Compliance into the Weeds is the only weekly podcast which 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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Citibank Failures in Risk Management