episode. Learn more about your ad choices. Visit megaphone.fm/adchoices What is the intersection of the PCAOB, auditing and compliance? Matt Kelly and I explore in this week's episode.

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]]> 1576 no Compliance into the Weeds-Episode 50 What is the upside to any US business engaging with the Trump Administration after its tepid response to the events in Charlottesville? Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 16 Aug 2017 14:00:00 -0000 Where’s the Upside? full 50 Tom Fox Where’s the Upside? What is the upside to any US business engaging with the Trump Administration after its tepid response to the events in Charlottesville? Learn more about your ad choices. Visit megaphone.fm/adchoices What is the upside to any US business engaging with the Trump Administration after its tepid response to the events in Charlottesville?

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]]> 1471 no Compliance into the Weeds-Episode 49 The Mattis Memo on ethics is so significant that every CCO and compliance practitioner should read it and the Memo's substance into your compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 09 Aug 2017 15:00:00 -0000 The Mattis Memo on Ethics full 49 Tom Fox The Mattis Memo on Ethics The Mattis Memo on ethics is so significant that every CCO and compliance practitioner should read it and the Memo's substance into your compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices The Mattis Memo on ethics is so significant that every CCO and compliance practitioner should read it and the Memo's substance into your compliance program.

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]]> 1489 no Compliance into the Weeds-Episode 48 We consider the enforcement action around the issue of internal controls, their effectiveness (or lack thereof) and management over-ride of internal controls. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 02 Aug 2017 16:00:00 -0000 Halliburton FCPA Enforcement Action full 48 Tom Fox Halliburton FCPA Enforcement Action We consider the enforcement action around the issue of internal controls, their effectiveness (or lack thereof) and management over-ride of internal controls. Learn more about your ad choices. Visit megaphone.fm/adchoices We consider the enforcement action around the issue of internal controls, their effectiveness (or lack thereof) and management over-ride of internal controls.

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]]> 1384 no Compliance into the Weeds-Episode 47 In this episode, Matt Kelly and I take a deep dive into the Dodd-Frank and Sarbanes-Oxley reform initiatives in the House of Representatives and as articulated by incoming SEC Chairman Jay Clayton. Will the new administration gut SOX and Dodd-Frank compliance requirements? For more see Matt Kelly's blog post SEC Chair Clayton Talks Compliance Costs.  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 26 Jul 2017 14:00:00 -0000 Compliance Costs Under SOX and Dodd-Frank full 47 Tom Fox Compliance Costs Under SOX and Dodd-Frank In this episode, Matt Kelly and I take a deep dive into the Dodd-Frank and Sarbanes-Oxley reform initiatives in the House of Representatives and as articulated by incoming SEC Chairman Jay Clayton. Will the new administration gut SOX and Dodd-Frank compliance requirements? For more see Matt Kelly's blog post SEC Chair Clayton Talks Compliance Costs.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the Dodd-Frank and Sarbanes-Oxley reform initiatives in the House of Representatives and as articulated by incoming SEC Chairman Jay Clayton. Will the new administration gut SOX and Dodd-Frank compliance requirements? For more see Matt Kelly's blog post SEC Chair Clayton Talks Compliance Costs. 

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]]> 1478 no Compliance into the Weeds-Episode 46 In this episode, Matt Kelly and I discuss the recent Second Circuit Court of Appeals decision in HSBC v. Moore. In this case a federal district court had ordered the release of redacted monitor’s report in the HSBC money-laundering Deferred Prosecution Agreement (DPA), based upon the request of an interested citizen. Both the Department of Justice (DOJ) and HSBC appealed the order and the Court of Appeals supported their position in overturning the trial court’s decision. The case is about a hook, line and sinker overturning of any trial court jurisdiction as one can have. The district court tried to claim it did not have the same role as a “potted plant” but the Court of Appeals left no doubt that is the only role it sees for any district court where a DPA is filed. We discuss the implications for the compliance practitioner, FCPA enforcement and any potential changes going forward.  For additional reading, see my blog post on this case by clicking  here. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 19 Jul 2017 13:52:00 -0000 full Tom Fox The Potted Plant Edition In this episode, Matt Kelly and I discuss the recent Second Circuit Court of Appeals decision in HSBC v. Moore. In this case a federal district court had ordered the release of redacted monitor’s report in the HSBC money-laundering Deferred Prosecution Agreement (DPA), based upon the request of an interested citizen. Both the Department of Justice (DOJ) and HSBC appealed the order and the Court of Appeals supported their position in overturning the trial court’s decision. The case is about a hook, line and sinker overturning of any trial court jurisdiction as one can have. The district court tried to claim it did not have the same role as a “potted plant” but the Court of Appeals left no doubt that is the only role it sees for any district court where a DPA is filed. We discuss the implications for the compliance practitioner, FCPA enforcement and any potential changes going forward.  For additional reading, see my blog post on this case by clicking  here. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I discuss the recent Second Circuit Court of Appeals decision in HSBC v. Moore. In this case a federal district court had ordered the release of redacted monitor’s report in the HSBC money-laundering Deferred Prosecution Agreement (DPA), based upon the request of an interested citizen. Both the Department of Justice (DOJ) and HSBC appealed the order and the Court of Appeals supported their position in overturning the trial court’s decision. The case is about a hook, line and sinker overturning of any trial court jurisdiction as one can have. The district court tried to claim it did not have the same role as a “potted plant” but the Court of Appeals left no doubt that is the only role it sees for any district court where a DPA is filed. We discuss the implications for the compliance practitioner, FCPA enforcement and any potential changes going forward. 

For additional reading, see my blog post on this case by clicking  here.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1221 no Compliance into the Weeds-Episode 45 In this episode, Matt Kelly and I take a deep dive into the 4th of July weekend use of the New Jersey beaches by Governor Chris Christie. Governor Christie had closed the beaches in a budget dispute but was still able, as Governor, to give himself and his family full access to the now wide open beaches on the recently passes holiday weekend. We consider Governor Christie’s example of undeserved privilege in the context of ethical leadership and tone at the top. Matt draws upon his Catholic school education to remind us that undeserved privilege is private law, as “privilege” comes from the Latin privus, private law; and lex, law. It’s a private law that benefits only one person, who doesn’t deserve it.  Read more about the issue and Matt’s thoughts on his blog post  Tone at the Top Gone Wrong: The Christie Example. Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 11 Jul 2017 14:00:00 -0000 full Tom Fox The Undeserved Privilege Edition In this episode, Matt Kelly and I take a deep dive into the 4th of July weekend use of the New Jersey beaches by Governor Chris Christie. Governor Christie had closed the beaches in a budget dispute but was still able, as Governor, to give himself and his family full access to the now wide open beaches on the recently passes holiday weekend. We consider Governor Christie’s example of undeserved privilege in the context of ethical leadership and tone at the top. Matt draws upon his Catholic school education to remind us that undeserved privilege is private law, as “privilege” comes from the Latin privus, private law; and lex, law. It’s a private law that benefits only one person, who doesn’t deserve it.  Read more about the issue and Matt’s thoughts on his blog post  Tone at the Top Gone Wrong: The Christie Example. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the 4th of July weekend use of the New Jersey beaches by Governor Chris Christie. Governor Christie had closed the beaches in a budget dispute but was still able, as Governor, to give himself and his family full access to the now wide open beaches on the recently passes holiday weekend. We consider Governor Christie’s example of undeserved privilege in the context of ethical leadership and tone at the top. Matt draws upon his Catholic school education to remind us that undeserved privilege is private law, as “privilege” comes from the Latin privus, private law; and lex, law. It’s a private law that benefits only one person, who doesn’t deserve it. 

