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 it fully. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss Anthropic’s S-1 registration statement for a forthcoming IPO, focusing on what it reveals about corporate governance and risk oversight rather than financials. Kelly notes Anthropic has a seven-member board with three insiders (CEO Dario Amodei, Daniela Amodei, and CFO Christina Rao) and four outsiders, operating through four committees: audit, compensation, nominating/governance, and a safety and risk committee tasked with AI safety, security, and broader legal/regulatory/compliance risks. They question whether a two-member safety and risk committee, chaired by Novartis CEO Vas Narasimhan and joined by Christopher Liddell, has sufficient capacity, and note that the committee has an undisclosed written charter. They also flag uncertainties about Anthropic’s internal compliance/risk leadership and reporting filters, potential amended filings, and a five-member long-term benefit trust (one seat vacant) with influence over nominating outside directors. Key highlights: Anthropic IPO S-1 overview Board size and committees Risk committee staffing questions CEOs talking about AI risks More filings and disclosure gaps Resources: Matt in Radical Compliance Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded 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 dives deep into compliance-related topics, going into the weeds to uncover hard-hitting compliance insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent OCC and Federal Reserve enforcement actions against BAO for $1.2bn. The enforcement action against Bank of America (with OCC, FinCEN, OFAC, and others) was for BOA’s failure to maintain an effective Bank Secrecy Act/AML program, including flawed transaction monitoring that led to inadequate suspicious activity reporting, weak customer due diligence, and deficient sanctions screening, sometimes with law enforcement flagging issues to the bank rather than the reverse. They place this alongside recent actions against UBS, American Express, and a New York DFS fine of SEB, arguing recurring failures stem from poor transaction analysis. Kelly ties Bank of America’s problems to its homegrown “Event Processor” system, launched in 2010, which critics say uses arbitrary risk-scoring thresholds and lacks recalibration, compounded by insufficient staffing and management support. They highlight governance and accountability concerns, including unresolved findings from a 2024 OCC order, questions about board oversight of compliance, and doubts that fines alone will drive lasting remediation. Key highlights: BofA Fine Breakdown What Went Wrong in AML How the Tech Failed Leadership and Culture Accountability Fixing It People and Oversight Risk Assessments and Too Big to Remediate Resources: Matt in Radical Compliance Tom in the FCPA Compliance Report 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, the Top 10 Business Law Podcasts, and the Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded 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 compliance topics, literally going into the weeds. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recent OCC and Federal Reserve enforcement actions against American Express. The penalties included a $350 million civil penalty, cease-and-desist orders, and extensive compliance obligations tied to weaknesses in customer due diligence, suspicious activity reporting, staffing, and risk assessment. Tom highlighted that Amex processed billions of transactions, many ordinary credit-card transactions, showing banks must know all customers, not just high-dollar activity, and noted regulators’ broader pattern of similar actions across the industry as financial innovation outpaced compliance investment. Matt noted that regulators depend on SARs as critical inputs for broader enforcement “mosaics,” explaining why SAR failures draw intense scrutiny. The orders’ notable feature is direct board involvement, requiring a board-level compliance committee and action plan to hold management accountable, with a strong focus on end-to-end documentation and evidence trails; they see no facts suggesting the egregious, employee-involved criminality seen in TD Bank. Key highlights: Industry Pattern and Root Causes Innovation as Compliance Risk Board Oversight Mandates Why SARs Matter DOJ Risk and TD Bank Comparison Disjointed Compliance and Fixes Resources: Tom in the FCPA Compliance Report, Part 1 and Part 2 Tom Instagram Facebook YouTube Twitter LinkedIn A multi-award-winning podcast, Compliance into the Weeds, was recently named one of the Top 25 Regulatory Compliance Podcasts, Top 10 Business Law Podcasts, and Top 12 Risk Management Podcasts. Compliance into the Weeds has been awarded a Davey, Communicator, and W3 Award, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

The DOJ’s new fraud priorities put companies on notice. The discussion explores ten prosecution factors, how small incidents can reveal systemic weaknesses, and risks spanning business lines, supply chains, immigration, and political exposure. It also covers voluntary disclosure, whistleblower incentives, board engagement, and the continuing role of compliance evaluations and corporate enforcement.

