Compliance into the Weeds is the only weekly podcast which 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 re...
Aug 12, 2020•26 min
Compliance into the Weeds is the only weekly podcast which 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 cu...
Aug 05, 2020•20 min
Compliance into the Weeds is the only weekly podcast which 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 abou...
Jul 29, 2020•17 min
Compliance into the Weeds is the only weekly podcast which 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 m...
Jul 22, 2020•19 min•Ep. 181
Compliance into the Weeds is the only weekly podcast which 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 pr...
Jul 15, 2020•22 min•Ep. 180
Compliance into the Weeds is the only weekly podcast which 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 Ethi...
Jul 08, 2020•22 min•Ep. 179
Compliance into the Weeds is the only weekly podcast which 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-Introdu...
Jul 01, 2020•29 min•Ep. 178
Compliance into the Weeds is the only weekly podcast which 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 me...
Jun 24, 2020•24 min•Ep. 177
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 n...
Jun 20, 2020•28 min•Ep. 176
Compliance into the Weeds is the only weekly podcast which 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 ro...
Jun 17, 2020•21 min•Ep. 40
Compliance into the Weeds is the only weekly podcast which 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 incendiar...
Jun 10, 2020•25 min•Ep. 174
Compliance into the Weeds is the 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 compli...
Jun 03, 2020•24 min
Compliance into the Weeds is the only weekly 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 h...
May 27, 2020•24 min•Ep. 172
Compliance into the Weeds is the only weekly 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...
May 20, 2020•24 min•Ep. 171
Compliance into the Weeds is the only weekly 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 ...
May 13, 2020•23 min
Compliance into the Weeds is the only weekly 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 Norw...
May 06, 2020•18 min
Compliance into the Weeds is the only weekly 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 possib...
Apr 29, 2020•18 min•Ep. 168
Compliance into the Weeds is the only weekly 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 ...
Apr 22, 2020•21 min•Ep. 167
Compliance into the Weeds is the only weekly 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 lengthenin...
Apr 15, 2020•19 min•Ep. 166
Compliance into the Weeds is the 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 failu...
Apr 08, 2020•17 min•Ep. 165
Compliance into the Weeds is the only weekly 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 ...
Apr 01, 2020•17 min•Ep. 164
Compliance into the Weeds is the 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...
Mar 25, 2020•20 min•Ep. 163
Compliance into the Weeds is the 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 th...
Mar 18, 2020•20 min
Compliance into the Weeds is the only weekly podcast 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 mode...
Mar 11, 2020•22 min
Compliance into the Weeds is the only weekly podcast 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 ...
Mar 04, 2020•20 min
Compliance into the Weeds is the only weekly podcast 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 DO...
Feb 26, 2020•25 min•Ep. 159
Compliance into the Weeds is the only weekly podcast 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 sa...
Feb 12, 2020•22 min•Ep. 158
Compliance into the Weeds is the only weekly podcast 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 a...
Feb 05, 2020•22 min•Ep. 157
Compliance into the Weeds is the only weekly podcast which 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 ...
Jan 29, 2020•20 min•Ep. 156
Compliance into the Weeds is the only weekly podcast which 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 thorou...
Jan 22, 2020•40 min•Ep. 155