Read more about the issue and Matt’s thoughts on his blog post  Tone at the Top Gone Wrong: The Christie Example.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 967 no Compliance into the Weeds-Episode 44 In this episode, Matt Kelly and I take a deep dive, literally into the weeds of the convergence of the compliance profession and the nascent cannabis industry. While several states have made pot for medical use legal and one state, Colorado has made it legal for personal consumption, it is still illegal under federal law. We consider such questions as: Lawyers and accountants are required to report large cash transactions to the federal government—but large cash transactions are common in the cannabis industry, since commercial operators don’t have easy access to the banking system. So if you report one of these transactions, are you turning over evidence of illegal activities of your client to authorities? Or do you not report, and risk sanctions against yourself?If the Justice Department does act against a commercial weed business, will prosecutors really seek to impanel a federal grand jury, with jurors drawn from a state where they voted to legalize? Could prosecutors ask a candidate juror whether he or she smokes weed? Could that juror invoke the Fifth Amendment?Should lawyers be allowed to own equity in a legally operating marijuana business? What about judges? Do the two groups need different standards? Professional conduct rules for lawyers require competency in rendering legal advice. What does competency even look like in this branch of business conduct, when the laws are so new and in conflict with federal law?Will the nascence of the cannabis industry allow for innovations such as incorporation of blockchain to create fully auditable trails for all aspects of the business?Will any state which taxes cannabis sales be required to remit this money under a theory of profit disgorgement from funds generated by illegal activity.For more from Matt Kelly: See his blog post  Compliance, Careers and Cannabis Industry; Hear Matt Kelly’s interview with Amy McDougal (yes Matt has his own podcast as well-the Radical Compliance podcast) by clicking  here. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 28 Jun 2017 14:00:00 -0000 full Tom Fox Compliance and the Cannabis Industry In this episode, Matt Kelly and I take a deep dive, literally into the weeds of the convergence of the compliance profession and the nascent cannabis industry. While several states have made pot for medical use legal and one state, Colorado has made it legal for personal consumption, it is still illegal under federal law. We consider such questions as: Lawyers and accountants are required to report large cash transactions to the federal government—but large cash transactions are common in the cannabis industry, since commercial operators don’t have easy access to the banking system. So if you report one of these transactions, are you turning over evidence of illegal activities of your client to authorities? Or do you not report, and risk sanctions against yourself?If the Justice Department does act against a commercial weed business, will prosecutors really seek to impanel a federal grand jury, with jurors drawn from a state where they voted to legalize? Could prosecutors ask a candidate juror whether he or she smokes weed? Could that juror invoke the Fifth Amendment?Should lawyers be allowed to own equity in a legally operating marijuana business? What about judges? Do the two groups need different standards? Professional conduct rules for lawyers require competency in rendering legal advice. What does competency even look like in this branch of business conduct, when the laws are so new and in conflict with federal law?Will the nascence of the cannabis industry allow for innovations such as incorporation of blockchain to create fully auditable trails for all aspects of the business?Will any state which taxes cannabis sales be required to remit this money under a theory of profit disgorgement from funds generated by illegal activity.For more from Matt Kelly: See his blog post  Compliance, Careers and Cannabis Industry; Hear Matt Kelly’s interview with Amy McDougal (yes Matt has his own podcast as well-the Radical Compliance podcast) by clicking  here. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive, literally into the weeds of the convergence of the compliance profession and the nascent cannabis industry. While several states have made pot for medical use legal and one state, Colorado has made it legal for personal consumption, it is still illegal under federal law. We consider such questions as:

Lawyers and accountants are required to report large cash transactions to the federal government—but large cash transactions are common in the cannabis industry, since commercial operators don’t have easy access to the banking system. So if you report one of these transactions, are you turning over evidence of illegal activities of your client to authorities? Or do you not report, and risk sanctions against yourself?If the Justice Department does act against a commercial weed business, will prosecutors really seek to impanel a federal grand jury, with jurors drawn from a state where they voted to legalize? Could prosecutors ask a candidate juror whether he or she smokes weed? Could that juror invoke the Fifth Amendment?Should lawyers be allowed to own equity in a legally operating marijuana business? What about judges? Do the two groups need different standards? Professional conduct rules for lawyers require competency in rendering legal advice. What does competency even look like in this branch of business conduct, when the laws are so new and in conflict with federal law?Will the nascence of the cannabis industry allow for innovations such as incorporation of blockchain to create fully auditable trails for all aspects of the business?Will any state which taxes cannabis sales be required to remit this money under a theory of profit disgorgement from funds generated by illegal activity.For more from Matt Kelly:

See his blog post  Compliance, Careers and Cannabis Industry;

Hear Matt Kelly’s interview with Amy McDougal (yes Matt has his own podcast as well-the Radical Compliance podcast) by clicking  here.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1352 no Compliance into the Weeds-Episode 43 On June 16, 2017, the Department of Justice (DOJ) issued a Declination to Linde North American Inc. and Linde Gas North America LLC (collectively “Linde”). This is the first Declination issued by the DOJ in the era of the Trump Administration. For that reason alone, it was instructive and should be studied by the compliance profession. However, the case presented several interesting factors which merit consideration so we are discussing in depth to present lessons to be learned for the Chief Compliance Officer (CCO) or compliance practitioner. Lessons Learned This was yet another Foreign Corrupt Practices Act (FCPA) action where a company performed insufficient due diligence in the acquisition phase. The timing of the Linde purchase of Spectra Gases and Spectra Gases’ purchase of the income producing assets is too close in time to be a coincidence. It would certainly appear that Linde purchased Spectra Gases to facilitate its acquisition of the boron column and other assets. If your company is going to make such a multi-step acquisition, you must perform due diligence on all the actors and the assets involved. The Byzantine corporate structure created for the ownership of the boron column, its operation and management contract are clear red flags that any CCO should sniff out immediately. While I am sure the internal corporate excuse for this clear ruse was the ubiquitous ‘tax considerations’; every such transaction should be reviewed by compliance as well. Anytime there is more than one entity to accomplish one task, there is the possibility of fraud present. Further, it is not clear how Linde could not have been aware of the ownership interests of a company which it ultimately controlled. It would seem that the company did not even make any inquiry. Even in 2006, the Republic of Georgia’s reputation for bribery and corruption was quite high. The 2006 Transparency International-Corrupt Perceptions Index (TI-CPI) listed Georgia at 99 out of 176 countries listed so that alone warranted red flag scrutiny. If you are purchasing an entity in a country with such well known affinity for corruption, extra care is warranted. Perhaps back in 2006, Linde did not view the FCPA as something which it would deal with in such a situation. Yet even with all the apparent miss-steps and non-steps of compliance, the company was able to secure a declination from the DOJ. While there may be some additional penalties or sanctions by the Securities and Exchange Commission (SEC) for the failures of internal controls, the result obtained by Linde was certainly a superior result. The company would seem to have met the four pillars under the FCPA Pilot Program through (a) self-disclosure, (b) extraordinary cooperation, (3) full remediation, and (d) profit disgorgement. Interestingly, the profit disgorgement in this case would appear to have been beyond the five year of limitations for profit disgorgement under the recent Supreme Court decision in Kokesh. If there is a FCPA enforcement action brought by the SEC perhaps additional facts will be recited in any resolution documents. Nevertheless, kudos are due to Linde and its counsel for obtaining this declination. Every CCO should study it for both the superior result received and underlying facts to see if you face anything similar in the Republic of Georgia or elsewhere. For a full copy of the Linde Declination, click here.  Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 22 Jun 2017 14:39:00 -0000 full Tom Fox The Linde Declination On June 16, 2017, the Department of Justice (DOJ) issued a Declination to Linde North American Inc. and Linde Gas North America LLC (collectively “Linde”). This is the first Declination issued by the DOJ in the era of the Trump Administration. For that reason alone, it was instructive and should be studied by the compliance profession. However, the case presented several interesting factors which merit consideration so we are discussing in depth to present lessons to be learned for the Chief Compliance Officer (CCO) or compliance practitioner. Lessons Learned This was yet another Foreign Corrupt Practices Act (FCPA) action where a company performed insufficient due diligence in the acquisition phase. The timing of the Linde purchase of Spectra Gases and Spectra Gases’ purchase of the income producing assets is too close in time to be a coincidence. It would certainly appear that Linde purchased Spectra Gases to facilitate its acquisition of the boron column and other assets. If your company is going to make such a multi-step acquisition, you must perform due diligence on all the actors and the assets involved. The Byzantine corporate structure created for the ownership of the boron column, its operation and management contract are clear red flags that any CCO should sniff out immediately. While I am sure the internal corporate excuse for this clear ruse was the ubiquitous ‘tax considerations’; every such transaction should be reviewed by compliance as well. Anytime there is more than one entity to accomplish one task, there is the possibility of fraud present. Further, it is not clear how Linde could not have been aware of the ownership interests of a company which it ultimately controlled. It would seem that the company did not even make any inquiry. Even in 2006, the Republic of Georgia’s reputation for bribery and corruption was quite high. The 2006 Transparency International-Corrupt Perceptions Index (TI-CPI) listed Georgia at 99 out of 176 countries listed so that alone warranted red flag scrutiny. If you are purchasing an entity in a country with such well known affinity for corruption, extra care is warranted. Perhaps back in 2006, Linde did not view the FCPA as something which it would deal with in such a situation. Yet even with all the apparent miss-steps and non-steps of compliance, the company was able to secure a declination from the DOJ. While there may be some additional penalties or sanctions by the Securities and Exchange Commission (SEC) for the failures of internal controls, the result obtained by Linde was certainly a superior result. The company would seem to have met the four pillars under the FCPA Pilot Program through (a) self-disclosure, (b) extraordinary cooperation, (3) full remediation, and (d) profit disgorgement. Interestingly, the profit disgorgement in this case would appear to have been beyond the five year of limitations for profit disgorgement under the recent Supreme Court decision in Kokesh. If there is a FCPA enforcement action brought by the SEC perhaps additional facts will be recited in any resolution documents. Nevertheless, kudos are due to Linde and its counsel for obtaining this declination. Every CCO should study it for both the superior result received and underlying facts to see if you face anything similar in the Republic of Georgia or elsewhere. For a full copy of the Linde Declination, click here.  Learn more about your ad choices. Visit megaphone.fm/adchoices On June 16, 2017, the Department of Justice (DOJ) issued a Declination to Linde North American Inc. and Linde Gas North America LLC (collectively “Linde”). This is the first Declination issued by the DOJ in the era of the Trump Administration. For that reason alone, it was instructive and should be studied by the compliance profession. However, the case presented several interesting factors which merit consideration so we are discussing in depth to present lessons to be learned for the Chief Compliance Officer (CCO) or compliance practitioner.

Lessons Learned

This was yet another Foreign Corrupt Practices Act (FCPA) action where a company performed insufficient due diligence in the acquisition phase. The timing of the Linde purchase of Spectra Gases and Spectra Gases’ purchase of the income producing assets is too close in time to be a coincidence. It would certainly appear that Linde purchased Spectra Gases to facilitate its acquisition of the boron column and other assets. If your company is going to make such a multi-step acquisition, you must perform due diligence on all the actors and the assets involved.

The Byzantine corporate structure created for the ownership of the boron column, its operation and management contract are clear red flags that any CCO should sniff out immediately. While I am sure the internal corporate excuse for this clear ruse was the ubiquitous ‘tax considerations’; every such transaction should be reviewed by compliance as well. Anytime there is more than one entity to accomplish one task, there is the possibility of fraud present. Further, it is not clear how Linde could not have been aware of the ownership interests of a company which it ultimately controlled. It would seem that the company did not even make any inquiry.

Even in 2006, the Republic of Georgia’s reputation for bribery and corruption was quite high. The 2006 Transparency International-Corrupt Perceptions Index (TI-CPI) listed Georgia at 99 out of 176 countries listed so that alone warranted red flag scrutiny. If you are purchasing an entity in a country with such well known affinity for corruption, extra care is warranted. Perhaps back in 2006, Linde did not view the FCPA as something which it would deal with in such a situation.

Yet even with all the apparent miss-steps and non-steps of compliance, the company was able to secure a declination from the DOJ. While there may be some additional penalties or sanctions by the Securities and Exchange Commission (SEC) for the failures of internal controls, the result obtained by Linde was certainly a superior result. The company would seem to have met the four pillars under the FCPA Pilot Program through (a) self-disclosure, (b) extraordinary cooperation, (3) full remediation, and (d) profit disgorgement. Interestingly, the profit disgorgement in this case would appear to have been beyond the five year of limitations for profit disgorgement under the recent Supreme Court decision in Kokesh. If there is a FCPA enforcement action brought by the SEC perhaps additional facts will be recited in any resolution documents.

Nevertheless, kudos are due to Linde and its counsel for obtaining this declination. Every CCO should study it for both the superior result received and underlying facts to see if you face anything similar in the Republic of Georgia or elsewhere.

For a full copy of the Linde Declination, click here. 

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1639 no Compliance into the Weeds-Episode 42 In this episode, Matt Kelly and I take a deep dive into the corporate governance fiasco which is Uber. We consider the revelations in the failures of corporate governance, culture and internal controls at the organization. The company provides a fascinating study of what happens when a tech start up raised in the fraternity culture is successful and how changes are required for it to act like a multi-billion organization. Both Matt and I have written on Uber. Our podcast comes out the same day the Holder Report to the Uber Board was released so we weave in the recommendations from Covington & Burling as well.  For more on Uber see the following:  Matt Kelly’s piece  Car Crash Governance at Uber Tom Fox’s pieces on Uber  Will Culture Change at Uber Before its Too Late  CEOs and Win at All Costs-Where Does it Lead  Uber and Corporate Culture   For a copy of the Holder Report on corporate governance, cultural and internal controls failures at Uber and recommendations, click  here. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Jun 2017 12:00:00 -0000 full Tom Fox The Uber Governance Edition In this episode, Matt Kelly and I take a deep dive into the corporate governance fiasco which is Uber. We consider the revelations in the failures of corporate governance, culture and internal controls at the organization. The company provides a fascinating study of what happens when a tech start up raised in the fraternity culture is successful and how changes are required for it to act like a multi-billion organization. Both Matt and I have written on Uber. Our podcast comes out the same day the Holder Report to the Uber Board was released so we weave in the recommendations from Covington & Burling as well.  For more on Uber see the following:  Matt Kelly’s piece  Car Crash Governance at Uber Tom Fox’s pieces on Uber  Will Culture Change at Uber Before its Too Late  CEOs and Win at All Costs-Where Does it Lead  Uber and Corporate Culture   For a copy of the Holder Report on corporate governance, cultural and internal controls failures at Uber and recommendations, click  here. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the corporate governance fiasco which is Uber. We consider the revelations in the failures of corporate governance, culture and internal controls at the organization. The company provides a fascinating study of what happens when a tech start up raised in the fraternity culture is successful and how changes are required for it to act like a multi-billion organization. Both Matt and I have written on Uber. Our podcast comes out the same day the Holder Report to the Uber Board was released so we weave in the recommendations from Covington & Burling as well. 

For more on Uber see the following: 

Matt Kelly’s piece  Car Crash Governance at Uber

Tom Fox’s pieces on Uber

 Will Culture Change at Uber Before its Too Late

 CEOs and Win at All Costs-Where Does it Lead

 Uber and Corporate Culture

 

For a copy of the Holder Report on corporate governance, cultural and internal controls failures at Uber and recommendations, click  here.

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]]> 1203 no Compliance into the Weeds-Episode 40 In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM Framework into functional business units moving to operationalize ERM in organizations and we consider how the ERM Framework differs yet is complimentary to the COSO Internal Controls Framework.    For additional information, see Matt's Blogs posts on the COSO ERM Framework:  More Details on COSO ERM Framework  Update to COSO ERM Framework Update  ERM Framework: Govt. Calls for Unity  More Clues on Draft ERM Framework  Draft ERM Framework is Here: How to Get Started Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 31 May 2017 14:57:00 -0000 full Tom Fox COSO ERM Framework Update In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM Framework into functional business units moving to operationalize ERM in organizations and we consider how the ERM Framework differs yet is complimentary to the COSO Internal Controls Framework.    For additional information, see Matt's Blogs posts on the COSO ERM Framework:  More Details on COSO ERM Framework  Update to COSO ERM Framework Update  ERM Framework: Govt. Calls for Unity  More Clues on Draft ERM Framework  Draft ERM Framework is Here: How to Get Started Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM Framework into functional business units moving to operationalize ERM in organizations and we consider how the ERM Framework differs yet is complimentary to the COSO Internal Controls Framework. 

 

For additional information, see Matt's Blogs posts on the COSO ERM Framework:

 More Details on COSO ERM Framework

 Update to COSO ERM Framework Update

 ERM Framework: Govt. Calls for Unity

 More Clues on Draft ERM Framework

 Draft ERM Framework is Here: How to Get Started

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]]> 1402 no Compliance into the Weeds-Episode 39 In this episode Matt Kelly and I take a deep dive into the question of whether a company has a duty to disclose ransomware attacks. We consider it from the regulatory, legal, ethical, law enforcement, business, PR and some other angles. What may seem to be a straight-forward answer to a regulatory obligations turns out to be anything but.  For additional research, see Matt Kelly's blogpost, "Ransomware: To Disclose or Not". Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 24 May 2017 12:00:00 -0000 full Tom Fox Disclosure of Ransomware Attacks In this episode Matt Kelly and I take a deep dive into the question of whether a company has a duty to disclose ransomware attacks. We consider it from the regulatory, legal, ethical, law enforcement, business, PR and some other angles. What may seem to be a straight-forward answer to a regulatory obligations turns out to be anything but.  For additional research, see Matt Kelly's blogpost, "Ransomware: To Disclose or Not". Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take a deep dive into the question of whether a company has a duty to disclose ransomware attacks. We consider it from the regulatory, legal, ethical, law enforcement, business, PR and some other angles. What may seem to be a straight-forward answer to a regulatory obligations turns out to be anything but. 

For additional research, see Matt Kelly's blogpost, "Ransomware: To Disclose or Not".

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]]> 1197 no Compliance into the Weeds-Episode 38 In this episode Matt Kelly and I take a deep dive into the cutting edge topic of artificial intelligence in many areas, including compliance. We discuss the uses of Artificial Intelligence in compliance. We consider how AI has progressed and what it means now for the compliance practitioner and what it will mean in the future. For Matt's blog post on the topic go to  Don't Outsmart Yourself: AI and Compliance For Tom's blog post on the topic go to AI for Risk Management: A New Business Advantage  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 17 May 2017 12:00:00 -0000 full Tom Fox AI and Compliance In this episode Matt Kelly and I take a deep dive into the cutting edge topic of artificial intelligence in many areas, including compliance. We discuss the uses of Artificial Intelligence in compliance. We consider how AI has progressed and what it means now for the compliance practitioner and what it will mean in the future. For Matt's blog post on the topic go to  Don't Outsmart Yourself: AI and Compliance For Tom's blog post on the topic go to AI for Risk Management: A New Business Advantage  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take a deep dive into the cutting edge topic of artificial intelligence in many areas, including compliance. We discuss the uses of Artificial Intelligence in compliance. We consider how AI has progressed and what it means now for the compliance practitioner and what it will mean in the future.

For Matt's blog post on the topic go to  Don't Outsmart Yourself: AI and Compliance

For Tom's blog post on the topic go to AI for Risk Management: A New Business Advantage 

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]]> 1301 no Compliance into the Weeds-Episode 37 In this episode, Matt Kelly and I take a deep dive into the weeds of the soon-to-be-released the House Financial Services Committee, the Financial Choice 2.0 Act. We consider some of the ideas in the legislation which Matt thinks are bad including: 1. Repeal of the Chevron deference repealed.  2. Attempts to clip the SEC rule making authority. 3. Exempting more companies which desire to go public from SOX 404(b) requirements and reporting.  4. (Matt's most particular bad idea) The exemption of more filers exempted from XBRL reporting. We also discuss some of the potential benefits from the legislation and where it may all go in the Senate. For more see Matt's blog post House GOP Regulatory Reform Axe, on his site Radical Compliance.     Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 03 May 2017 12:00:00 -0000 full Tom Fox House Financial Services Committee Financial Choice 2.0 Act In this episode, Matt Kelly and I take a deep dive into the weeds of the soon-to-be-released the House Financial Services Committee, the Financial Choice 2.0 Act. We consider some of the ideas in the legislation which Matt thinks are bad including: 1. Repeal of the Chevron deference repealed.  2. Attempts to clip the SEC rule making authority. 3. Exempting more companies which desire to go public from SOX 404(b) requirements and reporting.  4. (Matt's most particular bad idea) The exemption of more filers exempted from XBRL reporting. We also discuss some of the potential benefits from the legislation and where it may all go in the Senate. For more see Matt's blog post House GOP Regulatory Reform Axe, on his site Radical Compliance.     Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into the weeds of the soon-to-be-released the House Financial Services Committee, the Financial Choice 2.0 Act. We consider some of the ideas in the legislation which Matt thinks are bad including:

1. Repeal of the Chevron deference repealed. 

2. Attempts to clip the SEC rule making authority.

3. Exempting more companies which desire to go public from SOX 404(b) requirements and reporting. 

4. (Matt's most particular bad idea) The exemption of more filers exempted from XBRL reporting.

We also discuss some of the potential benefits from the legislation and where it may all go in the Senate.

For more see Matt's blog post House GOP Regulatory Reform Axe, on his site Radical Compliance. 

  

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]]> 1353 no Compliance into the Weeds-Episode 36 In this episode, Matt Kelly and I take a very deep dive into two recent speeches by Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden in which he addressed multiple topics and issues around the Foreign Corrupt Practices Act (FCPA). The  first set of remarks were made in Washington DC at the Anti-Corruption, Export Controls & Sanctions (ACES) 10th Compliance Summit (the “DC speech”). The  second set of remarks were made at the American Conference Institute (ACI) 19th Conference on the FCPA in New York City (the “NYC speech”). We consider the evolving rationale for FCPA enforcement which has changed in the 40 years since it was enacted, the mandatory corporate response to FCPA compliance requirements, and how McFadden sees Justice Department enforcement of the FCPA going forward in the Trump administration.  For Matt Kelly blog post on McFadden's remarks, click  here. For Tom Fox's segments of a three part series, click here for  Part I, Part II and Part III.  Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 25 Apr 2017 14:00:00 -0000 full Tom Fox Trevor McFadden on FCPA Enforcement In this episode, Matt Kelly and I take a very deep dive into two recent speeches by Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden in which he addressed multiple topics and issues around the Foreign Corrupt Practices Act (FCPA). The  first set of remarks were made in Washington DC at the Anti-Corruption, Export Controls & Sanctions (ACES) 10th Compliance Summit (the “DC speech”). The  second set of remarks were made at the American Conference Institute (ACI) 19th Conference on the FCPA in New York City (the “NYC speech”). We consider the evolving rationale for FCPA enforcement which has changed in the 40 years since it was enacted, the mandatory corporate response to FCPA compliance requirements, and how McFadden sees Justice Department enforcement of the FCPA going forward in the Trump administration.  For Matt Kelly blog post on McFadden's remarks, click  here. For Tom Fox's segments of a three part series, click here for  Part I, Part II and Part III.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a very deep dive into two recent speeches by Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden in which he addressed multiple topics and issues around the Foreign Corrupt Practices Act (FCPA). The  first set of remarks were made in Washington DC at the Anti-Corruption, Export Controls & Sanctions (ACES) 10th Compliance Summit (the “DC speech”). The  second set of remarks were made at the American Conference Institute (ACI) 19th Conference on the FCPA in New York City (the “NYC speech”). We consider the evolving rationale for FCPA enforcement which has changed in the 40 years since it was enacted, the mandatory corporate response to FCPA compliance requirements, and how McFadden sees Justice Department enforcement of the FCPA going forward in the Trump administration. 

For Matt Kelly blog post on McFadden's remarks, click  here. For Tom Fox's segments of a three part series, click here for  Part I, Part II and Part III. 

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]]> 1306 no Compliance into the Weeds-Episode 35 In this episode Matt Kelly and I take a deep dive into the recently released, Public Company Accounting Oversight Board (PCAOB) semi-annual  white paper. The white paper providing general information about certain characteristics of emerging growth companies (EGCs). Matt and I discuss some of the PCAOB's key findings: There were 1,951 companies that identified themselves as EGCs in at least one SEC filing since 2012 and have filed audited financial statements with the SEC in the 18 months preceding the measurement date (“EGC filers”). The PCAOB staff observe that the number of EGC filers has grown since the enactment of the Jumpstart Our Business Startups (JOBS) Act, but has stabilized recently.There were 742 EGC filers (or 38 percent) that have common equity securities listed on a U.S. national securities exchange (“exchange-listed”). The five most common industries for EGC filers as of November 16, 2016, are pharmaceutical preparations, blank check companies, real estate investment trusts, prepackaged software, and surgical/medical instruments and apparatus.Many EGC filers that were not exchange-listed had limited operations. Approximately 50 percent of the non-listed EGC filers reported zero revenue in their most recent filing with audited financial statements and 23 percent of non-listed EGCs that filed periodic reports disclosed that they were shell companies.Approximately 51 percent of EGC filers, including 74 percent of those that were not exchange-listed, received an explanatory paragraph in their most recent auditor’s report expressing substantial doubt about the company’s ability to continue as a going concern.Among the 1,951 EGC filers, 1,262 provided a management report on internal control over financial reporting in their most recent annual filing. Of those 1,262 companies, approximately 47 percent reported material weaknesses.Approximately 96 percent of EGC filers were audited by accounting firms that also audited issuers that are not EGC filers, including 39 percent of EGC filers that were audited by firms that provided audit reports for more than 100 issuers and were required to be inspected on an annual basis by the PCAOB. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 12 Apr 2017 14:00:00 -0000 full Tom Fox PCAOB Report on Emerging Growth Companies In this episode Matt Kelly and I take a deep dive into the recently released, Public Company Accounting Oversight Board (PCAOB) semi-annual  white paper. The white paper providing general information about certain characteristics of emerging growth companies (EGCs). Matt and I discuss some of the PCAOB's key findings: There were 1,951 companies that identified themselves as EGCs in at least one SEC filing since 2012 and have filed audited financial statements with the SEC in the 18 months preceding the measurement date (“EGC filers”). The PCAOB staff observe that the number of EGC filers has grown since the enactment of the Jumpstart Our Business Startups (JOBS) Act, but has stabilized recently.There were 742 EGC filers (or 38 percent) that have common equity securities listed on a U.S. national securities exchange (“exchange-listed”). The five most common industries for EGC filers as of November 16, 2016, are pharmaceutical preparations, blank check companies, real estate investment trusts, prepackaged software, and surgical/medical instruments and apparatus.Many EGC filers that were not exchange-listed had limited operations. Approximately 50 percent of the non-listed EGC filers reported zero revenue in their most recent filing with audited financial statements and 23 percent of non-listed EGCs that filed periodic reports disclosed that they were shell companies.Approximately 51 percent of EGC filers, including 74 percent of those that were not exchange-listed, received an explanatory paragraph in their most recent auditor’s report expressing substantial doubt about the company’s ability to continue as a going concern.Among the 1,951 EGC filers, 1,262 provided a management report on internal control over financial reporting in their most recent annual filing. Of those 1,262 companies, approximately 47 percent reported material weaknesses.Approximately 96 percent of EGC filers were audited by accounting firms that also audited issuers that are not EGC filers, including 39 percent of EGC filers that were audited by firms that provided audit reports for more than 100 issuers and were required to be inspected on an annual basis by the PCAOB. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take a deep dive into the recently released, Public Company Accounting Oversight Board (PCAOB) semi-annual  white paper. The white paper providing general information about certain characteristics of emerging growth companies (EGCs). Matt and I discuss some of the PCAOB's key findings:

There were 1,951 companies that identified themselves as EGCs in at least one SEC filing since 2012 and have filed audited financial statements with the SEC in the 18 months preceding the measurement date (“EGC filers”). The PCAOB staff observe that the number of EGC filers has grown since the enactment of the Jumpstart Our Business Startups (JOBS) Act, but has stabilized recently.There were 742 EGC filers (or 38 percent) that have common equity securities listed on a U.S. national securities exchange (“exchange-listed”). The five most common industries for EGC filers as of November 16, 2016, are pharmaceutical preparations, blank check companies, real estate investment trusts, prepackaged software, and surgical/medical instruments and apparatus.Many EGC filers that were not exchange-listed had limited operations. Approximately 50 percent of the non-listed EGC filers reported zero revenue in their most recent filing with audited financial statements and 23 percent of non-listed EGCs that filed periodic reports disclosed that they were shell companies.Approximately 51 percent of EGC filers, including 74 percent of those that were not exchange-listed, received an explanatory paragraph in their most recent auditor’s report expressing substantial doubt about the company’s ability to continue as a going concern.Among the 1,951 EGC filers, 1,262 provided a management report on internal control over financial reporting in their most recent annual filing. Of those 1,262 companies, approximately 47 percent reported material weaknesses.Approximately 96 percent of EGC filers were audited by accounting firms that also audited issuers that are not EGC filers, including 39 percent of EGC filers that were audited by firms that provided audit reports for more than 100 issuers and were required to be inspected on an annual basis by the PCAOB.

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]]> 1459 no Compliance into the Weeds-Episode 34 In this episode Matt Kelly and I take a deep dive into the recent kerfuffle involving United Airlines and its policy which prevented to teenaged girls from boarding a flight wearing leggings. Was United within its rights to exclude the passengers for inappropriate dress? Is the policy valid? Did the gate agent receive appropriate training to make their decision? In the world of today, social media accelerates the ability to judge, without improving the ability to judge. For ethics & compliance officers, that means every compliance risk is now magnified into a reputation risk. Finally, we consider Matt's closing sentence, "Training, values, culture, judgment. Funny how those four things keep cropping up, isn’t it?" and what it means for compliance.  For more insight, read Matt's blog post, "United's Policy Management Lessons" Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 05 Apr 2017 14:00:00 -0000 full Tom Fox Lessons from United's Policy Management In this episode Matt Kelly and I take a deep dive into the recent kerfuffle involving United Airlines and its policy which prevented to teenaged girls from boarding a flight wearing leggings. Was United within its rights to exclude the passengers for inappropriate dress? Is the policy valid? Did the gate agent receive appropriate training to make their decision? In the world of today, social media accelerates the ability to judge, without improving the ability to judge. For ethics & compliance officers, that means every compliance risk is now magnified into a reputation risk. Finally, we consider Matt's closing sentence, "Training, values, culture, judgment. Funny how those four things keep cropping up, isn’t it?" and what it means for compliance.  For more insight, read Matt's blog post, "United's Policy Management Lessons" Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take a deep dive into the recent kerfuffle involving United Airlines and its policy which prevented to teenaged girls from boarding a flight wearing leggings. Was United within its rights to exclude the passengers for inappropriate dress? Is the policy valid? Did the gate agent receive appropriate training to make their decision? In the world of today, social media accelerates the ability to judge, without improving the ability to judge. For ethics & compliance officers, that means every compliance risk is now magnified into a reputation risk. Finally, we consider Matt's closing sentence, "Training, values, culture, judgment. Funny how those four things keep cropping up, isn’t it?" and what it means for compliance. 

For more insight, read Matt's blog post, "United's Policy Management Lessons"

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]]> 1154 no Compliance into the Weeds-Episode 33 In this episode, we take a look at a recent speech given by NY Fed Chairman William Dudley in London where he addressed improving corporate culture. Dudley provided three recommended steps. First, a bank must decide on its purpose and core values—or, as Dudley put it, “What are you for?” Second, after this identification of purposes and values, you can measure how well the workforce is striving to achieve that purpose. Third a bank can set its incentives so employees work harder to achieve those goals. As usual, Matt and I take a deep dive into the issue of enhancing corporate culture. For more on the speech, see Matt's blog post on Radical Compliance entitled, "Great Speech About Improving Corporate Culture". Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 28 Mar 2017 14:00:00 -0000 full Tom Fox Enhancing Culture In this episode, we take a look at a recent speech given by NY Fed Chairman William Dudley in London where he addressed improving corporate culture. Dudley provided three recommended steps. First, a bank must decide on its purpose and core values—or, as Dudley put it, “What are you for?” Second, after this identification of purposes and values, you can measure how well the workforce is striving to achieve that purpose. Third a bank can set its incentives so employees work harder to achieve those goals. As usual, Matt and I take a deep dive into the issue of enhancing corporate culture. For more on the speech, see Matt's blog post on Radical Compliance entitled, "Great Speech About Improving Corporate Culture". Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, we take a look at a recent speech given by NY Fed Chairman William Dudley in London where he addressed improving corporate culture. Dudley provided three recommended steps. First, a bank must decide on its purpose and core values—or, as Dudley put it, “What are you for?” Second, after this identification of purposes and values, you can measure how well the workforce is striving to achieve that purpose. Third a bank can set its incentives so employees work harder to achieve those goals. As usual, Matt and I take a deep dive into the issue of enhancing corporate culture. For more on the speech, see Matt's blog post on Radical Compliance entitled, "Great Speech About Improving Corporate Culture".