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the Southern Glazer NPA. The Southern Glazer Wine and Spirits’ non-prosecution agreement is a rare example where prosecutors credited compliance program remediation, rather than self-disclosure or extensive cooperation, as central to a favorable outcome. Southern Glazer, the largest US liquor distributor, faced a major California kickback and bribery scheme involving five former employees, fabricated records, sham agreements, and luxury benefits to retailers and others, along with alleged tax impacts. The company resolved the matter with a $12.5 million payment and a two-year NPA requiring the CEO and CCO to certify program effectiveness. Tom and Matt review how the NPA affirms DOJ’s Evaluation of Corporate Compliance Programs as still relevant and detail remediation steps: major headcount and budget increases, upgraded compliance leadership, audits of marketing spend, enhanced training, strengthened third-party controls and AP payment blocks, outside reviews, and tone-at-the-top messaging. Key highlights: Southern Glazer Case Setup Industry Risks and Scheme ECCP Guidance Still Matters Program Overhaul Timeline Concrete Remediation Metrics DOJ Signals Under Trump Era 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 received Davey, Communicator, and W3 Awards, 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 compliance-related topics, literally going into the weeds to explore a subject in greater depth. Looking for hard-hitting compliance insights? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss a GAO audit of the Department of Homeland Security’s whistleblower retaliation program. They use it as a case study for corporate compliance officers. DHS employees can report internally via the Office of Inspector General hotline or externally to the Office of Special Counsel. However, the GAO review focused on DHS’s internal process, where the OIG’s Whistleblower Protection Division (eight investigators) investigates retaliation and, if substantiated, sends cases to the Office of the Secretary and ultimately the DHS Secretary for corrective action. Although targets are six months for investigation and 30 days for secretarial action, GAO found investigations averaged 3.2 years (some up to six) amid rising complaint volumes, turnover, and evidence-gathering challenges. Meanwhile, none of the 11 substantiated cases were decided within 30 days because of missing written procedures and no designated accountable official—showing how delayed resolution erodes reporting culture and “institutional justice.” Key highlights: Why the GAO Report Matters DHS Whistleblower Program Structure Timeline Expectations vs. Reality Compliance Lessons and GAO Value 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 received Davey, Communicator, and W3 Awards, 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 compliance-related topics, literally going into the weeds to explore them fully and uncover hard-hitting compliance insights. Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the growing compliance and cybersecurity challenges posed by agentic AI. They focus on New York Department of Financial Services (DFS) guidance on cybersecurity risk assessments and a European survey Kelly cites. They argue DFS’s rule, requiring annual or as-needed reassessments after significant technology and threat changes and maintaining an accurate IT asset inventory, implicitly compels organizations to identify and track AI agents, even though agents are not mentioned. Kelly cites a Veeam Software survey of 1,000+ European executives reporting limited visibility into employee-created autonomous AI workflows and AI interactions with sensitive data, complicating EU AI Act requirements for human accountability. The conversation compares potential governance models to Sarbanes-Oxley sub-certifications and enterprise software management, questions whether CISOs can certify compliance amid decentralized agent creation, and notes potential enforcement avenues and the risks of industry self-regulation. Key highlights: Why DFS Guidance Matters Risk Assessments Meet Agents Accountability Under EU AI Act SOX Style Governance Model Enforcement and Self-Regulation Resources: Matt in Radical Compliance (2 posts) 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 Podcasts, and a Top 12 Risk Management Podcasts. Compliance into the Weeds has received Davey, Communicator, and W3 Awards, all for podcast excellence. Learn more about your ad choices. Visit megaphone.fm/adchoices

An NBA salary-cap scandal unfolds through sham endorsements, vague contracts, unusual counterparties, and a paper trail of incriminating emails. The discussion examines how roughly $18 million in extra compensation allegedly reached Kawhi Leonard, why repeated violations raised tone-at-the-top concerns, and what fines, suspensions, lost draft picks, and stronger contract oversight mean for compliance in professional sports.

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into compliance-related topics, literally going into the weeds to explore a subject in greater depth. 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 BAE export control enforcement action. Matt views the BAE export control enforcement action as a strong example of how ITAR compliance failures often stem from routine breakdowns in day-to-day operations rather than dramatic smuggling schemes. He notes that BAE’s U.S. subsidiary sent technical information and services overseas without proper licenses, including to China and even some allied countries, showing that export controls apply to both data and services, not just physical weapons. Kelly argues that the case reveals common compliance weaknesses such as poor training, unclear procedures, weak system warnings, and employee turnover that can leave staff unsure of the rules. His broader point is that companies in export-controlled industries must maintain current licenses and build strong, monitored compliance programs because governments will continue using export controls as an important geopolitical tool. Key highlights: ITAR data shipments trigger BAE’s $36 million penalty Broken execution in day-to-day compliance operations Export-control warnings before sensitive file transmission Missing Red-Flag Prompts in Export Control System Self-Disclosed, Cooperated, Remediated, Monitored by Another Name 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 the Davey, Communicator, and W3 Awards, 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 compliance-related topics, literally going into the weeds to explore them 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 Kelly’s collaboration with Ethena to run short, paid online AI classes for compliance professionals. Since May, there has been an excellent AI training for compliance professionals, covering vibe coding, content/video generation, and data analytics with hands-on exercises using dummy or public data. Kelly says his biggest takeaway has been how much AI education is still needed and that many compliance teams are only scratching the surface, despite fears that “everyone else” is further along. They review common tools but emphasize that success depends more on the inputs and outputs, data readiness, clear use cases, and acting on results than on which model is chosen. They also address governance, security, privacy, maintenance, technical debt, costs and token budgets, and the need to involve compliance, which often leads to AI governance. The episode ends with reflections on Dolly Parton’s leadership and a story about her retaining rights to the hit song “I Will Always Love You.” Key highlights: AI Class Overview AI Skills Gap Reality Check Good Enough to Start AI Angst and Cost Questions Why Compliance Should Lead AI Governance Dolly Parton Tribute 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 received Davey, Communicator, and W3 Awards, all for podcast excellence.  Learn more about your ad choices. Visit megaphone.fm/adchoices