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

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