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1322 no Compliance into the Weeds-Episode 32 In this episode, Matt Kelly and I take a deep dive into a dramatic 48 hours in the life of the FCPA last week, which portends the trend of continued FCPA enforcement. It included the announcement by Kevin Blanco, acting assistant attorney general for the Criminal Division, who speaking at the American Bar Association’s annual white collar crime conference of the extension of the FCPA Pilot Program; the retort by Secretary of State Rex Tillerson to President Trump on the power of the FCPA for US companies doing business overseas, the Justice Department brief and oral argument in the Hoskins appeal where the DOJ continued to press for an expansive view of FCPA jurisdiction as originally preferred by the Obama DOJ; and finally we discuss the summary of all US attorneys by the Trump administration and Matt's proffers an interesting theory on why Preet Bharara was fired. For more reading, see Matt's piece on Radicalcomplinance.com entitled, "FCPA: Pilot Program Extended, and Much More". Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 15 Mar 2017 14:00:00 -0000 full Tom Fox A Dramatic 48 hours in the FCPA In this episode, Matt Kelly and I take a deep dive into a dramatic 48 hours in the life of the FCPA last week, which portends the trend of continued FCPA enforcement. It included the announcement by Kevin Blanco, acting assistant attorney general for the Criminal Division, who speaking at the American Bar Association’s annual white collar crime conference of the extension of the FCPA Pilot Program; the retort by Secretary of State Rex Tillerson to President Trump on the power of the FCPA for US companies doing business overseas, the Justice Department brief and oral argument in the Hoskins appeal where the DOJ continued to press for an expansive view of FCPA jurisdiction as originally preferred by the Obama DOJ; and finally we discuss the summary of all US attorneys by the Trump administration and Matt's proffers an interesting theory on why Preet Bharara was fired. For more reading, see Matt's piece on Radicalcomplinance.com entitled, "FCPA: Pilot Program Extended, and Much More". Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and I take a deep dive into a dramatic 48 hours in the life of the FCPA last week, which portends the trend of continued FCPA enforcement. It included the announcement by Kevin Blanco, acting assistant attorney general for the Criminal Division, who speaking at the American Bar Association’s annual white collar crime conference of the extension of the FCPA Pilot Program; the retort by Secretary of State Rex Tillerson to President Trump on the power of the FCPA for US companies doing business overseas, the Justice Department brief and oral argument in the Hoskins appeal where the DOJ continued to press for an expansive view of FCPA jurisdiction as originally preferred by the Obama DOJ; and finally we discuss the summary of all US attorneys by the Trump administration and Matt's proffers an interesting theory on why Preet Bharara was fired.

For more reading, see Matt's piece on Radicalcomplinance.com entitled, "FCPA: Pilot Program Extended, and Much More".

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1774 no Compliance into the Weeds-Episode 30 The Justice Department Fraud Section recently revamped its website and it is quite an upgrade. I do not know when the Fraud Section did this update but as with the Evaluation of Corporate Compliance Programs document, it certainly was a soft launch. It appears the new site compiles several disparate sources of Fraud Section and Justice Department information into one website. Also, there looks to my eye to be some information posted on the Fraud Section website for the first time. In short, it is an excellent and most welcomed resource. A quick review of the site has a slide show of recent Justice Department resolutions scrolling across the screen. Go down to the bottom of the screen and you will see two very interesting documents, a 2015 and 2016 Fraud Section Year in Review. The FCPA Unit section includes such information as prior enforcement actions, Opinion Releases, other anti-corruption treaties and resources. There is also a list of Fraud Section leadership. However, the Fraud Section is made up of more than simply the FCPA unit and there are tabs for the following Health Care Fraud and Securities and Financial Fraud. Most interesting to me was the tab for the Strategy, Policy and Training Unit, which I have to admit, did not know was a part of the Fraud Section. The opening page for this Unit provides a description of its work. It is as wide ranging as international coordination and interaction with foreign prosecutors and investigators.  This new website revamp is a most welcomed resource for the compliance community. While it may be viewed as simply a compilation of other sites and locations within the greater Justice Department website by some; I believe the vast majority of compliance practitioners will find it a most welcomed compilation and resource. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 08 Mar 2017 15:00:00 -0000 full Tom Fox Expanded Fraud Section Website The Justice Department Fraud Section recently revamped its website and it is quite an upgrade. I do not know when the Fraud Section did this update but as with the Evaluation of Corporate Compliance Programs document, it certainly was a soft launch. It appears the new site compiles several disparate sources of Fraud Section and Justice Department information into one website. Also, there looks to my eye to be some information posted on the Fraud Section website for the first time. In short, it is an excellent and most welcomed resource. A quick review of the site has a slide show of recent Justice Department resolutions scrolling across the screen. Go down to the bottom of the screen and you will see two very interesting documents, a 2015 and 2016 Fraud Section Year in Review. The FCPA Unit section includes such information as prior enforcement actions, Opinion Releases, other anti-corruption treaties and resources. There is also a list of Fraud Section leadership. However, the Fraud Section is made up of more than simply the FCPA unit and there are tabs for the following Health Care Fraud and Securities and Financial Fraud. Most interesting to me was the tab for the Strategy, Policy and Training Unit, which I have to admit, did not know was a part of the Fraud Section. The opening page for this Unit provides a description of its work. It is as wide ranging as international coordination and interaction with foreign prosecutors and investigators.  This new website revamp is a most welcomed resource for the compliance community. While it may be viewed as simply a compilation of other sites and locations within the greater Justice Department website by some; I believe the vast majority of compliance practitioners will find it a most welcomed compilation and resource. Learn more about your ad choices. Visit megaphone.fm/adchoices The Justice Department Fraud Section recently revamped its website and it is quite an upgrade. I do not know when the Fraud Section did this update but as with the Evaluation of Corporate Compliance Programs document, it certainly was a soft launch. It appears the new site compiles several disparate sources of Fraud Section and Justice Department information into one website. Also, there looks to my eye to be some information posted on the Fraud Section website for the first time. In short, it is an excellent and most welcomed resource.

A quick review of the site has a slide show of recent Justice Department resolutions scrolling across the screen. Go down to the bottom of the screen and you will see two very interesting documents, a 2015 and 2016 Fraud Section Year in Review. The FCPA Unit section includes such information as prior enforcement actions, Opinion Releases, other anti-corruption treaties and resources. There is also a list of Fraud Section leadership.

However, the Fraud Section is made up of more than simply the FCPA unit and there are tabs for the following Health Care Fraud and Securities and Financial Fraud. Most interesting to me was the tab for the Strategy, Policy and Training Unit, which I have to admit, did not know was a part of the Fraud Section. The opening page for this Unit provides a description of its work. It is as wide ranging as international coordination and interaction with foreign prosecutors and investigators. 

This new website revamp is a most welcomed resource for the compliance community. While it may be viewed as simply a compilation of other sites and locations within the greater Justice Department website by some; I believe the vast majority of compliance practitioners will find it a most welcomed compilation and resource.

Learn more about your ad choices. Visit megaphone.fm/adchoices

]]> 1037 no Compliance into the Weeds-Episode 30 In this episode Matt Kelly and myself take a deep dive into SOX 404(b), what it requires and how companies comply with the reporting requirements set out in this statute. We consider the recent announcements from Congressman Jeb Hensarling to amend this section to exempt companies under the $500MM who wish to go public from its reporting requirements. We consider the corporate and audit response currently in place for 404(b) and how this response is now well embedded in not only corporate controls but also in reporting. We discuss the importance of internal controls over the time frame since the enactment of SOX and how any change may not be well received by institutional investors and private equity funders. For a more detailed discussion, see Matt’s blog post entitled, “Tale of Sound & Fury: The 404(b) Debate”. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 01 Mar 2017 17:00:00 -0000 full Tom Fox A Deep Dive into SOX 404(b) In this episode Matt Kelly and myself take a deep dive into SOX 404(b), what it requires and how companies comply with the reporting requirements set out in this statute. We consider the recent announcements from Congressman Jeb Hensarling to amend this section to exempt companies under the $500MM who wish to go public from its reporting requirements. We consider the corporate and audit response currently in place for 404(b) and how this response is now well embedded in not only corporate controls but also in reporting. We discuss the importance of internal controls over the time frame since the enactment of SOX and how any change may not be well received by institutional investors and private equity funders. For a more detailed discussion, see Matt’s blog post entitled, “Tale of Sound & Fury: The 404(b) Debate”. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and myself take a deep dive into SOX 404(b), what it requires and how companies comply with the reporting requirements set out in this statute. We consider the recent announcements from Congressman Jeb Hensarling to amend this section to exempt companies under the $500MM who wish to go public from its reporting requirements. We consider the corporate and audit response currently in place for 404(b) and how this response is now well embedded in not only corporate controls but also in reporting. We discuss the importance of internal controls over the time frame since the enactment of SOX and how any change may not be well received by institutional investors and private equity funders.

