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 Kelly (the coolest guy in compliance) and I go into the weeds to explore recent Facebook settlement with the SEC and the FTC. We also explore what the new DOJ antitrust investigation may portend going forward.  Some of the highlights include:This is now the second SEC settlement under this fact pattern.The SEC settlement was three times the amount of the Yahoo settlement.Did the FTC settle too low (or too high)?Is Facebook prevented from doing anything going forward?What is the impact if any on the stock price? Does the market even care?Is the DOJ antitrust investigation simply a politically motivated attack?Has the administration thought through the implications of its antitrust investigations?For further reading on Conn’s see Matt’s blog posts: Facebook, Power and Antitrust Issues  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 Kelly (the coolest guy in compliance) and I go into the weeds to explore recent SEC enforcement actions which Matt characterized as an “internal control Palooza”. We explore what went askance, how to learn from it and how to prevent it going forward.   Some of the highlights include: Ø The SEC recently had an “Internal Controls Palooza” of enforcement actions. Ø Microsoft demonstrated poor controls over third parties.Ø Why do does units need a ‘second set of eyes’ for non-standard discounts?Ø What is earnings management and why is it so risky? Ø Why do you need robust internal controls when engaging in earnings management? Ø Why must internal controls have an auditable trail? For further reading on Conn’s see Matt’s blog posts:Conn’s Lessons on Management EstimatesandMore on Embedding, Automating ControlsFor further reading on Microsoft see Matt’s blog post:FCPA Issues Nick Microsoft $25 MillionFinally see Tom’s blog postsPart 1-Microsoft FCPA Enforcement Actionand Part 2-the 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. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore Matt’s observations on compliance training. While traveling cross-country with the family for a well-earned vacation he paid close attention to the safety training video. We used that as a starting point for a deep dive into compliance training and communications.    Some of the highlights include:What are some fresh takes on compliance training?How do you implement both effective and tailored training?Is your training procedural? Ethical? Systemic?Do you want your employees to follow procedures or standards of behavior?Employees need to feel like there is someone listening.What is the role of ongoing communications in training?For further reading see Matt’s blog post-How Good Training Finds its Wings 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 Kelly (the coolest guy in compliance) and I take a deep dive into employees of the U.S. Customs and Border Protection who operated a closed Facebook group, replete with racist, sexist posts about migrants and Democratic politicians. For corporate compliance and governance professionals who think about the challenges of building a strong corporate culture, the mess at CBP offers a cautionary tale about the corrosive nature of subcultures.    Some of the highlights include: Ø Why are subcultures so corrosive?Ø What is Metcalfe’s Law and how does it apply here?Ø What is corporate culture v. subcultures?Ø How does an organization fight the growth of subcultures?Ø What is the role of the CCO?Ø Is all this simply protected speech? For additional reading see Matt’s blog post What CBP Tells Us About Subcultures 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 Kelly (the coolest guy in compliance) and I go into the weeds to explore Matt’s recent interview of Theranos whistleblower Tyler Schultz. We use this as a starting point to discuss what a company can do when everyone knows that fraud is going on but no one says anything about it.   Some of the highlights include:Tyler Schultz tells his story.What was the conversation inside Theranos?Was it an open secret the company was engaged in fraud?Why do employees take baby steps to whistleblowing?Employees need to feel like there is someone listening.Are there any alternative areas of power in a company, such as the Board of Directors?For further reading see Matt’s blog post-What Drives Open Secrets 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 Kelly (the coolest guy in compliance) and I take things in a different direction as we welcome Francine McKenna, reporter at MarketWatch. And blogger extraordinaire at Re: The Auditors. After one full week of writing, thinking and talking about the SEC enforcement action against KPMG, we provide our initial reflections.   For additional reading,  check out the following resources:You should start with McKenna’s great piece on the scandal in MarketWatch, “The KPMG cheating scandal was much more widespread than originally thought”Matt’s blog post-Questions on the KPMG Ethics FiascoTom’s blog post-Day of Reckoning for KPMG-Failures in Ethics 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 Kelly (the coolest guy in compliance) and I take a deep dive into SEC enforcement action announced against KPMG this week.   Some of the highlights include:Which part of the scandal is worse-bribery/corruption or falsifying standards?Can KPMG be trusted going forward?What led to the Board investigation of the educational scandal?Is this the end of KPMG? The Big Four?How could the firm create a culture so antithetical to integrity?Where does KPMG go from here?Who is qualified to be the Monitor?Will there be an additional SEC enforcement action?For additional reading see Tom’s blog post Day of Reckoning for KPMG-Failures in Ethics 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 Kelly (the coolest guy in compliance) and I take a deep dive into Robotic Process Automation.   Some of the highlights include:What is robotic process automation (RPA)?How does it differ from AI?How could a compliance professional use RPA?Why is does it pose unique risks to a corporate compliance function?For additional reading see Matt’s blog post Thoughts on RPA, Compliance and You 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 Kelly (the coolest guy in compliance) and I go into the weeds to explore how the complexity of modern-day corporations can lead to catastrophic failures such as the two crashes of the Boeing 737 Max.  Some of the highlights include: Ø Our podcast today was based upon two blog posts we both wrote this week based upon the NYT article The Late Change, and Fatal Flaws in Boeing’s Plane. Ø Why and how can complexity lead to catastrophic failre?Ø The modern corporation is very siloed. How does this contribute to risk?Ø Why every compliance professional should read the NYT article.Ø How should you think about systemic risk in your organization’s ecosystem?Ø How does the COSO 2013 Internal Controls Framework consider the issue of communication across an organization? In addition to the great NYT piece check out the following resources: Matt’s blog post-Another Lesson from Boeing-SilosTom’s blog post-Boeing and More Compliance Lessons 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 Kelly (the coolest guy in compliance) and I go into the weeds to explore what exactly is sub-regulatory guidance and why the debate around it by the current administration is seemingly against not only the government’s interest but also business’ interest. Be sure and listen all the way through as Matt goes on a rant at the end of the podcast.  Some of the highlights include: Ø What were the remarks of Claire Murray that got Matt so riled up?Ø Is the Evaluation of Corporate Compliance Programs, 2019 Guidance just paper?Ø What would happen to a company which does not use the 2019 Guidance as a roadmap?Ø Why business’ support sub-regulatory guidance?Ø Why documentation is critical for multiple parts of a compliance program?Ø What do Murray’s remarks mean for the compliance practitioner? For the full text of the remarks of Principal Deputy Associate Attorney General Claire Murray at the Compliance Week 2019 Annual Conference, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices