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? ·...
Dec 21, 2022•23 min•Ep. 305
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-accou...
Dec 14, 2022•26 min•Ep. 304
The award-winning, Compliance 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...
Dec 07, 2022•26 min•Ep. 303
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...
Nov 30, 2022•21 min•Ep. 302
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 domi...
Nov 16, 2022•23 min•Ep. 301
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 ...
Nov 09, 2022•29 min•Ep. 300
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 incentiv...
Nov 02, 2022•27 min•Ep. 299
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...
Oct 26, 2022•28 min•Ep. 298
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...
Oct 19, 2022•28 min•Ep. 297
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 o...
Oct 12, 2022•21 min•Ep. 296
Compliance into the Weeds is the only weekly podcast 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? R...
Oct 05, 2022•21 min•Ep. 295
Compliance into the Weeds is the only weekly podcast 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 t...
Sep 28, 2022•36 min•Ep. 294
Compliance into the Weeds is the only weekly podcast 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 practic...
Sep 21, 2022•35 min•Ep. 293
Compliance into the Weeds is the only weekly podcast 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 ...
Sep 14, 2022•18 min•Ep. 292
Compliance into the Weeds is the only weekly podcast 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 T...
Sep 07, 2022•17 min•Ep. 191
Compliance 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 ...
Aug 31, 2022•27 min•Ep. 290
Compliance into the Weeds is the only weekly podcast 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 ta...
Aug 24, 2022•22 min•Ep. 289
Compliance into the Weeds is the only weekly podcast 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...
Aug 17, 2022•20 min•Ep. 288
Compliance 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 r...
Aug 10, 2022•28 min
Compliance 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...
Aug 03, 2022•24 min•Ep. 286
Compliance into the Weeds is the only weekly podcast 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 hig...
Jul 27, 2022•23 min•Ep. 285
Compliance into the Weeds is the only weekly podcast 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 ...
Jul 20, 2022•24 min•Ep. 284
Compliance into the Weeds is the only weekly podcast 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 ce...
Jul 13, 2022•20 min•Ep. 283
Compliance into the Weeds is the only weekly podcast 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 compli...
Jun 29, 2022•26 min•Ep. 282
Compliance into the Weeds is the only weekly podcast 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...
Jun 22, 2022•25 min•Ep. 281
Compliance 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 Rad...
Jun 15, 2022•24 min•Ep. 280
Compliance into the Weeds is the only weekly podcast 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 ...
Jun 08, 2022•21 min•Ep. 279
Compliance 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 ...
Jun 01, 2022•32 min•Ep. 277
Compliance into the Weeds is the 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 actio...
May 25, 2022•24 min•Ep. 277
Compliance into the Weeds is the 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 pr...
May 18, 2022•22 min•Ep. 276