For a more detailed discussion, see Matt’s blog post entitled, “Tale of Sound & Fury: The 404(b) Debate”.

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]]> 1286 no Compliance into the Weeds-Episode 29 In this episode, Matt Kelly and myself take a deep dive into the Department of Justice (DOJ) recent release, entitled “Evaluation of Corporate Compliance Programs” (Evaluation), which went up on the Fraud Section website on February 8. The document is an 11-part list of questions which encapsulates the DOJ’s most current thinking on what constitutes a best practices compliance program. Within the list are some 46 different questions that a Chief Compliance Officer (CCO) or compliance practitioner can use to benchmark a compliance program. In short, it is an incredibly valuable and most significantly useful resource for every compliance practitioner. The Evaluation, most generally, follows the DOJ and Securities and Exchange Commission’s (SEC) seminal Ten Hallmarks of an Effective Compliance Program, released in the 2012 FCPA Guidance. If there is one over-riding theme in the Evaluation, it is the DOJ’s emphasis on doing compliance as the questions posed are designed to test how far down your compliance program is incorporated into the fabric of your organization. The Evaluation is not simply a restatement of the Ten Hallmarks, as it clearly incorporates the DOJ’s evolution in what constitutes a best practices compliance program, and it certainly builds upon the information put forward in the DOJ’s FCPA Pilot Program regarding effective compliance programs, most particularly found in Prong 3 Remediation. Learn more about your ad choices. Visit megaphone.fm/adchoices Tue, 21 Feb 2017 13:00:00 -0000 full Tom Fox The New DOJ FCPA Evaluation Documentation In this episode, Matt Kelly and myself take a deep dive into the Department of Justice (DOJ) recent release, entitled “Evaluation of Corporate Compliance Programs” (Evaluation), which went up on the Fraud Section website on February 8. The document is an 11-part list of questions which encapsulates the DOJ’s most current thinking on what constitutes a best practices compliance program. Within the list are some 46 different questions that a Chief Compliance Officer (CCO) or compliance practitioner can use to benchmark a compliance program. In short, it is an incredibly valuable and most significantly useful resource for every compliance practitioner. The Evaluation, most generally, follows the DOJ and Securities and Exchange Commission’s (SEC) seminal Ten Hallmarks of an Effective Compliance Program, released in the 2012 FCPA Guidance. If there is one over-riding theme in the Evaluation, it is the DOJ’s emphasis on doing compliance as the questions posed are designed to test how far down your compliance program is incorporated into the fabric of your organization. The Evaluation is not simply a restatement of the Ten Hallmarks, as it clearly incorporates the DOJ’s evolution in what constitutes a best practices compliance program, and it certainly builds upon the information put forward in the DOJ’s FCPA Pilot Program regarding effective compliance programs, most particularly found in Prong 3 Remediation. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt Kelly and myself take a deep dive into the Department of Justice (DOJ) recent release, entitled “Evaluation of Corporate Compliance Programs” (Evaluation), which went up on the Fraud Section website on February 8.

The document is an 11-part list of questions which encapsulates the DOJ’s most current thinking on what constitutes a best practices compliance program. Within the list are some 46 different questions that a Chief Compliance Officer (CCO) or compliance practitioner can use to benchmark a compliance program. In short, it is an incredibly valuable and most significantly useful resource for every compliance practitioner.

The Evaluation, most generally, follows the DOJ and Securities and Exchange Commission’s (SEC) seminal Ten Hallmarks of an Effective Compliance Program, released in the 2012 FCPA Guidance. If there is one over-riding theme in the Evaluation, it is the DOJ’s emphasis on doing compliance as the questions posed are designed to test how far down your compliance program is incorporated into the fabric of your organization. The Evaluation is not simply a restatement of the Ten Hallmarks, as it clearly incorporates the DOJ’s evolution in what constitutes a best practices compliance program, and it certainly builds upon the information put forward in the DOJ’s FCPA Pilot Program regarding effective compliance programs, most particularly found in Prong 3 Remediation.

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]]> 2475 no Compliance into the Weeds-Episode 27 In this episode, Matt and I take a look at the sorry story of Chris Correa, the St. Louis Cardinal executive convicted of hacking into the Houston Astros computer system, which expanded last month when Federal Judge Lynn Hughes unsealed details about the extent of the illegal conduct. For all his efforts, Correa was severely punished by Judge Hughes at this sentencing. Hughes accepted the US government’s recommendation in sentencing Correa to 46 months of incarceration and fining him some $300,000. Correa was also banned from Major League Baseball (MLB) for life by Commissioner Rob Manfred.  Matt and I have both blogged on this matter. Matt takes a look at some of the lessons to be garnered by the compliance professional in his post, Two Compliance Lessons from the Baseball World. I delved into the facts to mine some interesting tidbits and consider how to compensate a business when you have stolen their IP, in blog post Of Greek Gods and Data Breaches.  Rather amazingly the Greek gods make an appearance proving once again that the fall of man is always related to hubris.  Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 09 Feb 2017 13:00:00 -0000 full Tom Fox Hubris and Data Breaches In this episode, Matt and I take a look at the sorry story of Chris Correa, the St. Louis Cardinal executive convicted of hacking into the Houston Astros computer system, which expanded last month when Federal Judge Lynn Hughes unsealed details about the extent of the illegal conduct. For all his efforts, Correa was severely punished by Judge Hughes at this sentencing. Hughes accepted the US government’s recommendation in sentencing Correa to 46 months of incarceration and fining him some $300,000. Correa was also banned from Major League Baseball (MLB) for life by Commissioner Rob Manfred.  Matt and I have both blogged on this matter. Matt takes a look at some of the lessons to be garnered by the compliance professional in his post, Two Compliance Lessons from the Baseball World. I delved into the facts to mine some interesting tidbits and consider how to compensate a business when you have stolen their IP, in blog post Of Greek Gods and Data Breaches.  Rather amazingly the Greek gods make an appearance proving once again that the fall of man is always related to hubris.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode, Matt and I take a look at the sorry story of Chris Correa, the St. Louis Cardinal executive convicted of hacking into the Houston Astros computer system, which expanded last month when Federal Judge Lynn Hughes unsealed details about the extent of the illegal conduct. For all his efforts, Correa was severely punished by Judge Hughes at this sentencing. Hughes accepted the US government’s recommendation in sentencing Correa to 46 months of incarceration and fining him some $300,000. Correa was also banned from Major League Baseball (MLB) for life by Commissioner Rob Manfred. 

Matt and I have both blogged on this matter. Matt takes a look at some of the lessons to be garnered by the compliance professional in his post, Two Compliance Lessons from the Baseball World. I delved into the facts to mine some interesting tidbits and consider how to compensate a business when you have stolen their IP, in blog post Of Greek Gods and Data Breaches. 

Rather amazingly the Greek gods make an appearance proving once again that the fall of man is always related to hubris. 

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]]> 1035 no Compliance into the Weeds-Episode 25 In this episode Matt Kelly and I take a deep dive into a couple of recent SEC enforcement actions. The first involved L-3 Technologies and accounting irregularities. The second involves BlackRock and the continued issues around pre-taliation. We connect these enforcement actions to broader issues involving the COSO 2013 Framework, the DOJ mandated expertise in compliance, a speak-up culture and remedial actions. For additional information, check out Matt's blog posts on these topics:  Lessons Galore in New SEC Internal Controls Case; and SEC Dings BlackRock for Pre-Taliation Clauses. Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 18 Jan 2017 16:53:00 -0000 full Tom Fox Unforced Errors in Compliance In this episode Matt Kelly and I take a deep dive into a couple of recent SEC enforcement actions. The first involved L-3 Technologies and accounting irregularities. The second involves BlackRock and the continued issues around pre-taliation. We connect these enforcement actions to broader issues involving the COSO 2013 Framework, the DOJ mandated expertise in compliance, a speak-up culture and remedial actions. For additional information, check out Matt's blog posts on these topics:  Lessons Galore in New SEC Internal Controls Case; and SEC Dings BlackRock for Pre-Taliation Clauses. Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take a deep dive into a couple of recent SEC enforcement actions. The first involved L-3 Technologies and accounting irregularities. The second involves BlackRock and the continued issues around pre-taliation. We connect these enforcement actions to broader issues involving the COSO 2013 Framework, the DOJ mandated expertise in compliance, a speak-up culture and remedial actions. For additional information, check out Matt's blog posts on these topics:

 Lessons Galore in New SEC Internal Controls Case; and SEC Dings BlackRock for Pre-Taliation Clauses.

