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 Matt and Tom go into the weeds to look at the turbulence brought to the compliance profession and compliance job market. Some of the issues we consider are:  How Working From Home has brought a material change to the practice of compliance. How to follow the money in the age of Coronavirus? Has the pandemic made compliance more relevant? Why is there such turbulence in the compliance job market? How has the pandemic transformed one traditional risk into something that manifests quite differently.? How is the compliance profession evolving?  ResourcesSee Matt’s blog posts on Radical Compliance- Compliance and Career Turbulence 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 Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the US banking and finance entity Goldman Sachs. Some of the issues we consider are:  One of the most bold, audacious bribery schemes ever. Complete total and utter failure of compliance? Or something worse? Blatant assistance in money-laundering. How watches the watchers? Has Goldman really done anything different? Largest FCPA fine ever.  ResourcesSee Matt’s blog posts on Radical Compliance- Goldman Sachs, FCPA and Internal ControlsSee Tom’s exploration on the FCPA Compliance and Ethics BlogPart 1-IntroductionPart 2-Control FailuresPart 3-Fines and Penalties 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 Matt and Tom go into the weeds to look at the recent FCPA enforcement action involving the Brazilian megalith, J&F Investments. Some of the issues we consider are:  It was one of the most bold, audacious bribery schemes ever. Follow on from Brazil’s largest anti-corruption enforcement action, JBS. What happens when an acquirer of a US listed company is the corrupt entity? Is a target required to perform due diligence on the source of the money used in a M&A deal? Did Pilgrim’s Pride have any responsibility? Are there any US individuals involved? Is Pilgrim’s Pride a victim, entitled to compensation?  ResourcesSee Matt’s blog posts on Radical Compliance-JBS, Internal Controls and the FPCASee Tom’s exploration the FCPA Compliance and Ethics BlogPart 1-IntroductionPart 2-The Bribery SchemesPart 3-The SEC OrderPart 4-The Plea Agreement 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 Matt and Tom go into the weeds to look at the recent fine of $400 million against Citibank for its poor risk management processes. Some of the issues we consider are:·      Four areas of concern(1) Poor ERM; (2) Poor compliance; (3) Poor internal controls; and (4) Data governance.·      How the OCC Order is an audit road map.·      What does that mean for compliance on the Board?·      Did the OCC push out Michael Corbat?·      Focus on the ERM Blueprint.  ResourcesSee Matt’s blog posts on Radical Compliance-Citigroup’s Governance Issues, Part 1 and Citigroup, Part 2-Better ERM Program 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 Matt and Tom go into the weeds to look at the recent fine of $920 million against JPMorgan for spoofing. Some of the issues we consider are: What is spoofing? How did the CFTC use data analytics to build their case? What does that mean for compliance professionals? How did the JPMorgan remediation of its compliance function reduce ? Once again, the DOJ demonstrates that robust remediation will pay great dividends in the form of a significant penalty reduction.  ResourcesSee Matt’s blog posts on Radical Compliance-JPMorgan’s Compliance BenefitSee also, David Michaels piece in the Wall Street Journal, JPMorgan’s Probe Revived by Regulators Data Mining 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 Matt and Tom go into the weeds to look at some of the compliance issues that collaboration tools raise in the WFH era. Some of the issues we consider are: How do you assess the risks of collaboration tools? Does it matter only to regulated industries or all commercial operations? What can compliance do to manage the risk? When is training a better risk management tool than internal controls? Do you know your archiving status? ResourcesSee Matt’s blog posts on Radical Compliance-Compliance Risks and Collaboration Tools 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 Matt and Tom go into the weeds to look at the recent initiative of the Department of Education to go after Princeton University for diversity training which Trump says is “Anti-American propaganda” and the release of the FinCen papers. Some of the issues we consider are:  What is the Trump Administration up to? Will white nationalism be the order of the day if Trump wins? Why does impact compliance professionals? What are the FinCen papers? Why was their release so devastating to the Administration? ResourcesSee Matt’s blog posts on Radical ComplianceBoom: The FinCen Files are HereTrump Administration Targets Princeton for Diversity 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 Matt and Tom go into the weeds to look the recently announced Herbalife FCPA enforcement action. Some of the issues we consider are:  Why were the facts so egregious? How high up in the organization did the corruption scheme go? Why was the Board’s performance so abysmal? Was the head of Internal Audit in on the bribery scheme? What was the role of short-sellers in bringing this massive fraud to light? ResourcesSee Matt’s blog posts on Radical ComplianceHerbalife Pays $123M on FCPA Charges See Tom’s 3-part blog post series on the FCPA Compliance and Ethics BlogThe Herbalife FCPA Enforcement Action, Part 1The Herbalife FCPA Enforcement Action, Part 2The Herbalife FCPA Enforcement Action, Part 3 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 Matt and Tom go into the weeds to look at two recent pronouncements by FinCen on customer and PEP due diligence. We ask the question: Is the Guidance so vague as to actually hurt the efforts of a compliance practitioner.  ResourcesSee Matt’s blog posts on Radical ComplianceRegulators Talk PEPs and Due DiligenceFinCen Gives Guidance, Says Little 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 Matt and Tom go into the weeds to look at the first Cybersecurity breach case brought by the state of New York’s Department of Financial Services. Some of the highlights include: What is the DFS? What is Reg 500, Cyber Rules? What were the First American comedy of errors? CISO disavowed ownership of the issue, stating, among other reasons, that such controls were not the responsibility of respondent’s information security department. No training for new employee charged with remediation. First American said it did nothing wrong.  ResourcesSee Matt’s blog post, Parsing DFS’ First Cybersecurity Case on Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices