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. This week Matt and Tom take a deeper dive into the recent Credit Suisse enforcement action. Some of the issues we consider are: Is a broader view of risk needed? If so, who would perform that review? Too many silos? Public companies v. investment banks? What is under escalated risk? What is conduct risk? 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. This week Matt and Tom take a deep dive into the issue of compliance and artificial intelligence. Some of the issues we consider are: What are the AI risks for compliance? What guidance does the COSO Framework provide? What are some of the top areas of AI failure? Are we governing AI in the right manner? What about the audit of AI tools? Compliance, governance, ethics and AI.  ResourcesMatt in Radical ComplianceThoughts on AI From the Audit PerspectiveGrappling With Artificial Intelligence Tom in the FCPA Compliance and Ethics BlogCompliance Communications: Using an AI Marketing Strategy – Part 1Compliance Communications: Using an AI Marketing Strategy – Part 2 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. This week Matt and Tom take a deep dive into a recent speech by SEC Director of Enforcement Gurbir Grewal and the likely increase in a more expansive use of SEC enforcement.Some of the issues we consider are: What is the purpose of SEC penalties; to penalize or to deter others? How did SEC Commissioner Crenshaw presage this talk? What about a potential change in DOJ penalties? Its approach and focus? Are monitorships back on the table? What about the CFPB? Will Directors and Officers be held accountable or just the low level minions?  ResourcesMatt in Radical ComplianceMore on SEC Penalties Policy Shift 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. This week Matt and Tom take a deep dive into collapse (and perhaps rebirth) of Ozy Media and have our first round of culture failure bingo. Some of the issues we consider are: What is an Ozy and why does its collapse matter to compliance? Who is Ozzie Osbourne and what does he have to do with Ozy? What is culture failure bingo and why is it on Compliance into the Weeds? Who were the bingo winning companies this week? Why all this matter to compliance? ResourcesMatt in Radical Compliance Tom 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. This week Matt and Tom take a deep dive into the second FCPA enforcement action of 2021, involving the UK entity, WPP.Some of the issues we consider are: Why does a $15bn, 100K employee worldwide, multination not have a compliance function? What does that say about its culture? What is the role of compliance in M&A? When does a financial incentive become perverse? Where is the DOJ? Where is the SFO? How did WPP avoid a monitor?  ResourcesMatt in Radical ComplianceWPP Pays $19M on FCPA: An Analysis Tom in the FCPA Compliance and Ethics BlogPart 1-BackgroundPart 2-Structural Compliance DeficienciesPart 3-Bribery Schemes 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. This week Matt and Tom take a deep dive a recent survey around employee attitudes towards employer vaccination policies and enforcement of those policies.  Some of the issues we consider are:·      What are employee attitudes toward employer vaccination policies?·      Why is there a split between White Collar response v. Blue Collar responses?·      What will be government enforcement? ·      Will there be increased whistleblower reporting?·      What could be the social media impact on corporate reputations? ResourcesMatt in Radical CompliancePoll: 46% Would Report Lax Vax Policies 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. This week Matt and Tom take a deep dive into why an internal reporting system is not enough. Indeed having a speak up culture is not enough. Your company must have a listen up culture.  Some of the issues we consider are:·      What is a speak up culture?·      What is a listen up culture?·      What are some of the benefits of a true listen up culture? ·      How do you training middle managers to be speak up portals?·      Why is having a conversation so powerful? ResourcesMatt in Radical ComplianceCorporate Culture: Speak Up v. Listen Up 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. This week Matt and Tom take a deep dive the recent SEC enforcement action involving Kraft Foods. While the subject matter of the enforcement action was fraudulent expense recognition, it turns out the real culprit was a corrupt culture. Some of the issues we consider are:·      What were the underlying facts?·      What does tone at the top really mean?·      How does management cost cutting mantra lead to corruption? ·      Why is incentive based comp so deterius?·      What did SEC Commissioner Crenshaw say about this enforcement action?ResourcesMatt in Radical ComplianceFood For Thought From Kraft Foods 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. This week Matt and Tom take a deep dive the recent move by Delta Airlines to require employees who refuse to be vaccinated to pay a special health care insurance surcharge of $200 to cover the increased health care costs associated with unvaccinated employees who contract Covid-19. Some of the issues we consider are:·      What were the underlying facts?·      How did Delta Airline’s actions follow a risk management protocol?·      How did Delta’s actions demonstrate a commitment to compliance? ·      How about the data?·      How about Document Document Document? ResourcesMatt in Radical ComplianceDelta’s Smart Approach on Delta 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. This week Matt and Tom take a deep dive into the recent announcement by Walmart that former DOJ Deputy Attorney General, Criminal Matthew Miner had joined the company as CCO.  ResourcesMatt in Radical ComplianceWalmart Names ex-DOJ Boss CCO Learn more about your ad choices. Visit megaphone.fm/adchoices