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. On Tuesday, Matt and Tom began a special two-part year-end review of six topics which they saw as significant in 2021 and believe will be so into 2022 as well. They looked at SPACs, the Robinhood/GameStop phenomena and the new hybrid working environment and what is means for the compliance professional. Today in Part 2 we consider the Biden Administration’s Strategy on Countering Corruption, in conjunction with DAG Lisa Monaco's speech on the refocus of the Department of Justice on FCPA enforcement and other white collar prosecutions, the continuing evolution of ransomware attacks and ESG in 2021 and beyond.ResourcesMatt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog 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. Today, Matt and Tom begin a special two-part year-end review of six topics which they saw as significant in 2021 and believe will be so into 2022 as well. In this episode we discuss SPACs, the Robinhood/GameStop phenomena and the new hybrid working environment and what is means for the compliance professional. Join us on Thursday of this week as we post Part 2 and look at the Biden Administration’s Strategy on Countering Corruption, the continuing evolution of ransomware attacks and ESG in 2021 and beyond. ResourcesMatt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog 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. Today, Matt and Tom take a deep dive into the JPMorgan settlement with the SEC and CFTC for faulty electronic record-keeping. Some of the issues we consider are:·      Why does Matt ‘almost feel bad' for JPMorgan?·      There was a paucity of facts. So why is the fine so high?·      Is it a ‘Compliance Consultant’ or a Monitor? ·      The remediation agreed to by JPMorgan.·      Lessons learned for the compliance professional and ephemeral communications.·      Focus on consistent and even-handed discipline for JPMorgan employees going forward.ResourcesMatt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog 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. Today, Matt and Tom take a deep dive into the recently released US Strategy on Countering Corruption. After beginning with a debate on whether the document is simply a nice to have or something more significant, some of the issues we consider are: What is the significance domestically v. internationally? What new data will be collected and analyzed? What new agencies and departments in the US government will be involved? What additional international NGOs will be involved? Enhanced whistleblower protections? New focus on government procurement and in the Department of Defense. ResourcesMatt in Radical ComplianceTom in the FCPA Compliance and Ethics Blog 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. Today, Matt and Tom take a deep dive into the difference between a privacy breach and a ransomware attack.Some of the issues we consider are: Why are privacy breaches different from ransomware attacks? What is an authenticated v. unauthenticated cyber-attack? Why would the SEC get involved? What are the internal controls need to prevent and detect a ransomware attack? How will they be audited? How can a material weakness in internal controls around ransomware lead to a financial restatement? What will the SEC look at from an enforcement angle? 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. Today, Matt and Tom take a deep dive into several issues regarding Special Purpose Acquisition Companies (SPACs).Some of the issues we consider are: What did the Klausner and Olhrogge Research Paper show about conflicts of interest? What did Calcbench analysis show about not only the number of SPAC filings but how they are driving the dramatic increase in M&A activity. What are the corporate governance issues involved in with SPACs? What are the internal controls issues involved with SPACs? What has (or will) the Delaware Supreme Court have to say. What have been the pronouncements from the SEC? ResourcesMatt in Radical Compliance, Paper Raises Red Flags on SPACs Governance 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. Today, Matt and Tom take a the recently filed lawsuit by Shaquala Williams against JPMorgan for alleged retaliation for her internal whistleblowing. Williams was in a compliance function at the bank and claimed she was terminated for raising the issues that JPMorgan was not living up to its reporting requirements under a DPA.Some of the issues we consider are: Facts of the claim? Made in the context of an ongoing DPA. The lack of lack of documented policies and procedures. Siloed nature of compliance functions. Inconsistency in risk assessments. Why is a single source of truth so critical? ResourcesMatt in Radical Compliance, That Lawsuit Against JP Morgan 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. Today, Matt and Tom take a look at the Department of Defense retreat on its cybersecurity initiative for contractors, from the original CMMC to the new standard of CMMC 2.0.Some of the issues we consider are:·      What is CMMC and what morphed into CMMC 2.0?·      Who led the charge to make these changes?·      Do these changes help or hurt federal government overall cybersecurity? ·      Will self-assessments work?·      New FCA claims coming?·      What about compliance?ResourcesMatt in Radical Compliance, Pentagon Sounds Retreat on CMMC 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. Today, Matt and Tom continue their look at the recent speech by DAG Lisa Monaco to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Today we consider potential changes to DPAs and NPAs and other settlement mechanisms.Some of the issues we consider are:·      Are DPAs and NPAs simply the cost of doing business?·      Is the Wells Fargo growth cap a valid model?·      What about greater DOJ or Monitor oversight? ·      Longer terms for DPAs?·      New enforcement tools coming?·      New review of DPAs and NPAs.ResourcesMatt in Radical ComplianceSo What Happens Next with DPAsTom in the FCPA Compliance and Ethics BlogMonaco Speech - Individual AccountabilityMonaco Speech - MonitorsText of DAG Monaco 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. Today, Matt and Tom have a rare emergency podcast on DAG Lisa Monaco’s speech to the ABA White Collar Institute on some very significant change to white collar, including FCPA enforcement. Some of the issues we consider are: Return to the Yates Memo. Disavowal of the Benczkowski Memo. Change in the FCPA Corporate Enforcement Policy? Whither recidivists? New enforcement tools coming? New review of DPAs and NPAs? ResourcesMatt in Radical Compliance, Justice Dept. Unveils Big Compliance ShiftsText of DAG Monaco Speec Learn more about your ad choices. Visit megaphone.fm/adchoices