Compliance into the Weeds

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, we look at the recently announced SEC Foreign Corrupt Practices Act enforcement action involving Oracle. Highlights include: Recidivist behavior in same countries with similar schemes. Policy, procedure and internal controls failures. Why no monitor. Compliance programs lessons learned. What about the DOJ?  ResourcesMatt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog Background The Schemes in Action Parking in India The Comeback and DOJ What it all means Learn more about your ad choices. Visit megaphone.fm/adchoices

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, we look at the recently announced Monaco Doctrine as encapsulated in the Monaco Memo. Highlights include: Corporate accountability. Timeliness in turning over evidence of wrongdoing. Baby Carrots in evaluating corporate history of misconduct. Additions to Evaluation of Corporate Compliance Programs. Tweaks to the Yates Memo formulation. Monitors and Monitorships.  ResourcesMatt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog Introduction Self-Disclosure Corporate Compliance Programs Monitors The heat is on Monaco Memo Learn more about your ad choices. Visit megaphone.fm/adchoices

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, we look at the recent speech Assistant Attorney General Kenneth A. Polite delivered at the University of Texas Law School. The speech focused on corporate and individual accountability in FCPA enforcement actions. Highlights and questions posed include:·      What are clawbacks and how would they work in practice?·      Does a lack of corporate clawbacks lead to aggravating factors?·      How much credit will a company receive by instituting clawbacks?·      CCO certifications are here to stay.·      How does the Polite Speech relate to the Monaco Memo. ResourcesMatt in Radical ComplianceText of Polite Speech Learn more about your ad choices. Visit megaphone.fm/adchoices

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, we look at the implementation of a national suicide prevention hotline, 988 and consider what it might teach compliance professionals.  Highlights and questions posed include:·      What is the new national Suicide Prevention hotline? ·      How does it inform your corporate hotline and speak up culture?·      How do you teach the trait of listening?·      Engaged employees are more effective employees.·      How easy are the mechanics of your hotline to navigate. ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

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, we mine the whistleblower allegations by Peiter Zatko, AKA “Mudge” made against Twitter for lessons for the cyber-security professional and wide compliance discipline.  Highlights and questions posed include:·      The allegations made by Mudge. ·      Why does an organization need a CISO (or CCO or CECO)? ·      How did Twitter get hacked, its employees duped and its controls by-passed?·      What is pedestrian yet telling in this saga?·      Why data mapping is mandatory if not critical?·      Where were the external auditors?·      Is there a Caremark claim here?ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

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 more fully explore a subject. In this episode, we explore the recently publicly released whistleblower allegations by Peiter Zatko, AKA “Mudge,” made against his former employer Twitter. Highlights include: The allegations made by Mudge. What possible enforcement actions and legal ramifications could develop? What does this mean for the Twitter/Elon Musk litigation? Where was the Board, and who was the Board? Is there more to come? ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

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, we explore the recent disclosure by HanesBrands of a cyber security breach which cost the company over $100MM in sales in Q2 2022. Highlights include: Why the public disclosure. What might the SEC rules around disclosure be when adopted. Why CISOs and IT (and a whole host of other corp functions) needs to talk to compliance. What if this were a physical breach? How and where to get started. ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

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, we explore the recent CFPB circular which noted a company’s failure to implement adequate data protection measures can qualify as an unfair practice prohibited under the Consumer Financial Protection Act.  Highlights include:·      The CFPB is going to start bringing charges against more companies for sloppy data protection programs. ·      Three Key data protection security controls. ·      Why CISOs and IT needs to talk to compliance.·      The role of auditing and monitoring.·      How and where to get started.ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

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 more fully explore a subject. In this episode, we explore the new requirements for CCO certification by considering what is meant by the term ‘reasonably designed’ compliance program. Highlights include:·      What does ‘reasonably designed’ mean in practice and the eyes of the DOJ?·      Should the DOJ articulate a standard?·      Are CCOs certifying under greater risk?·      What have other thought leaders opined?·      Does this standard impact ‘effective’ compliance programs?ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices

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 more fully explore a subject. In this episode, we deep dive into recent failures detected in the state of Wisconsin regarding cyber security risks around election integrity. Highlights include: The risks were uncovered. What is a material risk? Why Multi-Factor Authentication is important cyber security control. What are the consequences of a single point of failure? How and when should redefine a hazard? What does CISA say about MFAs? ResourcesMatt in Radical Compliance Learn more about your ad choices. Visit megaphone.fm/adchoices