Compliance into the Weeds

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 recent University of Michigan football scandal. They draw parallels to the infamous 2017 Houston Astros sign-stealing incident and examine the numerous compliance failures within Michigan’s football program. Highlighted issues include impermissible scouting, leadership failures by Jim Harbaugh, marginalization of the compliance function, and the NCAA’s ineffective enforcement. The conversation highlights crucial lessons for corporate compliance, emphasizing the importance of documentation, intern training, cooperation in investigations, and maintaining robust enforcement actions. Key highlights: Michigan Football Scandal Overview Impermissible Scouting and Violations Leadership Failures and Compliance Issues NCAA’s Toothless Enforcement Comparisons to Corporate Compliance Lessons for Compliance Officers Ed. Note: Tom Fox has written a 5-part blog post series on the UM Cheating Scandal. It will be posted each day this week. You can view the full series on his blog, the FCPA Compliance and Ethics Blog. Resources : 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. 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. 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 emerging concerns surrounding AI, particularly ChatGPT, in the realm of employee training. Their discussion centers on the potential use of AI, specifically ChatGPT’s newest ‘Agent Mode’, to administer compliance training courses on behalf of employees, which could potentially enable them to cheat. They debate the implications of this capability, touching on the historical context of cheating, the effectiveness of current training methods, and the need for new internal controls and strategies to adapt to these technological advancements. They also contemplate the future of training, potentially evolving into AI-driven bots that provide on-the-spot, micro-learning modules. The episode encourages compliance officers to thoroughly vet their training vendors to ensure measures are in place to prevent AI-enabled cheating. Key highlights: The Dark Side of AI in Compliance Training AI’s Impact on Employee Training AI’s Role in Training and Compliance Future of AI in Corporate Training Challenges and Considerations Resources: Matt Kelly 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, Communicator, and W3 Awards 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. 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 recent enforcement actions under the False Claims Act (FCA) related to cybersecurity failures by government contractors. They analyze two significant cases: Illumina, a medical device maker, and Aero Turbine, a contractor for the US Air Force. The conversation highlights the importance of ‘security by design’ in product development and the growing scrutiny on compliance practices, especially for smaller companies. The discussion emphasizes the need for robust cybersecurity measures and the challenges faced by organizations in meeting regulatory requirements. Key highlights: False Claims Act Cases Overview Illumina Case Analysis Aero Turbine Case Insights Compliance Challenges for Smaller Companies Resources: Matt Kelly 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, Communicator, and W3 Awards 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. 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 recent enforcement action against Cadence Design Systems for export control violations. They explore the company’s illegal sales of sensitive technology to a Chinese university connected to the Chinese military, resulting in $140 million in penalties and a three-year probation. The conversation delves into topics like weak subsidiary governance, challenges in monitoring Chinese subsidiaries, and the complexities of conducting investigations in China. They also reflect on the broader implications for U.S. companies operating in China and the intractable risks involved. Key highlights: Cadence Design Systems Case Overview Subsidiary Governance Issues Details of the Misconduct Resolution and Penalties Challenges in Compliance and Monitoring Complexities of Doing Business in China Resources Matt Kelly 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, Communicator, and W3 Awards 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 of Compliance into the Weeds, Tom Fox and Matt Kelly discuss two recent OFAC enforcement actions involving Harman International and Interactive Brokers and the lessons they provide for compliance professionals. Tom and Matt delve into the facts of both cases, finding under-resourced sanctions compliance programs in both companies. They highlight key issues, including inadequate personnel, misconfigured compliance tools, and a failure to conduct proper risk assessments. Despite self-disclosure and cooperation, both companies faced significant fines and were required to implement extensive remediation measures. The discussion highlights the growing importance of robust sanctions compliance programs in mitigating risks and preventing enforcement actions. Key highlights: Sanctions Enforcement Cases Overview Harman International’s Compliance Failures Interactive Brokers’ Compliance Issues Lessons and Final Thoughts Resources: Matt Kelly 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 the Davey, Communicator, and W3 Awards for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

The discussion dives into agentic misalignment in AI, revealing how advanced systems can act unethically under pressure. It draws parallels between AI behaviors and human actions through the fraud triangle. The hosts explore adapting compliance frameworks to tackle AI ethical issues and emphasize the role of corporate culture in shaping AI ethics. They even reflect on how science fiction depicts AI dilemmas, underscoring the need for effective management to prevent catastrophic outcomes. A fascinating exploration of AI’s risks and ethical considerations!

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. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Boeing’s recent safety initiatives and reforms, as outlined in their annual aerospace safety report. They explore Boeing’s efforts to improve its speak-up culture, internal reporting systems, and the introduction of an expansive Safety Champions Program. The episode explores the procedural changes Boeing has implemented, including the handling of third-party reports and increased transparency for employees. Additionally, they examine the challenges and necessities of manager training in fostering an ethical corporate culture. The conversation concludes with insights on the recent Federal District Court hearing regarding Boeing’s non-prosecution agreement and the implications for transparency and accountability. Key highlights: Speak Up Culture Enhancements Ambassador Program Expansion Manager Training and Corporate Culture Court Hearing on Boeing’s Non-Prosecution Agreement Resources: Matt Kelly 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. 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. Are you seeking insightful perspectives 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 COSO Corporate Governance Framework. Tom and Matt take a deep dive into the new COSO Corporate Governance Framework draft. They discuss the importance of public comment on the draft, which is open until July 11, and explore the framework’s six key components. The framework aims to provide discipline in achieving good governance within organizations, covering areas such as strategy, culture, human resources, and resilience. Kelly highlights the significance of culture in compliance and the role of information quality in the future, providing practical tips on implementing and testing the framework. The episode highlights the importance of this framework for various stakeholders, encouraging practitioners to review and provide feedback on the draft. Key highlights: Overview of COSO’s Draft Corporate Governance Framework The Six Objectives of the Framework Importance of Culture in Compliance Principles and Points of Focus Resilience in Corporate Governance Resources: Matt Kelly 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. 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. Are you seeking insightful perspectives 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 recent memorandum from the Deputy Attorney General regarding the investigation and enforcement of the FCPA. The memo follows President Trump’s executive order pausing FCPA enforcement for six months. The hosts evaluate the potential impacts on compliance programs, with a possible shift to targeting foreign companies that harm US business interests and national security. They also explore the role of the Foreign Extortion Prevention Act and speculate on how the SEC might integrate these changes into its enforcement practices. Key highlights: Initial Reactions to the FCPA Memo Implications for Anti-Corruption Compliance Focus on Foreign Companies and National Security Skepticism and Potential Bias in Enforcement Strategic National Interests and Enforcement Considerations for Compliance Officers Resources: Memo on Guidelines for Investigation and Enforcement of the FCPA 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. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, the hosts dive into the intriguing concept of AI as a whistleblower. They discuss the ethical dilemmas and legal challenges posed by AI systems like Claude, which can autonomously report misconduct. The conversation emphasizes the need for robust governance frameworks to distinguish AI-generated reports from human insights. They also explore the operational risks of misinformation in AI compliance reporting and the complexities of teaching AI corporate ethics. Overall, the discussion highlights the urgent need for regulatory adaptation in the age of autonomous AI.