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]]> 1315 no Compliance into the Weeds-Episode 24 In this episode Matt Kelly and myself take a deep dive into the compliance weeds by looking at a paper written by then SEC General Counsel James Doty (later head of the PCAOB) in 2007 where he proposes a regulatory scheme for FCPA compliance. Matt and I discuss the pros and cons and how the SEC Chairman designate Jay Clayton may view the issues. We then take a brief look at the arrest of VW executive Oliver Schmidt and both conclude that it presents ZERO problems for any Chief Compliance Officer or compliance practitioner going forward.  For additional reading, see Matt Kelly blog post on Doty article, "Ye Olde Plan for FCPA Compliance";Matt Kelly blog post on Oliver arrest, "Enough About CCO Liability"Tom Fox blog post on Oliver arrest "Honey I Think We Should Vacation at Home this Year"' and Jim Doty article "Toward a Reg. FCPA: A Modest Proposal for Change in Administering the Foreign Corrupt Practices Act"   Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 11 Jan 2017 20:29:00 -0000 full Tom Fox Jim Doty's Proposal for a Regulatory FCPA Scheme In this episode Matt Kelly and myself take a deep dive into the compliance weeds by looking at a paper written by then SEC General Counsel James Doty (later head of the PCAOB) in 2007 where he proposes a regulatory scheme for FCPA compliance. Matt and I discuss the pros and cons and how the SEC Chairman designate Jay Clayton may view the issues. We then take a brief look at the arrest of VW executive Oliver Schmidt and both conclude that it presents ZERO problems for any Chief Compliance Officer or compliance practitioner going forward.  For additional reading, see Matt Kelly blog post on Doty article, "Ye Olde Plan for FCPA Compliance";Matt Kelly blog post on Oliver arrest, "Enough About CCO Liability"Tom Fox blog post on Oliver arrest "Honey I Think We Should Vacation at Home this Year"' and Jim Doty article "Toward a Reg. FCPA: A Modest Proposal for Change in Administering the Foreign Corrupt Practices Act"   Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and myself take a deep dive into the compliance weeds by looking at a paper written by then SEC General Counsel James Doty (later head of the PCAOB) in 2007 where he proposes a regulatory scheme for FCPA compliance. Matt and I discuss the pros and cons and how the SEC Chairman designate Jay Clayton may view the issues. We then take a brief look at the arrest of VW executive Oliver Schmidt and both conclude that it presents ZERO problems for any Chief Compliance Officer or compliance practitioner going forward. 

For additional reading, see

Matt Kelly blog post on Doty article, "Ye Olde Plan for FCPA Compliance";Matt Kelly blog post on Oliver arrest, "Enough About CCO Liability"Tom Fox blog post on Oliver arrest "Honey I Think We Should Vacation at Home this Year"' and Jim Doty article "Toward a Reg. FCPA: A Modest Proposal for Change in Administering the Foreign Corrupt Practices Act"  

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]]> 1538 no Compliance into the Weeds-Episode 23 In this episode Matt Kelly and I take a deep dive into 6 compliance issues you should keep an eye on in 2017. They include the Wal-Mart FCPA resolution, the future of the FCPA Pilot Program, the SEC Whistleblower program, the Next PCAOB Chairman, the future of new overtime rules and finally the Barclay's trial for mortgage fraud in the context of the 2008 financial crisis. We also take a look at the GOP attempt to denude the Office of Congressional Ethics and their immediate reversal in the face of intense criticism. For additional reading check out Matt's two blogs on these subjects:  Ethics, Politics, and Optics in New Washington and  Six Compliance Events to Watch in 2017.  Learn more about your ad choices. Visit megaphone.fm/adchoices Thu, 05 Jan 2017 13:00:00 -0000 full Tom Fox Six Compliance Issues to Consider in 2017 In this episode Matt Kelly and I take a deep dive into 6 compliance issues you should keep an eye on in 2017. They include the Wal-Mart FCPA resolution, the future of the FCPA Pilot Program, the SEC Whistleblower program, the Next PCAOB Chairman, the future of new overtime rules and finally the Barclay's trial for mortgage fraud in the context of the 2008 financial crisis. We also take a look at the GOP attempt to denude the Office of Congressional Ethics and their immediate reversal in the face of intense criticism. For additional reading check out Matt's two blogs on these subjects:  Ethics, Politics, and Optics in New Washington and  Six Compliance Events to Watch in 2017.  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take a deep dive into 6 compliance issues you should keep an eye on in 2017. They include the Wal-Mart FCPA resolution, the future of the FCPA Pilot Program, the SEC Whistleblower program, the Next PCAOB Chairman, the future of new overtime rules and finally the Barclay's trial for mortgage fraud in the context of the 2008 financial crisis. We also take a look at the GOP attempt to denude the Office of Congressional Ethics and their immediate reversal in the face of intense criticism. For additional reading check out Matt's two blogs on these subjects:  Ethics, Politics, and Optics in New Washington and  Six Compliance Events to Watch in 2017. 

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]]> 1422 no Compliance into the Weeds-Episode 22 In this episode Matt Kelly and I take deep dive into the United Airlines SEC enforcement action for violation of internal controls around its reinstitution of a route from Newark to South Carolina at the insistence of the then Chairman of the New York and New Jersey Port Authority David Sampson in exchange for a concession to expand its physical facilities at the Newark airport. We review the background facts, as set out in the SEC Cease and Desist Order and the Justice Department Non-prosecution. We take a look at the internal controls violation of the former UA CEO for violating the company's Code of Conduct, the finding of a lack of internal controls around its route reinstitution protocol and finally discuss the problem of senior management override of internal controls.  For more information on this enforcement action, check out Matt's blog post on this matter, entitled, "This Weird United Airlines Case Just Happened"  and my blog post entitled, "The Chairman's Flight and the US Corrupt Practices Act".  Learn more about your ad choices. Visit megaphone.fm/adchoices Wed, 14 Dec 2016 13:00:00 -0000 full Tom Fox United Airlines SEC Enforcement Action In this episode Matt Kelly and I take deep dive into the United Airlines SEC enforcement action for violation of internal controls around its reinstitution of a route from Newark to South Carolina at the insistence of the then Chairman of the New York and New Jersey Port Authority David Sampson in exchange for a concession to expand its physical facilities at the Newark airport. We review the background facts, as set out in the SEC Cease and Desist Order and the Justice Department Non-prosecution. We take a look at the internal controls violation of the former UA CEO for violating the company's Code of Conduct, the finding of a lack of internal controls around its route reinstitution protocol and finally discuss the problem of senior management override of internal controls.  For more information on this enforcement action, check out Matt's blog post on this matter, entitled, "This Weird United Airlines Case Just Happened"  and my blog post entitled, "The Chairman's Flight and the US Corrupt Practices Act".  Learn more about your ad choices. Visit megaphone.fm/adchoices In this episode Matt Kelly and I take deep dive into the United Airlines SEC enforcement action for violation of internal controls around its reinstitution of a route from Newark to South Carolina at the insistence of the then Chairman of the New York and New Jersey Port Authority David Sampson in exchange for a concession to expand its physical facilities at the Newark airport. We review the background facts, as set out in the SEC Cease and Desist Order and the Justice Department Non-prosecution. We take a look at the internal controls violation of the former UA CEO for violating the company's Code of Conduct, the finding of a lack of internal controls around its route reinstitution protocol and finally discuss the problem of senior management override of internal controls. 

For more information on this enforcement action, check out Matt's blog post on this matter, entitled, "This Weird United Airlines Case Just Happened"  and my blog post entitled, "The Chairman's Flight and the US Corrupt Practices Act". 

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