Compliance into the Weeds

Anticipated FCPA enforcement against telecom giant ZTE raises questions about the impact of political influence on corporate prosecutions. They discuss the controversial indictment of SmartMatic and the risks of self-disclosure in a politicized Department of Justice. Additionally, there's concern over potential changes to Qui Tam lawsuits under the False Claims Act and ongoing conflicts between federal and state AI regulations. The financial landscape for AI funding deals is also examined, with fears of a crisis reminiscent of 2008.

Delve into the fascinating world of compliance with a gripping case of tariff evasion at MGI International. Explore how self-disclosure and robust internal investigations earned them a declination from the DOJ. The discussion includes insights on the importance of cooperation and the implications for future compliance policies. Hear about the COO's guilty plea and the evolving DOJ landscape that encourages voluntary disclosures. It's a roadmap for navigating the complexities of compliance, wrapped in an engaging holiday context!

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. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the mixed and muddled messages coming out of the DOJ on FCPA and white collar enforcement.    We discuss recent signals from the DOJ suggesting a reinvigorated stance on corporate malfeasance, juxtaposed with actions like the pardoning of convicted offenders which muddle the overall message. The conversation covers Deputy Attorney General Todd Blanche's inflammatory speech on the seriousness of FCPA actions, the controversial pardons by President Trump, and the apparent selective enforcement against foreign versus U.S. companies. The episode examines the ramifications of these mixed signals for compliance professionals, companies, and whistleblowers, emphasizing the need for clearer guidance and consistency from the DOJ.  Key Highlights  ·      Mixed Messages from the Justice Department on FCPA and White Collar Enforcement ·      Deputy Attorney General's Angry Speech ·      Controversial Pardons and Their Implications ·      ZTE and FCPA Charges ·      Inconsistencies and Compliance Challenges ·      The Impact of Presidential Pardons on Compliance  Resources Matt in Radical Compliance  Tom   Instagram Facebook YouTube Twitter LinkedIn  A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices

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 it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss their initial reflections on the first day of the recently concluded ACI-FCPA and Global Anti-Corruption Conference. Key points include the current state of FCPA enforcement, the impact of reduced DOJ manpower, and the continued importance of robust compliance. Despite claims about ramping up enforcement, the number of staff dedicated to FCPA cases has been significantly reduced. They also touch on the DOJ’s focus on comprehensive white-collar crime enforcement, including healthcare fraud and cartel-related activities. Additionally, they discuss Severin Wirz’s new book, Bribery Beyond Borders, on the historical context of FCPA enforcement. Key highlights: FCPA Enforcement Realities White Collar Crime and DOJ Priorities Cartels and Corruption Whistleblower Program Insights Book Signing and Historical Context Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

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 it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recently released Serious Fraud Office (SFO) guidance on compliance programs. Tom and Matt highlight the SFO's lack of specific directives and contrast them with more detailed guidance from the United States. The conversation focuses on the ambiguity organizations face in understanding what the SFO looks for in assessing compliance programs and underscores the need for a more holistic, tailored approach to individual circumstances. Key highlights: Introduction to SFO Guidance Comparing SFO Guidance with US Standards Uncertainty in SFO's Expectations Holistic Assessment by SFO Resources: Matt in Radical Compliance Tom in the FCPA Compliance and Ethics Blog A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

Dive into the complex case of Millicom Cellular, where duffel bags stuffed with drug cartel cash were used to bribe Guatemalan officials. Discover how this intricate FCPA enforcement action unfolded, revealing a lack of operational control within the joint venture. The episode explores the critical implications for compliance in high-risk regions and the importance of robust due diligence. With insights on narco-trafficking connections and lessons for joint-venture compliance, this discussion is both compelling and educational.

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. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the basics of fraud prevention with headlines torn from the NBA and a FinServ enforcement action.  The embezzlement scandal at the Atlanta Hawks has drawn attention to critical weaknesses in corporate governance and internal control systems, serving as a cautionary tale for organizations everywhere. They view the scandal as a glaring example of the consequences of neglecting internal controls and the segregation of duties, where an executive, Leslie Jones, exploited their finance role to embezzle funds for personal indulgences. His experience underscores the value of routine audits, which, despite their perceived monotony, are essential for uncovering fraud. Meanwhile, Matt is equally concerned, focusing on the need for robust internal controls and the principle of least privilege, warning against granting excessive access to employees to prevent misuse of power and safeguard organizational integrity.  Key Highlights  ·      Lessons from Atlanta Hawks Fraud Case ·      Least Privilege Access for Preventing Financial Fraud ·      Financial Data Examination for Fraud Detection ·      Executives' Lavish Misconduct: Lessons in Ethics  Resources Matt in Radical Compliance   Tom   Instagram Facebook YouTube Twitter LinkedIn   A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices

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 more fully. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss the intricacies of integrating incentives into corporate compliance programs. Matt shares insights from a recent webinar and blog posts, discussing how companies can encourage ethical behavior through executive compensation plans, performance bonuses, and other incentive schemes. The conversation explores the Justice Department’s guidelines on executive compensation, the intricacies of designing these programs to align with industry-specific risks, and the implications for various levels of management. They also examine the challenges of establishing meaningful compliance metrics and striking a balance between compliance incentives and overall business objectives across multiple sectors. Key highlights: The Role of Incentives in Compliance Programs Structuring Executive Compensation for Compliance Challenges and Nuances in Incentive Programs Incentives for Different Business Models Compensation Types and Ethical Behavior Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been honored with a Davey, Communicator, and W3 Award, all for excellence in podcasting. Learn more about your ad choices. Visit megaphone.fm/adchoices

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 it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the unfolding NBA betting scandal and explore what it all might mean for the compliance professional.  Their discussion covers the allegations and implications involving high-profile NBA figures, including Terry Rozier, Damon Jones, and Chauncey Billups. They explore the role of material non-public information, the importance of risk assessment, the effectiveness of current compliance measures, and the crucial role of data analytics in detecting fraudulent activities. Insights into sports betting, preventive controls, and the ethical challenges faced by professional athletes are also discussed, drawing parallels for corporate compliance professionals.  Key highlights: NBA Betting Scandal Overview Historical Context and Data Analytics Conflict of Interest and Risk Assessment Investigation and Compliance Strategies  Resources: Tom is writing a multipart series on the scandal on the ⁠FCPA Compliance and Ethics blog.⁠ Tom   ⁠Instagram⁠ ⁠Facebook⁠ ⁠YouTube⁠ ⁠Twitter⁠ ⁠LinkedIn⁠ A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the ⁠Top 25 Regulatory Compliance Podcasts⁠ , a ⁠Top 10 Business Law Podcast⁠, and ⁠a Top 12 Risk Management Podcast⁠. Compliance into the Weeds has been conferred a Davey, a Communicator Award, and a W3 Award, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices

The discussion delves into Smartmatic's unusual FCPA indictment, shedding light on its political sensitivities and legal battles with Fox News. Concerns about selective prosecution emerge, questioning whether political alliances influence the case. The hosts debate the implications for voluntary self-disclosure and how changing administrations complicate compliance strategies. They highlight a lack of new allegations against Smartmatic and explore the potential impact on its business amidst shifting political interests.