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 deep dive into the 2021 PwC Global CEO Survey, including its findings about digital transformation of business processes and risk management.Some of the issues we consider are: What are the top risks CEOs are worried about in 2021? How has that list changed since 2020? What is the digital transformation of business process and risk management? How will compliance response to these new risks? What does this mean for compliance officers?  ResourcesMatt’s blog post on Radical Compliance: Thoughts from CEOs 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 Commissioner Caroline Crenshaw on a new philosophy in SEC financial penalty enforcement.  Some of the issues we consider are: Who is SEC Commissioner Caroline Crenshaw? What was the 2006 policy regarding enforcement priorities? What changes did Commissioner Crenshaw propose? What about the timing of the remarks? Is this a response to the Supreme Court decision in Lui? What does this mean for compliance officers? ResourcesMatt’s blog post on Radical Compliance:SEC Enforcement Speech, Umm Wow 2006 SEC Enforcement Policy Statement 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 findings, conclusions and recommendations in the ECI 2021 GBES.  Some of the issues we consider are: What were the key findings of the GBES? What pressure are employees under? What were the findings on observed misconduct and the reported misconduct? Troubling findings on retaliation. What has been the impact of Covid-19 on compliance and ethics? What were the conclusions and recommendations?  ResourcesMatt’s blog post on Radical Compliance:Report: Ethics Pressures Mounting on EmployeesECI2021 Global Business Ethics SurveyNext week, Tom will have a 5-part podcast series on the FCPA Compliance Report, featuring ECI President Pat Harned discussing the 2021 GBES. 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 the SEC that it would start paying more attention to companies’ climate change disclosures.  Some of the issues we consider are: What did acting Chairman Allison Herren Lee announce? A review of the 2010 Climate Guidance What changes might be in the offing? What will the SEC process be going forward? What frameworks might the SEC use as a guide? What does this mean for the compliance function? What are the compliance lessons?  ResourcesMatt’s blog post on Radical Compliance:SEC Fires Warning Shot on Climate Disclosure 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 one of the most delicious legal decisions recently seen: the attempt by Citibank to recoup $500MM of the $900MM it erroneously wired out on behalf of Revlon.  Some of the issues we consider are:·      How did this Fubar occur?·      What was the role of complexity?·      Why did the employees make this mistake?·      What about training?·      Where were internal controls?·      What is the ‘value for discharge’ defense?·      Does this all just come down to finders keepers?·      What are the compliance lessons? ResourcesTom’s blog posts on the FCPA Compliance and Ethics Blog:Too Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 1 - The FactsToo Complex to Succeed: Citibank Incorrect Wires Out $900MM: Part 2 – Lessons Learned The Citibank decision 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. Last week we considered the SEC regulations requiring companies to detail human capital issues in their annual reports and what it meant for compliance. This led to a week-long dialogue between Matt and myself about the current state of employee trust and its role in corporate culture and a best practices compliance and ethics program.  Some of the issues we consider are: Trust is down. The now former UK KPMG Chairman who told employees to ‘quit whining’ about the Coronavirus health crisis issue. Employees are under more pressure to deliver results. What does this do to trust? Employee to employee trust issues in WFH. Trust issues around RTW, both employee to employee and management response to employee health and safety issues at the workplace. Benjamin Moore getting rid of legal department and then restricting employee access to legal assistance. Greater fear toward retaliation stopping whistleblowers from coming forward.  ResourcesMatt’s blog post in Radical Compliance:Corporate Culture and Human Capital Disclosures Tom’s blog posts on the FCPA Compliance and Ethics Blog:A Macro Approach for Human Capital ComplianceHal Holbrook, Mark Twain and Employee TrustHow to Destroy Employee TrustLeadership Lessons from Abraham Lincoln 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 we consider the SEC regulations requiring companies to detail human capital issues in their annual reports. What have some of the initial disclosures revealed? What does it mean for compliance? Some of the issues we consider are: Why is this issue so important? What are the SEC reporting rules? How did companies report their human capital issues? What does all this mean for corporate culture? ResourcesMatt’s blog post in Radical Compliance:Corporate Culture and Human Capital Disclosures 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 we consider the GameStop matter through the lens of the compliance profession.  Some of the issues we consider are:·      What is the background?·      What are the compliance implications of this matter? ·      Is this a black swan event or just ‘business as usual? ·      Short sellers in the bulls-eye? ·      The role of the regulators?·      Who are Robinhood’s stakeholders?·      What is the more relevant precedent; Long Term Capital or the Panic of 1907?·      What is the role (or responsibility) of social media?ResourcesCheck out Tom’s 5-part blog post series on GameStop and Compliance:GameStop and Compliance-IntroductionGameStop and Compliance-The ShortsGameStop and Compliance-The Squeeze and Social MediaGameStop and Compliance-The Regulatory ResponseGameStop and Compliance-Lessons for the Compliance Professional 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 we consider what will be the implications of our working environments post-pandemic. Will we be permanently working from home, returning to the office, a mix of both or something else? Some of the issues we consider are: What are the compliance implications of a distributed workforce? How to maintain culture? Is WFH communications too much like social media? What about cyber-bullying from co-workers? ResourcesMatt’s blog post in Radical Compliance: Thoughts on Return to Work 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 we consider the Capital One resolution of the FinCEN enforcement action. We look at the compliance program; red flags missed, and how the bank was faulted as its compliance program was found to be not effective.Resources:See Matt's blog post Capital One Whacked on AML FailuresSee Tom's blog post the Capital One FinCEN Enforcement Learn more about your ad choices. Visit megaphone.fm/adchoices