Compliance into the Weeds is the 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 C...
Mar 17, 2021•23 min•Ep. 214
Compliance into the Weeds is the 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 retaliati...
Mar 10, 2021•29 min•Ep. 213
Compliance into the Weeds is the 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 offin...
Mar 03, 2021•19 min•Ep. 212
Compliance into the Weeds is the 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 ...
Feb 24, 2021•35 min•Ep. 211
Compliance into the Weeds is the 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 ethi...
Feb 17, 2021•29 min•Ep. 210
Compliance into the Weeds is the 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...
Feb 10, 2021•27 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. 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? · W...
Feb 03, 2021•29 min•Ep. 208
Compliance into the Weeds is the 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 co...
Jan 27, 2021•26 min•Ep. 207
Compliance into the Weeds is the 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 FinC...
Jan 20, 2021•28 min•Ep. 206
Compliance into the Weeds is the 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? ...
Jan 13, 2021•27 min•Ep. 205
Compliance into the Weeds is the 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 Bi...
Jan 06, 2021•34 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. 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 h...
Dec 30, 2020•22 min•Ep. 203
Compliance into the Weeds is the 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 fron...
Dec 23, 2020•22 min•Ep. 202
Compliance into the Weeds is the 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 cu...
Dec 16, 2020•25 min•Ep. 201
Compliance into the Weeds is the only weekly 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 t...
Dec 09, 2020•22 min•Ep. 200
Compliance into the Weeds is the only weekly podcast which 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...
Dec 02, 2020•22 min•Ep. 199
Compliance into the Weeds is the only weekly podcast which 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 tra...
Nov 25, 2020•24 min•Ep. 198
Compliance into the Weeds is the only weekly podcast which 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 itsel...
Nov 18, 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 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...
Nov 11, 2020•33 min•Ep. 196
Compliance into the Weeds is the only weekly podcast which 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 ma...
Nov 04, 2020•22 min•Ep. 195
Compliance into the Weeds is the only weekly podcast which 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 assistan...
Oct 28, 2020•24 min•Ep. 194
Compliance into the Weeds is the only weekly podcast which 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 hap...
Oct 21, 2020•23 min•Ep. 193
Compliance into the Weeds is the only weekly podcast which 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 ...
Oct 14, 2020•22 min•Ep. 192
Compliance into the Weeds is the only weekly podcast which 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 comp...
Oct 07, 2020•22 min•Ep. 191
Compliance into the Weeds is the only weekly podcast which 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 man...
Sep 30, 2020•18 min•Ep. 190
Compliance into the Weeds is the only weekly podcast which 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...
Sep 23, 2020•22 min•Ep. 189
Compliance into the Weeds is the only weekly podcast which 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 t...
Sep 16, 2020•23 min•Ep. 188
Compliance into the Weeds is the only weekly podcast which 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 Dilige...
Sep 09, 2020•15 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 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...
Aug 26, 2020•28 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 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 organ...
Aug 19, 2020•20 min•Ep. 185
